Proposed hydro power station at Augrabies

Post by **Richprins** » Mon Aug 24, 2015 6:33 pm

viewtopic.php?f=303&t=4100

A thread here, H.!

Post by **H. erectus** » Mon Aug 24, 2015 6:39 pm

I tried some homework before posting with little luck,
please merge,..... $\O$

Post by **Richprins** » Mon Aug 24, 2015 6:42 pm

Post by **Mel** » Mon Aug 24, 2015 8:33 pm

H. erectus wrote:I tried some homework before posting with little luck,
please merge,..... $\O$

Your wish is my command

Post by **H. erectus** » Tue Aug 25, 2015 6:53 pm

Ok,..allow me to filter these pages,..??????

Thanks Mello,...

Post by **Mel** » Tue Aug 25, 2015 7:42 pm

Not sure what you mean with "filter these pages"

Post by **H. erectus** » Tue Aug 25, 2015 7:48 pm

In closer scrutiny,...

Are we on about job creation,...

or maybe,..

are we on about electrification,..???

Job creation being all about employment promise,..
Electrification being all about tangible finance promise!!!

Can the authority please be more clear about the purpose
and intent of this venture,...

Post by **H. erectus** » Thu Oct 01, 2015 1:11 pm

Proposed Hydro SA Riemvasmaak Hydro Project - Submission of Final Environmental Impact Assessment Report (FEIR)

Dear Stakeholder,

Find attached the Issues and Response Trail and our letter clarifying the submission of the Final Environmental Impact Assessment Report for the proposed Hydro SA Riemvasmaak Hydro Project to the Department of Environmental Affairs in Pretoria.

Sincerely,
Shawn Johnston
Process Specialist
Sustainable Futures ZA
P.O. Box 749 Rondebosch 7701
Cape Town, South Africa
Tel:++27 083 325 9965
Fax: 086 510 2537
E-mail: swjohnston@mweb.co.za

Post by **H. erectus** » Thu Oct 01, 2015 1:16 pm

01 October 2015
Dear Stakeholder,
ENVIRONMENTAL IMPACT ASSESSMENT PROCESS PROPOSED HYDROSA RUN-OF –RIVER HYDRO POWER PROJECT, RIEMVASMAAK, NORTHERN CAPE PROVINCE (DEA REF. NO.: 14/12/16/3/3/2/600)
NOTIFICATION OF FINAL ENVIORONMENTAL IMPACT ASSESSMENT REPORT SUBMISSION TO THE NATIONAL DEPARTMENT OF ENVIRONMENTAL AFFAIRS
RVM 1 Hydro Electric Power (Pty) Ltd (RVM), intends to construct a run-of-river hydroelectric power station on the Orange River on the farm Riemvasmaak (Portion 1 of farm No 497) and Remainder of farm No. 497, north of the Augrabies Falls, approximately 32km north-west of Kakamas in the Northern Cape Province of South Africa. The power station will have an installed generating capacity of up to 40 megawatts (MW), and the annual energy output from the facility is anticipated to be approximately 235 gigawatt-hours (GWh).
In terms of Regulation 56(2) and (6) of the NEMA EIA Regulations of June 2010, EOH Coastal & Environmental Services, as the environmental impact assessment practitioner (EAP) managing the application for environmental authorisation, is hereby giving notice to all registered Interested and/or Affected Parties (I&APs) for the proposed project, of the EAP’s intention to submit the Final EIA Report (FEIR), the Final Environmental Management Programme (EMPr), and the Comment and Response Report on the public

review of the Draft EIA Report to the National Department of Environmental Affairs Pretoria (as the competent authority).
This letter also serves to inform I&APs of the availability of the reports described above, as well as the Specialist Study reports and documentation relating to the Water Use Licence Application, on the EOH Coastal & Environmental Services website (http://www.cesnet.co.za – follow the link to Public Documents, RVM 1 Hydro Electric Power (Pty) Ltd - 40 MW Hydroelectric Scheme on Orange River), and afford all registered I&APs access to, and an opportunity to comment on the report in writing. CD copies of the reports will be sent to I&APs on request.
As required in terms of Regulation 56(6), registered I&APS must submit any comments they may have on the Final EIA Report direct to the Department of Environmental Affairs Pretoria with a copy to Sustainable FuturesZA. The relevant contact details are as follows:
National DEA Vincent Chauke Tel: 012 399 9399 Fax: 012 320 7539 Email: vchauke@environment.gov.za Post: Private Bag X 447, Pretoria, 0001
Sustainable Futures ZA: Shawn Johnston Tel: 083 325 9965 Fax: 086 510 2537 Email: swjohnston@mweb.co.za Post: PO Box 749, Rondebosch, Cape Town, 7701
Sincerely, SHAWN JOHNSTON Process Specialist, Sustainable FuturesZA (not signed, sent via email)

Post by **H. erectus** » Thu Oct 01, 2015 1:27 pm

RVM 1 HYDROELECTRIC POWER (PTY) LTD
RIEMVASMAAK HYDROPOWER PROJECT, ORANGE RIVER, NORTHERN CAPE PROVINCE, SOUTH AFRICA
ENVIRONMENTAL IMPACT ASSESSMENT VOLUME 5: COMMENT AND RESPONSE REPORT
DEA Reference Number: 14/12/16/3/3/2/600
Prepared for:
Prepared by:
RVM1 Hydro Electric Power EOH Coastal & Environmental Services
Loft Office No. 6 The Woodmill Lifestyle Centre Vredenburg Road Stellenbosch
Grahamstown P.O. Box 934, Grahamstown, 6140
South Africa South Africa
FINAL REPORT
SEPTEMBER 2015
PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Final Environmental Impact Assessment Report September 2015
Coastal & Environmental Services i RVM 1 Hydro Electric Power
EOH Coastal & Environmental Services
Report Title: Comment and Response Report Report Version: Final Project Number: 279
Name Responsibility Shawn Johnston (SFZA) Compiler Bill Rowlston Reviewer
Copyright This document contains intellectual property and proprietary information that is protected by copyright in favour of RVM 1 Hydro Electric Power, EOH Coastal & Environmental Services (CES) and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of these parties. The document is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.
REPORTS PRODUCED AS PART OF THIS EIA:
Volume 1: Environmental Scoping Report Volume 2: Specialist Reports Volume 3: Environmental Impact Assessment Report Volume 3a: Appendices to Environmental Impact Assessment Report Volume 4: Environmental Management Programme Volume 5 Comment and Response Report
Notes: (i) The Environmental Scoping Report was produced by Aurecon and accepted by DEA in October 2013 (ii) Volume 2 was compiled by EOH Coastal & Environmental Services (iii) Volumes 3, 4 and 5 were prepared by EOH Coastal & Environmental Services
Environmental Impact Assessment Report – Comment and Response Report
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COMMENTS AND RESPONSE REPORT Comments & Issues submitted on the Draft Environmental Impact Assessment Report
Notes on the Report  Comments and issues are listed in alphabetical order of the surname of the person who submitted the comment or issue.  Some comments and issues were submitted by I&APs in PDF format and had to be retyped by Sustainable Futures ZA (SFZA). Minor typing errors may have occurred.  For this report comments and issues that were submitted in Afrikaans were translated into English. The original submissions are included in Appendix E of the EIA Report.  For some comments or issues headings were added or words highlighted to make it easier for the reader to identify the focus of the comment or issue.
No. Issue Raised by Response from CES EIA team or Hydro SA African Paddling Association and Gravity Adventures – Louise Kellet 1. Dear Mr Johnson, Is the Draft EIA already completed? How is this possible since the previous process was stopped and new consultants (yourselves) were appointed? I was under the impression that the process would begin anew and I have not received any communications from you at all? Please explain the process in detail so that I can understand what has been happening. We have not made any submissions to you as part of the new process – are you using all the information and comments gathered as part of the Aurecon process? I also need to make the following points. These have been raised before in the previous process and so I assumed you would have been aware of them. 1. Surely the wording of the notice should use the word “would” and not “will”. “Will” implies that the project is definitely going ahead and this is not the case – it is merely a proposal at this stage. 2. This project is of National and International importance. You cannot just make Draft EIA report available locally and you cannot just consult locally. This would be a travesty of your role as an independent consultant. You need to consult widely and meaningfully. 3. Similarly, the public meetings need to be held throughout Louise Kellet, African Paddling Association and Gravity Adventures, 23 April 2015. Dear Mrs Louis-Marie Kellet, Thank you for your e-mail. I hereby acknowledge receiving your e-mail and attached comments. The DEIR has been completed. I sent a CD copy to your street address by registered mail for review and comment. The DEIR is also available on the CES web site. The EIA process was not cancelled. The process continues on from the scoping process as indicated in the acceptance of scoping by the DEA Pretoria. The environmental impact assessment practitioner was changed from Aurecon to CES. CES is continuing with the EIA process. We are now in the comments period of the DEIR. I have not received the comments you submitted previously, but I will included the comments in the final environmental impact assessment when I receive them. I look forward to your comments on the DEIR. Sincerely, Shawn Johnston EAP’s response Wording (1): The use of the word “will” does not mean that the project is definitely going ahead. Used in the context of an EIA “will” indicates intention, and carries with it an implicit “if the project is authorised.”
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No. Issue Raised by Response from CES EIA team or Hydro SA the country, at least in the major centres – this development is happening in a national park, which belongs to the people of the country and is a national asset. 4. I have attached the comments we submitted as part of the Aurecon process – have these been included? 5. The Draft EIA needs to made available in an electronic form so that it can be widely distributed for comment Sincerely, Marie-Louise Kellett, African Paddling Association & Gravity Adventures Advertisements (3&4): The availability of the Draft EIAR was advertised nationally, provincially and locally in the Sunday Times (25th April), and Die Burger, Die Gemsbok and Die Volksblad (29th April), all as required by DEA. We believe we have conducted a consultation process that provides an opportunity to comment on the proposed project to anyone who wishes to do so. Documents (4): See comments from Shawn Johnston above. Availability of Draft EIAR (5): The Draft EIAR was and still is, available on CES’s website – www.cesnet.co.za – follow the link to Public Documents. 2. Dear Shawn I strongly suggest that you send a mail to each and every IAP and ask them to re‐submit their earlier comments. If mine have been “lost” in the changeover of consultants, I am sure that the others have also. It would be in your interest to ensure that the Public Participation process has been properly conducted as this is one of the major issues highlighted earlier on in the process. I also urge you to consult widely and meaningfully – this is a national, not a local issue. Thank you, Marie-Louise Kellett Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: The commentator was informed of the continuation of the assessment process by e-mail on 13th March 2015, reregistered as an I&AP, and provided with a copy of the BID. All I&APs who were registered for the Scoping phase of the assessment were similarly informed of the continuation of the assessment process. 3. Preliminary Comments on the proposed Hydropower Plants at Augrabies Falls, Northern Cape. Submitted by Marie-Louise Kellett for the Environmental Working Group, African Paddling Association. December 17 2013 The African Paddling Association is a voluntary body representing the commercial paddling industry in southern Africa. As such, we are well informed on the various water bodies in our country as well as on their potential to develop green jobs for our people through ecotourism. Tourism is currently the largest provider of jobs in South Africa. The APA recognises the need to develop alternative energy production technologies in order to reduce our reliance on fossil fuels. We are, however, 100% opposed to developing any projects in pristine, wilderness areas and areas of ecological importance. Sites of less ecological significance should be investigated as a priority over sites of such a pristine and ecological sensitive nature. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: We note your concerns about developing projects that might affect your association’s activities, and your suggestion that alternative, less sensitive sites should be investigated. Alternative sites: Alternative sites studied by the applicant are discussed in Chapter 5 of the EIA Report, where it is pointed out that there are few sites on South African rivers that are suitable for the generation of electricity without the need to construct large impounding reservoirs to generate the necessary head, such as, for instance, the Gariep and Van der Kloof dams, both of which have had, and will continue to have, a profound influence on the flow regime of the Orange River. In this context we note that DEA has recently granted environmental authorisation for another large instream dam, about 30m high, on the Orange River, to facilitate the generation of 22MW of power at the Rooikat HPP. Protected areas: We believe that this project can be developed
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No. Issue Raised by Response from CES EIA team or Hydro SA and operated with minimal effects on the nature of the park and its surroundings, and with minimal effect on the Augrabies Falls or the Orange River as a whole as a tourist attraction,. 4. The APA also would like to object in the strongest possible terms to the public participation process for the following reasons; 1. The Augrabies Falls (Riemvasmaak) project is of national and international importance – Augrabies Falls is in a national park and is of importance to the whole country. Despite this, the consultants and developer have treated it as a local project and have only notified people in the immediate area. This project should have been advertised at a provincial and national level with a meaningful public participation process. National and provincial tourism bodies as well as civil society should have been fully and meaningfully consulted. In our opinion, the public participation is fatally flawed and should be declared null and void and the process started from scratch. 2. Individualised Scoping studies and EIA’s fail to recognise the cumulative effects of the various hydro schemes, dams and ‘flood control’ weirs being constructed and planned for the Orange. This applies particularly to the site identified at the Ritchie Falls near Onseepkans as the combined effect of this and the Augrabies Falls project will be to destroy two of the last remaining wilderness areas on the entire river. The combined effects of all of this construction needs to be considered as a whole and proper consultation done. In our opinion, a Strategic Environmental Assessment is of vital importance before any projects progress any further. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: Your objections are noted. Advertisement (1): See details of the extent of advertisement in Comment No 1 above. Cumulative effects (2): The cumulative effects of the development of structures in and on the Orange River are considered in section 7.6 of the EIA Report. It is important to note that the RVM HPP will not “destroy” the Augrabies Falls. The commentator is referred section 3.3.1 of the EIA Report for details of the effect of the project on the flow regime of the falls. The project will not affect the river downstream of a point in the middle of the Augrabies Gorge at all. 5. To comment in more detail: The APA does not support the proposed hydropower plants at Augrabies Falls and Ritchie Falls, inter alia based on the following reasons: 1. Transboundary River The Orange River is a transboundary river, whose basin is shared between Lesotho, South Africa, Botswana and Namibia. The utilisation of these water resources is governed by bilateral agreements between the participation countries. The overall development and management of the Basin is carried out by the Orange-Senqu Basin Commission (ORASECOM). Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: The Orange as an international river: We are aware of the status of the Orange River as an internationally-shared river, and of the various instruments that relate to its management. However, given that the proposed project will affect the flow regime of the river only between the diversion weir and the point at which the diverted flow is returned undiminished to the mainstem river, a distance of about 10km, mostly through the rocky gorge downstream of the Augrabies Falls, the project will not affect the downstream riparians (and will certainly not affect
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No. Issue Raised by Response from CES EIA team or Hydro SA All of the member States, and especially South Africa are signatories to the UN Convention on the Law of the NonNavigational Uses of International Watercourses, as well as the SADC revised Protocol on Shared Watercourses. Any development activities impacting on the Orange river must be in accordance with the principles of these conventions and protocols, as well as the bilateral agreements (especially Article 4 sub-clause 2 specifically refers to environmental protection and preservation). Further, on the list of I&APS published (on the environmental project website) ORASECOM is not listed as an Interested and Affected Party. In relation to this, ORASECOM has commissioned several detailed studies on the river as part of the process of developing a Basin Specific management plan. None of these studies has been referenced or even mentioned in the report, including the environmental flow requirements report. In a similar vein, the National legislation of the participating countries requires water resources to be managed from a catchment approach i.e. from source to sea. In light of these proposed hydropower plants, a strategic assessment that assess the cumulative impacts of all of the proposed hydropower plants on the Orange river should be carried rather than the current process of individual site-specific assessments. the upstream riparian, Lesotho). The requirements of the SADC Water Sharing Protocol are the basis of the management of the basin, which requires each basin-sharing state to “ utilise the resources of the River System in their territories, take all appropriate measures to prevent the causing of significant harm to any other Party. The term "significant harm" shall be interpreted in line with the Revised Protocol on Shared Watercourses in the Southern African Development Community (SADC) Region.” (Agreement on the Establishment of the Orange-Senqu River Commission, 7.4). Accordingly there is no significant effect on the river that requires consultation with the other basin states in accordance with the SADC Protocol. Management of the River: The South African Department of Water and Sanitation is responsible for the management of the Orange River Basin in South Africa, and for administering waterrelated agreements between South Africa and Namibia. The department has not raised any objections to the project, and has written to the applicant confirming that sufficient water is available for the construction (3 years) and operational (20 years) phases of the project, should it be approved. The period of availability of water for operation relates to the maximum period of a water use licence, and not to the anticipated lifetime of the project, which may be of the order of 80 years or more. 6. 2. Due process – Augrabies Falls (Riemvasmaak Farm) The main objections to constructing power plants at this site relate to the sense of place and ecological sensitivity of the site. In terms of process, as the Augrabies site affects a National Reserve – a national asset and thus the impact to the asset extend beyond the boundaries of the municipality within which it is located. Therefore public participation should have been carried out at a National scale including adverts and calls for comments in all the major national newspapers. Further, the Augrabies Falls is a declared National Park, and therefore subject to the National Environmental Management: Protected Areas Act, Act 57 of 2003, and its regulations for the proper administration of special nature reserves, national parks and world heritage sites, published un Government Notice R1061 IN Government Gazette 28181 of 28 October 2005. In reference to these regulations: 39. Interference with soil or substrate Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: National park; public consultation: The issue of consultation is addressed in the response to Comment 1 above. We are aware that elements of the infrastructure necessary to operationalise this project will be constructed across land that is part of the AFNP, and that other infrastructural elements will be in land that is not within the boundaries of the park but which are immediately adjacent to the park. We are also aware, and have taken account of, the requirements of the NEM: PAA and its Regulations. We are also aware that there are no absolute legal prohibition of activities such as those contemplated in respect of this project, but that it is necessary to obtain permission from the management authority – in this case SANParks - before the project may be implemented. We are of the opinion that this project can be developed and operated without significant impacts on the nature of the park and
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No. Issue Raised by Response from CES EIA team or Hydro SA (1) No person shall, except with the prior written permission of a management authority - (a) remove from a special nature reserve, national park or world heritage site any- (i) soil, rock, mineral or similar material; (ii) wood, mulch or other dead vegetation; (iii) fossil, archaeological remains or cultural artefacts; (iv) ritual or spiritual remains; (v) coral or shells; or (vi) a shipwreck, flotsam or jetsam. (b) dig or intentionally disturb any soil or similar material in a special nature reserve, national park or world heritage site; or (c) intentionally disturb any - (i) wood, mulch, peat or other dead vegetation or animal in a special nature reserve, national park or world heritage site; (ii) termite mounds; (iii) fossil, shell midden, archaeological remains or paleontological specimens or meteorites in a special nature reserve, national park or world heritage site; or (iv) any of the marine components contemplated in paragraph (a); or (v) any object or material that is or was used for any ritual, spiritual or other practice. Further (2) No person shall construct an impoundment or weir on any river or river bed or abstract any water from any impoundment or weir on any river or in any river bed within a special nature reserve, national park or world heritage site, nor abstract any water by means of a pump, pipes, gravitation or any other means, located outside the boundary of a special nature reserve, national park or world heritage site, from any river or river bed forming a boundary with a special nature reserve, national park or world heritage sites without the written permission of a management authority and without conducting an environmental impact assessment. (own emphasis). its surroundings, and with minimal impacts on the Augrabies Falls as a tourist attraction. 7. 42. Removal and dumping in water area No persons shall, without the prior written consent of a management authority and subject to the conditions imposed by the management authority, in any manner - Louise Kellet, African Paddling Association and Gravity Adventures, 04 May The response to Comment No 6 also refers to this comment.
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No. Issue Raised by Response from CES EIA team or Hydro SA (a) remove, dredge, pump or move any sand, soil or stones from a water area; (b) deposit, dump or throw sand, soil, stones or other material of any kind in a water area; or (c) construct any retaining wall or weir in a water area. Further, section 46 refers to buildings and improvements, requiring the prior written approval of a management authority and where necessary obtaining the necessary environmental authorisations prior to applying to the management authority for approval. While an EIA is being conducted, it only refers to application for authorisation in terms of the NEMA GN 544 AND GN545 listed activities, it does not include application for the necessary authorisation in terms of the NEM:PAA GNR 1061. Further: 17 Purpose of protected areas The purposes of the declaration of areas as protected areas are- (a) to protect ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes in a system of protected areas; (b) to preserve the ecological integrity of those areas; (c) to conserve biodiversity in those areas; (d) to protect areas representative of all ecosystems, habitats and species naturally occurring in South Africa; (e) to protect South Africa’s threatened or rare species;; (f) to protect an area which is vulnerable or ecologically sensitive; (g) to assist in ensuring the sustained supply of environmental goods and services; (h) to provide for the sustainable use of natural and biological resources; (i) to create or augment destinations for nature-based tourism; (j) to manage the interrelationship between natural environmental biodiversity, human settlement and economic development; (k) generally, to contribute to human, social, cultural, spiritual and economic development; or (l) to rehabilitate and restore degraded ecosystems and promote the recovery of endangered and vulnerable species. 2015.
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No. Issue Raised by Response from CES EIA team or Hydro SA Constructing of a hydropower plant and ancillary activities and infrastructure at the Augrabies Falls are in contradiction to these principles. 8. 3. Sense of Place and the Wilderness Experience – Augrabies Falls and Ritchie Falls Along the entire length of the Lower Orange River, a high percentage of the riparian habitat is transformed (63.8%). Only 11.2% can be classified as pristine. The Augrabies Falls and Ritchie Falls sites are located within the areas deemed to be pristine wilderness. This pristine wilderness nature and associated sense of place will be irrevocably damaged by the construction of a hydropower plant, regardless of any and all attempts to mitigate the impact. Given that so few areas of wilderness still exist along the Orange, together with the fact that a river is a continuous system with impacts upstream having an effect downstream, these two sites are irrevocably linked, since the same developer is planning hydro power plants for BOTH sites and comments will therefore apply to both. Much has been written about the importance and effect of wilderness and its effect upon the visitor. In “The Role and Function of Wilderness Trails in the Kruger National Park” By Barry Hopgood and Jaco Badenhorst, the authors use the definition of wilderness as enshrined in United States of America Wilderness act of 1964: "In contrast with those areas where man and his own work dominate the landscape, as an area where the earth and its communities of life are untrammelled by man, where man himself is a visitor who does not remain". The act went on to require that a wilderness retains "its primeval character and influence", and that it be protected and managed in such a way that it "appears to have been affected primarily by the forces of nature". They go on to say that “Although wilderness means something different to everyone, the main aspects of wilderness are: the value of the wilderness experience; the value of wilderness as a scientific resource and environmental baseline; the value of wilderness as heritage sites and the spiritual and symbolic value of wilderness to the nation and the world.” The Augrabies Falls and Gorge and to a greater degree, the Ritchie Falls and Orange Gorge fulfil all of the above Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: Note: This response addresses only the proposal to develop a hydroelectric power project (HPP) – the Riemvasmaak HPP - using the natural head generated by the Augrabies Falls, as set out in the EIA Report currently under consideration. The possibility of an HPP being developed that uses the head generated by the Ritchie Falls has nothing whatever to do with the Riemvasmaak HPP, and this response does not address any aspect of such a project. We do not agree that the two sites are “irrevocably linked”. These comments are not relevant to the issues at hand. Riparian habitat: We are aware that the construction of the diversion weir and offtake structure will necessitate the removal of some riparian vegetation. The botanical report assesses the impact thuswise: “The construction of the intake weir will impact Lower Gariep Alluvial Vegetation to a small localised extent and will not make a significant contribution to the cumulative loss of this Endangered vegetation type.” Impact on flow regime: The impact of the project on the flow regime of the river is set out in section 3.3.1 of the EIA Report as follows:  For ±20% of the time no flow will be diverted into the tailrace:  For ±15% of the time (55 days) the river flows at or less than 30m³/s, so no flow will be diverted into the headrace and the HPP will not operate.  For ±5% of the time (18 days) the river flows at more than 800m³/s. At this flow rate it is anticipated that the sediment loads in the river will begin to increase to such an extent that sediment could be drawn into the headrace, and could result in damage to the turbines. No flow will be diverted into the headrace; power generation will be shut down to prevent damage to the turbines.  For ±45% of the time (165 days, or 5.4 months) river flows are between 30m³/s and 90m³/s, diverted flow will progressively increase from zero to 38m³/s, and the power station will operate at less than its installed generating capacity.  For ±35% of the time (128 days, or 4.2 months river flows
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No. Issue Raised by Response from CES EIA team or Hydro SA requirements. In fact, the Ritchie Falls and Orange Gorge have been recognised as significant from an ecological and ecotourism point of view and recommended for formal environmental protection. (LORMP, 2008:73) Augrabies Falls has a particular sense of place The Khoi people called it ‘Aukoerebis’, or place of Great Noise, as this powerful flow of water is unleashed from rocky surroundings characterized by the 18km abyss of the Orange River Gorge (ORASECOM, 2007:65). Reducing this thunder takes away the sense of place from the falls, a little trickle down the falls doesn’t inspire the same sense of awe, inspiration and wonder when one stands on the edge of the falls. Wilderness areas, or areas with pristine habitat, devoid of human intrusions, both visually and audibly, are becoming extremely scarce, and along the LOR, areas perceived as being wild and pristine, are isolated and rare. Only a small portion of the river still retains this character, and it is imperative that these areas are formally protected (LORMP, 2008:73). Both Augrabies Falls and Ritchie Falls fall within the identified wilderness areas with pristine habitat. Both sites are parts of the Orange River in reasonably natural condition which represent ecosystem types not conserved elsewhere. Areas of particular conservation importance include the gorge downstream of Augrabies Falls and the Falls at Onseepkans (Ritchie falls) (ORASECOM, 2007:60). In fact, to further enhance Augrabies’ pristine characteristic, it was recommended that the boathouse and equipment store, as well as the motorised boat currently used in the gorge be removed. The transition from pristine to high and even total impacts does change the quality of the experience (LORMP, 2008:81). Further, it is recommended that ecotourism overnight campsites within the pristine sections of the river must be based on wilderness camping principles, with no permanent infrastructure allowed. In addition the LOR Management Plan recommends that the status of this pristine section (Richie Falls and gorge) should be formalised by seeking protected area status in South Africa and Namibia (LORMP, 2008:103). The potential mitigation of the visual intrusion of the power plants at these sites is severely limited and does not mitigate exceed 90m³/s but are less than 800m³/s, diverted flow will be at a maximum of 38m³/s, and the power station will operate at its full design capacity This means that, during the time when flow will be diverted to the hydropower station, the percentage reduction in the flow rate over the falls will range from zero at a total river flow of 30 cubic metres per second (m3/sec) to 42.2% at 90m3/sec, falling to 4.2% when the river flow is at 800 m3/sec. The project will therefore never reduce the flow over the falls to a trickle. The flow regime over the falls can only be reduced to accord with the commentators; fears by improper management of releases from the very large dams upstream of Augrabies, and mismanaged and / or uncontrolled abstractions from the river for off-channel consumptive uses. Pristine area: We appreciate the commentator’s acknowledgement that the area that will be affected by the project is not, in the true sense of the word, in “pristine” condition, but is in a “reasonably natural condition.” As stated previously, we believe that the project can be implemented so as not to significantly affect the current nature of the area. We do not wish to comment on the commentator’s perception of wilderness, nor on the various recommendations as to how the area should be managed.
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No. Issue Raised by Response from CES EIA team or Hydro SA the human influence and impact to the area. There are no measures that can be taken to completely hide or disguise the structures effectively. One can’t plant a forest to hide the 4m high structures or transformer yard, as forest is not the natural vegetation in the area. Rock cladding may hide bland concrete walls, but the square, rigid and linear form of the infrastructure will still be in contrast to the abstract and random features of the area. At Ritchie Falls it will no longer be a pristine and undisturbed area. At the Ritchie Falls site, in addition to the impact on the Falls themselves, where the water will be almost entirely diverted except during high water events, the sense of place of the Orange Gorge (referred to in the report as the Southern Channel) will similarly be permanently affected – diversion of the flow into the northern channel will turn this awe inspiring gorge filled with rapids (and a world class whitewater kayaking route) into a series of stagnant pools, except during the high water events which occur far less often than in the past. 9. 4. Ecological Sensitivity Any effects on the ecology of the river as a result of the Augrabies Falls development will have to also, at a minimum, also have to consider a scenario where the Ritchie Falls project also goes ahead. This is because of the reasons pointed out above – the fact that the river is a system and if you consider the combined effects of both projects, the result might be catastrophic for the ecology of the river as a whole. The Lower Orange River (LOR) downstream of the Augrabies Falls is very important with regard to fish species, with 13 of the 15 indigenous freshwater fish of the Orange River found in the LOR (ORASECOM, 2007:188) including endemic and red data species. Five of the six endemic Orange River Fish species occur in this lower river section. Three of the five endemic species, B. hospes, B. kimberleyensis, and Austroglanis sclateria are Red Data listed (ORASECOM, 2007:121). Further, these red data species tend to favour fast-flowing water, below rapids (Cambray, 1984; Skelton and Cambray, 1981; Benade, 1993; in ORASECOM (2007:189)). Therefore altering the flow regime over the falls and adjacent rapids will directly and seriously impact on the breeding habitat of these red data species. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: Aquatic ecology: The aquatic ecology study indicated that, with the implementation of recommended mitigation measures, the impacts of the project on the ecology of the river downstream of the diversion weir will not be significant. The specialist opined that the rocky nature of the gorge, with a distinct lack of riparian and instream vegetation, is such that the reduction in flow rates (described above in Comment 8) will not result in significant impacts on the ecology of the gorge. The impacts on aquatic ecology downstream from the point where the diverted flow re-joins the mainstem river will be negligible. Impacts on the river as a whole: We have no reason to doubt the validity of the information provided by the commentator on the impacts that have resulted from the regulation of the Orange River. However, these impacts relate to major, macro-level manipulation of the river’s flow regime, over the entire length of the river in South Africa, by major dams inside South Africa (including the diversion of significant quantities of water to the Eastern Cape by the Orange-Fish Tunnel), and the abstraction of increasing volumes of water from the Orange for, among others, irrigation
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No. Issue Raised by Response from CES EIA team or Hydro SA Barbus hospes, the fish found only in the Orange river downstream of Augrabies Falls, is a known species which should be considered of special conservation importance (ORASECOM, 2007:60). Note that special conservation requires the protection of the species habitat, in order to support the continued breeding and survival of the fish species. Further, within the distribution range of B. hospes, geographically isolated populations of two fish species, Mesobola brevianlia and barbus trimaculatus, occur. These two species are of considerable interest for they may provide evidence of an ancient link between the drainages of the Okavango system and the Orange (ORASECOM, 2007:60). The report notes that should it become necessary to develop a dam in the lower Orange River, the conservation of these species would best be served by preserving as long an uninterrupted stretch of the lower river as possible. This would apply to the construction of weirs as well. The ecological consequences of flow changes include loss of species diversity, reed encroachment, loss of water through evaporation, change in water temperature and change in water quality. Loss of species diversity The review of available information has shown that loss of species diversity has taken place in the riparian vegetation, which is highly modified in many places. This can be directly ascribed to development of water resources of the river. Its importance lies in the fact that river reaches with natural riparian vegetation are limited and considered to be of conservation importance. Due to electric power generation (between Gariep and Vanderkloof dams and below Vanderkloof for some 200kms) loss of species diversity is severe. The river immediately below Vanderkloof has been described as an ecological desert. The creation of further “ecological deserts” would not be desirable (ORASECOM, 2007:61). Reed encroachment Reed encroachment of the channel in the middle reaches of the orange river has been considerable, subsequent to the regulation of flow by the Gariep and Vanderkloof dams (ORASECOM, 2007:61). This is problematic to flow and and mining. More recently, since the implementation of the LHWP, the flow regime in the Senqu has been manipulated by the dams in Lesotho, which also facilitate the transfer of water into the Reef area of South Africa via the Trans-Caledon Tunnel. The impacts of the diversion of a maximum flow rate of 38 m3/sec, when the flow rate in the river permits (see Comment 8), for a distance of 10km before returning it undiminished to the river, cannot reasonably be compared to the major alterations to the river’s flow regime described above.
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No. Issue Raised by Response from CES EIA team or Hydro SA sediment regimes and ecological habitat provision. The regulating of the flow via diverting-weirs will reduce the energy of the water and result in sediment deposition which promotes reed encroachment into the river channel. Blackfly increase Flow regulation has been accompanied by the appearance of major outbreaks of Simulium chutteri (black fly), which have resulted in annual losses of livestock to farmers estimated at R33million along an 800km stretch of the river. As in the case of reed encroachment, these outbreaks are ascribed to the artificial flow regime and it is considered that other flow regimes may contribute to their amelioration (ORASECOM, 2007:61). Adult female blackflies usually need a blood meal to complete the development of eggs. All outdoor activities are seriously affected, particularly general population, stock farming, irrigation farming, river rafting and other tourist activities (WRC, 2007:1). In terms of treatment, releases from Vanderkloof Dam are usually highly variable, and this makes it difficult to determine accurate dosages (WRC, 2007:2). The impact of the directing weirs on the flow regime will also impact on the ability to determine accurate dosages, or flush the larvae. Changes in temperature A changed temperature regime has profound impacts on the life of rivers and can result in conditions totally unsuitable for certain organisms (ORASECOM, 2007:62). Lower water levels can result in the water warming up quicker, whereas dam releases tend to result in thermic shock to fish resulting in fish deaths, as the water is suddenly colder than normal. Controlling the present mechanical manipulation of the river bed, banks and floodplain is extremely important as these factors are major contributors towards the decline in the condition of the riverine ecosystem, which together with the current manipulation of the flow regime will eventually lead to its complete collapse (LORMP, 2008: 31). The mechanical manipulation referred to above includes the controlled releases of water for irrigation, and would similarly include the control of flows in hydropower generation, especially where numerous hydro projects are planned for the same river. In an analysis of the median monthly flows, with Boegoeberg Dam as a point of reference going downstream to the
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No. Issue Raised by Response from CES EIA team or Hydro SA confluence with the Fish river, using data from 1914-01-01 to 1998-04-03, calculated that the natural flow patterns in the system showed an 82% summer (October to May) versus 18% winter (May to October) distribution. Minimum flow occurred during August (Wellington, 1933; Chutter, 1973; Benade, 1993) and maximum flow during February (Tomasson & Allanson, 1983; Benade, 1993), showing erratic flow peaks coupled with high silt loads (Tomasson & Allanson, 1983) (ORASECOM, 2007:120). Riverbed degradation resulting from suspended solid precipitation caused by the combination of low flows (river regulation), high evaporation rates and high mineral content (Agricultural and other pollution) leads to aquatic degradation, which could be detrimental to the survival of certain indigenous, including endemic organisms, while promoting the unwanted establishment of other indigenous, as well as alien organisms (ORASECOM, 2007:121) e.g. reed encroachment. Increasing river regulation and catchment utilisation will result in increases in filamentous Phycophytes and blue-green alga (algal blooms), and will also promote habitat changes suitable for the encroachment and colonisation of plant species. It can be expected that further river regulation will enhance habitat possibilities for economically important invertebrates such as Blackflies, the snail intermediate hosts of Bilharzia and Fluke spp, mosquito’s, etc. (ORASECOM, 2007:121). These species are economically important because of the devastation or economic impact they can impose should there be an outbreak of these invertebrates. When considering the Present Ecological State (PES) of the Orange river, the Augrabies and Richie Falls fall within the reach PESEIS 4: Orange Catchment from the Hartbees confluence to the estuary. The main PES of this reach is category C – moderately modified. Loss and change of natural habitat and biota have occurred, but the basic ecosystem functions are still predominantly unchanged. The improvement (in relation to upstream reaches) is due to the fact that the river is inaccessible or protected in many sections and the increasing abstractions of flow upstream has lessened the impact of the flow releases for hydropower and agriculture (ORASECOM, 2010:96). In other words, maintaining these
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No. Issue Raised by Response from CES EIA team or Hydro SA pristine and protected areas as natural and pristine is helping to maintain and improved ecological state of the river, i.e. if they were lost the ecological state of the river would decline. 10. In terms of the Ecological Importance and Sensitivity (EIS), the Augrabies Falls and Richie Falls fall into the reach of EFR 03 (ORASECOM, 2010b:65). The EIS evaluation results in a HIGH importance, including:  Rare and endangered instream biota: BKIM, Simulium gariepense;  Rare and endangered riparian biota: Clawless otter, black stork, straw-coloured fruit bat. A. erioloba (IUCN listed as declining). Euclea pseudenus (SANBI protected tree). Vegetation type = Lower Gariep Alluvial vegetation (Conservation status: endangered).  Unique aquatic biota: Some fish species are endemic to the Orange System (ASCL, BAEN, and LCAP). BTRI IN Lower Orange possible unique population, BHOS endemic to lower Orange, MBRE isolated population in the Orange.  Unique riparian biota: Orange river white-eye restricted to catchment, paradise frog (SA Endemic), 6 endemic vegetation plants;  Riparian biota – taxon richness: 70 out of 87 riverine faunal species present (80% of expected);  Riparian habitat: Diversity of types and features: cobble beaches, grazing lawns, backwaters, intact riparian zones, reed beds and some mud flats.  Riparian migration corridor: a riparian band in the area annually inundated by high floods, remains intact, despite the larger area in the floodplains being cleared and planted with agricultural crops. This intact band forms a very important migration corridor for most of the riverine faunal species present in the area.  National parks, wilderness areas, reserves, heritage sites, natural areas: Augrabies Falls (ORASECOM, 2010b:65) and Richie Falls. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. Note: Remarks in Comment 8 relating to responses not addressing the Ritchie falls / Orange Gorge apply equally to this comment. PES & EIS: We do not disagree with the information provided by the commentator in respect of the Ecological Importance and Sensitivity. The aquatic specialist assessed the Ecological Status of the section of the river that will be affected by HPP as Category C, while the EIS was assessed as HIGH. 11. Changes in flows impact on the food source (Abundance of fish) of piscivorous species (ORASECOM, 2010b:68), e.g. otters and kingfishers. Lower flows eliminate associated deep pool habitat (overhanging vegetation for kingfishers; emerging Louise Kellet, African Paddling Association and Gravity Adventures, 04 May EAP’s response: Important Note: Remarks in Comment 8 relating to responses not addressing the Ritchie falls / Orange Gorge apply equally to this comment.
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No. Issue Raised by Response from CES EIA team or Hydro SA vegetation for warblers, weavers and moorhen and slower backwater habitats (ducks, coots, storks) (ORASECOM, 2010b:68). The changes in flows (removal of higher flows) resulted in the marginal zone being vegetated with reeds and hygrophilous shrubs, reducing mudflats and alluvial sandbars. Thus less waders (sandpipers, plovers) and open habitat animals (plovers, geese) present. Also species that use sandbars and sandbanks lose digging substrate (monitors, bee-eaters, martins) (ORASECOM, 2010b:68). Clearing the site for construction, will remove the riparian vegetation which provide refuge, shelter, breeding and feeding habitats, and migration routes for riparian species. The Recommended Ecological Category (REC) for the reach including Augrabies and Richie Falls, is a category B (ORASECOM, 2010b:73). The REC refers to the management objective of the river reach, i.e. the river should be managed to achieve an improved PES status of category B. The river mouth ecological requirements currently released from Vanderkloof Dam amounts to 289 million m3/a, and is based on fairly old methodology. Recent estimation of the ecological requirement indicated an average requirement in the order of 1 062million m3/a (ORASECOM, 2007b:57). While the proposed plants are run of river, and the volume of water in the greater flow of the river will not be reduced by the hydropower plants, the volume of water through the falls at the selected sites will be reduced, especially in low flow and average conditions. In terms of the combined operating flows of the Richie Falls plant (Oranje Falls Farm) and the environmental flow requirements for the REC category B (ORASECOM, 2010b:91, table 9.8), the combined flow requirements exceed the monthly average flow. Further, the design flow alone exceeds the monthly average flow for 8 months of the year. As the Augrabies plant is a higher design capacity, it is assumed the flows will exceed the monthly average to a greater extent and further reduce the ability to implement the environmental flow requirements at the Falls. 2015. Changes in flow: Remarks in Comment 9 about the comparison of macro-scale manipulation of the river’s flow regime with that arising from this project apply equally here. Environmental water requirements: We note the previous estimates of the EWR at the river mouth and elsewhere quoted by the commentator. A new section – 3.3.2 Previous environmental water requirements recommendations – has been added to Chapter 3 of the EIA Report. It should be noted that the report referred to by the commentator assessed the Present Ecological Status of the Boegoeberg to Augrabies reach of the river as Category C, while the Desired Ecological Status was Category B, which resulted in considerably higher environmental flow recommendations. As described above (see Comment 8) no flow will be diverted from the river until the flow rate approaching the diversion weir reaches 30 m3/sec, which is the environmental flow recommended by DWS. Noting that, on average during the last 20 years of record, the flow rate in the river has been less than 30 m3/sec for 15% of the time (55 days a year), failure to achieve the environmental flow through the falls of 30 m3/sec will be as a result of upstream influences beyond the control of the applicant, and will never be due to water being diverted to the HPP. 12. 5. Ecotourism: Augrabies Falls There are various ecotourism products on offer associated with the Augrabies Falls. The magnificence of the falls are Louise Kellet, African Paddling Association and Gravity EAP’s response: See Comment 8 for details of the impacts of flow diversion on the flow regime downstream of the diversion weir and through the
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No. Issue Raised by Response from CES EIA team or Hydro SA central to all of the experiences on offer and it is very hard to predict exactly what the effect of the loss of the wilderness character as well as the loss of water flow on the falls will have on them. The effect of visitor numbers to the National Park is also hard to quantify. This requires further study and consultation. Various rafting operators will have their routes severely curtailed on the section of the Orange above the falls and the compensation for the associated financial losses that they will incur must be included in the project planning process. Further studies and consultation will be needed to investigate this properly. Anecdotal reports suggest that although certain rafting operators have made written submissions protesting against the development, these have been ‘lost’ by the consultants. This is obviously of great concern to us as it means that these submissions need to be made again, which is time consuming and disheartening for those opposing the project – those opposing the project are forced to use their own time and money to research and write comments for the project, in contrast to the environmental consultants who are paid to do it – not exactly a level playing field! Adventures, 04 May 2015. Augrabies Falls. Rafting: The diversion weir is 2.35km upstream from the actual entrance to the Augrabies falls, and 1.1km upstream of the furthest point that a raft or canoe could safely navigate before entering the narrow, rocky channel immediately upstream from the entrance to the falls. The configuration of the HPP diversion weir is such that it will be passable by raft or canoe under all but very high and very low flow rates. It is difficult to understand how this will “severely curtail” the routes currently travelled by the rafting operators. “Lost” submissions: All I&APs who were registered for the Scoping phase of the assessment (conducted by Aurecon) were requested to re-register for the EIA phase, which was conducted by EOH Coastal & Environmental Services. We are not aware that any comments have been “lost”, and all comments received from all I&APs during this phase of the assessment have been included in this report. 13. 6. Construction and operation Again, although the Ritchie Falls and Augrabies Falls projects are considered as separate, in terms of the potential impacts on the river system as a whole, it is impossible to consider the one without the other. The following comments will focus on the Augrabies Falls projects but we need to reiterate that the effects of the construction and operation of the Ritchie Falls project HAVE to be considered as well in order to get an accurate picture of the cumulative effect. Construction and Operation: Augrabies Falls Due to the flawed public consultation process, the APA only became aware of this project in recent weeks. Time has therefore not permitted us to make a properly considered response on this subject and we would like this to be noted as a major problem in this project – due process has not be adequately followed and the consultants have erred in setting up a wholly under representative and meaningless public consultation process. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. Important Note: Remarks in Comment 8 relating to responses not addressing the Ritchie falls / Orange Gorge apply equally to this comment. Consultation process: We have conducted a comprehensive public consultation process for the EIA phase of the assessment that satisfies the requirements of the NEMA EIA Regulations. The commentator was informed of the continuation of the assessment process by e-mail on 13th March 2015, re-registered as an I&AP, and provided with a copy of the BID. All I&APs who were registered for the Scoping phase of the assessment were similarly informed of the continuation of the assessment process.
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No. Issue Raised by Response from CES EIA team or Hydro SA 14. 7. Conclusions Ritchie Falls and Orange Gorge: Given the many negative impacts identified above, we strongly recommend that further planning permission for this project be denied and that this area be given protected status as soon as possible to help prevent any such projects in the future. This is part of our country’s natural heritage and should not be handed over to a private company to generate profit for their own benefit and to our detriment. Augrabies Falls: Given the national and international significance of the site, we recommend that this project be abandoned completely. Alternatively, given the fatally flawed consultation process, we recommend that this project be halted and started again from scratch. Augrabies Falls and Ritchie Falls projects and all other proposed projects along the length of the Orange River: Given the unknown cumulative effects of all of the various structures being planned for the Orange, including but not limited to hydro-electric power stations, dangerous “flood control’ weirs etc, we recommend that a Strategic Environmental Assessment as well as a Reserve Assessment be conducted for the river as a whole. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: We note your objections to the project. We also note your recommendation for an SEA to be conducted on the Orange River. 15. REFERENCES Lower Orange River Management Plan (LORMP)(2008). Unlocking the Ecotourism potential of the river. Compiled by Ecotoursim Afrika, for //Ai/Ais-Richtersveld Transfrontier park, funded by South African Department of Water and Forestry. ORASECOM (2007). Environmental Considerations Pertaining to the Orange River. Report 005/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2007b). Summary of water requirements from the orange River Basin. Report 006/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2010). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Desktop EcoClassifcation assessment. Prepared by WRP. Louise Kellet, African Paddling Association and Gravity Adventures, 04 May 2015. EAP’s response: Thank you for the list of references you used in your comments.
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No. Issue Raised by Response from CES EIA team or Hydro SA ORASECOM Report: 016/2011. ORASECOM (2010b). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Environmental Flow Requirements Volume 1 (Main Report). Prepared by WRP, funded by GIZ. ORASECOM Report: 016/2011. “The Role and Function of Wilderness Trails in the Kruger National Park” By Barry Hopgood and Jaco Badenhorst, http://www.sanparks.co.za/parks/kruger/ ... ties/wilde rness/articles/RoleFuncti onWTrailsKNP.pdf Water Research Commission (WRC)( 2007). Guidelines for integrated control of pest blackflies along the orange river. Compiled by Palmer, R.W., Rivers-Moore, N., Mullins, W., McPherson, V., and Hattingh, L. WRC Report No. 1558/1/07 Andrew Hockley - Augrabies 16. Hi Shawn, Dankie Gerhard Please register me as an interested and affected party for this unsolicited proposal of a Hydro Electric Scheme in the primitive and remote areas of the Augrabies Falls National Park and the Riemvasmaak Community Conservancy. In order for a realistic assessment of the proposal I hereby request the documents from which this new set of consultants will be referring to in making this assessment. In particular: Any document calculating the amount of water which could be available. Preferably from DWAF. Any Geological data, in particular the Earthquake Risk assessment. A fine scale contour map of the proposed Diversion Weir and Outtake structures, covering the full island, the island and in particular the potential for the erosion of the entire island. An assessment of the noise pollution inevitability during construction covering all weather variations and wind directions. Particularly important is the winter cold periods when any sound stays low and carries. An assessment of the water quality as returned to the river just above the man-made lake from Vredesvallei. Adding dead water to dead water appears unadvisable. Any research on the Cape Clawless Otter. Thanks and regards, Andrew Hockley, Augrabies, 11 March 2015, comment by email. EAP’s response: The commentator was provided with access to all available documents relating to the project.
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No. Issue Raised by Response from CES EIA team or Hydro SA Andrew Hockly 17. Dear All and Dr Avis, Not sure if this is a comment or a request but my understanding is that Farm 497 is the Farm Waterval 497, property of and location of the major disturbance in this proposal. Is it not disingenuous for the location to be referred to as the Farm Riemvasmaak. A location I first hear of here.. Should the title of the proposal not be: UNSOLICITED PROPOSAL FOR THE DIVERSION OF THE ORANGE RIVERS NORTH CHANNEL WITHIN THE BORDERS OF THE AUGRABIES FALLS NATIONAL PARK ON FARM 497 WATERVAL, AND EXTENDING TO THE MELKBOSRAND NATURE RESERVE, PROPERTY OF THE RIEMVASMAAK TRUST.? Andrew Hockly Andrew Hockley, Augrabies, 28 April 2015, comment by email. EAP’s response: The suggested project title is noted. 18. To whom it may concern The application is a monster of misinformation, half--‐truths and bluster. Our internet connections out here in the remote Northern Cape are slow, unreliable and expensive. The time set aside for us to fully comment after studying the proposal has been insufficient to do justice to this flagrant disregard to the protections our constitution allows to protected areas and the protections it gives to our most protected areas and the deliberations one should give to such an enormous breach of these. Currently I am attempting to analyse the map, “ The South African Renewable Energy EIA Application Database” which contains spatial data for renewable energy applications for environmental authorisation. On a brief study of this it is lacking this proposal which I see as disingenuous and does not allow for a considered response. I therefore must request an extension to the comment period which will allow the map to be updated and the full import of this unsolicited development proposal to be fully considered and further comments as to its undesirable nature be formulated, described and put forward. We would probably require that the second and 3rd quarter updates appear on the map and then some time to allow us to download, ponder and revert. I therefore request a 3 to 6 Andrew Hockley, Augrabies, 22 June 2015, comment by email. EAP’s response: It is not possible to respond to the general comments in paragraphs 1 and 3. With regard to the commentator’s request in paras 4, 5 and 6 for an extension of time for comment we sent the following message by e-mail shortly after receiving the request: Dear Mr Hockly, I refer to your request, included at the end of your e-mail message dated 22nd June 2015, for an extension of the time period for you to review and comment on the Draft Environmental Impact Report and other associated documents that relate to the EIA for the above project. I note that your request comes seven weeks after the project documents were made available to all I&APs for comment, and one week after the end of the two-week extension of the required 30-day comment period. I also note that you have requested a “3 to 6 month extension once these updates are available”, where “these updates” are the 2nd and 3rd quarter updates of the map associated with The South African Renewable Energy EIA Application Database. We estimate, working with the parameters you have set out, that we might expect to receive your comments and observations on the project documents sometime between January and April 2016.
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No. Issue Raised by Response from CES EIA team or Hydro SA month extension once these updates are available. Yours sincerely Andrew Hockly, Augrabies I am of the opinion that you have had sufficient time to review the available documents, ponder, and prepare your comments. Accordingly I am not willing to entertain your request. If we receive your comments by the end of June (2015) we will ensure that they are submitted to the Department of Environmental Affairs as part of the Comment and Response Report. If you are unable to let us have your comments by the end of June please send them direct to the Department, with a copy to us. Yours sincerely, Shawn Johnston 19. Hi Shawn, On the other hand, an incredible opportunity does present itself for Hydro and tourism working together. With a limited number of "Instream Flow Diversions", drop pools and other leading edge flow technology, a seriously world-class opportunity presents. The outlet alone promises almost 4 km of what could be a world class attraction... I hereby claim copyright of attached and included materials etc etc. These outlines may be dated, included as is. Trusting this could open some interesting discussions. Andrew Hockly, Augrabies Andrew Hockley, Augrabies, 07 July 2015, comment by email. Dear Mr. Andrew Hockley, The commentator’s change of attitude towards the project is noted. Thank you for your comments. I acknowledge receiving it and will include it in the issues and response trail. Sincerely, Shawn Johnston BirdLife South Africa – Simon Gear & Daniel Marnewick 20. Dear Kobus, I am copying Simon Gear, our Policy and Advocacy Manager, who will register us as an I&AP as soon as possible. Thank you for bringing this matter to our attention. Kind regards, Daniel Marnewick Manager: Important Bird and Biodiversity Areas and Regional Conservation Programme BirdLife South Africa Daniel Marnewick, Manager: Important Bird and Biodiversity Areas and Regional Conservation Programme, BirdLife South Africa, comment by e-mail, 29 April 2015. The message was sent to Mr Kobus van Coppenhagen, who drew Mr Marnewick’s attention to the project. Shawn Johnston
21. Hi Shawn,
Please register BirdLife South Africa as an I&AP on this project, using my details below.
With thanks,
Simon Gear, Policy & Advocacy Manager, BirdLife South Africa, comment by e-mail, 14 May 2015.
Dear Simon, Thank you of your e-mail. I hereby acknowledge that BirdLife SA has been registered and an interested and affected party on the proposed HydroSA Riemvasmaak run-of-river hydro environmental impact assessment. Sincerely, Shawn Johnston
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No. Issue Raised by Response from CES EIA team or Hydro SA Simon Gear Policy & Advocacy Manager Cliff Rossenrode 22. I would like to be listed as an interested and concerned party to try and stop the proposed building of a dam on the Gariep river that would definitely be detrimental to the environment and Augrabies park.
Thank you, Cliff Rossenrode
Cliff Rossenrode, comment by sms, 19 August 2015
Dear Mr. Rossenrode, Thank you for your sms. You have been registered as a interested and affected party on the stakeholder database and will be informed of all project developments. Sincerely, Shawn Johnston
Kalahari Outventures – Craig Eksteen
Important Note: Comments Nos 23 to 34 were submitted by Mr Eksteen on 5th May 2015.09.10 Subsequently Mr Eksteen has reconsidered his view of the project, and has submitted the following documents in support of his reveised opinion
Hi Bill, Shawn Thank you for your email and the opportunity to update my comments regarding the Augrabies Hydro Project. I have attached an official letter reflecting our updated views on the project. We wish you the best of luck with the finalisation of your project. If you have any questions or need anything further, please do not hesitate to contact me. Please also let me know if you would like a signed version of the attached letter. Kind Regards Craig +27 (0)54 453 0001 (o) +27 (0) 82 476 8213(c) +27 (0) 86 613 5692(f) info@kalahari-adventures.co.za www.kalahari-adventures.co.za www.facebook.com/KalahariOutventures www.outventures.iblog.co.za
Dear Mr Johnston, I refer to my earlier submissions regarding the proposed RVM Hydro Power facility. Further study of the information provided by EOHCES in the Draft Environmental Impact Assessment has given me new insight regarding the project. The technology to be used and the construction method proposed, does not appear to be as invasive or destructive as I initially was led to believe. Furthermore, since it is now clear to me that the facility doesn’t use or pollute water, I cannot see it having any negative
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No. Issue Raised by Response from CES EIA team or Hydro SA impacts on my business on the Orange River. South Africa needs electricity generation and why not from a renewable source. I therefore retract my negative comments and wish to advise that although a portion of the construction will be in a sensitive area, if managed carefully, the overall impact will beneficial to the region and the country. I hope and trust that you will find this in order. If you have any questions or queries, please do not hesitate to contact me. Yours Sincerely Craig B. Eksteen (Owner/Director) +27 (0)82 476 8213 +27 (0)54 453 0001 craig@kalahari-adventures.co.za
EAP’s response: Thank you for your revised comments.
Accordingly the original comments can be ignored, but they have been left in place to conserve this report as a record of all comment suibmitted.as a record of all
23. Hi Shawn, Hope you are well? It seems as though there have been a few lost comments in the handover period from Aurecon to yourselves. We would like to resubmit our comments as we will be highly affected and our input needs to be included in the final EIA process Please suggest the way forward and who we should be submitting more comments to and making sure that we are properly represented. Kind Regards, Craig
Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015.
Dear Craig, Thank you for your e-mail. You can send all of your comments to me directly and I will include them into the Final EIR. Craig, it would be important for your organization to review the draft environmental impact assessment report and comment on the report in addition to your original comments you will be submitting to me. The draft environmental impact assessment report is available on the CES web site: http://www.cesnet.co.za/publicdocuments.html. My team look forward to receiving your comments. Sincerely, Shawn Johnston
24. COMMENTS AND OBJECTIONS BY KALAHARI ADVENTURES PTY LTD WITH REGARDS TO THE PROPOSED AUGRABIES HYDRO SCHEME Kalahari Adventures is a professional Adventure Safari company specialising in personalised wilderness trips on the Orange River and into the Green Kalahari Desert. KA is currently the largest provider of adventure activities on the river at Augrabies, operating within a 180km radius both
Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015.
EAP’s response: Your use of the river for your commercial activities is noted, together with your objections to the project. Alternative sites: The criteria used for selecting this site for the development of a hydroelectric project, and the alternative sites are set out in Chapter 5 of the EIA Report.
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No. Issue Raised by Response from CES EIA team or Hydro SA upstream and downstream of the Waterfall. KA also has contractual concessions within the Augrabies Falls National Park specifically relating to the proposed project. In 1997 a proposal was put forward to SANPARKS for access to the 9km of river upstream of the Augrabies waterfall in order to provide adventure and river activities. This concession was approved and has been in operation ever since. Currently the only adventure activity on offer within the Augrabies Waterfall national Park. The proposed site for the scheme and weir development is exactly in the middle of the wilderness paddling trip and pristine area. Audited figures reflect that approximately 20 000 people have enjoyed this experience since the concession has been active and that it is one of the highlights of a visitors stay in AFNP. Kalahari Adventures is 100% opposed to developing any projects in pristine, wilderness areas and areas of ecological importance. Sites of less ecological significance should be investigated as a priority over sites of such a pristine and ecological sensitive nature. 25. Ecotourism: Augrabies Falls There are various ecotourism products on offer associated with the Augrabies Falls. The magnificence of the falls are central to all of the experiences on offer and it is very hard to predict exactly what the effect of the loss of the wilderness character as well as the loss of water flow on the falls will have on them. ALTHOUGH; WE HAVE ALREADY NOTICED A MASSIVE INFLUENCE TO WATER CLARITY, RIVER FLOWS AND ENVIRONMENTAL IMPACT FROM THE NEUS HYDRO PROJECT. The evidence is real and very visible. It is now public knowledge that the weir built was lower than planned/proposed and less water goes over what is left of the scenically beautiful Neus waterfall. The readings from water affairs are far from what was suggested. Also a loss to one of the well - known travel routes called the Rocky Route and a huge impact to related tourism roleplayers. The effect of visitor numbers to the National Park is also hard to quantify. This requires further study and consultation as over 80 000 day visitors enjoy the park, waterfall and all its splendour..... annually. The effect is much farther reaching with regards to tourism, as Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015. EAP’s response: Impacts of Neusberg HPP: We cannot comment on the issues raised concerning the alleged impacts of the Neusberg HPP on the Orange River or associated activities, and these concerns should be addressed to DWS and the owner / operator of the facility. Curtailment of river route: Refer to the response to Comment 12 above. Fly fishing: the location of the fly fishing enterprise is not specified, and we are therefore not able to comment in an informed manner on the potential impacts of the project on this activity. Tourism: The specialist report on socio-economic and tourism impacts did not identify any impacts with significance greater than Medium, most of which can be mitigated to Low. It is acknowledged that these are estimates of what is expected to happen, and the actual impacts cannot be determined unless the project is implemented. Accordingly we are not able to comment on the question of entitlement to compensation, except to say that they will need to relate to actual losses incurred as a direct result of the project, should it proceed.
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No. Issue Raised by Response from CES EIA team or Hydro SA not only operators would be affected, agents, booking offices, equipment manufacturers, fuel stations and all related parties would feel the consequences if these highly rated wilderness assets are impacted. Kalahari Adventures will have its route severely curtailed on the section of the Orange above the falls and the compensation for the associated financial losses that we will incur must be included in the project planning process. Further studies and consultation will be needed to investigate this properly. With Flyfishing being one of the country’s biggest role-players in tourism worldwide and also KA’s biggest breadwinner, the effect of river flows, water clarities, and temperatures will have a huge negative impact to the recently recognised World Class Wilderness Flyfishing Venue. Having been operational for 20 years on the Orange River, we have very recently noticed the huge impact as mentioned above relating to the now operational Neus Hydro Scheme. In turn forcing us to move our activities further downstream to find the conditions that were once very suitable, but no longer. This has had a huge impact on our business, the environment, the flyfishing industry, the community and the area in general. Operators have made written submissions protesting against the development, these have been ‘lost’ by the consultants. This is obviously of great concern to us as it means that these submissions need to be made again, which is time consuming and disheartening for those opposing the project – those opposing the project are forced to use their own time and money to research and write comments for the project, in contrast to the environmental consultants who are paid to do it – not exactly a level playing field! “Lost” submissions: The commentator’s remarks about “lost” submissions is a repeat of the remark in Comment 12. All I&APs who were registered for the Scoping phase of the assessment (conducted by Aurecon) were requested to re-register for the EIA phase, which was conducted by EOH Coastal & Environmental Services. We are not aware that any comments have been “lost”, and all comments received from all I&APs during this phase of the assessment have been included in this report. 26. Construction and operation Construction and Operation: Augrabies Falls Due to the flawed public consultation process, Kalahari Adventures Pty Ltd only became aware of this project late last year. Time has therefore not permitted us to make a properly considered response on this subject and we would like this to be noted as a major problem in this project – due process has not be adequately followed and the consultants have failed in setting up a transparent and meaningful public consultation process. Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015. EAP’s response: Consultation: We do not agree that the public consultation process for the EIA phase of the assessment was flawed. All I&APs who were registered for the Scoping phase of the assessment (conducted by Aurecon) were requested to reregister for the EIA phase, which was conducted by EOH Coastal & Environmental Services. Even if previously-registered I&APs did not re-register they were provided with all available information. 27. Conclusions Craig Eksteen, EAP’s response:
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No. Issue Raised by Response from CES EIA team or Hydro SA Kalahari Adventures Pty Ltd: Given that IAP’s have not been properly consulted and due process not followed, our company along with other stakeholders are already suffering the consequences from recently completed projects. We are left with no choice but to highly object on all fronts to the proposed site, claim loss of income and get suitably compensated for the huge impact on our business already and in the future if this project goes ahead. Tourism: We request a full economic impact study to be done on the impact to tourism, as it is not only our company that will lose money, but our agents, retailers, service stations, Sanparks, staff, catering companies, equipment suppliers, TV productions and locally employed people. The impact is far wider reaching than being considered. Augrabies Falls: Given the national and international significance of the site, we recommend that this project be abandoned completely. Alternatively, given the fatally flawed consultation process, we recommend that this project be halted and started again from scratch. Augrabies Falls and all other proposed projects along the length of the Orange River: Given the unknown cumulative effects of all of the various structures being planned for the Orange, including but not limited to hydro-electric power stations, dangerous “flood control’ weirs etc, we recommend that a Strategic Environmental Assessment as well as a Reserve Assessment be conducted for the river as a whole. Kalahari Outventures, comment by e-mail 05 May 2015. Consultation: Response as for Comment 25 above. Impacts on tourism, loss of income, etc: The specialist report on socio-economic and tourism impacts did not identify any impacts with significance greater than Medium, most of which can be mitigated to Low. It is acknowledged that these are estimates of what is expected to happen, and the actual impacts cannot be determined unless the project is implemented. Accordingly we are not able to comment on the question of entitlement to compensation, except to say that they will need to relate to actual losses incurred as a direct result of the project, should it proceed. 28. Kalahari Adventures would also like to object in the strongest possible terms to the public participation process for the following reasons; (ADDITIONAL INFORMATION COMPILED BY MRS M-L KELLET ON BEHALF OF THE AFRICAN PADDLING ASSOCIATION) 1. The Augrabies Falls (Riemvasmaak) project is of national and international importance – Augrabies Falls is in a national park and is of importance to the whole country. Despite this, the consultants and developer have treated it as a local project and have only notified people in the immediate area. This project should have been advertised at a provincial and national level with a meaningful public participation process. National and provincial tourism bodies as well as civil society should have been fully and meaningfully consulted. In our Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015. Comment 28 is a repeat of Comment 4 above. The response is the same.
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No. Issue Raised by Response from CES EIA team or Hydro SA opinion, the public participation is fatally flawed and should be declared null and void and the process started from scratch.
2. Individualised Scoping studies and EIA’s fail to recognise the cumulative effects of the various hydro schemes, dams and ‘flood control’ weirs being constructed and planned for the Orange. This applies particularly to the site identified at the Ritchie Falls near Onseepkans as the combined effect of this and the Augrabies Falls project will be to destroy tow of the last remaining wilderness areas on the entire river. The combined effects of all this construction needs to be considered as a whole and proper consultation done. In our opinion, a Strategic Environmental Assessment is of vital importance before any projects progress any further. 29. To comment in more detail: Kalahari Adventures Pty Ltd does not support the proposed hydropower plant at Augrabies Falls or other identified sites along the Orange River, inter alia based on the following reasons: Transboundary River
The Orange River is a transboundary river, whose basin is shared between Lesotho, South Africa, Botswana and Namibia. The utilisation of this water resources is governed by bi-lateral agreements between the participation countries. The overall development and management of the Basin is carried out by the Orange-Senqu Basin Commission (ORASECOM). All of the member States, and especially South Africa are signatories to the UN Convention on the Law of the NonNavigational Uses of International Watercourses, as well as the SADC revised Protocol on Shared Watercourses. Any development activities impacting on the Orange river must be in accordance with the principles of these conventions and protocols, as well as the bilateral agreements (especially Article 4 sub- clause 2 specifically refers to environmental protection and preservation).
Further, on the list of I&APS published (on the environmental project website) ORASECOM is not listed as an Interested and Affected Party.
Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015.
Comment 29 is a repeat of Comment 5 above. The response is the same.
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No. Issue Raised by Response from CES EIA team or Hydro SA In relation to this, ORASECOM has commissioned several detailed studies on the river as part of the process of developing a Basin Specific management plan. None of these studies has been referenced or even mentioned in the report, including the environmental flow requirements report.
In a similar vein, the National legislation of the participating countries requires water resources to be managed from a catchment approach i.e. from source to sea. In light of these proposed hydropower plants, a strategic assessment that assess the cumulative impacts of all of the proposed hydropower plants on the Orange river should be carried rather than the current process of individual site- specific assessments. 30. Due process – Augrabies Falls (Riemvasmaak Farm) The main objections to constructing power plants at this site relate to the sense of place and ecological sensitivity of the site. In terms of process, as the Augrabies site affects a National Reserve – a national asset and thus the impact to the asset extend beyond the boundaries of the municipality within which it is located. Therefore public participation should have been carried out at a National scale including adverts and calls for comments in all the major national newspapers.
Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015.
Comments 30 & 31 are repeats of Comment 6 & 7 above. The responses are the same.
31. Further The Augrabies Falls is a declared National Park, and therefore subject to the National Environmental Management: Protected Areas Act, Act 57 of 2003, and its regulations for the proper administration of special nature reserves, national parks and world heritage sites, published un Government Notice R1061 IN Government Gazette 28181 of 28 October 2005. In reference to these regulations: 39. Interference with soil or substrate (1) No person shall, except with the prior written permission of a management authority a) remove from a special nature reserve, national park or world heritage site any- (i) soil, rock, mineral or similar material; (ii) wood, mulch or other dead vegetation; (iii) fossil, archaeological remains or cultural artefacts; (iv) ritual or spiritual remains; (v) coral or shells; or (vi) a shipwreck, flotsam or jetsam.
Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015.
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No. Issue Raised by Response from CES EIA team or Hydro SA (b) dig or intentionally disturb any soil or similar material in a special nature reserve, national park or world heritage site; or (c) intentionally disturb any - (i) wood, mulch, peat or other dead vegetation or animal in a special nature reserve, national park or world heritage site; (ii) termite mounds; (iii) fossil, shell midden, archaeological remains or paleontological specimens or meteorites in a special nature reserve, national park or world heritage site; or (iv) any of the marine components contemplated in paragraph (a); or (v) any object or material that is or was used for any ritual, spiritual or other practice. Further (2) No person shall construct an impoundment or weir on any river or river bed or abstract any water from any impoundment or weir on any river or in any river bed within a special nature reserve, national park or world heritage site, nor abstract any water by means of a pump, pipes, gravitation or any other means, located outside the boundary of a special nature reserve, national park or world heritage site, from any river or river bed forming a boundary with a special nature reserve, national park or world heritage sites without the written permission of a management authority and without conducting an environmental impact assessment. (own emphasis). 42. Removal and dumping in water area No persons shall, without the prior written consent of a management authority and subject to the conditions imposed by the management authority, in any manner - (a) remove, dredge, pump or move any sand, soil or stones from a water area; (b) deposit, dump or throw sand, soil, stones or other material of any kind in a water area; or (c) construct any retaining wall or weir in a water area. Further, section 46 refers to buildings and improvements, requiring the prior written approval of a management authority and where necessary obtaining the necessary environmental authorisations prior to applying to the management authority for approval. While an EIA is being conducted, it only refers to application for authorisation in terms of the NEMA GN 544
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No. Issue Raised by Response from CES EIA team or Hydro SA AND GN545 listed activities, it does not include application for the necessary authorisation in terms of the NEM:PAA GNR 1061. Further: 17 Purpose of protected areas The purposes of the declaration of areas as protected areas are- (a) to protect ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes in a system of protected areas; (b) to preserve the ecological integrity of those areas; (c) to conserve biodiversity in those areas; (d) to protect areas representative of all ecosystems, habitats, species naturally occurring in SA (e) to protect South Africa’s threatened or rare species; (f) to protect an area which is vulnerable or ecologically sensitive; (g) to assist in ensuring the sustained supply of environmental goods and services; (h) to provide for the sustainable use of natural and biological resources; (i) to create or augment destinations for nature-based tourism; (j) to manage the interrelationship between natural environmental biodiversity, human settlement and economic development; (k) generally, to contribute to human, social, cultural, spiritual and economic development; or (l) to rehabilitate and restore degraded ecosystems and promote the recovery of endangered and vulnerable species. Constructing of a hydropower plant and ancillary activities and infrastructure at the Augrabies Falls are in contradiction to these principles. 32. Sense of Place and the Wilderness Experience – Augrabies Falls Along the entire length of the Lower Orange River, a high percentage of the riparian habitat is transformed (63.8%). Only 11.2% can be classified as pristine. The Augrabies Falls site is located within the area deemed to be pristine wilderness. This pristine wilderness nature and associated sense of place will be irrevocably damaged by the construction of a hydropower Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015. Comment 32 is a repeat of Comment 8 above. The response is the same.
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No. Issue Raised by Response from CES EIA team or Hydro SA plant, regardless of any and all attempts to mitigate the impact. Given that so few areas of wilderness still exist along the Orange, together with the fact that a river is a continuous system with impacts upstream having an effect downstream, these two sites are irrevocably linked, since the same developer is planning hydro power plants for BOTH sites and comments will therefore apply to both.
Augrabies Falls has a particular sense of place The Khoi people called it ‘Aukoerebis’, or place of Great Noise, as this powerful flow of water is unleashed from rocky surroundings characterized by the 18km abyss of the Orange River Gorge (ORASECOM, 2007:65). Reducing this thunder takes away the sense of place from the falls, a little trickle down the falls doesn’t inspire the same sense of awe, inspiration and wonder when one stands on the edge of the falls.
Wilderness areas, or areas with pristine habitat, devoid of human intrusions, both visually and audibly, are becoming extremely scarce, and along the LOR, areas perceived as being wild and pristine, are isolated and rare. Only a small portion of the river still retains this character, and it is imperative that these areas are formally protected (LORMP, 2008:73). Both Augrabies Falls and Ritchie Falls fall within the identified wilderness areas with pristine habitat. Both sites are parts of the Orange River in reasonably natural condition which represent ecosystem types not conserved elsewhere. Areas of particular conservation importance include the gorge downstream of Augrabies Falls and the Falls at Onseepkans (Ritchie falls) (ORASECOM, 2007:60).
In fact, to further enhance Augrabies’ pristine characteristic, it was recommended that the boathouse and equipment store, as well as the motorised boat currently used in the gorge be removed. The transition from pristine to high and even total impacts does change the quality of the experience (LORMP, 2008:81).Further, it is recommended that ecotourism overnight campsites within the pristine sections of the river must be based on wilderness camping principles, with
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No. Issue Raised by Response from CES EIA team or Hydro SA no permanent infrastructure allowed. The potential mitigation of the visual intrusion of the power plants at these sites is severely limited and does not mitigate the human influence and impact to the area. There are no measures that can be taken to completely hide or disguise the structures effectively. One can’t plant a forest to hide the 4m high structures or transformer yard, as forest is not the natural vegetation in the area. Rock cladding may hide bland concrete walls, but the square, rigid and linear form of the infrastructure will still be in contrast to the abstract and random features of the area. The Augrabies Falls area will no longer be a pristine and undisturbed area.
At the Augrabies Falls site, in addition to the impact on the Falls themselves, where the water will be tapped, the sense of place of the river and area will similarly be permanently affected – diversion of the flow into the northern channel will turn this wilderness area filled with rapids (and top class rafting, flyfishing and wilderness adventure) into a series of slow and stagnant pools, except during the high water events which occur far less often than in the past. 33. Ecological Sensitivity Any effects on the ecology of the river as a result of the Augrabies Falls development will have to also, at a minimum, also have to consider a scenario where the Ritchie Falls project also goes ahead. This is because of the reasons pointed out above – the fact that the river is a system and if you consider the combined effects of both projects, the result might be catastrophic for the ecology of the river as a whole. The Lower Orange River (LOR) downstream of the Augrabies Falls is very important with regard to fish species, with 13 of the 15 indigenous freshwater fish of the Orange River found in the LOR (ORASECOM, 2007:188) including endemic and red data species. Five of the six endemic Orange River Fish species occur in this lower river section. Three of the five endemic species, B. hospes, B. kimberleyensis, and Austroglanis sclateria are Red Data listed (ORASECOM, 2007:121). Further, these red data species tend to favour fast-flowing water, below rapids (Cambray, 1984; Skelton and Cambray,
Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015.
Comment 33 is a repeat of Comments 9, 10 & 11 above. The responses are the same.
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No. Issue Raised by Response from CES

No. Issue Raised by Response from CES EIA team or Hydro SA 1981; Benade, 1993; in ORASECOM (2007:189)). Therefore altering the flow regime over the falls and adjacent rapids will directly and seriously impact on the breeding habitat of these red data species. Barbus hospes, the fish found only in the Orange river downstream of Augrabies Falls, is a known species which should be considered of special conservation importance (ORASECOM, 2007:60). Note that special conservation requires the protection of the species habitat, in order to support the continued breeding and survival of the fish species. Further, within the distribution range of B. hospes, geographically isolated populations of two fish species, Mesobola brevianlia and barbus trimaculatus, occur. These two species are of considerable interest for they may provide evidence of an ancient link between the drainages of the Okavango system and the Orange (ORASECOM, 2007:60). The report notes that should it become necessary to develop a dam in the lower Orange River, the conservation of these species would best be served by preserving as long an uninterrupted stretch of the lower river as possible. This would apply to the construction of weirs as well. The ecological consequences of flow changes include loss of species diversity, reed encroachment, loss of water through evaporation, change in water temperature and change in water quality. Loss of species diversity The review of available information has shown that loss of species diversity has taken place in the riparian vegetation, which is highly modified in many places. This can be directly ascribed to development of water resources of the river. Its importance lies in the fact that river reaches with natural riparian vegetation are limited and considered to be of conservation importance. Due to electric power generation (between Gariep and Vanderkloof dams and below Vanderkloof for some 200kms) loss of species diversity is severe. The river immediately below Vanderkloof has been described as an ecological desert. The creation of further “ecological deserts” would not be desirable (ORASECOM, 2007:61). Reed encroachment
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No. Issue Raised by Response from CES EIA team or Hydro SA Reed encroachment of the channel in the middle reaches of the orange river has been considerable, subsequent to the regulation of flow by the Gariep and Vanderkloof dams (ORASECOM, 2007:61). This is problematic to flow and sediment regimes and ecological habitat provision. The regulating of the flow via diverting-weirs will reduce the energy of the water and result in sediment deposition which promotes reed encroachment into the river channel. Blackfly increase Flow regulation has been accompanied by the appearance of major outbreaks of Simulium chutteri (black fly), which have resulted in annual losses of livestock to farmers estimated at R33million along an 800km stretch of the river. As in the case of reed encroachment, these outbreaks are ascribed to the artificial flow regime and it is considered that other flow regimes may contribute to their amelioration (ORASECOM, 2007:61). Adult female blackflies usually need a blood meal to complete the development of eggs. All outdoor activities are seriously affected, particularly general population, stock farming, irrigation farming, river rafting and other tourist activities (WRC, 2007:1). In terms of treatment, releases from Vanderkloof Dam are usually highly variable, and this makes it difficult to determine accurate dosages (WRC, 2007:2). The impact of the directing weirs on the flow regime will also impact on the ability to determine accurate dosages, or flush the larvae. Changes in temperature A changed temperature regime has profound impacts on the life of rivers and can result in conditions totally unsuitable for certain organisms (ORASECOM, 2007:62). Lower water levels can result in the water warming up quicker, whereas dam releases tend to result in thermic shock to fish resulting in fish deaths, as the water is suddenly colder than normal. Controlling the present mechanical manipulation of the river bed, banks and floodplain is extremely important as these factors are major contributors towards the decline in the condition of the riverine ecosystem, which together with the current manipulation of the flow regime will eventually lead to its complete collapse (LORMP, 2008: 31). The mechanical
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No. Issue Raised by Response from CES EIA team or Hydro SA manipulation referred to above includes the controlled releases of water for irrigation, and would similarly include the control of flows in hydropower generation, especially where numerous hydro projects are planned for the same river. In an analysis of the median monthly flows, with Boegoeberg Dam as a point of reference going downstream to the confluence with the Fish river, using data from 1914-01-01 to 1998-04-03, calculated that the natural flow patterns in the system showed an 82% summer (October to May) versus 18% winter (May to October) distribution. Minimum flow occurred during August (Wellington, 1933; Chutter, 1973; Benade, 1993) and maximum flow during February (Tomasson & Allanson, 1983; Benade, 1993), showing erratic flow peaks coupled with high silt loads (Tomasson & Allanson, 1983) (ORASECOM, 2007:120). Riverbed degradation resulting from suspended solid precipitation caused by the combination of low flows (river regulation), high evaporation rates and high mineral content (Agricultural and other pollution) leads to aquatic degradation, which could be detrimental to the survival of certain indigenous, including endemic organisms, while promoting the unwanted establishment of other indigenous, as well as alien organisms (ORASECOM, 2007:121) e.g. reed encroachment. Increasing river regulation and catchment utilisation will result in increases in filamentous Phycophytes and blue-green alga (algal blooms), and will also promote habitat changes suitable for the encroachment and colonisation of plant species. It can be expected that further river regulation will enhance habitat possibilities for economically important invertebrates such as Blackflies, the snail intermediate hosts of Bilharzia and Fluke spp, mosquito’s, etc. (ORASECOM, 2007:121). These species are economically important because of the devastation or economic impact they can impose should there be an outbreak of these invertebrates. When considering the Present Ecological State (PES) of the Orange river, the Augrabies and Richie Falls fall within the reach PESEIS 4: Orange Catchment from the Hartbees confluence to the estuary. The main PES of this reach is category C – moderately modified. Loss and change of natural habitat and biota have occurred, but the basic ecosystem
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No. Issue Raised by Response from CES EIA team or Hydro SA functions are still predominantly unchanged. The improvement (in relation to upstream reaches) is due to the fact that the river is inaccessible or protected in many sections and the increasing abstractions of flow upstream has lessened the impact of the flow releases for hydropower and agriculture (ORASECOM, 2010:96). In other words, maintaining these pristine and protected areas as natural and pristine is helping to maintain and improved ecological state of the river, i.e. if they were lost the ecological state of the river would decline. In terms of the Ecological Importance and Sensitivity (EIS), the Augrabies Falls and Richie Falls fall into the reach of EFR 03 (ORASECOM, 2010b:65). The EIS evaluation results in a HIGH importance, including:  Rare and endangered instream biota: BKIM, Simulium gariepense;  Rare and endangered riparian biota: Clawless otter, black stork, straw-coloured fruit bat. A.erioloba (IUCN listed as declining). Euclea pseudenus (SANBI protected tree). Vegetation type = Lower Gariep Alluvial vegetation (Conservation status: endangered).  Unique aquatic biota: Some fish species are endemic to the Orange System (ASCL, BAEN, and LCAP). BTRI IN Lower Orange possible unique population, BHOS endemic to lower Orange, MBRE isolated population in the Orange.  Unique riparian biota: Orange river white-eye restricted to catchment, paradise frog (SA Endemic), 6 endemic vegetation plants;  Riparian biota – taxon richness: 70 out of 87 riverine faunal species present (80% of expected);  Riparian habitat: Diversity of types and features: cobble beaches, grazing lawns, backwaters, intact riparian zones, reed beds and some mud flats.  Riparian migration corridor: a riparian band in the area annually inundated by high floods, remains intact, despite the larger area in the floodplains being cleared and planted with agricultural crops. This intact band forms a very important migration corridor for most of the riverine faunal species present in the area.  National parks, wilderness areas, reserves, heritage sites,
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No. Issue Raised by Response from CES EIA team or Hydro SA natural areas: Augrabies Falls (ORASECOM, 2010b:65) and Richie Falls. Changes in flows impact on the food source (Abundance of fish) of piscivorous species (ORASECOM, 2010b:68), e.g. otters and kingfishers. Lower flows eliminate associated deep pool habitat (overhanging vegetation for kingfishers; emerging vegetation for warblers, weavers and moorhen and slower backwater habitats (ducks, coots, storks) (ORASECOM, 2010b:68). The changes in flows (removal of higher flows) resulted in the marginal zone being vegetated with reeds and hygrophilous shrubs, reducing mudflats and alluvial sandbars. Thus less waders (sandpipers, plovers) and open habitat animals (plovers, geese) present. Also species that use sandbars and sandbanks lose digging substrate (monitors, bee-eaters, martins) (ORASECOM, 2010b:68). Clearing the site for construction, will remove the riparian vegetation which provide refuge, shelter, breeding and feeding habitats, and migration routes for riparian species. The Recommended Ecological Category (REC) for the reach including Augrabies and Richie Falls, is a category B (ORASECOM, 2010b:73). The REC refers to the management objective of the river reach, i.e. the river should be managed to achieve an improved PES status of category B. The river mouth ecological requirements currently released from Vanderkloof Dam amounts to 289 million m3/a, and is based on fairly old methodology. Recent estimation of the ecological requirement indicated an average requirement in the order of 1 062million m3/a (ORASECOM, 2007b:57). While the proposed plants are run of river, and the volume of water in the greater flow of the river will not be reduced by the hydro-power plants, the volume of water through the falls at the selected sites will be reduced, especially in low flow and average conditions. In terms of the combined operating flows of the Richie Falls plant (Oranje Falls Farm) and the environmental flow requirements for the REC category B (ORASECOM, 2010b:91, table 9.8), the combined flow requirements exceed the monthly average flow. Further, the design flow alone exceeds the monthly average flow for 8 months of the year. As the Augrabies plant is a higher design capacity, it is assumed the flows will exceed the monthly average to a greater extent
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No. Issue Raised by Response from CES EIA team or Hydro SA and further reduce the ability to implement the environmental flow requirements at the Falls. 34. REFERENCES Lower Orange River Management Plan (LORMP)(2008). Unlocking the Ecotourism potential of the river. Compiled by Ecotoursim Afrika, for //Ai/Ais-Richtersveld Transfrontier park, funded by South African Department of Water and Forestry. ORASECOM (2007). Environmental Considerations Pertaining to the Orange River. Report 005/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2007b). Summary of water requirements from the orange River Basin. Report 006/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2010). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Desktop EcoClassifcation assessment. Prepared by WRP. ORASECOM Report: 016/2011. ORASECOM (2010b). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Environmental Flow Requirements Volume 1 (Main Report). Prepared by WRP, funded by GIZ. ORASECOM Report: 016/2011. Water Research Commission (WRC)( 2007). Guidelines for integrated control of pest blackflies along the orange river. Compiled by Palmer, R.W., Rivers-Moore, N., Mullins, W., McPherson, V., and Hattingh, L. WRC Report No. 1558/1/07 Craig Eksteen, Kalahari Outventures, comment by e-mail 05 May 2015. Comment 34 is a repeat of Comment 15 above. The response is the same. Department of Environmental Affairs Pretoria – Danie Smit 35. From: "Danie Smit" <dsmit@environment.gov.za> Subject: RE: Proposed HydroSA Riemvasmaak Hydro Project / Voorgestelde HydroSA Riemvasmaak Hidro Project Date: 28 April 2015 2:51:25 PM SAST To: "Howard Hendricks" <howard.hendricks@sanparks.org>, ShawnJohnston <swjohnston@mweb.co.za> Cc: "AbrahamsA@dwa.gov.za" <AbrahamsA@dwa.gov.za>, "FransVan Rooyen" <frans.vanrooyen@sanparks.org>, "Hugo Bezuidenhout" <hugo.bezuidenhout@sanparks.org>, "Lucius Danie Smit Control Environmental Officer Grade B (Deputy Director) Integrated Environmental Authorisations (Protected Areas) Department of Dear Mr. Danie Smit, Thank you for your note on receipt of the Draft EIR. Sincerely, Shawn Johnston EAP’s response: We note that the message was sent / copied to staff members of SANParks and DWA, and copied to Shawn Johnston, PPP Coordinator.
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No. Issue Raised by Response from CES EIA team or Hydro SA Moolman" <lucius.moolman@sanparks.org>, "Nomvuselelo C. Songelwa" <Mvusy.Songelwa@sanparks.org>, "Paul Daphne" <paul.daphne@sanparks.org>
Dear All, Thanks for the info forwarded to DEA. I have just today received the Draft EIR that is in the public at the moment. Please be so kind as to forward your comments on the documents to me also so that I can have a record of your comments and concerns. Kind Regards, Danie Smit Control Environmental Officer Grade B (Deputy Director) Integrated Environmental Authorisations (Protected Areas) Department of Environmental Affairs
Environmental Affairs, comment by e-mail, 28 April 2015.
We note that Mr Smit did not request copies of comments from other commenting parties.
36. Dear Danie, We refer to your letter dated 30th October 2013 in which you accepted the Scoping Report for the above project. In that letter, under the heading Public Participation you required us to include in the Draft EIA Report a copy of the minutes of a meeting held on 28th August 2013 between Hydro SA, Aurecon and staff of your department. Initially we believed that you had misquoted the date of this meeting, because on that date our principals at Hydro SA, Mr Theron and Ms Grimbeek, were in Namibia, but it has recently been brought to our attention that the meeting was in fact held on that date, but the attached e-mail trail indicates that the then Case Officer, Ms Poll-Jonker, was responsible for preparing the minutes of the meeting and distributing them to the participants. Neither Mr Theron nor Ms Grimbeek has any record of receiving the minutes, and as a consequence the Draft EIA Report we have recently submitted to you does not include a copy of the minutes. We will be pleased if you will follow the matter up with Ms PollJonker, and provide us with a copy of the minutes. Alternatively, if it turns out that no minutes were prepared, we will be pleased if you will let us know. We look forward to hearing from you in the near future. Sincerely,
Bill Rowlston – EOH CES & Shawn Johnston – Sustainable Futures, 05 May 2015.
EAP’s response: Comment noted.
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No. Issue Raised by Response from CES EIA team or Hydro SA Bill Rowlston – EOH CES Shawn Johnston – Sustainable Futures 37. Dear Danie, Please refer to Shawn Johnston’s e-mail– below – dated 5th May 2015 on the above subject. We have not yet received a reply to the message. We are being pressed by one of the registered I&APs to provide him with a copy of the Minutes of the meeting, and we will be very pleased if you will, as a matter of urgency, either: (i) Provide us with a copy of the Minutes that were prepared by Ms Poll-Jonker; or (ii) Confirm, in writing, that no Minutes were written for the meeting. I need to hear from you in the very near future please. Sincerely, Bill Rowlston Bill Rowlston – EOH CES, comment by email, 04 June 2015. Response from Mr Smit Dear Bill, Apologies for the delay but it took me some time to look for old documents. Unfortunately I could only retrieve an agenda and an attendance register. My opinion is that we never received minutes on this meeting. I see from the attendance list that the previous consultant were also present at the said meeting. It would have been their task to provide minutes. From the attendance list it is clear that whatever the discussions were, it would be in line with the comments received from the relevant parties on the list to date. I was at that meeting and can confirm that the viewpoints were similar to all later meetings later. I have no other documents related to this date. Regards, Danie
38. Dear Danie, The e-mail trail – attached – clearly shows that the responsibility for writing kites / minutes for the meeting lay with, and was accepted by, Ms Poll-Jonker of your staff. Accordingly we are not able to include a copy of these Minutes in the Final EIAR, as instructed in your letter 30th October 2013, in which the department accepted the Scoping Report for the above project, nor are we able to provide a copy of the Minutes to the I&AP who has requested the Minutes. Will you let me have your observations please, as a matter of urgency? Sincerely, Bill
Bill Rowlston – EOH CES, comment by email, 05 June 2015.
EAP’s response: We have not received a response to this message, and accordingly we are not able to provide a copy of the Minutes, as requested by DEA.
This is noted in the Foreword of the EIA Report.
Department of Environment and Nature Conservation Northern Cape – Ordian Riba and L. Tools-Bernado
39. Dear Sir/Madam, Please find attached comments from the Department of Environment and Nature Conservation: Impact Management regarding the proposed project with the ref: NC/NAT/ZFM/KAI!/RIE1/2015.
Ordian Riba, Northern Cape Department of Environment and Nature Conservation, 26 May 2015.
Dear Odain Riba, Thank you for the comments received from the Department of Environment and Nature Conservation Northern Cape on the proposed Riemvasmaak Run-of-River Hydro draft environmental impact assessment study.
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No. Issue Raised by Response from CES EIA team or Hydro SA Kind Regards, Ordain Riba Sincerely, Shawn Johnston 40. The Department confirms having received the EIA Report for environmental authorisation of the above mentioned project on 06th May 2015. As required in term of the Environmental Impact Assessment Regulations, 2010.
The application has been assigned the reference number. Kindly quote this reference NC/NAT/ZFM/KAI!/RIE1/2015 number in any future correspondence in respect of the application. Please note the responsible officer is going to be Mr. O. Riba and can be contacted at (053) 807 7468.
L. Tools-Bernado, Northern Cape Department of Environment and Nature Conservation, 26 May 2015.
EAP’s response: Comment noted.
Department of Rural Development and Land Reform – Khathu Muruba
41. Dear Shawn Johnston, ENVIRONMENTAL IMPACT ASSESSMENT PROCESS FOR THE PROPOSED HYDRO SA RUN-OF-RIVER HYDRO POWER PROJECT, RIEMVASMAAK, NORTHERN CAPE: DEA REF NO: 14/12/16/3/3/2/600 I hereby acknowledge receipt of your letter(s).
The Department of Rural Development and Land Reform (DRDLR) would like to convey its gratitude for being notified about the availability of the Environmental Impact Assessment Report for the proposed Hydro SA Run-of-River Hydro Power Project. The Department has perused the documentation(s) sent. Based on the above, thus far the Department does not have any objections to the proposed. However, the Department would like to be notified of anything related to the project in future. Yours sincerely, Khathu
Khathu Muruba, Pr. Planner (SA) A/2059/2015 Professional Town and Regional Planner Spatial Planning & Land Use Management Branch NATIONAL DEPARTMENT OF RURAL DEVELOPMENT & LAND REFORM, comment by e-mail, 23 June 2015.
EAP’s response: Comment noted. The department will be kept updated on progress with the project.
42. Dear Shawn Johnston, PROPOSED RIEMVASMAAK RUN-OF-RIVER HYDRO POWER STATION I hereby acknowledge receipt of your correspondence. The Department of Rural Development and Land Reform (DRDLR) would like to convey its gratitude for being notified about the proposed Run-of-River Hydro Power Station. The Department does not have any objections to the project at
Khathu Muruba, Pr. Planner (SA) A/2059/2015 Professional Town and Regional Planner Spatial Planning & Land Use Management Branch
Dear Khathu, Thank you for your e-mail and comments on the DEIR for the proposed RVM Hydro Project. Sincerely, Shawn Johnston
The department will be kept updated on progress with the project.
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No. Issue Raised by Response from CES EIA team or Hydro SA this stage. However, the Department would like to be notified of anything related to the project in future. Yours sincerely, Khathu Pr. Planner (SA) A/2059/2015 Professional Town and Regional Planner Spatial Planning & Land Use Management Branch NATIONAL DEPARTMENT OF RURAL DEVELOPMENT & LAND REFORM NATIONAL DEPARTMENT OF RURAL DEVELOPMENT & LAND REFORM, comment by e-mail, 17 July 2015. Dr. Rian Wolhuter - Interested and Affected Party 43. HydroSA Riemvasmaak / Augrabies Falls National Park Hydro Project Environmental Impact Assessment Process Comments With reference to the proposed Augrabies Hydropower scheme, I would like to comment as follows: According to published information and the project website itself, the scheme is planned to generate up to 40 MW. The project's proposed location and associated topography shows that the hydrostatic pressure height for the scheme cannot be more than 120m and will probably be closer to 100m in practice. Simple power calculations and assuming an 85% utilization rate, show that a volume flow of just under 50 cumec (m3/s) will be required. During a visit to the Park in April 2013, the flow was 35 cumec, only 70% of the required value. The fall was still nice, but not spectacular. During my last recent visit in April it was even below this at 27 cumec, according to information provided by the Department of Water Affairs. Perusing flow figures over the last 10 years for that part of the Orange, as available from Department of Water Affairs, is instructive. The period includes about 6 times of flood during which the flow factor increases by 10--‐20 times momentarily. If we want to preserve something of the visual attraction of the falls and generate 40 MW, then app. 30 + 50 = 80 cumec is required, which has only been achieved 50% of the total time. If the 6 short peak periods are omitted, this required flow incidence reduces to 18% over the period. It should also be noted that hydro power generation through turbines would not be an option during flood periods, due to the silt content of the river at those times. A very typical annual average flow for that Dr Riaan Wolhuter Senior Researcher, Stellenbosch University, comment by e-mail, 01 June 2015. EAP’s response: Available head and flow requirements: Detailed calculations undertaken by the applicant show that the net head (that is, after deducting head losses through delivery conduits), is 123.6m, and that a flow rate of a little less than 38m3/sec is sufficient to generate 40MW of power at an 88% efficiency (that is, allowing for turbine, generator, transformer and transmission losses). Availability of water: The availability of water was derived from analysis of 20 years of recorded data (daily average flow between 1994 and 2014) from DWS’s hydrological gauging weir at Neusberg Weir (D7H014), some 47km upstream from the proposed diversion weir. On DWS’s advice a constant 3m3/sec was deducted from the flow rates recorded at the gauging station to allow for abstraction for irrigation between Neusberg and the diversion weir site. Energy calculations: The energy model used in the analysis considers that the project does not operate until river flow is equal to 30m3/sec, and is shut down when flows exceed 800m³/s, when high sediment loads are anticipated. Diversion of water: More detail on the diversion schedule and its impacts on the flow regime at the Augrabies falls are provided in the response to Comment 8. Generating capacity: Comparisons between the generating capacity at this project and in Mpumalanga are meaningless. The transmission practitioner on the project design team remarks as follows: “A 40 MW hydro plant connecting at Blouputs will have a positive impact on the stability of the South African Electricity Grid. While the small relative size of the units will have negligible impact on the overall system frequency stability, the units will provide
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No. Issue Raised by Response from CES EIA team or Hydro SA river section in non--‐flood years, lies between 35 and 60 cumec. In e.g. 2012, the overall annual average was only 57 cumec. Sobering, in view of the 50 cumec required. In the Mail & Guardian of 13th March 2013, Mr. Theron of Hydro SA is quoted as follows: "... The Amount of water [Extracted] is very little in terms of the flow regime" This statement clearly does not correspond with the facts and is grossly misleading. Moreover, according to Die Burger of 10th April 2013, Hydro SA stated that a minimum flow of 30--‐35 cumec will be maintained for the falls. Further, again according that report: "We will not take away the waterfall ....". This is completely erroneous. The facts are clear. It is impossible to avoid serious or fatal damage to the falls during the vast majority of the time for the declared energy generation capacity, or even a significant part of it. ANY diversion of the flow, especially in the drier months, will have a disastrous impact on the visitor experience and thus on the Park. The seasonal variation in the appearance of the fall and side falls is also part of the Park's attraction. There are other misrepresentations regarding the project. The information website of the project engineers (who have apparently withdrawn in the interim) contains the following statement: “Furthermore, the station will aid in balancing South Africa’s energy grid as most of the country’s current electricity generation is located in the Northern provinces such as Gauteng, Mpumalanga, etc.” According to Eskom, the installed capacity in Mpumalanga alone, is about 30 GW. In relation to that capacity, the 40 MW of the proposed Augrabies scheme represents 0.13%. To suggest that this will assist to stabilize the national grid, is ludicrous. The 2.5 m dia. pipeline to the generating station will run through part of the park. Pipelines necessarily follow a geometric / hydrological design and large ones particularly cannot be laid to follow existing jeep tracks, as proposed. The nature of the pipeline and other construction work will require extensive earthworks and apart from the disturbance of wildlife and vegetation during construction, permanent damage will be significant local voltage support. This voltage support is mandated in the RPP Grid code for this sort of generating unit. The voltage support improves the efficiency of the local transmission and distribution network, makes solar PV less prone to interruption due to voltage dips and enhances fault detection and clearing through higher local fault levels. All these effects provide a more secure, reliable and higher quality electricity supply for customers in the region. The presence of synchronous generation in a region can also facilitate faster system restart after blackouts and assist the supply authorities in system outage management.” The above paragraph has been added to section 4.2.6 of the EIA Report
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No. Issue Raised by Response from CES EIA team or Hydro SA inevitable. The pipeline must be serviceable and will require infrastructure like a good access road with sufficient load bearing capacity. There is also the issue of excavated material and other construction artefacts. What happens to that in a National Park? Renewable energy generation is often, like in this instance, presented as being clean and environmentally friendly. It is not always the case at all. One of the many unfortunate examples is the Ruacana Falls project in Namibia, where the spectacular falls are destroyed, except during random flooding. It's a fact that that the overall average generation from the scheme is far below the maximum capacity. A visit to the area reveals a disturbing and visible ecological disaster. Apart from the rock wall without water, construction damage is seen everywhere. One can only wonder what the long‐term eco‐tourism asset for Namibia would have been if nature has been left alone. According to witnesses the falls were once spectacular. There is much evidence that in general the long-term job creation and income potential from sustainable eco--‐tourism could very often be much higher than high impact short--‐term development. The Victoria Falls tourism complex and huge sustainable revenue source, come to mind immediately. Interestingly, after many objections on environmental, social and economic grounds, similar to the those voiced here, the possible Epupa hydro scheme further downstream in the Kunene River in Namibia has not been approved. The usual motivations, such as community involvement and job creation, are valid and certainly sound good to political decision‐makers who must approve the project. If this, as well as the government's energy buy--‐back program (REIPPP) is the purpose, there are a number of other renewable generation alternatives without any impact on a National Park, that could be pursued. There are large current Northern Cape developments of that type, particularly solar based, which certainly appear attractive to other developers. The Park as a whole is a very unique and beautiful area with the fall as one of his best assets. The actual generation capacity of the proposed scheme is highly volatile and insignificant in the larger South African context. This is convincingly evident from the flow statistics of the Orange.
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No. Issue Raised by Response from CES EIA team or Hydro SA Faced with these facts, it is very easy to be highly sceptical about the bona fides of those who are driving this project. What on earth is the real motivation to target our biggest waterfall and surrounding National Park for such a misguided development with such minimal return? We will solve absolutely no problem with this proposed scheme and only cause serious damage to one of South Africa's increasingly popular and unique natural areas. The claim that the falls and Park will not be affected, is misleading and blatantly untrue. Are we really prepared to go ahead with such foolishness? We owe it to future generations due to it not to do so. Dr Riaan Wolhuter Dr. Gerhard Smit - Interested and Affected Party 44. Augrabies Hydro – Electric Power Station. Thanks for your invite to write a column. 1. I live in Vereeniging and am one of many citizens concerned about the misuse and exploitation of our habitat and National and natural resources. 2. Much is being made of job creation and the need for electricity in our country, I realise this however not at the cost of destruction while other alternatives are readily available. 3. My wife and I have been visiting our National Parks regularly since 1967, Augrabies is one of our wonders which has been carefully conserved and preserved by our National Parks authorities for many decades. 4. Now a Hydro- Electric power generating facility is planned for construction in the Orange (Gariep) River a few kilometres upstream from the Augrabies National Park. 5. Few sights are as awesome or a sound as deafening as water thundering down the 56m Augrabies Waterfall when the Orange River is in full flood. 6. The Khoi people called it ‘Aukoerebis’, or place of Great Noise, as this powerful flow of water is unleashed from rocky surroundings characterised by the 18km abyss of the Orange River Gorge. 7. Picturesque names such as Moon Rock, Ararat and Echo Corner are descriptive of this rocky region. Klipspringer and kokerboom (quiver trees) stand in stark silhouette against the African sky, silent sentinels in a strangely Dr Gerhard Smit, Interested and Affected Party, comment by email to Shawn Johnston and Daniella Di Gaspero, Journalist Intern at Daily Southern African Tourism Update, 17 July 2015. EAP’s response: Points 1-7:: No response is necessary. Points 8-12: The Orange River is a highly altered and highly manipulated system, in which the flow regime is not rain fed, but depends almost entirely on the operation of the major impoundments upstream of the Augrabies Falls, particularly the Gariep and Van Der Kloof dams. Only the very largest floods, the 2010 and 2011 events being the most recent, are not significantly attenuated by these reservoirs. The extent to which the flow regime at the falls is set out in the response to Comment 8 above. Monitoring adherence to this flow regime will be a matter between the operator, DEA and SANParks in terms of Conditions attached to the EMPr, as well as conditions imposed by DoE. Points 13-15: Comments about the benefits of solar and wind energy are noted, but such projects are not the subject of this assessment. Run-of-river hydroelectric power has the benefit over solar and wind that continuous baseload power can be generated as long as water is available to turn the turbines. Point 16: The project will not mean the end of the AFNP.
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No. Issue Raised by Response from CES EIA team or Hydro SA unique environment where only those that are able to adapt ultimately survive. The 55 383 hectares on both the northern and southern sides of the Orange River provide sanctuary to a diversity of species, from the very smallest succulents, birds and reptiles to Hartmann's mountain zebra, springbok, gemsbok and giraffe. 8. The >60 000 visitors to Augrabies (12.2% of visitors to our National Parks) per annum do not visit the park because it is there, they visit to experience and enjoy this wonders of a waterfall in an arid area. Augrabies is the sixth most visited National Park in the RSA. 9. The Orange River does not have a consistent high volume flow of water, it is dependent on rainfall upstream. 10. In high rainfall seasons the falls are spectacular, during poorer periods flow is often reduced to not much more of a trickle over the falls. 11. Much is said in the EA documentation about the flow not being less than the required minimum for the flow through the Augrabies National Park. We all are well aware that our environment does not mean much when money is at stake. 12. Wonderful EMP’s can be drawn up, but when the river flow diminishes sufficient mitigation will be improvised to use whatever is left in the river to keep the power station operational, why: because the people have gotten used to the electricity and now it cannot be cut. We are experiencing power outages now especially in winter also the drier months, the Northern Cape and the Orange River will not be spared. 13. There are much less harmful alternatives available, the Northern Cape is well known for having the most cloudless days with good sunshine per annum, and therefor solar energy could offer a guaranteed supply of non-destructive green energy for the inhabitants of the surrounding areas. 14. Wind energy is another source of non-destructive energy. 15. Both 14 and 15 above will also offer the mentioned job opportunities. 16. A Hydro Electric power station above the Augrabies National Park in the Orange River, will spell the end to one of our esteemed National Parks and also to the
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No. Issue Raised by Response from CES EIA team or Hydro SA surrounding tourist industry. 17. Persons who also care for the environment and especially the arid Northern Cape are requested to register as Interested and Affected Parties (I&AP’s) with Shawn Johnston at email address: swjohnston@mweb.co.za and lodge their objections which will form part of the public participation process. Unfortunately time is running out. 18. Our Department of Environmental Affairs and our Government will now have the grand opportunity to prove to the RSA citizens and the world that they really care by not approving this project. Yours sincerely and with kind regards Gerhard Smit. Dr. Howard Hendricks and Dr. Hugo Bezuidenhout - South African National Parks Pretoria and Kimberley 45. Dear Mr Johnson, -In respect of South African National Parks official position as communicated to the previous environmental consultants; SANParks supports renewable energy generation traditionally provided by technologies such as hydro, wind, solar and biogas; Insofar this project, SANParks does not support the construction of the weir, canal and a portion of the power line within the Augrabies Falls NP; In its effort of participation during the public meetings as well as direct correspondence, SANParks have communicated the following concerns to the previous environmental consultants; a) Elements of the proposal will have a visual impact on the park, specifically the weir and power lines as well as the powerhouses of options A and C which would have to be mitigated if such proposal will continue; b) All options fall within the park’s buffer zone, being both in the priority natural areas buffer as well as the viewshed protection areas in accordance to the National Strategy on Buffer Zones around National Parks; 1.4 To this effect, SANParks seeks an alignment between the proposed hydropower station development and the National Environmental Management: Protected Areas Act, 2003 (Act No. 57 of 2003), (NEM:PAA) being the primary Act for managing protected areas in the country for the following Dr. Howard Hendricks, South African National Parks Pretoria, comment by e-mail, 28 April 2015. Dear Dr. Howard Hendricks, Thank you for the comments submitted by yourself on behalf of the South African National Park (SANPArks). I hereby acknowledge receiving your comments and look forward to the comments of on the Draft Environmental Impact Assessment Report (DEIR). Copies of the DEIR has been submitted to:  Frans van Rooyen at Augrabies Falls National Park ( hard copies and CDs);  Lucius Moolman - Regional Manager Arid Park; and,  Your office in Pretoria. I have also sent the DEIR to Willem Louw at Park Planning and Development Conservation services. Sincerely, Shawn Johnston EAP’s response:  Dr Hendricks’ lack of support for the project is noted.  It is noted that the comments relate to the Basic Assessment Reports, which addressed two 10Mw stations served by a common headrace, and subsequently the Draft Scoping report for the EIA for the single 40MW project. Comments on the BARs  We are aware of the existence of the National Strategy on Buffer Zones around National Parks and the requirements of the NEM: PAA. We are also aware that South Africa is experiencing ongoing difficulties in providing sufficient
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No. Issue Raised by Response from CES EIA team or Hydro SA reasons; The proposal to divert a sizable portion of the river’s flow from the falls would have a negative impact on the visitor experience to the falls. A statement in the proposal that extraction may be limited to the night during periods of low flow is unrealistic as the falls are lighted at night so that visitors can experience them outside daylight hours; We anticipate that the planned volume of water to be diverted would also have a negative impact outside low flow periods as SANParks requires the minimum reserve flow to maintain ecosystem integrity especially since the choice of the availability of electricity to consumers is likely to supersedes the volume of water flowing towards the falls because the provision of electricity will be regarded as a priority;SANParks requires the justification of the figure mentioned of 30 kumec; While not explicitly forbidden in the National Environmental Management: Protected Areas Act (Act 57 of 2003), the provision of land for infrastructure linked to the commercial generation of power is not listed as one of the functions of SANParks and it is therefore questioned if SANParks is in a position to lease or otherwise provide rights for power generation infrastructure such as those contained in the proposal; The area of the park through which the pipe or canal is planned is currently zoned remote and falls in the special management area category. The remote zone according to the zonation plan of the Augrabies Falls NPark is the zone providing the highest form of protection. This is an area retaining an intrinsically wild appearance and character, or capable of being restored to such and which is undeveloped. There are no permanent improvements or any form of human habitation. It provides outstanding opportunities for solitude with awe inspiring natural characteristics. If present at all, sight and sound of human habitation and activities are barely discernable and at a far distance. The zone also serves to protect sensitive environments from development impacts and tourism pressure. The conservation objective is to maintain the zone in as near to a natural state as possible with no impact on biodiversity pattern or processes. Existing impacts on biodiversity either from historical usage or originating from electrical power to support growth and development for all of its people. We are of the opinion that the project can be constructed and operated for the benefit of the nation, without significantly disrupting the integrity of the ecological systems of the national park.  The extent to which the flow regime at the Augrabies Falls is set out in the response to Comment 8 above. We are of the opinion that the diversion of a maximum flow rate of 38 m3/sec to the HPP will not significantly affect the visitors’ enjoyment of the spectacle of water flowing over the falls. The project will never cause the falls to run dry. Only improper management of the large dams upstream of the falls and abstractions for offchannel use can prejudice the falls to that extent. There is no proposal in the Draft EIA Report, which has been provided to Dr Hendricks for comment, to divert water during the night and during low flow periods.  A new section – 3.3.2 Previous environmental water requirements recommendations – has been added to Chapter 3 of the EIA Report, in which the issue of environmental flow regimes in the river is explored.  We are aware of the provisions in the NEM: PAA relating to commercial activities in national parks, and also that the list of activities in the Regulations to the Act does not include the commercial generation of electrical power.  We are aware of the nature of the land across which the headrace is proposed to run. We have been informed of its past uses as the home of the RVM community, and as a practice range for the military. As far as present uses are concerned we believe that access by the public is not allowed, and as far as we know only park staff may gain access to this portion of land. We are aware of the need for a revision of the park‘s Management Plan if such a development were to be approved.  Only a small section of the riparian vegetation will need to be removed to accommodate the offtake structure, and the botanical specialist assessed this impact as being of low significance.  The construction of the headrace will be done in sections, so that as much access across the route as possible is maintained during excavation. Backfilling and surface
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No. Issue Raised by Response from CES EIA team or Hydro SA outside the zone should be minimized. It must be noted that amendments to the management plan and zoning have to be approved by the Minister of the Department of Environment Affairs for which the Minister may recommend a public participation process; The already diminishing riparian vegetation along the river due to increased farming practices (removal of vegetation right up to the edge of the river), is a major concern. The water level upstream of the weir will cause vegetation to be exposed to more water and downstream to less water (the distance between where water is extracted up to being released back into the river) which inevitably will be detrimental to the riparian vegetation; Animals are dependent on water from the river and nearby affected drainage lines with low water flow will present a difficulty for animals with access to water, particularly along the stretch of land where game readily make use of feeding routes; Subsequently, SANParks made the following comments on the Draft Scoping Report for the Proposed Hydropower Station; Discrepancies between the proposed development and SANParks mandate must be regarded within all the applicable environmental legislation both nationally and internationally, not just NEM:BA as the draft scoping report alludes; There seems to be no procedural explanation for the valid application upgrade from approximately two 10 x 10 MW substations to one 40 MW substation, including the regulatory framework that provided for three applications which were lodged by RVM1Hydro Electric (Pty) Ltd, RVM 2 Hydro Electric (Pty) Ltd and RVM 3 Hydro Electric (Pty) Ltd, respectively in comparision with Department of Energy lifting the cap of ≤10 MW; Whilst providing the fundamental arguments for “Riemvasmaak land, owned by the Riemvasmaak Community Trust, located within the borders of the Augrabies Falls National Park” followed their forced removal in 1973/1974 during Apartheid, the report uses such notion of land ownership interchangeable to avoid referencing the cabinet decision of parliament that such land must be used for the purpose of conservation, hence the current contractual rehabilitation will be done as soon as possible after construction of the headrace, including reinstating episodic watercourses crossing the route. On completion there will be no hindrance to crossing the route. Comments on the DSR  We are of the opinion that SANParks mandate in the AFNP in terms of relevant legislation can continue to be successfully implemented, mutatis mutandis, if the project is allowed to be constructed and operated..  The change of project from two BAs to one Scoping+EIA was permitted and facilitated by DEA, to whom any queries about procedural irregularities should be addressed.  The only evidence provided to us by SANParks for the existence of a contractual agreement between SANParks and the RVM community over the management of the RVM land is a document entitled Konsep vir Bespreeking deur Onderhandelsing Komittee, being the minutes of a meeting held on 7th Match 1998. This is to all intents and purposes an agreement to establish an agreement, but we have no indication from SANParks or the community that such an agreement has ever been concluded. Despite a request to SANParks to provide us with a copy of the Cabinet decision mentioned by the commentator nothing has been forthcoming. A Legal Review addressing land ownership and management issues has been commissioned by the applicant, and this will be available in the Final EIA Report.  The disagreement between DEA and the previous EAP regarding the relevance of Listed Activity 10 in GN R.545 (transfer of water) is irrelevant, since at least one other Listed Activity required Scoping+EIA, and the impacts of the transfer infrastructure have in any case been assessed as a matter of course.  The impacts of diverting a portion of the flow of the river to the HPP, and the way in which the diversion will be implemented, are discussed at some length in the EIA Report. The main features of the diversion are that no diversion will take place at flow rates in the river less than or equal to 30 m3/sec, and that about 10% of the total average annual flow will be diverted. We do not understand the difference between the visual impact and the tourism experience. The question of increasing
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No. Issue Raised by Response from CES EIA team or Hydro SA agreement between SANParks and the Riemvasmaak Trust including the acceptance of an annual ex gratia payment – this highlights the need for clarity on land ownership and the appropriate landuse thereof; While not explicitly forbidden in the NEM:PAA, the provision of land for infrastructure linked to the commercial generation of power is not listed as one of the functions of SANParks and it is therefore questioned if SANParks is in a position to lease or otherwise provide rights for power generation infrastructure such as those contained in the proposed development; The difference of opinion between DEA and the Aurecon regarding Listing Notice 2 (GN No. R545) of the NEMA EIA Regulations must be resolved with immediate effect, rather than just prior to the submission of the final EIA Report Regulations must be resolved with immediate effect, rather than just prior to the submission of the final EIA Report for decision--‐making; SANParks concern about diverting a sizable portion of the river’s flow from the falls that would have a negative impact on the visitor experience to the falls, is ignored – instead, the report confuses this concern with the visual impact group rather than a tourism experience which highlight the shortcoming of the draft scoping report in defining a tourism experience as merely a visual impact; The developer is silent on the planned volume of water to be diverted during the low flow period; the minimum reserve flow is required to maintain ecosystem integrity whilst an additional amount of volume of water will be required to provide a heightened tourism experience at the falls; The revision of an approved Park Management Plan is the prerogative of the Minister in accordance to NEM:PAA Section 40 (2), whereas the change of a particular zone within a National Park is subject to Section 41 (g) of the same Act compelling SANParks to change such zones with predetermined conservation objectives and activities for all the national parks in the country to allow for the proposed project – the conservation objective is to maintain remote and primitive zones in as near to a natural state as possible with no impact on biodiversity pattern or processes, essentially these areas retaining an intrinsically wild appearance and character, the overall flow regime at the falls for a “heightened tourism experience” is for DWS to address, as that department manages releases from impoundments and abstractions from the river upstream of the falls.  We are aware that the parks’ Management Plan will need to be amended to accommodate the project, and that the Minister’s approval will be required for such amendments.  We are aware of the intentions of the National Strategy on Buffer Zones around National Parks. However, we are of the opinion that the issue of ensuring that South Africa has sufficient energy resources to provide an acceptable standard of living for all of her people is of such critical importance, particularly by means of a project that we believe will have limited impacts on the nature of this area of the park, that it can be accommodated within the spirit of the policy.  The criteria used for selecting this site for the development of a hydroelectric project, and the alternative sites are set out in Chapter 5 of the EIA Report. It is pointed out that there are very few sites suitable for the provision of hydroelectricity that do not require the construction of large impounding reservoirs. A run-of-river project has already been developed and is operating at Neusberg, and a project has been developed for Boegoeberg, both of which depend on large existing constructed barriers across the river to generate the driving head.  The status of the national park is not “downplayed “ in the EIA Report, but it is suggested that the hydroelectric scheme and the national park can coexist satisfactorily with minimal disruption to the park, including minimal impacts on the conservation of species and significant benefits to the local population and the nation as a whole.  Note that a specialist study was undertaken on the potential impacts of the project on tourism in the area as part of the EIA phase of the assessment.
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No. Issue Raised by Response from CES EIA team or Hydro SA or capable of being restored to such and which is undeveloped, there are no permanent improvements or any form of human habitation, and provides outstanding opportunities for solitude with awe inspiring natural characteristics; SANParks notes that the proposed development is not in accordance with the spirit of the National Strategy on Buffer Zones around National Parks; The developer uses location alternatives interchangeable between alternatives sites along the Orange River versus alternative sites in the country which limits a proper understanding of what feasibility studies were done towards alternatives sites for the waterfall, no indication is given as to where the 12 sites along the Orange River were located (Ps. both Neusberg and Boegoeberg are ideal alternative sites to the Augrabies Falls National Park site which together is likely to deliver at least 30% of the 75MW allocation for small hydro stations); It is a grave concern that the developer down plays the status of a National Park with the high positive social impact that the project will have (especially for the landowners, i.e. Riemvasmaak Community), as well as the contribution it will make to the energy grid in South Africa as the best practicable environmental option for the proposed site of development thereby disregarding regrettably the importance of a National Park and the legal status thereof; From a species management point of view, the developer’s proposal falls short on the importance the park provides towards the conservation of many species to this environment, including large breeding colony of birds nesting in trees along the river and on a small islands whilst the disturbance of normal riverine habitat and the interference with the flow and stratum of the river bed and bank are likely to permanently flood many large rocks in the vicinity of the weir thereby disturbing a watercourse that would otherwise have been used as perching sites for birds such as cormorants which constitutes a prohibition in NEM:PAA Regulations; SANParks submits grave concern about the fact that the developer incorporates the impact on tourism synonymous with the visual impact of the proposed development and
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No. Issue Raised by Response from CES EIA team or Hydro SA loosely as part of the impact on the socio--‐economic environment – the impact on tourism has merit to be investigated on its own, hence a separate and additional specialist study will be required. Regards, Howard 46. Dear Mr Johnston, Herewith, please find SANParks comments to the Draft Environmental Impact Assessment Report for consideration. These comments should also be read together with: Bezuidenhout, H. September 2013. Field visit and meeting with DEA officials and other interested and affected parties – on the proposed hydropower station in Augrabies Falls National Park. Internal SANParks report, Scientific Services, Kimberley. Bezuidenhout, H. October 2014. Proposed Riemvasmaak Hydro electric power stakeholder site visit. Internal SANParks report, Scientific Services, Kimberley. Regards, Howard Dr. Howard Hendricks, South African National Parks Pretoria, comment by e-mail, 31 May 2015. Dear Howard & Hugo, Thank you for the SANParks review of the proposed Riemvasmaak Run-of-River Hydro Draft Environmental Impact Assessment Report. I hereby acknowledge receiving the SANPArks submission prepared by Dr Hugo Bezuidenhout dated 31 May 2015. Sincerely, Shawn Johnston Dear Mr Johnston – these reports are internal SANParks documents and not to be confused with the official submission which Dr Howard Hendricks submit on Sunday 30/05/2015. I and other SANParks colleagues have given our comments to Dr Hendricks and he then gave you our official submission. Best wishes, Regards, Hugo Fred de Groot – Africa Wild 47. Dear Mr. Johnston, Having read the article, regarding the hydro electrical power station, Planned to be constructed near Augrabies national park, please can I be listed as a IAP in this matter. Myself being a member /representative of a wild life forum, Africa Wild, Matters such as these developments are always of concern to us and We would like to be kept updated as developments proceed. Thanking you in advance,.. Fred de Groot Africa Wild Fred de Groot, Africa Wild, comment by email, 24 August 2015. Dear Mr. Fred de Groot, Thank you for your e-mail and request. You have been registered as an interested and affected party. We will keep you posted on the environmental impact assessment process. Sincerely, Shawn Johnston International Rafting Federation – Sue Liell-Cock 48. Dear Shawn, Please register me on the Project database for the International Rafting Federation. Sue Liell-Cock (Ms) International Rafting Federation - Secretary Dear Sue, Thank you for your e-mail. I herby confirm that the International Rafting Federation has been registered and an interested and
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No. Issue Raised by Response from CES EIA team or Hydro SA Thanks Sue General, comment by e-mail, 23 April 2015. affected party on the proposed HydroSa Riemvasmaak Run-ofRiver Hydro Project environmental impact assessment process. Sincerely, Shawn Johnston Jean Senogles – Interested and Affected Party 49. Sir, Please register me as an Interested and Affected Party. I too have taken tourist to the Falls during trickle time and while in full flood. They are truly inspiring. (See attachment) I am so against this outrage on the landscape of this wonderful arid place. It will spoil it for ever seeing it from the air. Knowing the flow is being controlled by Homo saps too will distract something from the place for me. We seldom do anything that doesn’t harm. Solar power is getting more and more efficient and will be cheaper than this hydroelectric installation. Who will be benefitting personally? Follow the money trail. I don’t believe someone will not be pocketing a lump sum. That is the way of our country. Jean Senogles Jean Senogles, Interested and Affected Party, comment by email, 22 July 2015. Dear Jean Senogles, Thank you for your e-mail. I hereby confirm receiving your comments on the proposed Riemvasmaak Hydro Project. Sincerely, Shawn Johnston Attachment, refer to article written by Dr. Gerhard Smit. EAP’s response: Control of the flow regime: The flow regime in the Orange River is highly altered, and has been artificially regulated since the completion of the Gariep and Van der Kloof dams in the 1970s. The exceptions have been the few very large floods that cannot be attenuated by the impoundments. These dams have facilitated large-scale abstractions of water from the river for irrigation, as well as transfers of water to the Eastern Cape. More recently the dams of the Lesotho Highlands Water Project have facilitated the transfer of large volumes of water into Gauteng. The extent of alteration to the flow regime over the falls by the hydropower project cannot reasonably be compared to the macro-level manipulations of the river described above. See the response to Comment 8 for an explanation of how the project will impact the river flow. Kai!Gariep Municipality – G. Lategan, Acting Municipal Manager 50. Mr. Johnston, Attached, find the letter of support for the Riemvasmaak Hydro Electric Power Project. Kind regards, Leandri D. Schwartz Leandri D. Schwartz Admin Officer – PMU Kai !Garib Municipality, comment by e-mail, 08 June 2015. Dear Leandri, Thank you for your e-mail and letter of support for the proposed Riemvasmaak Run-of-River Hydro Project and for the review of the draft environmental impact assessment report. I hereby acknowledge the submission received from the Kai! Garib Municipality. Sincerely, Shawn Johnston 51. Dear Sir, Based on EIA documents received on 29 April 2015 for the Riemvasmaak Hydro Electrical Power Project, Northern Cape, G. Lategan, Acting Municipal Manager, comment by e-mail Kai !Garib Municipality’s support for the Riemvasmaak Run-ofRiver Hydro Project is noted for the record.
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No. Issue Raised by Response from CES EIA team or Hydro SA South Africa outlined a plan for the proposed development of the hydro energy plant to the Kai !Garib Local Municipality, the municipality confirm her support to the project. The above mentioned was preceded by a presentation on the potential environmental impacts of the project by yourself as well as the Environmental Consultancy in the Office of the Mayor in Keimoes, Kai !Garib Municipality. Beside the fact that you conducted a public participation process for the EIA in the Kai !Garib Municipal area, the Council’s Standing Committee dealing with socio-economic issues on Tuesday, 26 May 2015 express support for the project. Furthermore, the Kai !Garib Municipal Council at a Council Meeting held on 2 June 2015 compliments the decision of the Committee. However the following is noted as development contributions of the project:  The Environmental Impact Study addresses all the potential issues relating to the project;  The project will have a significant economic impact in terms of job creation and revenue generation both within the municipality and outside of the municipality;  It was noted that these positive impacts are expected to multiply should other renewable solar energy projects be established on adjacent sites;  The project has the potential to assist the municipality in achieving its immediate and long-term development goals inter alia, infrastructure services, LED and social cohesion;  Avoidance of greenhouse emissions and particulate pollution associated with thermal energy options;  Skills development to science students, visits by schools and interested parties in renewable energy;  Through social policy dialogue with local communities the project can contribute immensely to local investment by unlocking economic activity as a catalyst for social change.
Kai !Garib Council herby extends its support for the project. G. Lategan Acting Municipal Manager
letter, 08 June 2015.
Kalahari River and Safari Company – Philippa van Zyl
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No. Issue Raised by Response from CES EIA team or Hydro SA 52. Hello Shawn, I’ve just received the mail from the APA council regarding this proposed Scheme. We would be directly influenced as we operate and have our camp just above the falls! Please advise what you require from us so we can have our say. Warm Regards Philippa Van Zyl Ten 3 Safaris Philippa van Zyl, Kalahari River and Safari Company, comment by e-mail, 08 June 2015. Dear Phillippa, Thank you for your e-mail. I have registered you as a interested and affected party. Please send me your comments on how this project will impact and affect your camp, operations and livelihood. Sincerely, Shawn Johnston 53. 8 June 2015 To whom it may concern. We are tourism operators who have newly taken over a camp on the Orange River roughly 10km above the Augrabies Falls. The Camp was previously known as Khamkirri, a very well known sort after destination along the Orange River. Now under new owner/management we are opening Kalahari River & Safari company on the 1st of July 2015. This proposed scheme is unacceptable, our location from a geographical point would be directly affected as we not only utilize the river for recreational adventure activities but the surrounding area where we take tourists too. The Augrabies falls and Riemvasmaak are 2 direct tourism attractions that would be severely affected. Our camp as well as surrounding B&B’s, Lodges and tour operators would then no longer be able to offer the diverse products that we do for our Clients. Private tourism Operators and investors as well as Northern Cape Tourism has spent huge amounts on promoting the province as a tourism destination for local and international tourism alike, working towards long term sustainability not only for eco tourism but job creation for local communities. Apart from the unsightly invasion the Hydro scheme will pose, noise pollution, water pollution, such environmental abomination is unacceptable. The Ripple effects of such a scheme is greater than the instant financial gratification and energy source for the companies and communities supporting this. I simply cannot support such a proposed scheme in our beautiful area that has so much else to offer. Regards, Philippa van Zyl Philippa van Zyl, Kalahari River and Safari Company, comment by e-mail, 08 June 2015. EAP’s response: Your objections to the project are noted. We believe that the commentator’s concerns about the impacts of the project on tourism in the area in general, and on her business in general, are exaggerated and unfounded. As described previously in this report it is our opinion that the impacts of the alteration of the flow regime over the Augrabies Falls will be minimal, and will be unnoticed by the very large majority of visitors. We repeat that the project will never be responsible for “drying the falls up” or for ”reducing the flow to a trickle”. We also believe that, although there will be disruption during construction, the site can be rehabilitated so that most of the infrastructure will not be visible. The commentator’s fears appear to be based on the belief that visitors to the area will not tolerate any form of development in the area, even if it is for the purposes of providing renewable energy for the benefit of the nation as a whole.
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No. Issue Raised by Response from CES EIA team or Hydro SA Kobus van Coppenhagen - Daberas (Draft Environmental Imapct Assessment Comments) 54. Dr. Avis We are a registered affected party for the above mentioned application, which was launched by three separate SPE's in Dec 2012 and which was subsequently "upgraded" to double the capacity of the proposed installation. For the sake of brevity we will not elaborate any further, assuming that your company is in possession of the details of all the registered IAP's together with all the correspondence which was exchanged between IAP's and AURECON. As a matter of interest; we have suggested 2 years ago that AURECON should be replaced as the consultants because they were conducting a procedurally flawed and administratively unfair process. This happened a few months ago and your company has the unenviable task of concluding the process in a transparent and fair manner. As a matter of record it must be noted that a precedent was set several years ago when another applicant was directed by the Competent Authority, to allow the IAP's to participate in the appointment of the consultants due to the impacts of the proposal, which was also our notion in this case, from the outset. Details of this directive can be provided on request and which would then serve as proof of precedent. We do respectfully request that your facilitator contact us (and perhaps others) to confirm our status as affected parties, especially due to our many valid concerns and the incompetent manner in which it was being dealt with. We also need to verify with the facilitator that your company is in possession of a full record our correspondence, for consideration. In the meantime we do need a copy of the valid upgraded application (requested by DEA 18 June 2013) together with the subsequent instructions and directives issued by this competent authority, which would have validated the application and which would lead the consultants in the design of the Scoping and EIA Reports. We also need a copy of the water license application, together with the instructions and directives issued by DWA. Regards Kobus & Hannecke van Coppenhagen Augrabies. Kobus van Coppenhagen, Daberas, comment by e-mail, 09 March 2015 EAP’s response: We note and do not doubt the commentator’s status as a registered I&AP for the Scoping phase of the EIA. Public consultation: We do not wish to comment on the commentator’s views on the adequacy of the public consultation process conducted before we – EOH CES – were appointed to complete the EIA process. The commentator was provided with a copy of the Application as he requested: see Comment 56 below.
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No. Issue Raised by Response from CES EIA team or Hydro SA 55. Dr Avis, We have requested more than 4 weeks ago, that you should furnish us with the copy of the valid application form date stamped by the DEA and according to which the ToR for your EIA has been determined. You have failed to provide us with this document, without which the application is invalid and the procedurally flawed. Do you refuse to provide this document? Your response is urgently required. Regards Kobus van Coppenhagen Kobus van Coppenhagen, Daberas, comment by e-mail, 15 April 2015 Dear Mr van Coppenhagen, Thanks you for your email. My apologies for the late response, but we are in the final stages of completing all documents for the HydroSA project and somewhat busy. Our engagement process, and indeed that of the EIA process, is to gather all correspondence from IAPs and integrate this into a comments and response trail, in preference to individual and piece-meal responses. The latter is an inefficient and somewhat exclusive way of engaging, whereas including concerns and responses in the comments trail of the EIAR is a more transparent and inclusive manner of engaging with IAPs. This way everyone is privy to the debate, rather than a select few. With regard to the application form, it will be included in the Draft EIAR as an appendix for all to see. Regards, Ted Avis 56. Dear Dr. Avis, It is quite clear that we are not "on the same page", so to speak. The applicant/s are obliged to provide the information on request of an IAP, not whenever they feel like doing it. The failure to provide a copy of the valid application form at the time when we requested it, about 18 months ago, is a serious failure on the part of the applicant and our objections to the continuation of this application must be recognized, when a review is conducted. Unfortunately it seems as if the basic concept of fair procedure and administration as laid out on the relevant document, is beyond comprehension. To refresh your memory and for the sake of brevity, we will only quote note (8) from the front page of the original "RVM1....." application;"Unless protected by law, all information filled in on this application shall become public information on receipt by the competent authority (CA). Any interested and affected party should be provided with the information contained in this application on request, during any stage of the application process." The bold type and underlining is used to reinforce our point. The record will show that we have been requesting this very relevant information for a long time and that the indulgence/failure of the CA does not absolve the applicant Kobus van Coppenhagen, Daberas, comment by e-mail, 22 April 2015 Dear Mr van Coppenhagen, Kindly find the revised application form attached. Regards, Ted
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No. Issue Raised by Response from CES EIA team or Hydro SA from this duty. We are stating again, also for the record at the CA, that you are not conducting a valid application, for the various reasons we have furnished and which you admitted to have received copies of, from the previous EAP. Do you understand that we were only asking you for a copy of the valid application form, which was used to determine the ToR for the Scoping Report? This was a request for information, not comments !!! Best regards, Kobus van Coppenhagen 57. Dear Dr. Avis, Thank you for the document which you have forwarded to us. Unfortunately it seems as if some panelbeating has been done as far as the original project title is concerned. This is a very important detail, when appeals/objections are lodged. To refresh your memory we do attach a copy of page one of the "RVM1" application, which shows the original title and which covers ONE hydro electric power station WITHOUT the water and electricity conveyance infrastructure, which was applied for in "RVM3". Since you acknowledged receipt of our documents from AURECON, you would have noted our concern about the incorrect statement in a letter by AURECON dated 3 June 2013 (see below), which states that RVM1 has launched 3 applications, which is patently false. The closure of "RVM3" has led to the lapsing of that application. We also need a copy of the letter of acceptance by the DEA which "authorised" the transfer/inheritance/consolidation of the activities applied for in the lapsed "RVM3" application into your new? (no reference to RVM1) application. The reason for this is so that we can engage with the official to determine whether he/she/they were misled by the false statement referred to above, or whether it was a conscious decision. You do realise that these are administrative questions and not comments, thus we would expect a copy of the letter of acceptance from DEA to be forthcoming within a reasonable time frame. In the mean time our contention that you are conducting an invalid and flawed procedure, which could lead to destruction inside a National Park, remains firm. It is literally incomprehensible, how businesses with highly educated and skilled people can make such errors unwittingly. Kobus van Coppenhagen, Daberas, comment by e-mail, 28 April 2015 Dear Mr van Coppenhagen, Kindly find attached the DEA acceptance of the amended application. We acknowledge receipt of your other comments and we will address these issues through the independent facilitator and the Issues Response Trail, as well as during the focus Groups and public meetings, all of which will be minuted. Regards, Ted
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Coastal & Environmental Services 57 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA Regards, Kobus van Coppenhagen 58. Hallo Shawn, We are actually requesting a copy of the minutes of the meeting held with the DEA on 28 August 2013. I believe that Mr Smit and others from DEA were present. Regards Kobus van Coppenhagen On 04 May 2015, at 1:41 PM, Kobus van Coppenhagen wrote: Hallo Shawn Our telecon of this morning refers; We have not yet received a copy of the minutes of the DEA meeting of 28/8/2013, as requested. Regards, Kobus van Coppenhagen Kobus van Coppenhagen, Daberas, comment by e-mail, 04 May 2015 Dear Mr van Coppenhagen, We refer to our e-mail to you yesterday, 4th May 2015, in which we sent you a copy of the minutes of a meeting held between Hydro SA and SANParks on 25th July 2013, and to your subsequent reply received this morning, 5th May 2015. You are correct in saying that this is not the meeting referred to in DEA’s letter dated 30th October 2013, in which the department accepted the Scoping Report for the above project. At the time of writing to you we believed that DEA had misquoted the date of this meeting, because on the date in question date our principals at Hydro SA, Mr Theron and Ms Grimbeek, were in Namibia. However, it has recently been brought to our attention that such a meeting was in fact held, and that the then Case Officer, Ms Poll-Jonker, was responsible for preparing the minutes of the meeting and distributing them to the participants. Neither Mr Theron nor Ms Grimbeek has any record of receiving the minutes. As a consequence the Draft EIA Report we have recently submitted to DEA does not include a copy of the minutes, and we are currently unable to provide a copy to you and the other I&APs. We have contacted Mr Danie Smit at the department and requested him to follow the mater up with Ms Poll-Jonker, and either provide us with a copy of the minutes, or let us know if no minutes were prepared. As soon as we hear from Mr Smit we will be in touch with you, but in the meantime please accept our apologies for the confusion over this issue. Sincerely, Bill Rowlston – EOH CES Shawn Johnston – Sustainable Futures Re submission of Mr Kobus van Coppenhagen’s Comments (Listed 1-16) Row 58-72 of this table 59. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (1) Kobus van Coppenhagen Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015 Dear Mr. Kobus van Coppenhagen, Thank you for our submission (1) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely,
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 58 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA Date: 07 April 2013 4:57:31 nm. SAST To: David Jury McDonald <dave@bergwind.co.za> Cc: Louise Corbett <louise.corbett@aurecongroup.com>, Mike Knight <mknight@nmmu.ac.za> Subject: Botanical Assessment for Riemvaasmaak Hydro-power Project
Sir We live in the Lower Orange river valley and share a common boundary of approximately 18 km with the Augrabies Falls National Park and are in the process of contracting the land into the National Park on a long term agreement, since 2008. This is a long process which was initiated by the desire to establish a transfrontier park (LORI Project) along the Lower Orange river, of which the Augrabies Node would stretch to Onseepkans and cover an area of 120 000ha. The river in this area is managed by a Joint Managent Board which is comprised of government departments of Namibia and South Africa. Unfortunately the finacial crisis put the process on ice, but SANParks declared their intent of continuing the process, during the review of the Park Management Plan towards the end of 2012. It was confirmed by a specialist at the time (2008) that this area falls within a biodiversity hotspot and is worthy of protection. We are studying your assessment and have a few specific questions to ask; 1) Were you aware of the existence of GN 106 of 8 February 2012, published in GG no. 35020 ? Title: Biodiversity Policy & Strategy for South Africa : Strategy on Buffer Zones for National Parks. We would appreciate your assessment of the desirabilty of this planned industrial complex in the light of the recommendations made in this policy document. Several questions arise from this document and specifically that all ranks/levels of government " should respect the views of SANParks" as far as the desirability of developments around declared National Parks are concerned. We believe that this document would make it "unwise" to apply for large scale projects in and around national parks. 2) Have you done any new work on black flies, which cause universal problems in the Bushmanland. We believe that an
Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 59 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA impoundment of the river and also the outlet site could aggravate/exacerbate the problem. The Departments of Agriculture and Water Affairs are responsible for the control measures. The cost of a single spraying event alone is estimated to be about R 1 million and that covers only specific areas, not the whole river. 3) Were you involved in any public participation process? We would appreciate some kind of declaration from you on this regard, because there seems to be inconsistency between the specialist declarations. 4) Aurecon, by way of ms L Corbett, seems to think that our concerns only need to be recorded for the decision makers to adjudicate. However, due to the lack of notification, virtually nobody in the area received notice of this project and we have many issues which must to be considered. The number of private land owners notified were only 4 and they own the land on which the power lines need to be built. We are in no position to make any meaningful contribution at this stage, except to raise the alarm that there was no public participation process. Please be so kind to respond to this e-mail, since it is a matter of great importance to us. Regards
Kobus van Coppenhagen 0836564498 PS : Ms Corbett, today is Sunday and you will notice that we are busy with this matter every day and do not intend to waste your time, but we need you to urgently contact the applicant to re-open the lacking public participation process, since our approach is to contact a higher level of authority every 48 hours or so ! 60. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (2) Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 10 April 2013 12:31:29 nm. SAST To: Louise Corbett <louise.corbett@aurecongroup.com>
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (2) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response:
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 60 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA Cc: A B Abrahams <abrahamsa@dwa.gov.za>, Howard Hendricks <howard.hendricks@sanparks.org>, Mike Knight <mknight@nmmu.ac.za>, Lea Visser <ondpoort@gmail.com> Subject: Hydrology of the Orange river
Ms Corbett Although an aquatic study was done, it seems as if the hydrological aspect was neglected from a water balance perspective and it seems as if no new work has been commissioned to adress the potential future reductions in water transfers between CMA's, which might influence this project's viability. Some background information/data needs to be gathered i.r.o future projects and approved projects, currently in the "pipe line" which could reduce the quantity of water reaching Augrabies Falls. The reason for this question is that there are other, external factors which will permanently reduce the quantity of water flowing through the Augrabies Falls in future. It is prudent to note that the majority of water use from the Orange river occurs before Augrabies Falls and most future requirements will originate upstream. This could be projects for which the water use has already been allocated, for example; 1) The 12 000 ha irrigation quota set aside for historically disadvantaged individuals. As far as we know, this is an allocation which would be used, mostly in the Lower Vaal CMA, which is more or less between Gariep dam and Augrabies Falls. We are currently noticing a lot of development and expansion in the sense of land preparations, where irrigation has not yet started. 2) Transfers to other Catchment Management Areas, which might reduce the quantity reaching Augrabies Falls. Perhaps increased transfers from the the Lesotho Highlands Scheme to the Wilge river, due to increased demand in the Upper Vaal Catchment Management Area, eg. for new power stations like Kusile PS, near Ogies. This activity would reduce the quantity of water released to Gariep dam. Kusile is a power station which would have a capacity in excess of 4 200 MW, with at least 98% availability for the next 20 years. This is about 600 times of the annual capacity compared to your to your estimated/projections of about 30% output of the proposed
These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator. .
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 61 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA RVM hydroscheme. Although these transfers would take place before the Gariep dam wall, it is still a reduction in total volume of water available for discharge, which will eventually reduce the quantity of water, which can be released during dry seasons. 3) If your proposed scheme was a regular, run of the river scheme, like the proposed Neusberg scheme, the above scenario's wouldn't matter as much, as at Augrabies Falls, because you are applying to conduct a streamflow reduction activity, which would ultimately lead to the demise of either the Augrabies Falls (and the National Park) or the power station. Thus, together with the convenient vertical drop in height, comes a direct competition with the actual existence of the Augrabies Falls. No-one in this part of the Northern Cape would be willing to sacrifice the spectacle of Augrabies Falls in exchange for a few MW of unprofitable power station. A power station was built in the old Bophutatswana, about 30 years ago, but they did not make provision for water, so it was never started up. 4) Section 21(a) of the 1998 Water Act : We intend to lodge a request with DWA Lower Vaal in Kimberley to declare this activity, as a stream flow reduction activity, if they do not already deem it to be and we will request SANParks to do the same. Should DWA decline the request, it would be an administrative error, for which we would have to approach the Water Tribunal for relief and to set it aside. It is a well known fact that a substantial amount of water returns to the river from irrigation farms close to it, but that quantity is not added to the irrigation quota, which underpins the principle, that the quantity returned to the river cannot be subtracted from the quantity abstracted/diverted. Should DWA agree with your ASSUMPTION that section 21(a) is not applicable, it would create a precedent for other water users to deduct the quantity returned to the river as a portion of water use which does not require licensing. Thus your water license application is flawed and should not be granted because the activity will reduce the quantity of water, at least in a section of the river, which makes it a stream flow reduction activity in the true sense of the word. Thus your assumption that the water license should not be applied for in terms of section 21 (a), is fatally flawed.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 62 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA 5) To what extent does DWA/the applicant expect potential climate changes for example, to affect the reliable quantity of water, which can be transferred into the Lower Vaal CMA, in future? This would also reduce the quantity, which could be allocated. 6) The applicant is making a great effort to confirm that the area has been excluded from the National Park, which still manages it, but in terms of the recently published Strategy on Buffer Zones around National Parks, it is quite possible that the area will be listed as such during revision of spatial development plans and that the project would be declared undesirable at that stage because it is a large industrial complex. Regards Kobus van Coppenhagen 083 6564498
PS : Mike, we suggest that you consider applying for this activity, to be declared as a streamflow reduction activity by DWA, if you have not already done so. 61. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (3)
Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 11 April 2013 12:45:46 nm. SAST To: Louise Corbett <Louise.Corbett@aurecongroup.com> Cc: A B Abrahams <abrahamsa@dwa.gov.za>, Howard Hendricks <howard.hendricks@sanparks.org>, Mike Knight <mknight@nmmu.ac.za>, Lea Visser <ondpoort@gmail.com> Subject: Additional time for comments
Ms Corbett Thank you for the allowance of additional time for comments, we would like to draw your attention to an offer made by SANParks to make their boardroom available for the additional meeting, subject to it being available for that date. Please take notice of their mail, which we are forwarding separately. To
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen,
Thank you for our submission (3) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study.
Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 63 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA ensure that most IAP's are informed, we would suggest that you place an advert in Die Gemsbok, which would satisfy our first "demand", i.r.o. public notification. We also want to draw your attention to the fact, that even though we have concerns about the proposed project, we are not trying to delay the process, but rather to have an opportunity to participate in a process which is procedurally and administratively fair. We want our concerns to enjoy proper consideration by the specialists and also to get feedback from them. We are busy with a process of integrating privately owned land into the Augrabies Falls National Park, for a very long period (99 years) and conclusion will be dependant on the long term viability of this National Park. However every application for a listed activity on either our land or the Park delays this urgent process, which was initiated in 2008. The National Park is under constant threat of development, not in line with its mission and Management Plan, however the Strategy on Buffer Zones around National Parks should give them the tool to remove/manage threats of large scale developments like the one you are proposing. You should note that there is for example applications pending with DMR, for prospecting rights in this very same Park and associated buffer zones. We can submit information for your perusal if required. We hope that this explanation makes our frustration and predicament clear to you. We will be in Cape Town between 30 April to 5 May, due to unforseen circumstances, for consultation with a medical specialist and will not be available at that time. Regards Kobus van Coppenhagen 0836564498 62. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (4)
Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 10 April 2013 9:00:38 vm. SAST To: A B Abrahams <abrahamsa@dwa.gov.za>, A B Abrahams
Kobus van Coppenhagen, Daberas, comment by e-mail, 31 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (4) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 64 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA <abe@dwa.gov.za> Cc: Louise Corbett <louise.corbett@aurecongroup.com>, Howard Hendricks <howard.hendricks@sanparks.org>, Mike Knight <mknight@nmmu.ac.za>, Lea Visser <ondpoort@gmail.com> Subject: Riemvasmaak hydropower generation
Sir We became aware of the planning of hydro-generation schemes in the Lower Vaal CMA, specifically the Neusbergweir run-of-river scheme outside of Kakamas and also the Riemvasmaak hydro- generation scheme, which would divert water from JUST before the Augrabies Falls, to a site in the Riemvasmaak area and then to utilise the drop in elevation into the Lower Orange river valley for a power generation complex. This mail is dealing specifically with the latter proposal, for the Riemvasmaak area. Ms. L. Corbett has confirmed during a telecon, last week Thursday 4 April, that Aurecon has been appointed to conduct the Environmental Impact Assesment for the applicant and that they have placed an advert in a local newspaper, Die Gemsbok, late in December of 2012 to publically invite comments for the proposed hydrogeneration schemes on farm 497 and portion 1 of Farm 498, with the following DEA reference no's; RVM1( DEA ref. no. : 14/12/16/3/3/1/681) application date 17 August 2012; RVM 2 (DEA ref. no. : 14/12/16/3/3/1/685) application date 17 August 2012 & RVM 3 ( DEA ref. no. : 14/12/16/3/3/1/767) application date 14 November 2012. During the telecon we reminded her that nobody in this area seems to know about the project and asked that they consider, restarting this public participation process to ensure that it would be procedurally fair. She confirmed that they would only insert our comments into the final report, because it is already months after the closing date for meetings, etc. At this stage we requested that the applicant should then rather contact us with a view to appoint a consulting company which would at least have some form of public participation programme, which
Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 65 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA was ignored even after an e- mail to that effect. She did forward a link which, enabled us to access documents and because we did not want to waste any time, worked the whole weekend of 6&7 April. However on checking the declarations all of the specialists except one, it became apparent that they have signed declarations on dates prior to the supposed advert, which confirms that they have participated in a public process. On Monday 8 April when we contacted Die Gemsbok and they confirmed that no advert was placed in December 2012 for Aurecon, or the applicant. This information was relayed to ms.Corbett on Monday 8 April 2012 and she promised to to send a copy of the advert as proof. At this stage attention must be drawn to the Draft BAR document on the Aurecon website, which does not display a copy of the advert in the position allocated for it. We phoned ms. Corbett late on Tuesday 9 April to expedite delivery of this proof, when she confirmed that the actual advert was placed in the Volksblad newspaper which is published in Bloemfontein about 800 km away from Augrabies. WE BEG YOU TO REJECT AND RETURN ALL THE WATER LICENSE APPLICATIONS FOR THE PROPOSED HYDROPOWER PROJECTS AND TO ISSUE A DIRECTIVE THAT THE PUBLIC PARTICIPATION PROCESS BE STARTED FROM SCRATCH. WE BELIEVE THAT THE UNWILLINGNESS OF AURECON TO YIELD TO OUR REASONABLE REQUEST SHOULD DISQUALIFY THEM FROM HAVING ANY FURTHER PART IN THIS PROCESS. We have already raise valid questions and concerns which are not in the specialist reports and which needs to be adressed, however for the sake of brevity we will send those questions, amongst many other potential impacts, by separate mail. Regards Hannecke van Coppenhagen 083 6564498 63. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (5) Kobus van Coppenhagen 0836564498 Begin forwarded message: Kobus van Coppenhagen, Daberas, comment by e-mail, 31 May 2015 Dear Mr. Kobus van Coppenhagen, Thank you for our submission (5) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 66 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 09 Mei 2013 10:52:08 vm. SAST To: Louise Corbett <Louise.Corbett@aurecongroup.com>, A B Abrahams <abrahamsa@dwa.gov.za>, M Gordon <mgordon@environment.gov.za> Cc: Howard Hendricks <howard.hendricks@sanparks.org>, Mike Knight <mknight@nmmu.ac.za> Subject: Re: RVM Hydrogeneration scheme
Ms Corbett For information of other recipients of this message the reference no's of the applications are recorded; RVM 1: DOS verw. 14/12/16/3/3/1/681, NEAS verw. DEA/EIA/0001403/2012 RVM 2: DOS verw. 14/12/16/3/3/1/685, NEAS verw. DEA/EIA/0001410/2012 RVM 3: DOS verw. 14/12/16/3/3/1/767, NEAS verw. DEA/EIA/0001571/2012 Firstly we need to submit the following information as full clarification of our reason for attempting to participate in the process you are conducting; We have been involved in negotiations for several years to voluntarily incorporate our land into the Augrabies Falls National Park on a long term contract of 99 years, to expand the range for endangered species. This project has been approved by the EXCO of SANParks. Initially, applications for prospecting rights on our land and also the National Park were made which delayed the process, because the land cannot be incorporated into the National Park if a prospecting right is awarded to a third party. Now, have a situation where the status of the National Park (or part of it) might be revoked, similar to the Lake Pedder National Park debacle in Australia, where the HEC(HydroTasmania), was involved. This arm of the Tasman Government is also involved in this application by way of their shareholding in the company applying for the environmental authorisation. However it seems that the branch of SA government (SANParks) which manages land set aside for the preservation of areas with special natural attributes, must look on while a barrage of applications are made, which could
Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 67 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA irreversibly change the nature and status of the National Park. We are at the moment reluctant to proceed with this process of incorporation, because of the perceived lack of SANParks authority or ability to perform its functions as guardians of the National Parks of South Africa. We do believe that the person from DEA (Sandile Vilakazi) mentioned in your draft executive summary document (page 7), should have informed the applicant of the status of the land on which it wants to construct this plant or parts of it. Your e-mail below refers; We appreciate the fact that you have drawn attention to the regulations set out in GN 543, published in GG 33306 of 18 June 2010; Section 57 makes provision for direct communication with the competent authorities, whom in this case would be Mr M Gordon of DEA and Mr AB Abrahams of DWA and by way of this message we are stating our dissatisfaction with the manner in which this process is being conducted. We want to draw their attention to 5 specialist declarations which are displayed on your website, in which they have ALREADY considered comments/inputs from a public participation process almost three weeks PRIOR to the anouncement of the public participation process, in a Free State newspaper, Volksblad, published in the first week of Jan 2013. We have drawn your attention to this fact, but you chose not to contradict our allegation. In addition to this you have mentioned on page 5 of your draft executive summary, confirmation of publishing the required notification in the Gemsbok, which is a local newspaper, but on request you have failed to provide proof of the publication. You have subsequently confirmed by telecon that the advert has indeed not been placed. We have also drawn your attention to the exaggeration of information between documents and newspaper articles, some of which can only be described as hyperbole. For the sake of brevity we do not include details again, but we would forward these messages to the competent authority if needed. It is a specific requirement of public particpation processes that the information in applications and press releases should correspond and be accurate, not to mislead the public.
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 68 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA Furthermore we want to indicate to you that the attempt by Nelis Bezuidenhout of your office (to organise) to gain access to the National Park to do project work, as indicated on an email request should be construed as commencement of the activity, which is a serious offence, or at least an indication of bias towards the applicant. This should also disqualify the parties involved from the applicant's side from further participation in this process, especially since you did so eloquently draw our attention to your knowledge of this GN 543. Now then, we believe that you have neglected to adress our concerns in an objective or satisfactory manner, considering the timeframes allowed and we can only record our total objection to the public participation process which has been conducted and that procedural and administrative fairness could not be achieved, by intervention, but rather that the process should start afresh and be subject to S&EIR at least. This is obviously a matter for the departments to decide, but we insist that they should consider that the process is completely flawed and one-sided and we are expecting urgent relief in this regard. As far as the processing of applications for environmental authorisation for activities inside National Parks are concerned, we have also indicated to you that the Strategy on Buffer Zones around National Parks should dictate that it is unwise to apply for environmental authorisation, for activities which are not specifically envisaged in the relevant acts and regulations. This issue needs to be considered and clarified by all government departments, especially the competent authorities receiving applications. Regards Kobus van Coppenhagen 64. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (6) This message was also forwarded to DEA once we found the correct address Kobus van Coppenhagen 0836564498 Begin forwarded message: Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015 Dear Mr. Kobus van Coppenhagen, Thank you for our submission (6) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely,
Environmental Impact Assessment Report – Comment and Response Report
Coastal & Environmental Services 69 RVM 1 Hydro Electric Power
No. Issue Raised by Response from CES EIA team or Hydro SA From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 16 April 2013 11:21:11 vm. SAST To: Louise Corbett <louise.corbett@aurecongroup.com> Cc: Lea Visser <ondpoort@gmail.com>, Howard Hendricks <howard.hendricks@sanparks.org>, Mike Knight <mknight@nmmu.ac.za>, Frans Van Rooyen <frans.vanrooyen@sanparks.org>, Marius Burger <sungazer@iafrica.com>, A B Abrahams <abrahamsa@dwa.gov.za> Subject: Proposed Riemvasmaak power generation scheme.
1) We are of the opinion that this application should be subjected to a full scoping and EIA process, due to the the following reasons; a) It is an extremely sensitive and brittle environment, ie. you cannot mitigate the impact of the construction activities, due to the hard rock environment. b) The area subject to the placement of the individual elements of the plant will be substantially larger than one hectare and even if you divide the footprint of the various applications between 3 companies as individual applications, the cumulative impact would still be large enough to justify a full scoping and EIA process. c) The specialist studies does not make reference to the hidden fauna of this area; lizards, snakes and scorpions, etc. Some of these species can only be observed by specialists and it is possible that the route for the pipeline could even harbour red data species. We want to draw your attention to SARCA expedition 11, during which a very rich diversity of reptile species was recorded. We attach a list, of species recorded, from the Herpetological Society of SA website, at the end of the e-mail. The Project Herpetologist was Marius Burger, but we are unable to locate him for more information at this stage. Our contention is that regardless of the destruction caused by the construction activity, the lasting impact of these structures would be that it will present a formidable barrier to several of the reptile species and other Fauna. d)The placement of the weir elements in the river channels could cause outbreaks of malaria due to the pooling effect of the structure. Perhaps you are not aware, but Kakamas is a
Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
Environmental Impact Assessment Report – Comment and Response Report
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No. Issue Raised by Response from CES EIA team or Hydro SA low risk malaria area and sporadic outbreaks have occurred in the past, with thousands of reported cases during one previous event. e) The applicant did not demonstrate that they have permission from the owners or management authority of the sites and the potential for disagreement between the various parties and even between the historically disdvantaged owners of the "power station site", requires sensitivity, facilitation and a broad public participation process, with sufficient time for the owners to decide whether they want to participate in this risky project, or not. The document which you submit as proof of excision from the National Park for the power station site, states that the SANParks remain responsible for the management of that area. The applicant also did not use the opportunity to introduce the project to interested parties at the meeting for the revision of the Park Management Plan late in 2012. f) Shortly after our engagement, a press release was made in "Die Burger" newspaper, by the applicant, with information which could be regarded as misleading. The information should not be conflicting with those in the documents, presented to the Competent Authority. One should elaborate, because the variation in data/information is significant and it is important that the public should not be misled/pacified with false information. Specifically the value of the project is stated as R 700 million in the article, which is 233% up on the figure of R 300 million, in your BAR document. The additional effect of this exaggeration is that the historically disdvantaged community would now have to pay R 84 million for their 12% share instead of R 36 million. The height of the weir is also stated to be 2,5m maximum and your document indicates less than 5 m,which is more or less double the height. Incorrect statements are an indication that the applicant is conducting a flawed process. This tendency would also suggest that information submitted by the applicant should be subjected to stringent verification. The job creation figures are another scenario, etc. g) We have highlighted several other shortcomings in recent communication and will not repeat it, for the sake of brevity. However the declarations of the specialists remain a matter of
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No. Issue Raised by Response from CES EIA team or Hydro SA huge concern; especially since it seems to be a standard (identical) form which was completed by all but one specialist. Did Aurecon provide this document, or where did it originate from, because you did not make use of the same document for your declaration. h) The tourism value is completely overestimated and the examples are inappropriate for this project, because it seems as if none of your examples are for run of river projects. 2) This application is indicative of an absolute lack of sensitivity and respect for the sense of place of the National Parks of South Africa and makes one wonder whether the Tasman Government, as owner of Hydro-Tasmania and partner in Hydro-SA, is aware that they might be party to potential destruction inside a South African National Park. Perhaps we should contact the Tasman/Australian government, to confirm their appetite for this activity inside a high priority conservation area in one of our National Parks, if you would be kind enough to provide the contact details. 3) Anyway, there are several renewable energy plants proposed or under construction in the Northern Cape, some of which were assessed by you, Ms Corbett. Many of the renewable energy plants, either proposed or under construction, would dwarf this proposed installation as far as output is concerned, and it is situated outside of a National Park boundary. The latest "Gemsbok" newspaper of 12 April, for example, published the following notices; Environmental Authorisation for Karoshoek Solar installation 700 MW in total Environmental Authorisation for Tutwa Solar installation on Farm Narries 7, output not specified, quite close to the National Park (20km). Environmental Authorisation for Solar Installation of 100MW on Farm 188 Zwartbast, near Kenhardt. Environmental Notification for PV Solar Installation (output not specified) on Farm 91 Konkoonsies, near Pofadder In addition to this we are aware of the following plants which are currently under construction; KaXu One 100 MW Solar Installation between Augrabies and Pofadder Khi One 50 MW Solar Installation near Upington. From this information, you should deduct that the Northern
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No. Issue Raised by Response from CES EIA team or Hydro SA Cape has massive potential for renewable energy generation, especially solar power generation, which does not have to impact directly on Conservation Areas; which makes sense. Thus the alternative to the proposed development which would have a significant impact, but insignificant output due to the expected 30% availability, would be the erection of a solar generation installation on Riemvasmaak land, which by the way, is approximately 75 000 ha in extent, but which would not spoil the sense of place of the relatively pristine conservation area, which is also bio-diversity hotspot. This type of installation can be erected quite rapidly and the cost is probably lower per installed Watt. A solar trough installation doesn't require a power tower, but it could have heat storage of between 2 and 3hours, and it can have a PV installation adjacent to it. The contribution to the national electricity grid could thus be more than 10 times the output of this proposed hydroscheme and it could be expanded in future. The focus should thus be on preserving the small area of the Lower Orange River Valley which does have a high intrinsic conservation value and use another portion of the communal land to generate an income. The other issue about a hydroscheme is that during a verification process it will become apparent that there are water allocations which are not yet fully utilised and also increases in consumption/transfers which can be forecast for the near future, which would lead to a reduction in the quantity of water ultimately reaching Augrabies Falls. Please forward the contact details of the designated officials at DEA, in order that we can forward this mail for their attention. Regards Kobus van Coppenhagen 65. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (7) Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 17 Mei 2013 3:11:21 nm. SAST To: Danie Smit <dsmit@environment.gov.za> Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015 Dear Mr. Kobus van Coppenhagen, Thank you for our submission (7) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston EAP’s response:
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No. Issue Raised by Response from CES EIA team or Hydro SA Cc: Louise Corbett <louise.corbett@aurecongroup.com>, Pieter van der Walt <peetvdw14@gmail.com>, Howard Hendricks <howard.hendricks@sanparks.org>, Frans Van Rooyen <frans.vanrooyen@sanparks.org> Subject: Riemvasmaak hidroskema
Meneer Smit, Baie dankie vir u oproep. Die besluitneming ivm die voorgestelde hidroskema moet gesien word teen die agtergrond dat die Augrabiesvalle Nasionale Park 'n GEOPark is, dws dat die landskap (litosfeer) bewaar word en ons glo dat julle ook 'n spesialismening in hierdie verband sal aanvra en oorweeg. Daar is 'n publikasie " Geological Journeys" waarin die skrywers verwys na Augrabies as 'n "Geologiese Paradys". Daar is ook 'n dokument getitel "The Geomorphology and Geoconservation Significance of Lake Pedder (Kiernan K, 2001) (pdf kan afgelaai word) wat gepubliseer is na aanleiding van die oorstroming van Lake Pedder in Tasmani , wat die meriete van die bewaring van GEOdiversiteit bepleit. Die redenasie is dan ook baie toepaslik, dat unieke landskappe nie gepreserveer kan word met biopreserveringstegnieke soos bv. plante of diere wat hervestig kan word, of saad wat versamel en geberg kan word, ens. 'n Interessante aspek wat in hierdie dokument aangespreek word, is die gebrek aan kennis van geodiversiteit by amptenare wat besluite geneem het. Dit is toepaslik in hierdie geval dat die meer oorstroom is vir 'n hidroskema van Hydro Tasmania (HEC)(een van die aansoekers) en ons stel voor dat u self verdere inligting ivm die geleentheid inwin (bg. dokument is jare daarna geskryf). Prof. P. vd Walt, skrywer van die gids "Augrabies Splendour" het ook bevestig, dat hy met sy navorsing in die argiewe opgemerk het dat 'n hidroskema by Augrabies oorweeg was in die sestigerjare, maar dat daarvan afgesien is en dat die gebied daarna as Nasionale Park verklaar is.
Dit sou ook meer relevant wees indien die sosio-ekonomiese studie sou fokus op Hydro Tasmania(een van die aansoekersby wyse van hulle aandeelhouding) se operasies aangesien daar heelwat inligting beskikbaar is. Daar is op
These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA stadium beweer dat hulle skemas baie skuld gehad het en dat dit nie winsgewend bedryf is nie.
Die aftakeling van so 'n installasie is natuurlik ook onmoontlik in 'n harde rots omgewing en die skade is dus permanent. Die konsultant se BAR dokument bespreek dan ook nie die moontlikheid daarvan, omdat dit onmoontlik is. Die moontlikheid van aardbewings soos wat onlangs in Augrabies voorgekom het, kan natuurlik skade aan so 'n projek aanrig, wat dit permanent uit bedryf kan stel. As gevolg van hierdie feit word hidroskemas ook nie as 'n vorm van omgewingsvriendelike energieopwekking beskou nie.
Hidroskemas soos hierdie kan natuurlik ook glad nie tot die basislading bydra nie aangesien dit nie 'n reserwe van water het nie, dus het dit geen voordeel bo 'n sonkraginstallasie wat in hibriedevorm ontwerp kan word om energie te stoor vir etlike ure per dag. 'n Soortgelyke 100MW sonkrag aanleg, KaXu One, word huidiglik deur Abengoa opgerig in ons omgewing.
Groete Kobus 66. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (8) The consultants did initially deny that HT was involved. I assume that after the SARAWAK debacle they wanted to remain below the radar. Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 30 Julie 2013 9:35:00 vm. SAST To: Louise Corbett <louise.corbett@aurecongroup.com>, Nelis Bezuidenhout <Nelis.Bezuidenhout@aurecongroup.com> Cc: M Gordon <mgordon@environment.gov.za>, A B Abrahams <abrahamsa@dwa.gov.za>, Howard Hendricks <howard.hendricks@sanparks.org>, Frans Van Rooyen <frans.vanrooyen@sanparks.org>
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (8) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA Subject: PowerPoint Presentation
Ms Corbett Your response to our comment in the CRR regarding the shareholding of Hydro Tasmania, through their SA subsidiary, refers; Attached is a presentation which was given to the various stakeholders and which was forwarded to us as part of the suite of documents. On pages 32 and 33 the company ownership is laid out and the Hydro Tasmania SA shareholding is discussed. On page 28 the remote control of this activity from Hydro Tasmania's control room is discussed in relative detail. Hopefully this places some of our concerns in context, bearing in mind that Hydro Tasmania was responsible for the Lake Pedder National Park debacle/disaster. Regards Kobus van Coppenhagen 67. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (9) These are our comments on the DSR Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 27 Augustus 2013 4:40:26 nm. SAST To: M Gordon <mgordon@environment.gov.za>, A B Abrahams <abrahamsa@dwa.gov.za>, Louise Corbett <louise.corbett@aurecongroup.com>, Nelis Bezuidenhout <Nelis.Bezuidenhout@aurecongroup.com> Cc: Howard Hendricks <howard.hendricks@sanparks.org>, Gene Visser <ondpoort@gmail.com>, Giel de Kock <giel.dekock@sanparks.org>, Frans Van Rooyen <frans.vanrooyen@sanparks.org>, Mike Knight <mknight@nmmu.ac.za>, Fritz Oosthuizen <fritz@augfalls.co.za>, Gawie Niewoudt <gawie@khamkirri.co.za>, Nardus du Plessis <nardus.duplessis@sanparks.org> Subject: Proposed Augrabies Hydro Power Plant, Northern
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen,
Thank you for our submission (9) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA Cape
To whom it may concern The above project with incomplete reference no 14/12/16/3/3/1/681 (see DEA letter dated 18/06/2013) refers; We have become frustrated with the inability of AURECON to provide the correct documentation for the proposed project timeously and realise that they might not be able to present a properly structured application for comment by the public and consideration by the relevant authorities. We have requested a copy of the current "valid" application on more than one occasion, but have received none so far. We believe that currently, there is no valid application, lodged with DEA, except for informal discussions which were followed up by a letter from DEA, dated 18/6/2013, which suggest that the applicant resubmit a revised application. The AURECON letter of 3/6/2013 and DSR page 13 refers to three applications which were lodged by RVM 1, which is incorrect, since the applications were lodged by RVM1Hydro Electric (Pty) Ltd, RVM 2 Hydro Electric (Pty) Ltd and RVM 3 Hydro Electric (Pty) Ltd, respectively. We do not doubt the technical ability of AURECON, but the document trail is very becoming difficult to follow, especially if you lodge an objection and want refer to the correct entity. We are challenging the perception that the process is beyond the application phase as proposed in page 16, because the other 2 applications were made in the names of other legal entities. We are thus objecting to the continuation of this process on the grounds that currently there isn't a valid application with either DEA or DWA. Site visit: We have requested months ago that a meeting be held inside the National Park and that was also requested by the SANParks representative during the public meeting of 5/8/2013. Unfortunately it could not be accomodated and no date has been put forward yet, but a meeting with another party in the area was scheduled by AURECON for 22/8/2013. We did request SANParks to allow us to visit the proposed site. This was arranged for 20/8/2013 and on arrival at the entrance to the land and also at the "Rhino" gate, only the original RVM1, 2 & 3 applications were found to be on display.
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No. Issue Raised by Response from CES EIA team or Hydro SA The following paragraphs are dedicated to our observations during the SHORT site visit. In the immediate area of the proposed weir, we could clearly observe a large and "noisy" breeding colony of birds, nesting in the trees on a small island. Three nesting/breeding species were observed and it was clear from droppings marking the branches of other trees in the area, that it was not yet fully colonised for this breeding season and that this site was repeatedly used over a long period of time. The species observed were African Darter, White-breasted Cormorant and Reed Cormorant, none of which are mentioned in your avifauna discussion on p 61 of the DSR. A number of other birds were observed and heard(hadeda) but we did not have time to spare. Many large rocks in the area were also exposed, which would be permanently flooded by a water level increase of 2,5 meters. We also noticed otter droppings with crustacean residue on the river bank. We do not exactly know how the environment would be affected by the clearing of virgin riverine habitat and the interference with the flow and stratum of the river bed and bank. NEMPAA regulation 1061; article 41, specifically prohibits disturbance of a watercourse inside a National Park. A SANBI report of 1995 mentions 192 species of birds for this area. Due to the topography, exibiting many drainage courses crossed at right angles by the vehicle track and variations in elevation it became apparent that it would be virtually impossible to integrate the water conduit structure into the existing terrain, without modifying it substantially. It is worthwhile to mention that there is no existing "road", which just needs to be "widened" and that the construction of a road alone would alter the terrain substantially. The track also displays a lot of hoofprints of animals, but we did not attempt to establish their movements. The northern section of the National Park would practically be cut into two fragments by this development and considering the long continuous length of the underground conduits, the linear disturbance would be up to 10 times the length of eg. the proposed Boegoeberg Hydroscheme. This disturbance would also become a new seedbed for the propagation of invasive plants eg. Prosopis spp., all of which have recently been cleared in this section of
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No. Issue Raised by Response from CES EIA team or Hydro SA the National Park. Revegetation as proposed in p 29 of DSR is not possible without irrigation since the average rainfall in this area is only 124,4mm per annum (std. dev=73,47mm)(SANBI report), not 251 mm as in DSR p 54 and summer temperature can exceed 40deg C, so daily irrigation is required (annual evaporation is >3000mm). A SANBI report also refers to the fact that recruitment of plants is episodic rather than a regular occurence, which really makes every existing plant specimen valuable. We urge the applicant to arrange a site meeting and to indicate exactly where the various elements would be sited for both options and it would be quite in order if DEA and DWA inspect this terrain at the same time. It would be pertinent to note that there is still a resident group of the rare Mountain Zebra in THIS SECTION of the National Park, amongst many animals. Although black rhino were reintroduced 20 years ago the area was never fenced with electric wiring and to prevent animals such as girrafe from taking flight, during construction it would be prudent to make electric fencing of the whole northern section of the Park a priority. A SANBI report mentions 51 species of mammals and a total of 68 amphibians and reptiles. We have previously referred to the fact that only specialists know where and how to observe many of the creatures in this area, eg scorpions, reptiles, etc. In a 17 m wide linear construction corridor as envisaged in the DSR p 29, a large percentage of this biota would be destroyed unwittingly. During the short visit one does become aware of an aire of solitude and the large scale disturbance envisioned would would harm it irreversibly. The number of cultural sites along both routes are a "red flag" and the possibility of objections by individual families at any stage before or after commencement would cause serious problems. Waste, dust and noise: The activity would generate at least 160 000 cubic meters of solid waste, which cannot be stored on site and surely the stockpiling of this waste must get due consideration, since there is no recognised dumping site currently available. Where would the aggregate batching plants be located and how will air quality and spillages be managed in that area. According to Mr N Theron (5/8/2014) only 3 truckloads of waste would leave
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No. Issue Raised by Response from CES EIA team or Hydro SA the site per day, which would leave more than 100 000 cubic meters still on site after 3 years. The notion of bringing a crusher onto the site (p31) is an indication of a very short memory. Ownership and water. Restoration of the site would be impossible by any means and how would disputes regarding ownership be resolved in the case of default by the developer, ie if the price of renewable energy falls drastically and less power is generated due to a lack of water, which we have predicted already, because no water balance determination was done for this application, which requires 3,2 million cubic meters of water/day. Our contention is still that the project would not be sustainable in the long term because the quantity of water constantly available is the paramount requirement for this project to succeed. The EAP has noted in the CRR regarding our concern about water availability; that any new use in future other than the current would have to take the "requirements" of the hydro power station into consideration, but the applicant does not want to apply for a certain quantity. What other rights are assumed to be conferred to the applicant which could supercede owners rights or which could transfer responsibility to land owners in the case of neglect by the applicant or the remote operator Hydro Tasmania? Alternative site: The applicant did also apply for the Neusberg and Boegoeberg shemes, which are the logical alternatives for the Augrabies area. These 2 schemes would give the applicant approximately 30% of the initially allocated quota of 75MW for small hydro, without proven capability or previous track record in this business. Is Hydro Tasmania aware that it will be held responsible for any damage caused by remote plant operation and safety aspects and that RVM 1 cannot/shouldn't be able to indemnify them? We do not object to the other projects in Neusberg or Boegoeberg in principle, because they are outside a National Park. Alternative technology: Mr F. Oosthuizen did mention in the meeting of 5 August 2013, that there is a large "brown field site" available, in the form of
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No. Issue Raised by Response from CES EIA team or Hydro SA roofs of existing structures in Augrabies, (or for that matter Riemvasmaak), onto which PV panels could be installed. Alternatively the the use of solar trough technology, PV panels or Stirling engines in a dedicated area of Riemvasmaak would be a better solution in most aspects, but as Mr. N Theron has stated in a meeting: he is only interested in developing hydro generation facilities; thus, those alternatives are not even an option to be considered. Any of the above would also be more enabling to the Riemvasmaak community and will give them a sense of ownership. Declaration of interest: Is AURECON responsible for the engineering design of the proposed scheme and what is the value of that service in the event that the project don't proceed.? DSR page 21 refers to the assumption that all information from the client is correct and unbiased. The EAP must assess this information and comment as they do on all other comments. The client is not an expert in hydro technology and is using the technology base of Hydro Tasmania, which is probably the Project Sponsor as envisaged in the Equator Principles documents. We want to recommend that the following documentation also inform the applicant over and above those mentioned in page 6 of the DSR. National Environmental Management: Protected Areas Act no 57 of 2003 and Regulation 1061as published in the Regulation Gazette no. 28181 of 28 October 2005; With specific reference to; Interference with soil or substrate as defined in article 39, Removal and dumping in water area as defined in article 41, Restriction or prohibition of the use of biological resources as defined in article 45, Restriction or prohibition in land use as defined in article 46, As well as any other applicable regulation in this publication or the Park Rules and Management Plan It is a matter of convenience to ignore this legislation and management rules and regulations which are specifically applicable and binding for the management and continued existence of our National Parks. SANParks also have a large number of specialists in their employment and their inputs
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No. Issue Raised by Response from CES EIA team or Hydro SA should be decisive in the final outcome. SANParks publications: A Framework For Developing And Implementing Management Plans For South African National Parks (April 2008). Stakeholder Participation In Support Of Developing And Implementing Management Plans For South African National Parks (December 2009). South African National Parks Week (information booklet) states on page 6; Augrabies Falls National Park "The park was initially proclaimed to conserve a small area of GEOLOGICAL INTEREST around the Augrabies Falls" Our note: The Augrabies Falls should be considered as a singular geological entity, worthy of protection for posterity. Very little of the riverine habitat which is unmodified and functions naturally, does remain. IUCN publication: Guidelines For Applying Protected Area Management Categories, edited by Nigel Dudley; discuss on p66 the preservation of Geodiversity as a separate category for National Parks but also states on p67 that geodiversity can be protected under all categories. S A Council for Geoscience publication : GEOclips vol 20 June 2007: back page; "We are currently witnessing a worlwide awareness of the importance of conserving and promoting sites and regions of geological and mining interest for the tourism business," Department of Environmental Affairs website: Environmental Indicators: "Grassland, Thicket and NAMA-KAROO biomes have the highest proportion of under-protected ecosystems." Department: Government Communications and Information System Pocket Guide to South Africa 2010/2011 Page 208: Environment, Conservation Areas : reporting on governments strategy to expand conservation areas from 6% to 10 % and that management categories for protected areas in SA conform to accepted categories of IUCN. Page 229; Tourism, Northern Cape: (the introduction to this section is recited) "The Augrabies Falls National Park, with its magnificent falls
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No. Issue Raised by Response from CES EIA team or Hydro SA pressing through a narrow rock ravine, REMAINS THE MAIN ATTRACTION OF THE NORTHERN CAPE." The following concepts of the Equator Principles and IFC Performance Standards refer; This is definitely a category A project. Project Sponsor ... Hydro Tasmania? Is "Effective Control", which is required for "unlisted countries" demonstrated by remote operation of the facility, which in this case would be an operational control room of the Tasmanian government agency, Hydro Tasmania. Indigenous people : project info and approval. It is quite interesting that the equity providers put great emphasis on this aspect, but the applicant only introduced the project to the trust decision makers and only started to inform the community at a very late stage. Finally, the method of integrating Carbon Pricing/Credits in the financial model of the business should be published. It is a matter of public knowledge that businesses like Hydro Tasmania depends heavily on Carbon Price subsidies to make it profitable. 70% of the Hydro Tasmania profit of approximately AU$ 100 million/pa in the last 2 years (CRR comment 10.3) were contributed by carbon pricing on the National Energy Market in Australia. The carbon footprint of large hydro dams can be very substantial due to methane release and it does not merit carbon crediting. The Carbon Price/Credit system should also be viewed as a short term initiative to promote "renewable energy" but that funding will ultimately be spent on carbon capture and storage or conversion projects. The consultant deliberately ignored our objection regarding public notices which does not indicate the location of the project within a National Park and that is unacceptable and our objection in that regard remain. Kobus & Hannecke van Coppenhagen 68. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (10) We were not able to access the FSR FOR THE WHOLE COMMENT PERIOD AND ASKED FOR EXTENSION WITH Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015 Dear Mr. Kobus van Coppenhagen, Thank you for our submission (10) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely,
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No. Issue Raised by Response from CES EIA team or Hydro SA NO RESPONSE, WHICH IS RED FLAG. Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Louise Corbett <Louise.Corbett@aurecongroup.com> Date: 09 Oktober 2013 7:43:14 nm. SAST To: Nelis Bezuidenhout <Nelis.Bezuidenhout@aurecongroup.com>, "Kobus van Coppenhagen" <kobusvc@gmail.com> Cc: Simon Clark <Simon.Clark@aurecongroup.com> Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Dear Kobus As noted on site today there will still be further opportunities to comment on the EIA Process. However, should you still wish to comment on the FSR you are welcome to do so. We will then forward your comment to DEA for their information and we will include and respond to it in our next report (the Draft Environmental Impact Assessment Report, unless DEA require us to revise the FSR). Kind regards Louise Louise Corbett
From: Nelis Bezuidenhout Sent: Wednesday, October 09, 2013 8:03 AM To: Kobus van Coppenhagen Cc: Simon Clark; Louise Corbett Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Dear Mr Van Coppenhagen Please find attached the email correspondence with regards to the matter in your email below. The first email was sent on 23 September 2013 (11h32) followed shortly by a follow-up email (15h23). Kind Regards Nelis
Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA
From: Nelis Bezuidenhout Sent: Wednesday, October 09, 2013 8:03 AM To: Kobus van Coppenhagen Cc: Simon Clark; Louise Corbett Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW
Dear Mr Van Coppenhagen Please find attached the email correspondence with regards to the matter in your email below. The first email was sent on 23 September 2013 (11h32) followed shortly by a follow-up email (15h23). Kind Regards Nelis
From: Kobus van Coppenhagen [mailto:kobusvc@gmail.com] Sent: Wednesday, September 18, 2013 12:23 PM To: Simon Clark Subject: Re: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Good day Simon Thank you for the e-mail, but the FSR & several other documents are not yet posted to the website. Would you be so kind to inform us when this has been posted? Regards Kobus van Coppenhagen 0836564498
On 17 Sep 2013, at 16:44, Simon Clark <Simon.Clark@aurecongroup.com> wrote: Dear Sir/ Madam PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK (REMAINDER OF FARM NO. 497 AND PORTION OF FARM NO. 498), ON THE ORANGE RIVER IN THE VICINITY OF AUGRABIES FALLS NATIONAL PARK, NORTHERN CAPE RVM 1: DEA Ref: 14/12/16/3/3/1/681;
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No. Issue Raised by Response from CES EIA team or Hydro SA NEAS Ref: DEA/EIA/0001403/2012; AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW
The abovementioned project refers. This email serves to notify I&APs of the availability of the Final Scoping Report (FSR) for the above mentioned project for comment. 1. Introduction Following the comment period on the DSR, the Final Scoping Report (FSR) was compiled. The FSR includes comments and concerns that were raised by Interested and Affected Parties (I&APs) during the comment period of 40 days which stretched from 19 July 2013 until 28 August 2013. 2. Changes made to FSR This FSR is an update of the DSR, including additional information on the current status of the public participation process and amendments made in light of some of the comments made. Substantive changes to the Draft Scoping Report are reflected as underlined text, while deletions are reflected with strikethrough text. For your convenience we have attached the non-technical summaries (English & Afrikaans) to this email. The following annexures have been updated: Annexure B (includes updated database and proof of I&AP correspondence); and Annexure C (includes Comments and Response Report 2 and comments received). 3. Way forward 69. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (11) Comments on FSR Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobus van Coppenhagen <kobusvc@gmail.com> Date: 10 Oktober 2013 2:01:30 nm. SAST To: Louise Corbett <louise.corbett@aurecongroup.com>, Danie Smit <dsmit@environment.gov.za>, A B Abrahams <abrahamsa@dwa.gov.za>
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (11) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and
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No. Issue Raised by Response from CES EIA team or Hydro SA Cc: Howard Hendricks howard.hendricks sanparks.org , Gene isser ondpoort gmail.com , M Gordon mgordon environment.gov.za , Kallie Naud <knaude@environment.gov.za>, "Dr. Hanneline SmitRobinson" <conservation@birdlife.org.za>, Charles Norman <charles.norman@af.aurecongroup.com> Subject: Comments on the Final Scoping Report for the proposed Hydropower scheme inside the Augrabies Falls National Park
To whom it may concern; The above mentioned application with ref no 14/12/16/3/3/1/681 as per DEA letter of 18 June 2013 refers; The FSR only became available on the AURECON website 1 week late, which allowed very little time for perusal of the documents. The need to comply with government's optimistic targets for renewable energy generation according to the REIPPP initiative, resulted in applications with large gaps and little benchmarking for the Competent Authorities against which to base decisions. Some of the targets should be viewed as arithmetical exercises or estimates, because they seem to be random, considering conventional knowledge. The pressure which is created by this scenario is an international phenomenon and resulted in some regrettable decisions. We had the privilege to visit the proposed site on 9 October and even though the applicant went to great lengths to confirm the seemingly innocuous nature of hydro-electricity generation, it became even more evident that such a development would result in unacceptable cumulative impacts, which we have previously highlighted to the Competent Authority, the applicant/Hydro Tasmania and the consultants. The habitat involved is the only remaining relatively unspoiled portion of the river before the Augrabies waterfall and therefor irreplaceable and it would be an administrative error for the competent authority to allow the process to continue or to grant environmental authorisation at any time in future. The ICPDR report which established twenty "Guiding Principles on Sustainable Hydropower Development in the Danube Basin" confirms our notion that National Parks (and it buffer zones)
Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA should not be subject to new hydropower developments and DEA should adopt it as a benchmark for the consideration of applications. We suggest that the Competent Authority should consider the environmental authorisation for the Neusberg scheme as the granting of the alternative to Augrabies/Riemvasmaak site, as provided for in the regulations. We also suggest that the proposed Boegoeberg scheme should be viewed as the second alternative, both of which are located outside of the buffer zones of the National Park and thus not fatally flawed in that regard. We record our objection to the the granting of environmental authorisation for this project and have furnished reasons in previous comments. We also record our objection to the granting of a water licence for the diversion of up to approximately 3,2 million cubic meters/day, for a reach of approx. 9 km along the Orange river inside the National Park. The RVM 1 application to DEA does not reflect that the applicants are applying for a water license as indicated on page 8 (section 3.2 ....... N/A) of the application, anyway. If the applicant does not read the explanatory notes (5) on page one, regarding cautious use of the term N/A, even after directing them to it, it is not possible to predict how they would interpret other documents/directives. Mr Christoff Le Grange of Hydro Tasmania is well aware of the "contested border" situation in the Lower Orange river valley and which has led to the launch of the LORI TFCA in 2008 by the Peace Parks Foundation, JMB and SA and Namibian government agencies and to which some parties including us, are still committed as recorded in the AFNP management plan which was recently approved by the Minister of Environmental Affairs. This management plan clearly underlines the desire of SANParks to change land use from agricultural (grazing) to formally "protected area" (in appropriate areas) in partnership with voluntary participants, in an effort to conserve a representative portion of the Nama-Karoo biome which is currently under-protected, thus classifying it as as a critical biodiversity area according to "South Africa's National Biodiversity Strategy and Action Plan; 2005, page 101 and DEA Environmental Indicators. This portion of the National Park land is already fragmented by
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No. Issue Raised by Response from CES EIA team or Hydro SA a road servicing the Riemvasmaak area, which would be further exacerbated by the linear disturbance of the proposed project. There are several potential solutions to satisfy the need for the generation of renewable energy and empowerment in the Riemvasmaak area, which would ultimately be more beneficial to the community, but it is the subject of another forum, since the applicant is only interested in developing hydroschemes. Regards Kobus van Coppenhagen 70. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (12) Regards Kobus van Coppenhagen From: Kobus van Coppenhagen [mailto:kobusvc@gmail.com] Sent: 02 March 2014 09:09 AM To: Louise Corbett; Danie Smit; M Gordon Cc: Howard Hendricks; Dr. Hanneline Smit-Robinson; Kallie Naud Subject: Application for Hydroscheme in Augrabies Falls National Park (AFNP)
Miss Corbett We have approached the Australian Public Corporation, Hydro Tasmania and also the Deputy Prime Minister of Tasmania Mr. Bryan Green, to inform them of the potential impact of a hydroelectric scheme on our National Heritage, but they chose to ignore all the issues and referred to the administrative process under way in South Africa. However, now they cannot claim innocence due a lack of knowledge/information. The Tasman Government has previously deproclaimed a National Park in order to erect a Hydro scheme and then subsequently proclaimed it as a National Park again. This type of activity would be referred to as "Greenwash" according to the "A to Z of Corporate Social Responsibility" (Visser, et al, p.248) and this is exactly what they want to repeat in South Africa 40 years later. We have previously referred to the financial viability of the
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (12) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA

proposed Hydroscheme, because a low Internal Rate of Return (IRR) would not be attractive to investors, especially the local community, who seems to be "locked" in due to preconditions. We need replies on the following questions; What is the projected real IRR for this project, based on the REIPPP ? Is the applicant intending to apply for certification of the project as "additional" according to the rules of the the *UNFCCC, Clean Development Mechanism? Considering the information in the opening paragraph, it is certain that this application cannot qualify, or be accepted for "additionality" under the CDM rules. Did/will the applicant receive any public funds from an *Annex1 Party for this or any of the other hydroschemes, eg. Neusberg Hydroscheme ? Has the feasibility study for the project been conducted internally or by an independent authority? Please confirm the name of the entity which conducted the feasibility study and whether a case of conflicting interests could be established, from your impartial viewpoint? Our contention is that this project and perhaps some of the other Hydroscheme applications needs to be scrutinized carefully for financial viability and the start-up cost burden which is transferred to the local community, whose share is financed by the IDC. There is no sense in making them shareholders in businesses which would hardly be profitable, considering the alternative options in the field of renewable energy. The details of financial transactions and relationship between the developers and contractors and financial beneficiaries should also be disclosed, to ensure transparency. Sustainability of the project: The main factor in determining the long term viability of a Hydroscheme is dependant on the availability of a constant supply of water to guarantee effective operation of the plant. We have referred to large increases in in consumption which was planned, in a previous e-mail to you (Hydrology of the Orange River 10 April 2013), which you chose to ignore. Amongst several issues which we highlighted at the time was
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No. Issue Raised by Response from CES EIA team or Hydro SA that there was planning under way to increase the transfer/diversion of water between Catchment Management Areas, with a subsequent increase in consumption of water from the Lesotho Highlands Water Scheme (phase 2) which would reduce the total run-off in the Lower Orange River Valley. Reference to this Phase 2 agreement was made on the Electricity Governance Initiative website on 24 May 2013, that the quantity of water transferred would increase from 24.6 m3/s to 45.5m3/s (~660 m/m3/a) and it would generate 1GW of hydroelectricity. The project is scheduled for completion in August 2020. The consideration of only historical data would thus present a fatal flaw in determining the certainty of supply for a Hydroscheme and should be seen as a misrepresentation to all the other parties involved, especially since you have been informed, but chose to ignore it. It is imperative that a proper water balance determination be made for all the Hydroscheme applications as we have referred to on a previous occasion. Financial viability of this project versus key conservation areas: We want to draw your attention to work which was conducted in 1995 by *Creemers, et al., which concluded that the economic contribution of key conservation areas can rival the projected/potential revenue from a major mining activity, ... with the added benefit of realizing international obligations, as far as conservation targets are concerned and could thus be termed as a "win-win" situation. The status of the Augrabies Falls National Park as a key conservation area and driver of tourism in the Northern Cape is incontestable. We propose that this fact should be one of several overwhelming reasons for maintaining the status quo of the AFNP, rather than the applicant's proposal to rezone and further fragmentation and "privatization" of the northern section of the National Park. In any case there is no precedent for the activities which the applicant is "wishing" to conduct inside a South African National Park, although such precedent does exist in Tasmania. The contribution to the sustainability of a whole network of activities/businesses just by the existence of National Parks is not limited to accommodation income alone, but it is a major
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No. Issue Raised by Response from CES EIA team or Hydro SA driver of the local economy spread over a wide spectrum, starting with airlines, car rental, and then drilling down to the smallest establishments located in the countryside. Any deterioration in the perceived value of visitors experience, local or international, will harm the whole "value-chain". Perhaps it is the right time to elaborate on other issues related to the management of National Parks which are covered by Regulation 1061 and it's purpose. The wellbeing of humans are of great importance inside National Parks but special consideration must also given to the needs of fauna which is technically captive inside the the area. Thus any reference to disturbance does also include the disturbance of especially Fauna and explains the "limited" access provided to National Parks. Noise and waste: The EAP elaborates on the fact that noise from the proposed activity might not offend visitors due to being removed from the site by some distance. However, the animals which occur in an area which is essentially a wilderness are easily disturbed and stressed by noise. During the site visit Mr. Le Grange referred to the placement of heavy machines inside the ravine by a large helicopter, the noise of which would be seriously offensive to animals, etc. The proposed dumping of a large portion of the 500 000 tons of waste rock in the small beach area at the "dry falls" is also relevant since National Parks are not zoned to be receptacles for waste! The roads which "only need to be widened" is also a fallacy, since the silt which must be traversed in certain areas, cannot support large equipment and trucks and must be excavated to build a proper road (which is not required for the purpose of the Park) and it would generate a large amount of dust because the area does only receive occasional rain. Due to the lack of reliable financial information in the reports i.r.o. the IRR for this proposal (the BAR document showed a very low estimate of operational income), it would be sensible to refer to the Neusberg Hydroscheme as an example, since there is existing documentation which can be scrutinized and the project is registered by the CDM Executive Board. (The Project Proponent (PP) is also the representative in that application)
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No. Issue Raised by Response from CES EIA team or Hydro SA The following quotations from the "CDM Validation Report No. CCL0078/NGCHPP/07022012", conducted by Carbon Check (Pty) Ltd (CCL) (with the page number in brackets) are of particular interest; "The PP has presented the financial unattractiveness of the project activity through investment barrier for which the PP has applied by applying the benchmark analysis (p17: 3.6)." "The pre tax project IRR is calculated as 4.47% (p18)" and in the next paragraph 3.6.5, it continues the discussion to emphasize that the Prime Lending Rate of banks (to its high rated customer) in SA was set at 9%, at the time of the investment(sic) decision. "PP has appointed a competent, experienced Engineering company, ENTURA, well known in the industry, to evaluate the feasibility of the proposed project; based on the initial findings of the engineering company's report /25/ PP approached the lender, Nedbank Capital Limited, .......(p18: 3.6.6)." The above quotation have relevance, since it would be not appropriate for a company to submit feasibility studies which were conducted internally, by shareholders or potential contractors/beneficiaries, as supporting documents with applications for finance as it could be construed as a conflict of interest. It also seems that public money by an *Annex 1 Party, has been used in this application, as is demonstrated by the submission to the Tasmanian Government Businesses Scrutiny Committee meeting (transcript 3/12/2013). According to the CCL validation report no public funding has been used in this project (p6 /21/, p 10, 27, 35, 36 & 63). The actual amount according to the audit report is AU$ 4.326 m (R 41.52 m ZAR at current exchange rate) which is supposed to represent 25% of the equity in the Neusberg Hydroscheme. It seems that the funds are actually used to pay ENTURA, thus Hydro Tasmania pays itself, according to the submission of Dr. Crean. (Both HT and ENTURA are trading entities of the HEC). Does this "methodology" mean that the company could be dysfunctional? Does HT get a better deal (substantial discount) for its share than other participants? The total cost of the project is estimated at around ZAR 489 m (have seen reference to R 540m?) and 25% would be around
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No. Issue Raised by Response from CES EIA team or Hydro SA ZAR 122.26. (Is the project cost inflated?) The following quotations from transcripts of meetings should be enlightening: The above information creates uncertainty as far as the real purpose of some of these projects are concerned. Because the applicant does not own the properties or offer a market related price for leasing it, the whole process should be regarded with suspicion. The applicant is also determining the ToR of investigations and appoint the specialists doing the investigations i.e. the applicant has control over virtually the whole process, which includes audiences with the Competent Authority, which we have not been able to secure after many attempts. This indicates that the administrative process is flawed in most aspects. Reference to the "additionality" of projects in terms of the CDM relates to its financial viability in a real world scenario, i.e. without financial assistance. It is understandable that such schemes can be promoted on private land, but definitely not in National Parks. It is not a win-win scenario! Surely, you must agree that we cannot sacrifice our heritage for a hand-out, which is not even guaranteed. Kobus van Coppenhagen 71. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (13) Shawn you have to bear in mind that the EAP/applicant "infighting" must have been ongoing since the end of 2013. In the meantime we were preparing for the DEIR which was just not forthcoming. We had to "unearth" the applicable documents, which should have been consulted before and application was lodged. Thus, we are sure that there are just too many gaps which remain at this stage. At the end we are referring to a scientific study(which can be downloaded) which shows that Mega Floods have occurred in the "recent" past i. The Lower Orange river. Regards Kobus van Coppenhagen 0836564498
Begin forwarded message:
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (13) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA From: Kobusvc van Coppenhagen <kobusvc@gmail.com> Date: 26 Mei 2014 9:09:10 vm. SAST To: Jeanne Nel <jnel@csir.co.za>, Mandy Driver <m.driver@sanbi.org.za>, Peter Bradshaw <Peter.Bradshaw@nmmu.ac.za> Cc: Howard Hendricks <howard.hendricks@sanparks.org>, Danie Smit <dsmit@environment.gov.za>, A B Abrahams <abrahamsa@dwa.gov.za>, M Gordon <mgordon@environment.gov.za>, Louise Corbett <louise.corbett@aurecongroup.com> Subject: FEPA Project & "Global-Environmental-ChangeAssessment-Aquatic-Ecosystems"
Good day Jeanne, Mandy and Peter We live on the western boundary of the Augrabies Falls National Park and are participating in the expansion of the National Park, to the west. The status of the National Park has been under threat of inappropriate development pressure, due to applications for prospecting rights in 2010 (in the western section) and lately (2012) by an application for the erection of a hydroscheme in the northern section of the Park. The prospecting rights application seems to have "fizzled out" when it became clear that the applicant had no money. The application for a Hydroscheme is another kettle of fish, since the applicants are composed of a South African company with no hydro experience and the infamous Hydro Tasmania (HT), whose hydro schemes in Tasmania are completed and they have a consulting "business" with about 300 employees, with very little work. South Africa, with its potentially lucrative REIPPP, has now become their next target and HT are financing applications for the erection of hydroschemes at sites with hydropower potential, regardless of its land-use zoning. Augrabies is a typical example, as far as their creativity is concerned. They propose that the northern section of the National Park be de-proclaimed to allow for the construction project which would create a river diversion of between 9 and 10 km and then to re-proclaim it, as was done previously in Tasmania. We have sent letters to the CEO of Hydro Tasmania and also to the Deputy Premier of Tasmania, requesting their withdrawal from this application, to no avail.
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No. Issue Raised by Response from CES EIA team or Hydro SA There is a substantial body of information which originated in various "spheres" of government and the scientific community, which presents compelling evidence for the protection of the National Park in its current format and for the expansion of its footprint. The documents which are referred to as subject (of which you are co-authors) are a case in point. It refers to the desirability of protecting both banks of a river, which in the case of the Orange river is occurring in Augrabies Falls National Park only. Unfortunately, due to slow data connections, I am not able to download the FEPA maps, which could provide us with valuable information, regarding the conservation value of the river reaches inside the Augrabies Falls National Park. The "Siyanda Environmental Management Framework Report of 2008"(EMF) however, classifies it as environmental control zone 3 and concludes on page 76: "In the instance of the Lower Gariep Alluvial Vegetation, conservation is the only acceptable use of the area because it represents: an endangered vegetation type with a conservation target that can already not be attained anymore due to the extent of transformation that has already occurred; and natural floodplain areas in the river system that is dynamic and subject to natural physical change over time due to the interaction between the alluvial nature of the area and flood events. The water body of the Orange River is the most important element in the area in terms of natural and economic services that depend on it. It is a dynamic and complex system. Any activity that will affect the functioning of the water body should be subjected to an appropriate environmental impact assessment. From a strategic long perspective such activities should be limited to the minimum." And page 74 (we have included the exclamation marks) "Zone 3: Potential high to very high vegetation conservation areas The area covered by this zone has the potential to become core parts of conservation areas that may be necessary in order to meet national conservation targets. It is therefore important that the potential is maintained by keeping these areas as natural as possible.
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No. Issue Raised by Response from CES EIA team or Hydro SA Due to the sandy nature and the grain size of the sand that occur in the area, the area is prone to severe wind erosion if the groundcover that acts as a protective layer is disturbed over large areas or in exposed places. "The following management parameters are suggested for the zone: Land uses and activities that are compatible with the zone and may be allowed without further assessment: Nature conservation.'!!!!!!!!!!!!!!!!!!!!!!!!!!! Land uses and activities that may be compatible (depending on the specific nature of land use or activity) and that may be considered in the zone after an appropriate level of impact assessment (as required by law) has been conducted: o Stock farming that does not exceed the carrying capacity of the veld; and o game farming that does not exceed the carrying capacity of the veld.
zone: o Agriculture of any kind; o establishment of towns or settlements (including components thereof) and related infrastructure; o opencast mining and quarrying; !!!!!!! o new tracks, roads, railways, pipelines and cables; and !!!!!!! o all off-road vehicle driving. !!!!!!
o The creation of unnecessary bare earth areas should be avoided at all cost; o The construction or creation of new roads and tracks should be avoided; o exposed bare areas should be paved or be rehabilitated with vegetation cover whenever feasible." Even though this document recommends that any activity inside certain zones/geographical areas can only be considered after being subjected to EIA process, the consultants only conducted a BAR, although they refer to the EMF in their desktop study? We believe that it is imperative that the relevant scientific data, together with its correct interpretation should be provided to the DEA to enable them to make an informed decision. The Renewable Energy Targets have caused
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No. Issue Raised by Response from CES EIA team or Hydro SA "some regrettable decisions" in Europe, which has led to the establishment of the Intercontinental Commission for the Protection of the Danube River (ICPDR), consisting of government departments, hydro industry, NGO's and scientists, which drafted the 20 "Guiding Principles on Sustainable Hydropower Development in the Danube Basin(PDF)." Principle 12 states:" In a first step those river stretches are identified where hydropower development is forbidden by national or regional legislation/agreements (exclusion zones). In a second step all other stretches will be assessed using the assessment matrix and classification scheme. Due to the lack of South African guidelines regarding hydropower development, we suggest that these principles should be adopted as a matter of precaution and suggest that you should perhaps consider those opinions in follow-up studies. Also, during our data collection activities, we did come across information which does perhaps explain the existence of the wide flood plain and multiple (dry?) waterfalls which leads into the Orange river ravine. *Apparently, four mega floods of around 27 000 cubic meters/s have occurred in the Orange river basin between 1450-1780 as determined by radiocarbon dating of sediments. As far as we are concerned these are recent events and since the sun is again entering a Maunder Minimum Phase, anything is possible. Several other major events are also described, which as a matter of interest, points to the inevitability of future occurrences. Would it be possible for anyone of you, to provide us with the relevant scientific information for the FEPA Project, as it relates to the Augrabies Falls National Park, and to the Environmental Assessment Practitioner from Aurecon, Louise Corbett, the Competent Authority at DEA mr Danie Smit and mr. AB Abrahams at DWA? We thank you in anticipation of a reply. Regards Kobus van Coppenhagen 0836564498 Augrabies.
*Extreme Floods around AD 1700 in the Northern Namib Desert, Namibia and in the Orange River Catchment, South
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No. Issue Raised by Response from CES EIA team or Hydro SA Africa - Were they forced by a decrease of solar irradiance during the Little Ice Age (PDF) Klaus Heine and J rg lkel. 72. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (14)
The Council for Geoscience has removed earthquake data from their website and have NEVER responded to our questionnaires after events, which does not reinforce our trust in them as a public institution. We regard them as strictly commercially oriented. Regards Kobus van Coppenhagen 0836564498
Begin forwarded message: From: Kobusvc van Coppenhagen <kobusvc@gmail.com> Date: 29 Mei 2014 8:15:02 nm. SAST To: Andrew Hockley <Augrabies@vodamail.co.za>, Angus Tanner <angus@sa.wild.org>, Louise Corbett <louise.corbett@aurecongroup.com> Cc: Danie Smit <dsmit@environment.gov.za> Subject: Tremors in Augrabies Hi Andrew We were in Upington on business for the whole day and just after arrival at home at about 18h05 today two tremors occurred in succession with a third 5 minutes later. At 18h50 another tremor occurred. This seems to be a repeat of the 2010 events. Are you in Augrabies? The Kai Garib municipality did have public meetings at the time and as far as we know an investigation was launched by them and Hannecke (my wife) spoke to the prof who was in "charge". The issue is that we had a number of rockfalls which occurred and which deposited material in the river bed. The explanation of the Council for Geoscience was really unsatisfactory and simplistic as far as conceptual matters are concerned. We have for example an ablution building at the campsite which was erected about 15 years ago and which is split (walls
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (14) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA and floor) on a NNE strike and this year after the the 100mm rain event we found on this strike about 400 m to the north an area in the river bed, a few meters wide which was still "bubbling air" 24 hours after the rain, which is really odd. We did phone the neighbor Gene Visser to go and have a look and he confirmed afterwards that it was still happening when he visited the site. This is probably an indication of a very deep seated joint. In that area to the north of that point, a kimberlite dike was encountered inside the diggings of the old tungsten mine workings and a kimberlite pipe occurs some 500 m to the west . (Daberas survey map and the "Geology of the Onseepkans Area" (Moen and Toogood) At that time we did some research and came across another very interesting document of which one page is pasted below; "Controls on post-Gondwana alkaline volcanism in Southern Africa" (PDF)(Moore, et al ) Fig. 4. The alkaline volcanic pipe lineament that extends from the west coast of South Africa into the Zambezi and Luangwa rifts of Zimbabwe and Zambia. The dates available for volcanic rocks on the lineament indicate a systematic increase in age to the NE. Note that the zircon ages only provide an upper limit on the emplacement age, as discussed in the text. The inset shows earthquake epicentres from Reeves (1972), a microearthquake study by Scholz et al. (1976), and epicentres from the National Earthquake information Centre (NEIC: http://earthquake.usgs.gov/regional/neic/). The Kalahari seismicity axis, approximately coincident with the lineament, was identified by Reeves (1972). Epicentres to the north west of the lineament in Botswana lie in the Okavango Rift Zone (Kinabo et al., 2007). Faults are marked in northern Botswana and the Mid Zambezi valley of Zimbabwe and Zambia from Scholz et al. (1976), Ballieul (1979), and Kinabo et al. (2007). Ok = Okavango Delta; Mk=Makgadigadi Pans. Key to pipe clusters: 1. Namaqualand Olivine melilitites; 2. Bushmanland Olivine melilitites; 3. post-Karoo diatremes; 4. Pofadder kimberlites; 5. Ariemsvlei kimberlites; 6. Noeniputs kimberlite; 7. Rietfontein kimberlite; 8. Southern Botswana kimberlites; 9. Kolongkweneng kimberlites; 10. Tsabong-Molopo kimberlites; 11. Khekhe fissure; 12. Mabuasehube kimberlites; 13. Kokong
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No. Issue Raised by Response from CES EIA team or Hydro SA kimberlites; 14. Kikao kimberlites; 15. Khutse kimberlites; 16. Gope kimberlites; 17. Orapa; 19: Binga kimberlites and Katete carbonatite; 20. Sengwa kimberlites; 21. Lower Luangwa (Kaluwe) carbonatites; 22. Kapamba lamproites. From this document and the info above you should be able to deduct that there are some geological formations which are deeply weathered and which might not be competent and could contribute to some of these events (Kimberlites weather deeply and easily due to its composition). The Daberas scenario described above is really "generic" of the area since we are located inside a kimberlite province. The "Geology of the Upington Area" (G Moen) p 117-121, discuss the structure of the area in more detail. It is imperative that a geologist engineer (geophysicist) investigate the stability of the site and it's suitability for the proposed installation, from a technical perspective. The cursory comments of the EAP, who was never present, regarding the tremors should be disregarded. A substantial number of insurance claims were lodged for damage sustained, after the events. It is an indication of the lack of engagement with the local community which is confirmation of their lack of understanding of its effect on the community. We have even suggested at some stage that the "thundering noise" generated by these tremors might be another reason for the name Augrabies. Kobus van Coppenhagen 73. Good day Shawn
Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (15) While the consultants were not forthcoming with their DEIR we felt the need to point out some relevant information..... Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobusvc van Coppenhagen <kobusvc@gmail.com> Date: 02 Junie 2014 9:39:49 vm. SAST To: Louise Corbett <louise.corbett@aurecongroup.com> Cc: A B Abrahams <abrahamsa@dwa.gov.za>, Howard Hendricks <howard.hendricks@sanparks.org>, M Gordon
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (15) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA <mgordon@environment.gov.za>, Danie Smit <dsmit@environment.gov.za> Subject: Incorrect Assumptions and Statements in the FSR for the hydropower station in Augrabies Falls National Park.
Miss Corbett We were expecting receipt of a copy of the revised "RVM1application" form for the proposed Hydropower scheme, as was directed by the DEA in a letter of 18 June 2013 and which was also requested by us on several occasions. In the meantime you have continued without complying with the instructions of the DEA and we are also still awaiting a response from the director of the DEA regarding the validity of the RVM1 application, considering its limited scope. We believe that currently, the DEA is only "indulging" your activities which are really a waste of public resources (administration) and that DWA has not received a water license application as suggested on the current RVM 1 application form. Your FSR document states on page 81: 5.4.5.3 Impact on Energy Production "The IRP sets out a 20 year electricity plan for South Africa and allows for an additional 123 000 MW of renewable energy in the electricity mix in South Africa by 2030", which is grossly overstated, because the figure estimated in 2010 for TOTAL generation capacity required in 2030 is actually 89 532 MW according to the IRP document, which does include the existing 48 220 MW total SA generation capacity(see B below), without Kusile and Medupi which adds about another 8 400 MW to the mix. The balance of the energy is made up of a variety of generation capabilities which includes renewable energy. Your interpretation of the NEED for renewable energy is thus overstated by a multiple of more than 4 and contextually incorrect. Thus, your Assumptions (p 21; FSR) on which this investigation (bullet 1) is based, are totally incorrect and exposes another fatal flaw in this application. 2.5 Assumptions and Limitations 2.5.1 Assumptions "In undertaking this investigation and compiling the Scoping
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No. Issue Raised by Response from CES EIA team or Hydro SA Report, the following has been assumed: The strategic level investigations undertaken by DoE regarding South Africa’s proposed energy mix prior to the commencement of the EIA process are technologically technically acceptable and robust; The information provided by the client is accurate and unbiased; The scope of this investigation is limited to assessing the environmental impacts associated with the proposed hydropower station and connections to the grid. The EIA does not include any infrastructure upgrades which may be required by Eskom to allow capacity in the local grid for the proposed project; and The AFNP Management Plan could be revised to allow for the proposed project, should the potential impacts assessed in this EIA be considered to be acceptable to DEA." Further discussion of IRP; The total generation capacity estimated to be required in 2030 has been reduced in the meantime, to 81 350 MW in the IRP 2010-2030 Update and requirements could be as low as 66 340 MW in certain scenarios, which again includes existing generation capacity. The amount set aside for renewables totals a small fraction of that quantity, which includes imports from INGA and Lesotho Highlands phase 2 (IRP page 32). 7.1.2 The Kobong pumped storage scheme in Lesotho which forms part of the second phase of the Lesotho Highlands Water Project. This facility provides 1200 MW of pumped storage capacity from 2023. This is the phase during which an additional 20,9 M3/s would be diverted/transferred to the Vaal Catchment. Thus, the use of the transferred water (which we have drawn your attention to on two occasions) to create an additional 1200 MW generation capacity, should also be viewed as a more beneficial use of the resource, considering the yield and perhaps as another site alternative for Augrabies and it represents a yield 30 times higher than the maximum of your proposed hydropower station. Future base load energy demand estimates should be considered as very flexible, especially since the consumer cannot be trapped in a spiral of escalation, forever. The
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No. Issue Raised by Response from CES EIA team or Hydro SA scenario described in the IRP Update p 33 section 8.0 regarding embedded generation refers; It is expected that up to 30 000 MW of embedded PV energy capacity could be installed in small installations by 2030, which would probably be the largest single contributing sector and government should prioritize training for that industry, due to the massive opportunities, or call on Elon Musk (a South African) who has done exactly that in the USA, by starting up the largest domestic installer of PV panels in that country. The main "danger" with renewable energy projects would be base generation "over-supply" scenarios or reduction in demand, due to the above scenario, which could cause a collapse of the large scale renewable energy installations, due to high financial start-up costs. This scenario is already happening in Australia as reported in the transcription of the Tasmania Legislative Council; Government Businesses Scrutiny Committee meeting for Hydro Tasmania, on 3/12/2013. It states on p16 : If you are unable to find/download this document we could forward a link on request. On top of this it seems that the wind farm industry in Germany and Australia are already facing financial difficulty and Hydro Tasmania made a statement recently, announcing substantial power purchasing agreement losses (AUD 103 million total, projected for period up to 2018-19) and suspension of further wind farm investments (The Australian 10 May 2014). A "pinch analysis" would reveal that if embedded renewable electricity can be fed directly into the grid, the excess could be used for pumped storage or hydrogen generation which could be utilized in vehicles (Toyota has just launched a hydrogen fuel cell vehicle, which is confirmation of confidence in the technology) or other applications. Obviously, the start-up of the "Hydrogen Economy" as proposed in the 1970's is overdue and needs due consideration by the authorities. We have also forwarded a copy of our request for FEPA (Freshwater Ecosystem Protection Areas) classifications, for your information and we request that you should consider the document as part of the comments provided by us for the FSR. The following information from the SIYANDA Environmental
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No. Issue Raised by Response from CES EIA team or Hydro SA Framework Report 2008 (EMF) deals with renewable energy generation in the Northern Cape and the document should be enlightening to you and the applicant; See also" Augrabies Weelde/Splendour " p33 by Prof. P. vd Walt which refers to the above-mentioned "tug-of-war" which occurred in the past between ESCOM and conservation authorities and which was only settled by government intervention, which led to the proclamation of the Augrabies Falls National Park on 5 August 1966. Instead the EMF refers to renewable energy opportunities on page 55; 2.3.6 Energy Use The rest of the article is not included for the sake of brevity. "Hydropower case studies and best practice examples" (PDF) of the ICPDR also highlights Norwegian best practice on p12; Norway Description: "Protection Plans for Watercourses The conflict between hydropower development schemes and environmental considerations brought about a need for protection plans for rivers and lakes as well as for master plans concerning hydropower development. Protection plans for inland waters were initiated in the early 1970s. By these plans, 388 watercourses (covering 40% of the catchment areas of Norway) have been protected against hydropower development and the hydro power production potential in these watercourses is close to 50 TWh. The purpose of the protection plans is to safeguard complete watersheds to maintain the environmental diversity stretching from the mountains to the fjords. The current plans only protect against hydropower, but a restraint policy should also be exerted towards other kinds of development activities. However, other activities may be permitted in accordance with the licensing system pursuant to the Water Resources Act. This may sometimes result in conflicting situations, where a protected watercourse/watershed actually can be exploited for other uses than hydropower, uses that can have even greater environmental impacts........." To conclude; We have previously referred to the inability of Aurecon to
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No. Issue Raised by Response from CES EIA team or Hydro SA provide accurate and contextually reliable information for comment by the I&AP's and consideration by the Competent Authority and now we propose in the interest of administrative fairness, that this application must finally be closed by the Competent Authority and that all other Hydropower scheme applications which are not "linked" to existing infrastructure, be suspended until government has given proper consideration to the protection of South Africa's threatened rivers. Regards Hannecke & Kobus van Coppenhagen 74. Good day Shawn Our correspondence with AURECON seems to have disappeared and we want to put it back on record. We will be sending many e-mails in the next few days. (16) Kobus van Coppenhagen 0836564498 Begin forwarded message: From: Kobusvc van Coppenhagen <kobusvc@gmail.com> Date: 05 Junie 2014 2:02:59 nm. SAST To: Lenka Thamae <lenka.thamae@orasecom.org> Cc: Louise Corbett <louise.corbett@aurecongroup.com>, Danie Smit <dsmit@environment.gov.za>, M Gordon <mgordon@environment.gov.za>, A B Abrahams <abrahamsa@dwa.gov.za>, Howard Hendricks <howard.hendricks@sanparks.org> Subject: Hydropower installation in Augrabies Falls National Park & ORASECOM IWRM Plan.
Good day sir We live in the Lower Orange River Valley on the western boundary of the Augrabies Falls National Park and are participating in the Range Expansion Project of the Park to the west. The introduction of Renewable Energy Targets (RET) to combat climate change and eventually reduce carbon emissions, have created worldwide opportunity and "floods" of applications for renewable energy installations. The RET's have in general not been aligned with existing legislation and regulatory frameworks, which has led to some regrettable decisions especially regarding hydropower installations. It seemed as if the generation of renewable energy was of
Kobus van Coppenhagen, Daberas, comment by e-mail, 30 May 2015
Dear Mr. Kobus van Coppenhagen, Thank you for our submission (16) relating to the proposed Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Sincerely, Shawn Johnston
EAP’s response: These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for record purposes, as requested by the commentator.
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No. Issue Raised by Response from CES EIA team or Hydro SA overriding concern, to other activities and has even led to applications inside protected areas. In Europe it had a similar effect and the need for strategic planning prompted governments to direct investigations into the matter as quoted below from ICPDR document "Guiding Principles on Sustainable Hydropower Development in the Danube Basin"(PDF) page ll ; "Aware of the fact that hydropower plants offer an additional reduction potential for greenhouse gases but recognizing as well their negative impacts on the riverine ecology, the Ministers of the Danube countries asked in 2010 for the development of Guiding Principles on integrating environmental aspects in the use of hydropower in order to ensure a balanced and integrated development, dealing with the potential conflict of interest from the beginning. The “Guiding Principles on Sustainable Hydropower Development in the Danube Basin” have been elaborated in the frame of a broad participative process, with the involvement of representatives from administrations (energy and environment), the hydropower sector, NGOs and the scientific community. The “Guiding Principles” are primarily addressed to public bodies and competent authorities responsible for the planning and authorization of hydropower but are also relevant for potential investors in the hydropower sector as well as NGOs and the interested public. The Guiding Principles have the character of recommendations and do not exert any legally binding force. As a follow-up, implementation is recommended to take place on the national level, accompanied by a further exchange on experiences with regard to administrative processes and technical provisions." We request that ORASECOM consider the possibility of incorporating a similar set of guidelines for the 10 year IWRM Plan. We noted that ORASECOM and ICPDR are International Cooperating Partners, which would make the sharing of such technical knowledge legitimate. Please note that we do not want to fabricate a case against hydropower developments but rather that protected areas should not be legitimate targets for renewable energy projects. We thank you for your consideration.
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No. Issue Raised by Response from CES EIA team or Hydro SA Regards Kobus & Hannecke van Coppenhagen 0836564498 If you need specific information we would gladly forward it for your attention. If we need to correspond with another person at the secretariat, we would appreciate it if you would forward the contact details. 75. Dr McDonald and Shawn Johnston You suggested that I should phone later on, without stating that it would be "irregular" to speak to me, which seems almost irregular? My question on the phone was quite simple and for clarification only; We noticed that you were not contracted to EOH CES, for the botanical survey and we wondered how the haul roads from the base of the ravine could have been investigated by you if it was a new idea, according to the consultants? This requires a simple yes/no. However, we do differ from your opinion in the sense that we believe that a directly affected party may present a question to the specialist(in whichever way). This is not about your opinion, but rather a matter of fact and it is material. Shawn, we need this reply, still today. In fact we want to receive a copy of the report as he has presented it to Aurecon. Regards Kobus van Coppenhagen 0836564498 Kobus van Coppenhagen, Daberas, comment by e-mail, 29 May 2015 On 29 Mei 2015, at 1:23 nm., Dave McDonald <dave@bergwind.co.za> wrote: Dear Mr van Coppenhagen, It would be irregular for me to answer your queries concerning my botanical studies at Augrabies directly and would be a breach of the environmental process protocol if I were to do so. Please would you direct all your queries in writing to Mr Shawn Johnston (swjohnston@mweb.co.za) who is dealing with all queries and comments from I & AP's. If necessary he would direct you queries to me for a response. It is vital that these channels be followed. Yours sincerely, Dave McDonald 76. On 29 May 2015, at 2:26 PM, Kobus van Coppenhagen wrote: Good day Shawn You are aware that the comment period for the DEIR is closing soon, thus we would require a response today regarding the Ravine Haul Road Impact Assessment, plus a copy of the Botanical Report as presented to AURECON, in order to see if it was done to suit the new project layout. As a matter of interest, could you forward some reference regarding this environmental process protocol, which the learned Dr. is referring to. We are still waiting for the minutes of the "FSR acceptance"meeting with DEA. Regards Kobus van Coppenhagen Kobus van Coppenhagen, Daberas, comment by e-mail, 29 May 2015 Dear Mr. Kobus van Coppenhagen, Thank you for our e-mail and request for information regarding the Ravine Haul Road Impact Assessment and the botanical assessment. I will request a response from the environmental impact assessment practitioner and the relevant specialist. I hereby acknowledge receiving your comments and request. Sincerely, Shawn Johnston EAP’s response All specialist reports associated with the Draft EIA Report were made available to the commentator, on a hand-delivered CD, since he claimed that his internet connection was insufficient to download material from CES’s website.
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No. Issue Raised by Response from CES EIA team or Hydro SA 77. Hallo Shawn Die fokusgroep vergadering het blykbaar nie plaasgevind nie. Die bure het lokale gastehuise opgespoor wat blykbaar geen kennis dra van hierdie aansoek nie. Ons voorstel is dat julle 'n vergadering by nie Park reel vir die mense op 'n tyd wat hulle pas. Bevestig asb dat jy ons kommentaar x 2 ontvang het vanaf Hannecke v Coppenhagen se rekenaar. Ons het dit in elk geval wyd versprei. Groete Kobus van Coppenhagen Kobus van Coppenhagen, Daberas, comment by e-mail, 02 June 2015 Geagte Mnr Kobus van Coppenhagen, Ek sal opvolg rondom die fokusgroep vergadering en terug kom daaroor. Mr. van Coppenhagen, hiermee bevestig ek, dat ek al die kommentaar ontvang het van u en u vrou, Hannecke van Coppenhagen. Die uwe, Shawn Johnston 78. Good day Shawn The e-mail from messrs Rowlston and Smit regarding consent for the above activity refers; It seems as if mr. Rowlston is attempting to "choke" our requests as "concerned citizens" for the clarification regarding the procedures (other than stated in NEM:PAA) to be followed by the applicants in order to obtain consent/permission for the activities planned inside the National Park. It is correct that this permission should be obtained prior to the commencement of the activity and we are quite happy with the instruction of the DEA, that the applicant should submit this consent prior to the submission of the FEIR. This is important since the procedure for obtaining permission for new activities inside National Parks are laid out in NEM:PAA and its regulations. However one of the specialist reports imply that the applicant has obtained legal advice which states that the management plan can be changed to suit this project. Now, we are very interested that this information which is already in the public domain, is also made available to all the parties since it MIGHT affect the procedures which has to be followed to obtain this permission. For the moment this will suffice and we would prefer that you as the facilitator, should liaise with the DEA and your client in order to provide us with the necessary information, which must satisfy the requirements of NEM:PAA, its regulations and norms and standards for the proper administration of National Parks. You would have noted that those and other relevant documents disappeared from the reference material after the submission of the FSR. In the meantime we do insist that the applicants do not have SANParks approval for the proposed Kobus van Coppenhagen, Daberas, comment by e-mail, 6 June 2015 Dear Mr. Kobus van Coppenhagen, Thank you for your e-mail regarding consent and the e-mails forwarded to you by Mr. Bill Rowlston. I hereby note you comments and will clarify it with the environmental impact assessment practitioner. Sincerely, Shawn Johnston EAP’s response This comment was also received from Mrs Van Coppenhagen (see the very lengthy Comment 80 below), to which the response was as follows, and which is equally applicable to Mr Van Coppenhagen’s comment: The commentator has misunderstood the piece of legislation she has quoted. The stipulation in NEM: PAA s50(5) is that “No development, construction or farming may be permitted in a national park, nature reserve or world heritage site without the prior written approval of the management authority.” The Act does not require the management authority’s approval for the preparation and submission of an EIA Report for a proposed development in a national park, only for the implementation of the development itself. There was no question of the EAP refusing to accept the requirements of the Act or failing to respect legislation, merely an insistence that it was correctly interpreted. DEA was in error in requiring evidence of SANParks’ approval of the project before submission of the EIA Report, and has confirmed that its interpretation of the Act’s requirement was mistaken (e-mail dated 22nd May 2015 from Mr Danie Smit (DEA) to Bill Rowlston (EOH CES)). A copy of this message has been provided to the commentator, but he is evidently unwilling to acknowledge that
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No. Issue Raised by Response from CES EIA team or Hydro SA activities and that it must be made very clear in all documents. Regards Kobus van Coppenhagen 0836564498 his interpretation of the Act, which is shared by his wife, was in error. There is no reason that, if the project receives a favourable EA, the AFNP Management Plan cannot be amended to accommodate the project. 79. This row has been left deliberately empty Hannecke van Coppenhagen - Daberas (Draft Environmental Impact Assessment Comments) 80. Sirs, Before commenting, it must be stated even the name of the project is chosen to mislead the general public. The correct description is PROPOSED HYDROPOWER STATION IN THE AUGRABIES FALLS NATIONAL PARK,(AFNP) as a large part of the footprint and impact of this power station will be INSIDE AND ON the land of the AFNP. It does not take a genius to know why the name of AFNP is deliberately omitted. In a recent television broadcast it was proudly announced that this project will be built in Riemvasmaak, but no word was uttered about the fact that it will be built in a National Park. However, it is clear that the applicant is trying to keep this fact under the blanket as far as possible. It was confirmed by Mr Rowlston in a recent public meeting that it is in fact a "very big engineering project", with large dumping sites, haul roads, underground pipelines to be blasted through solid rock, a weir, a power house, power lines and what not, IN THE NATIONAL PARK but then he compares the scope of this project as equivalent to the construction activities for a rest camp, which is very naive because he does not know the mission and purpose of SANParks. In this recent public meeting , Mr Rowlston also confirmed that the waterfall will be affected for 80% of the time, which in turn will affect conservation and tourism aspects within the Park and the surrounding establishments, but it seems that the consultant cannot accept the fact that at a project like this will have a serious impact. How would small establishments and tour operators mitigate a reduction in tourist numbers? We have tried to put all our concerns forward to the competent authorities and to the applicants since the onset of the application in 2012 but have now discovered that it conveniently disappeared with the appointment of EOH CES. The applicants are using the promise of employment and Hannecke van Coppenhagen, Daberas, comment by e-mail, 31 May 2015 Dear Mrs Hannecke van Coppenhagen, Thank you for your submission dated 31 May 2015 relating to the proposed Hydro SA Riemvasmaak Run-Of-River Hydro Power Station EIA study and draft environmental impact assessment report. I hereby acknowledge receiving your comments on the draft report and will forward it to the environmental impact assessment practitioner. Sincerely, Shawn Johnston EAP’s response Project name: There is no intention to mislead the general public or anyone else. The piece of land in question - Remainder of farm Waterval No 497 - is clearly stated on the second page of the Executive Summary of the Draft EIA Report, and later in section 2.6 of the report, to be (i) owned by the Republic of South Africa; (ii) included on the Assets Register of the Department of Public Works, the custodian of all national property; (iii) reserved for the National Parks Board (sic); and (iv) included within the boundaries of the Park. In the same part of the report it is clearly stated that the intention is to construct approximately 3.6km of the underground headrace, approximately 6km of underground power line, and approximately 6km of unpaved access road across this piece of land. The power station itself will not be constructed on this property, but will be situated on the adjacent Riemvasmaak land. Comparative size of the project: The commentator is correct in her assertion that Mr Rowlston described the construction of the hydropower project as a “very big engineering project”. She is, however, mistaken in saying that he likened the hydropower project to the construction of a rest camp in the park. What Rowlston actually said was that he believed that tourists at the
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No. Issue Raised by Response from CES EIA team or Hydro SA electric power to the Riemvasmaak community as leverage for this hideous project. The fact is, as stated in the original Socio--‐ Economic Tourism (Urban – Econ 2012) Impact Assessment page 58 “The poor, disadvantaged groups may not be included in the job creation opportunities during the construction phase if local labour is not used or if the local population does not have the skills to do the job” and then according to the EIR, after the completion, there will be work for not more than 4 local people, this just make no sense. I am not sure whether this fact was properly conveyed to the Riemvasmaak people. We all know that promises are easy to make but difficult to keep. To make matters worse is the fact that this community will inherit a financial burden, as it is clear that there will not be enough water in the future to run this hydroelectric power station, profitably. Again on page 58 it states “Also the poor, disadvantaged groups and future generations often bear a disproportionate share of the social and environmental costs of large projects/developments without gaining a commensurate share of the benefits”. In an effort to illustrate the risk to the community we have requested a water balance study from the start, and have asked for it again at the last meeting. Mr Rowlston could not provide it neither could he explain the fact why this has not been done. The problem for the applicant is that a water balance study is an integral requirement and will show that this project is doomed from the outset, as a result of lack of water, and this is why it is not forthcoming. The other fact is also that this project will be used to keep the workforce at HT/Entura on the payroll, regardless of the cost to the protected environment. This quote from an Australian newspaper explains the financial position of HT and in our view AFNP is a soft target as a result of the REIPPP in South Africa. “A planning document, leaked to The Weekend Australian,(10 May 2014) shows Hydro Tasmania’s power-‐purchasing agreements for its major Tasmanian wind farms – Musselroe and Woolnorth – will return a $12.5m loss this financial year, rising to $20.6m in 2014--‐15. Cumulative losses total $103.6m ( about 1billion Rand ) by 2018--‐19, according to the document, the authenticity of which was confirmed by the company.” This illustrates why Hydro SA/HT time the rest camp was constructed understood the need for it, although it would have directly and physically inconvenienced them, because they understood that it would ultimately improve the quality of their tourism experience. He went on to say that he believed that tourists would also understand the need for the construction of the hydropower project, which will take place in a part of the park to which the public is not allowed access, and which is some distance from any part of the park to which public access is allowed, because they will understand that the project will improve the quality of life of the people of South Africa and of the area surrounding the park. Diversion schedule: The Commentator is correct in saying that the diversion of water from the Orange River will affect the Augrabies Falls for 80% of the time. But, as she is well aware, this is by no means the full story. The actual situation was carefully explained at the public meeting, and is set out in section 3.3.1 of the Draft EIA Report, as follows:  For ±20% of the time no flow will be diverted into the tailrace:  For ±15% of the time (55 days) the river flows at or less than 30m³/s, so no flow will be diverted into the headrace and the HPP will not operate.  For ±5% of the time (18 days) the river flows at more than 800m³/s. At this flow rate it is anticipated that the sediment loads in the river will begin to increase to such an extent that sediment could be drawn into the headrace, and could result in damage to the turbines. No flow will be diverted into the headrace; power generation will be shut down to prevent damage to the turbines.  For ±45% of the time (165 days, or 5.4 months) river flows are between 30m³/s and 90m³/s, diverted flow will progressively increase from zero to 38m³/s, and the power station will operate at less than its installed generating capacity.  For ±35% of the time (128 days, or 4.2 months river flows exceed 90m³/s but are less than 800m³/s, diverted flow will be at a maximum of 38m³/s, and the power station will operate at its full design capacity This means that, during the time when flow will be diverted to the hydropower station, the percentage reduction in the flow rate over the falls will range from zero at a total river flow of 30 cubic
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No. Issue Raised by Response from CES EIA team or Hydro SA stated that they are only interested in Hydro Electric power, because it suits them in this case. In the light of the accusation that are they paying less for their share in the REIPPP projects should be seriously investigated. Is this why the Neusberg project escalated from 433.76milion ZAR (Neusberg PDD page 3) to 580mililion ZAR (IDC media), or is this a matter for investigation by the Public Protector? Furthermore, the Riemvasmaak community is made to believe that project will sort out all their power problems and they will never have power failures again, as can be seen in their comments. It is the duty of the DEA as the competent authority to stop this abuse. This is a company that is only interested to line their own pockets regardless of the impact this project will have on our South African heritage and its people. For the public, to try and comment on this project/study within a window of 30 days is unreasonable, bearing in mind that the applicant was allowed more than 30 months to compile the study, therefore, our objection that it is procedurally flawed remains. However, let me point out a few fatal mistakes/flaws and omissions which should render this report useless for proper consideration going forward. 1.The unrealistic EFR scenario by the Environmental Assessment Practioner, must be rejected due to the lack of a scientific basis. This must be seen against the disregard for any EFR as has been illustrated at Neusberg, by the very effective remote manipulation from Tasmania. EFR date, 20 May 2015 at 07h00 is +--‐ 15cumec and the flow through the Hydro scheme is 91cumec, and then the seemingly innocuous statement by the consultants that “ we will never dry up the Falls” begins to look like an absolute certainty AND IN THE LIGHT OR THIS A COMPULSORY WATER USE LICENCE PROCEDURE INCLUDING FULL PUBLIC PARTICIPATION MUST BE MANDATORY. Because of this irregularity it is imperative that the Water use licence for Neusberg must be made available for public scrutiny. 2. The whole issue is the fact that a Special Management Area with a High Sensitivity value inside the AFNP, is the target for this development, where biodiversity conservation is a critical component and therefore the specialist study must consult the correct references. Then when looking at this study we realise metres per second (m3/sec) to 42.2% at 90m3/sec, falling to 4.2% when the river flow is at 800 m3/sec. The commentator’s assertion that this alteration of the flow regime of the falls will result in a decrease in tourism to the park, with knock-on effects on the local hospitality industry, is a reflection of her personal fears, and is by no means the established fact that she believes it to be. Disappearing documents: The statement that we, EOH CES, have somehow deliberately made the commentators’ previous correspondence with the previous EAP “disappear” is without foundation, and is rejected. These previous comments have been resubmitted and included in this Comment and Response Report Employment: The applicant is committed to employing as many local people as possible during all phases of the project’s lifetime, as set out in section 6.8.2 - Project Employment Opportunities – of the Draft EIA Report. The applicant has also undertaken to provide the necessary training to employees to enhance their future employment prospects. The anticipated numbers of employment opportunities were presented to the Riemvasmaak Community members during three open-house meetings on 5th and 6th of May 2015, which were attended by a total of 138 people (Vredesvallei 32; RVM Mission 43, Augrabies & Marchand 63). Availability of water; WULA: The alleged potential for there not being sufficient water to operate the project in future, and the requirement for a “water balance”, apparently refers to an analysis of the balance between supply and demand in the Orange River catchment as a whole. This is, of course, the responsibility of the Department of Water and Sanitation, and the applicant cannot reasonably be expected to undertake such a task. This was carefully explained to the commentator at the public meeting. The applicant has, however, analysed the river’s flow regime for the past 20 years from the data recorded at the DWS gauging station a short distance upstream of the site of the diversion weir. He has satisfied himself that, under flow conditions in the river that have prevailed for the last 20 years, there will be sufficient water for the project, and that the project will be financially viable. The applicant has also consulted extensively with the Department, and has submitted an application for a Water Use Licence for the project. In a letter
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No. Issue Raised by Response from CES EIA team or Hydro SA that the wrong area information was used for this study, the Namakwa District (DC6) (p25) was used for the assessment. It is obvious that this study must be completely ignored and cannot be used in a decision at all. The correct study area is Siyanda District (DC8). Refer to our FEPA project comments dated 26 May 2014, facilitator document no13. 3.The lack of respect for legislation became clear in a recent meeting when Mr Rowlston’s attention was drawn to the requirement that SANParks approval must be obtained before the DEA would accept the final EIR. Refer to NEM:PAA 50 (5) He blatantly refuse to accept it and stated that they will submit it anyway, regardless. 4.The fact that new consultants were appointed should not be an excuse for the deliberate omission of any correspondence and comments, we see this as a strategy to minimise public participation, neither should they be allowed to reintroduce old reports that were tainted by false declarations or based on the wrong ToR. It now seems from certain documents ( Socio--‐ economic report Jan 2014) that EOH CES was already appointed in January 2014, without notification. Furthermore, the facilitator, Mr Shaun Johnston promised that a focus group meeting will be held at the AFNP, and we did not even receive a courtesy call. This renders the process procedurally flawed, fraudulent and unfair. 5.In all the specialist studies the word " mitigation" seems to be the magic bullet, but all it confirms is that the destruction in the AFNP and Melkbosrant will be complete and no matter what mitigation promises are made, the cumulative impacts will be overwhelming and irreversible. 6.As an affected party , with a vested interest, who is a voluntary participant in the expansion of the footprint of this National Park (see Park Management plan, page 20) we want to state categorically that the impact by the proposed activities will be severe and we want to record our strongest objection to any notion of approval for this application. Hannecke van Coppenhagen dated 8th July 2015 to the applicant, headed Confirmation of Water Availability for the Proposed 40MW Hydropower facility: RVM Hydroelectric (Pty) Ltd, near Augrabies in the Orange ProtoCMA, Northern Cape Operations, the Department wrote: Following due considerations of the water resource availability in the relevant catchment area, it was determined that sufficient water is available to meet the water requirement of the proposed project, requiring approximately 98 550m3 during the 36-month duration of the construction phase and 38 m3/s during the operational phase of 20 year long duration, which is a nonconsumptive water use. The department is evidently satisfied that the project is sustainable in the long term from the perspective of the availability of water, and the commentator’s misgivings in this respect are therefore unfounded. Applicant’s partners in the project: The applicant has the right to choose his partners in this project, irrespective of the country of origin of the personnel involved. The performance of that entity on projects in Tasmania is not relevant to this project, and neither is the cost of the Neusberg project. Availability of electricity in the area: No guarantees have been given to the Riemvasmaak community, or to anyone else in the project area, of an uninterrupted power supply when the project is implemented. The electricity generated by the project will be fed into the National Grid. A 40MW hydro plant connecting into the national grid Blouputs in the Northern Cape Province will have a positive impact on the stability of the South African Electricity Grid. While the small relative size of the units will have negligible impact on the overall system frequency stability, the units will provide significant local voltage support. This voltage support is mandated in the RPP Grid code for this sort of generating unit. The voltage support improves the efficiency of the local transmission and distribution network, makes solar PV facilities less prone to interruption due to voltage dips and enhances fault detection and clearing through higher local fault levels. All these effects provide a more secure, reliable and higher quality electricity supply for customers in the region. The presence of synchronous generation in a region can also facilitate faster system restart after blackouts and assist the supply authorities in
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No. Issue Raised by Response from CES EIA team or Hydro SA system outage management. Comment period: The 2010 EIA Regulations (in terms of which this project is being assessed) do not explicitly specify the length of the period for I&APs to comment on Draft reports. This lack of specificity about the comment period is reflected in the Companion to the Environmental Impact Assessment Regulations, 2010, which was published by DEA in October 2010 as Guideline 5 in the Integrated Environmental Management Guideline series, except to say that comments should be submitted within the specified timeframes, or any extension agreed by the EAP. However, Guideline 6 in this series – Environmental Management Frameworks – recommends “at least a 30 day review period” for an EMF, and regulation 3(8) of the 2014 EIA Regulations says that “Any public participation process must be conducted for a period of at least 30 days.” DEA therefore regards 30 days as a reasonable period for I&APs to comment on reports. It should, however, be noted that the comment period was extended by 14 days at the commentator’s request. WULA: A Water Use Licence Application (WULA) was submitted to DWS by MBB Consulting Engineers Pmb) on 15th May 2015. A series of 40 documents relating to the WULA was made available for public comment on CES’s website. A copy of the Draft EIA report was submitted to the Department in support of the application, and its receipt was acknowledged in a letter dated 30th June 2015 from DWS. Subsequently the Department issued a non-binding letter confirming that water was available for the project (referred to above). The letter also specified that the letter was not an authorisation to proceed with the water use, and that a full assessment of the application would be undertaken once the project had received preferred bidder status in terms of the Department of Energy’s REIPP programme (which requires environmental authorisation to have been granted). Public comments on the WULA will be submitted to the Department once they have been collated and responses prepared. Namakwa District: We are not certain to which report the commentator is referring. There is no doubt that the project is in the Siyanda DM (since 1st July 2013 known as the ZF Mgcawu District Municipality) and not the Namakwa DM. We can find only two references to the Namakwa DM in the specialist reports. One
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No. Issue Raised by Response from CES EIA team or Hydro SA is a reference in the Heritage Impact Assessment to a previous HIA carried out by the specialist, which is not explicitly mentioned in the text. The other is a quotation in the Faunal study from the Namakwa District Biodiversity Sector Plan (NDBSP). 2008. Namakwa Bioregional Plan, Northern Cape. pp 146 (referenced in the text as NDBSP 2008), as follows: However, the hunting and trapping of predators can often lead to an increase in predator numbers because of the elimination of alpha males that restrict access of other predators within their territory (NDBSP 2008). The reference is intended to illustrate the problems with predator control. It is an example, and has nothing to do with the subject matter in the 26th May 2014 facilitator document No 13 quoted by the commentator, in which one of the highlighted issues is (emphasis by commentator, Mr K Van Coppenhagen): In the instance of the Lower Gariep Alluvial Vegetation, conservation is the only acceptable use of the area because it represents:  an endangered vegetation type with a conservation target that can already not be attained anymore due to the extent of transformation that has already occurred; and  natural floodplain areas in the river system that is dynamic and subject to natural physical change over time due to the interaction between the alluvial nature of the area and flood events. The Botanical specialist report, in which the Namakwa DM is not mentioned, discuses Lower Gariep Alluvial Vegetation as follows: The construction of the intake weir will impact Lower Gariep Alluvial Vegetation to a small localised extent and will not make a significant contribution to the cumulative loss of this Endangered vegetation type. The commentator has misunderstood the piece of legislation she has quoted. The stipulation in NEM: PAA s50(5) is that “No development, construction or farming may be permitted in a national park, nature reserve or world heritage site without the prior written approval of the management authority.” The Act does not require the management authority’s approval for the preparation and submission of an EIA Report for a proposed development in a national park, only for the implementation of the
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No. Issue Raised by Response from CES EIA team or Hydro SA development itself. There was no question of the EAP refusing to accept the requirements of the Act or failing to respect legislation, merely an insistence that it was correctly interpreted. DEA was in error in requiring evidence of SANParks’ approval of the project before submission of the EIA Report, and has confirmed that its interpretation of the Act’s requirement was mistaken (e-mail dated 22nd May 2015 from Mr Danie Smit (DEA) to Bill Rowlston (EOH CES)). Specialist reports: When we – EOH CES - were appointed to progress the assessment that was started by Aurecon, we undertook a comprehensive review of all reports prepared during the Scoping phase to determine their continued relevance to the project, We are confident that we did not “introduce old reports that were tainted by false declarations”, and we do not know what the commentator is referring to here. Any of the existing reports that were carried forward into the EIA phase were either of such a nature that the revised scope of the project did not affect the relevance of the report (the Agriculture and Heritage assessments, for instance), or they were amended to reflect the new scope (the Botanical study, for instance). All I&APs who had been registered for the Aurecon project were informed of EOH CES’s appointment as soon as the appointment was finalised. The commentator’s accusation that the consultation has been fraudulent, flawed and unfair is without foundation. With regard to the focus group meeting, Mr & Mrs Van Coppenhagen were asked to provide proof that they were mandated by their neighbours and lodge operators to represent them but no such evidence was provided. Since the Van Coppenhagens responded to the invitation to attend the meeting in Kakamas and the other did not, the necessity for an additional meeting was not evident. Assessment of impacts - mitigation measures: The approach adopted to assessing the impacts of this proposed development on the natural and social environments, and subsequently proposing measures to mitigate – reduce, lessen, moderate or diminish – the severity of impacts to acceptable levels, is explicitly required by the EIA Regulations, and is standard practice for all EIAs. The assertion that “the destruction of the AFNP and the Melkbosrant will be complete no matter what mitigation promises are made” is the commentator’s opinion, and is by no means supported by the evidence presented in the Draft
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No. Issue Raised by Response from CES EIA team or Hydro SA EIA Report and the supporting specialist reports. The extent and significance of the impacts of the project is the commentator’s personal; opinion, to which she is entitled, but it is not supported by the objective evidence presented in the EIA Report. We appreciate the commentator’s declaration of her vested interest (which is stated elsewhere by Mr Van Coppenhagen), and her objections to the project are noted 81. Sir, The "Plan of Study Approval for EIA"; Appendix A ("A"), Draft Environmental Impact Report (DEIR) and Specialist Reports which have been published for comments, have reference;
The applicants knew from the outset that there is a legal requirement to obtain SANParks consent (before submission of the Final EIR as required by NEMA 50(5)) and that the Park Management Plan needs to reflect that the activity is appropriate. There is also the matter of a water license application which has not been launched yet and we are aware of the fact that the applicants have apparently asked for a non-binding agreement from DWS for the other hydro scheme applications, as a "substitute" for a water license. To assume that the diversion of a river, involving a volume of up to 1200 million cubic meters/a (MCM/a), over a distance of 10 km inside a National Park, would not require a compulsory licensing procedure, would be naive. The water use license is needed to assess the long term sustainability of the activity (Theron is talking about an 80 year period). During the recent public meeting the sentence: “we will never dry up the falls” have been used many times, but when one look at the EFR manipulation (15cumec EFR, 91cumec Hydro: 20 May 2015@07h00) of the Neusberg Hydro Scheme it becomes apparent that it will become a certainty virtually from day one.
The assumption that the Park Management Plan and land zoning plan (p 13-15, 52-61, 69-71) can be changed ad hoc, in order to accommodate this project is fatally flawed. The facts will show that the applicants (Hydro SA/hydro Tasmania (HT)) presented their proposal to SANParks on 30 July 2012 and that the public meetings for the revision of the Augrabies Falls National Park Management Plan was held several months
Hannecke van Coppenhagen, Daberas, comment by e-mail, 01 June 2015
Dear Mrs Hannecke van Coppenhagen, Thank you for your second submission dated 01 June 2015 relating to the proposed Hydro SA Riemvasmaak Run-Of-River Hydro Power Station EIA study and draft environmental impact assessment report. I hereby acknowledge receiving your comments on the draft report and will forward it to the environmental impact assessment practitioner. Sincerely, Shawn Johnston
EAP’s response: These comments deal with the following issues:  The commentator’s assertion that permission is required from SANParks to submit the EIA Report to DEA.  The requirement for a water use licence for the project.  The commentator’s assertion that the project will “dry up the falls”.  The commentator’s assertion that the park’s Management Plan cannot be amended to accommodate the project. All of these issues have been addressed in previous responses.
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No. Issue Raised by Response from CES EIA team or Hydro SA later and this Plan was approved by the Minister of Environmental Affairs in September 2013, with the "project area" zoned as a special management area. Thus, to be procedurally correct, the applicants should have presented their proposal during this public consultation period for proper consideration, as far as its acceptance in terms of the Management Plan for 2013- 2023 is concerned, because the previous Management Plan did not make provision for such an activity either. 82. During the recent public meeting mr. Bill Rowlston stated that the applicant is not interested in obtaining this consent from SANParks and that they will submit the Final EIR anyway. The following quotations of N Theron were taken from the minutes of the Riemvasmaak public meeting held on 6 August 2013: "2) NT noted that they met with SANParks and that SANParks did not in principle have a problem with the proposed project if HydroSA could deliver on all their promises. NT also noted that it might not be necessary to rezone, but that it depended on SANParks and whether they came onboard. NT explained that there were individuals within SANParks that were against the project, but that they did not have all the information." It is clear from the above that he is wrong in both cases, since we have NEVER seen any communication from SANParks which should be interpreted as consent for the activities. It does seem as if the DEA is indulging the applicants tardiness and unfair procedures in finalizing this process within a reasonable timeframe, which is unacceptable. Neither have we received minutes of the meetings between DEA and the applicant, which we have been requesting for a long time. Refer to "A". Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 The issue of the applicant requiring permission from SANParks to submit the EIA Report to DEA has been addressed in previous comments. EAP’s response: SANParks has formally expressed its opposition to the project (see comments from Dr Hendricks above), so Mr Theron’s remarks are not at issue. 83. Fragmentation: We have previously referred to the fact that the SANParks land to the north of the river is already fragmented by a service road to Riemvasmaak, resulting in a loss of about 4000 ha and that further fragmentation would be completely intolerable, because that would lead to a loss of 8000 ha in total. Mr. Rowlston referred to the fact (in the public meeting) that fragmentation would be a fatal flaw for the project to proceed, without realising that we have already advanced that Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: The commentator’s assertion that Rowlston said he regarded fragmentation as a fatal flaw is in error. He cannot imagine why he would venture such an opinion, since unpaved roads, unlike fences and open canals, are not insurmountable barriers to faunal movement.
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No. Issue Raised by Response from CES EIA team or Hydro SA proposal previously and that he was actually reinforcing our notion. The new proposals for haul roads 120 meters down into the ravine would convert/fragment the site completely into a true mining development area, which would harm the sense of place irreversibly. 84. Draft Environmental Impact Report The omission of NEM:PAA, its regulations and norms and standards for the management of National Parks, National Water Act and regulations, substitution of the Siyanda EMF 2008 with an unrelated report and SA National Biodiversity Strategy and Action Plan (2005), from the reference material of this report is a grave error. Considering the recent changes in the scope of the proposal and the period of time which has elapsed since the acceptance of the FSR, very little original work of any value has been conducted, to justify the excessive delays. We urge the DEA to revisit it's repeated decisions to allow more time for the finalization of the EIR due to a hiatus in activity of almost 9 months, from April 2014 until the appointment of new Geotechnical, Fauna and Aquatic specialists in 2015.(see facilitator doc 9 dated 27/8/2013 which refers to above docs) We reserve the right to forward more comments in due time, to reinforce our objection to DEA's indulgence of the applicant's to failure to submit the DEIR on time, since it is related to the administrative and procedural fairness of the application. The DEIR refers to the Namakwa District Biodiversity Sector Plan (2008) on p 25 (as introduced by the fauna specialist?) and elaborates on it over several pages. It is true that the impacts on the riverine ecology in that district is related to mining (destruction) which is virtually irreparable. However, the correct document for the Augrabies area is the Siyanda Environmental Management Framework Report 2008 (EMF), which deals very specifically with the remaining floodplains and riparian habitat. This was brought to the attention of the consultants and your reluctance to use this valid and material information, should be viewed as a fatal flaw. (Facilitator doc 13 dated 26 May 2014) DEIR 2.2.5 States that the study area should be an NPAES area and not a protected area, which is misleading and “Refer to 2.6 for explanation”, but it is not forthcoming in that section. Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: NEM: PAA & Regulations: We are aware of the requirements of the NEM: PAA and its Regulations. We are also aware that there are no absolute legal prohibition of activities such as those contemplated in respect of this project, but that it is necessary to obtain permission from the management authority – in this case SANParks - before the project may be implemented. However, we are of the opinion that this project can be developed and operated with minimal effects on the nature of the park and its surroundings, and with minimal effect on the Augrabies Falls, or the Orange River as a whole, as a tourist attraction. We also believe that the project is necessary to contribute to resolving South Africa’s ongoing electricity shortages. Namakwa DM: The references to the Namakwa DM are addressed in the response to Comment 80, also submitted by this commentator, Procedural unfairness: The commentator is advised to address allegations of procedural unfairness, etc, on DEA’s part to the department. Flow sharing: Rowlston has no recollection of discussing “flow sharing” during the public meeting in Kakamas, and does not understand what the commentator think it means in the context of this project.
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No. Issue Raised by Response from CES EIA team or Hydro SA The EAP is clearly on the wrong path with this line of thought and it should be considered as a fatal flaw. 3.3 Diversion Weir During the public meeting mr. Bill Rowlston stated that the concept of "flow sharing has been accepted" (also by the SANParks?). This is categorically wrong, since SANParks are legally obliged to participate in the outcome of any activity, even in its buffer zones, which could directly influence the water flow regime into or through a National Park. 85. "Norms and Standards for the Management of Protected Areas in South Africa" (Notice 528 of 2014) have been published and serve as guidelines for securing National Parks and its buffer zones: Page 10 and 11 elaborates "6. The protected area secured in terms of legislation. 6.1(b) Standard There are applicable legal mechanisms in place to control inappropriate activities" This standard confirms that management cannot be discretionary, i.e. it is a tool for the rejection of inappropriate activities, which could threaten the legal status of the National Park. On page 13, 14 & 15 "9. Planning outside the boundary to secure Protected Area Purpose The purpose for this norm and its standards is to promote and ensure the positive involvement of the protected area management in planning outside the protected area which may affect its integrity. ............ 9.1(c) Standard Water-use planning outside takes into account the objectives of the protected area. Indicators Management authorities play an active role in water use planning affecting the protected area. The water-use planning takes cognisance of the protected area and the achievement of protected area management objectives." From the above standard it would become clear that a water license application, to divert the water away from a river (or Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: NEM: PAA et al: As we have stated previously, we are aware of the regulatory instruments cited by the commentator, and we do not dispute it. We do, however, point out that there is no absolute prohibition on development of infrastructure in a national park, provided agreement can be reached with the management authority. WULA: The question of the necessity for a water use licence has been addressed in previous comments, and at the time of writing this response (August 2015) the commentator has been informed that DWS has issued a non-binding letter to the applicant confirming that water is available for the project. ORASECOM EWR Assessments: A new section has been added to the EIA Report - 3.3.2 Previous environmental water requirements recommendations – in which the EWR recommendations in three previous ORASECOM studies were analysed. Of the three the 2010 study edited by Louw & Koekemoer was the most comprehensive and science-based assessment of the reach of the Orange River between Boegoeberg and Augrabies. It recommended a Maintenance flow regime for PES Category C in which monthly flow rates varied seasonally between 18.9 and 41.7 m3/sec, with a total annual volume of flow of 886 Mm3. “High” flows added another 493 Mm3, bringing the total annual volume of flow to1 379 Mm3. The achievement of this flow regime ( as well as a desired regime to achieve ES of Category B, with much higher rates of flow and a much higher annual volume of flow of 2 341 Mm3) will depend almost entirely on the way in which upstream releases and abstractions are managed by DWS. The section concludes that
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No. Issue Raised by Response from CES EIA team or Hydro SA water fall) inside a National Park must be rejected. DEIR continues with a quotation from Orasecom documents (2) that the EFR is 900 MCM/a which is incorrect. The correct document to quote is: Louw MD and S Koekemoer (editors); Volume 1: Environmental Flow Requirements Produced for WRP as part of Support to Phase II ORASECOM Basin Wide Integrated Water Resources Management Plan" 2010, which indicates on p (ix) that the long term mean EFR for the Present Ecological Status C, is 1251 MCM/a, which is a minimum figure and which should be expressed as periodic low and high flows, more or less in line with the current flow regimes, not even as a constant value of 40 cumec. Thus, your figure of 900 MCM /a or 30cumec for the EFR is unrealistic, unscientific and a FATAL FLAW. there is no conflict between the ORASECOM recommendations outlined above (and described in considerably more detail in the new section 3.2.2 in the EIA Report) and the establishment of 30m3/sec as the flow rate at which diversion will commence, and below which no diversion will be permitted 86. Accepting this 900 MCM/a as the long term mean EFR would immediately place this section of the river in a lower ecological status, which would further decline once the diversions from Lesotho Highlands Water Scheme (LHWS) phase II to the Vaal Catchment are increased by an additional by 660 MCM/a from around 2020. Calculations from the optimistic flow duration curves in Fig. 3.17 provide a yield of around 202 GWh/a, not 235 GWh/a as stated elsewhere and which indicates a power factor of .57 (about 680MCM diverted) which is already a low yield and based on the WRONG EFR. Doing a type of haircut on your calculations would indicate a load factor below .40 which is approaching the original Basic Assessment Report scenario. SANParks did question the justification for this increase from 20MW to 40MW. On the other hand, a relatively crude but effective calculation would prove that the planned diversion for the .57 load factor (680 MCM) would be reduced to virtually NIL/ZERO when the 660 MCM of LHWS phase II is deducted. AND this is if we do actually use your incorrect (low) EFR assumption. If one use your 235 GWh/a the diverted quantity would exceed 800 MCM...........? Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: EWR: The environmental flow requirements of the river are addressed in the response to the previous comment. Flow duration curve – availability of water: The availability of water for the project was derived from analysis of 20 years of recorded data (daily average flow between 1994 and 2014) from DWS’s hydrological gauging weir at Neusberg Weir (D7H014), some 47km upstream from the proposed diversion weir. On DWS’s advice a constant 3m3/sec was deducted from the flow rates recorded at the gauging station to allow for abstraction for irrigation between Neusberg and the diversion weir site. The energy model used in the analysis considers that the project does not operate until river flow is equal to 30m3/sec, and is shut down when flows exceed 800m³/s, when high sediment loads are anticipated. We have no reason to doubt the validity of the estimates of power that can be generated by the project. In addition, we cannot imagine why the commentator imagines that then applicant would contemplate making a substantial investment in a project that was based on flawed data and erroneous calculations. 87. 4 Need and desirability This project is inappropriate and undesirable for a National Park We have previously made detailed comments in this regard and the facilitator has received copies of some of our Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: We note your objections to the project in this regard.
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No. Issue Raised by Response from CES EIA team or Hydro SA correspondence. 88. 5.1 Fundamental Alternatives: The following statement on p 85 refers; "Thus there are no other viable alternatives capable of being bid in South Africa".... and in 5.1.2 ....."Hydro SA has does not develop solar or wind energy projects and has no expertise or interest in doing so." The fact is that Mr. Theron (the applicant) doesn't have expertise in hydro electric schemes either, as his CV stated when HydroSA was part of Mulilo Energy Group, which was the case when this application was launched. Thus, another subsidiary of the group would have been able to propose/develop any one of the other types of RE scheme in Riemvasmaak, at the time. This confirm the facts regarding the overriding importance of job creation for Hydro Tasmania/ENTURA(his principals). As far as the contribution of hydro power to the energy mix, is concerned, it must be noted that the Kobong HPP would contribute 1000-1200 MW after completion of LHWS phase II. The INGULA HPP currently under construction, would also yield 1332 MW, peak demand power. It would be quite irrational to expect that many run of river/diversion hydro schemes could be erected in a country with low rainfall (below world average) and overallocated "hard working" rivers. (Facilitator doc 12 & 15) This section creates the impression that only diversion/run-ofriver hydro schemes can be classified as small hydro in the various RE generation scenarios, which is not true. It would be more correct if they state: Thus there are no other viable RUNOF-RIVER/DIVERSION HYDRO SCHEMES capable of being bid in South Africa..... except that mr. Theron has mentioned at some stage that they did "withdraw" from another potential site in the Tugela river, supposedly because DWS would not issue water license for a guaranteed volume. Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: We note the commentator’s opinion of Mt Theron and Entura, and also the information she has provided concerning the generating capacity of other hydroelectric schemes that are not related to the project under discussion. 89. SPECIALIST REPORTS 6.1 Agricultural Report. The specialist fails to use the recommendations of the SIYANDA EMF 2008, when doing this assessment, which renders it useless and it must be rejected in its entirety. Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: It is not possible to address this comment without knowing what specific recommendations from the EMF regarding agriculture the commentator is referring to. We do not find anything in the specialist report that is inimical to the EMF statements and recommendations. 90. 6.2 Aquatic Ecology Report. This "new" report fails to take note of the original BAR report's Hannecke van Coppenhagen, EAP’s response: Gas bubble disease: We are aware of Gas Bubble Disease, its
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No. Issue Raised by Response from CES EIA team or Hydro SA concern regarding the potential physical impact of super saturated water (which cause Gas Bubble Syndrome, "the bends", which is a physical effect) which would affect aquatic life detrimentally in the re-activated channel. Neither does it make provision for the mitigation of that effect, by suggesting the blending of the tailrace water in this channel, with fresh water, which should be a portion of the diverted water. Super saturation(with oxygen and nitrogen) of the water could easily occur under confined pressure and intimate mixing conditions, as was suggested by the original report.
This report does not deal with the excessive sediment load/turbidity of the Orange river which is the highest in Africa and 4th highest in the world (PDF: A tenfold increase in the Orange River mean Holocene mud flux: implications for soil erosion in South Africa, Compton et al) and its impact on the dispatchability of a HPP because, during the higher flow events sediment removal by flushing is being practised. Take the example of Boegoeberg which is permanently inundated with silt and where the sluice gates are permanently open to prevent silt intrusion into the irrigation canals. This silt will cause premature failure of the turbines of a HPP. In the Lower Orange river, localised flash floods could deposit thousands of tons of sand/silt into the river within one to two hours, (due to tributary gradients) which would have the same effect. A remote operator would not even be aware of the fact before it is too late.
This report also use 30 cumec as the EFR, which is an unscientific method because the EFR should have seasonal variations as it is currently regulated by DWS. Thus it should be clear that the EFR cannot be expressed as a fixed "magic" number beyond which water could be diverted away from the water fall. This report does not justify the assumption of 30 cumec for the EFR and this number must be rejected. The correct EFR is discussed in detail, above. Neither does it refer to NEM:PAA and it regulations and the Siyanda EMF 2008, regarding disturbance of water courses in National Parks and water licenses affecting the same.(Facilitator doc 2, 4 &13) Table 9 refers to Arsenic (As) as if it originates from an
Daberas, comment by e-mail, 09 June 2015
causes, and its potential impacts on aquatic life, especially fish. The typical occurrence of high total dissolved gas (TDG) occurs in very large, high-discharge dam spillways that plunge into receiving waters below. The very high pressure of the plunging water forces gases to dissolve in the receiving waters at supersaturated concentrations, and this has been known to result in fish kills. This is not such a project. The discharge from the turbines is relatively low, and will travel along a free-surface-flow tunnel to discharge into the receiving stream via a relatively gently-sloping spillway equipped with energy dissipators.
Sediment: The diversion of flow into the HPP will cease at a river flow of around 800 m3/sec, when it is anticipated that sediment concentrations could be sufficiently high to be carried through the headrace and into the headpond. If sediment proves to be a problem it will be possible to trap the sediment before it reaches the penstock by making modifications to the head pond design.
EWR: The environmental flow regime of the river is addressed the response to comment 85, and the commentator is referred to new section 3.3.2 in the EIA Report. It should be noted that a constant flow of 30m3/sec is not the entire environmental flow regime of the river, as the commentator appears to believe, but is the lowest flow recommended by DWS over the Augrabies Falls (provided that upstream releases and abstractions permit such a flow rate), and is a flow rate that will not be violated by diversions into the project.
Arsenic: The commentator’s remarks about the sources of arsenic in the river are noted.
Surplus excavated material: We aware that the area proposed for the disposal of surplus excavated material until it can be removed for off-site use is part of the buffer zone that SANParks would like to establish around the park, but we disagree that it is a wetland area that will be desiccated and fragmented by diversion of water into the power station.
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No. Issue Raised by Response from CES EIA team or Hydro SA agrochemical pesticide. This is not correct, but the source should rather be geological conditions; originating locally as an erosion product of the Kinzigite/metapelite which contain arsenopyrite ores. This is simply stated to ensure that the impression isn't created that the local agricultural produce is contaminated by arsenic spraying.
The map above displays the unaffected reach of the Orange river in the (boxed) eastern section and the portion located inside the AFNP. This explains why SANParks listed in the adjacent property in its buffer zone, (target area for 55ha dump and overhead power line) as set out in the current Management Plan, in order to protect a larger portion of this endangered and sensitive ecosystem. This is a wetland area which will be fragmented and destroyed (dry and desiccated due to lack of water) due to a diversion of the river. The map does also show that more than 50% of the riparian habitat along the river (white strip south of river) doesn't form part of the National Park. This activity would reduce the unaffected and protected portion of the riparian habitat inside the AFNP substantially and it would make the continued existence of the Park as a Protected Area senseless, if the activities are approved. 91. 6.3 Vegetation and Botanical Report. We have contacted the specialist in order to ascertain whether his study (for Aurecon) of April 2014 considered the impact of the proposed haul roads 120 m down into the ravine, which is a recent development, but could not receive a reply except for a request stating (in an e-mail) that there was some kind of protocol which prevents him from doing so, even though he was not contracted to EOH CES. This should be interpreted as NO, that development was not considered, which leaves more or less the same document as for the BAR. It does deal with the adjacent property regarding the 55ha spoil heap, but because he did not consult the AFNP Management Plan, his opinion doesn't recognise that it falls inside the buffer zone of the Park and that it would be undesirable as a waste disposal area. The boundary of this property is part of the wetland shown in the NFEPA map elsewhere in this document.
Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015
EAP’s response: Botanical study: The botanical study conducted in 2014 for Aurecon was updated in April 2015, and is therefore relevant to the current 40MW project. The specialist has confirmed in correspondence with EOH CES that the study has considered the impacts on the vegetation along the two potential routes of the haul roads, since there is nothing to suggest that the vegetation of these areas differs appreciably from the vegetation in the area of the headpond and the power station headworks. The specialist is aware that the proposed location for storage of surplus excavated material is in the buffer zone that SANParks would like to establish around the park, but this does not affect the nature of the vegetation in this area, not the fact that the piece of land in question is in private ownership. The specialist is explicit in acknowledging the conservation status of the riparian vegetation, and has assessed the impacts of the project on these areas as Low.
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No. Issue Raised by Response from CES EIA team or Hydro SA This report does not consider the NEM:PAA and its regulations, or the National Biodiversity Strategy and Action Plan 2005, nor the Siyanda EMF 2008 which deals very specifically with the remaining floodplain area and riparian habitat. (Facilitator doc 1, 6, 9& 13)
6.4 Faunal Report. The Terms of Reference (ToR) on which this report is based is just wrong. Branch introduced the Namakwa District Biodiversity Sector Plan 2008, the concept that biomes and fauna should be endangered to justify protection in a National Park, the concept of the secondary channel being a paleochannel, the notion that the tail race outlet (with its super saturated water) will have a positive impact on aquatic life, which is clearly NOT the probable scenario, which makes it incoherent and of no value for consideration of the proposed activities.
This report does not consult NEM:PAA and it regulations in order to establish the legitimacy of the conversion of the protected landscape and disturbance to fauna which is technically captive in a relatively small area which would become fully fragmented by the proposed activities, nor does it refer to the Siyanda EMF 2008, to establish whether the proposed activity would be desirable, even outside of a protected area. (Facilitator doc 6, 9 &13)
Faunal study: The specialist’s reference to the Namakwa BSP has been addressed in the response to Comment 80, from the same commentator. The specialist is aware that the requirements of the NEM: PAA and its regulations, but these do not alter the kinds of animals that will be found in the area, or his assessment of the potential impacts of the project on them.
92. 6.5 Seismic Study and Geotechnical Report. The seismic study is very relevant for us as inhabitants of the area and we have forwarded detailed information to the EAP i.r.o. other earthquake focussing mechanisms (volcanic alkaline lineament, Kalahari seismic axis and various hot springs) which does exist in our area, for the specialist's consideration, but again with no result.(facilitator doc14) The new methodology which is now being considered, to excavate and shift the several hundred thousand tons of rock from the base of the ravine to ground level 120 meters above, together with the construction of haul roads and a crusher, are the equivalent of a major mining operation inside a National Park and it would be absolute madness to allow it. The number of measures which would be needed to render the site
Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015
EAP’s response: Mining: The proposed underground excavations (for the penstock, ventilation and access shafts, power chamber and tailrace tunnel) do not fall under the definition of mining, since its primary purpose is not the sustainable development of the nation’s mineral resources. If it proves possible for some of the surplus excavated material to be used offsite, any statutorilyrequired permits and authorisations will be sought from the relevant regulatory authorities.
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No. Issue Raised by Response from CES EIA team or Hydro SA safe for the contemplated "mining activity" and continued existence of infrastructure like the "haul road"etc., would make it look like a christmas tree. The mining of about 1 000 000 tons of rock in total, some of which will be crushed on site for use, should be subject to a "mining and waste management license", because that is what the activity entails; producing aggregate for construction purposes. 93. 6.6 Heritage Impact Assessment. This report dates from 2012 but it states correctly under 3.4 Limitations "ACO was requested at very short notice.....and this unfortunately precluded proper preparation for the fieldwork...."(p8) This is followed up by the ASSUMPTION 7.3 (p37) : "The cultural landscape here is not deemed highly significant for two reasons. One is that it is not very old and the other is THAT THE COMMUNITY THAT CREATED IT HAS GIVEN ITS PERMISSION FOR THE PROPOSED PROJECT TO GO AHEAD. This ASSUMPTION was FALSE, because the community had not even been consulted at the time. 7.2 (p37) Graves "........., there are a large number of features on the landscape which may be graves. ....The Riemvasmaak community members need to be made aware of this issue and should be requested to issue a statement indicating their wishes for the deceased should any such features turn out to be graves". Because the alignment cannot be changed at that stage. None of the NEW alignments, ie ravine haul roads or proposed dump could have been investigated. The conclusion of the specialist must be weighed against the wrong information (ToR) from the applicant, that the community has already approved the project in 2012 regardless of the impact on their heritage. This specialist certified that a public participation process (bullet 8) has been followed, weeks before the public participation was announced in 2012. The popular booklet "Augrabies Splendour/Weelde" (P vd Walt) describes the historical background to the establishment of the AFNP and the cultural and heritage value of the Falls Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: Legality of agreement: Since the commentator wrote her comment a lease agreement has been signed by the RVM Community Development Trust and RVM Hydro 1 (see EIA Report section 2.6.1). This does not in any way alter the applicant’s obligation to adhere to the mitigation measures proposed by the heritage specialist, and included in the EMPr. With regard to graves these measures include ceasing work on discovery of what may be a grave, verification by a qualified specialist, followed by statutorilyrequired measures to remove and relocate human remains should the discovery prove to be a gravesite. The mitigation measures also address non-grave cultural heritage sites and artefacts.
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No. Issue Raised by Response from CES EIA team or Hydro SA and Riemvasmaak in a colourful and sensitive language and should be compulsory reading for anyone interested in the area. The displacement of the "Riemvasmakers" in the 1970's was wrong, but it was corrected with the return of their land with the first land claim under the new dispensation. However, government recognised the cultural significance and sense of place of Melkbosrant and directed that it should only be used for conservation purposes. The cultural heritage of the area (sense of place, cultural artefacts and graves) will be irreversibly harmed by this proposal, and should be rejected! Regulation 1061 states; Prohibitions 4. (1) No person shall, other than in an open access protected area, in a special nature reserve, national park or world heritage site, without the prior written consent of a management authority, license, permit or receipt (i) significantly alter or change the sense of place or any environmental, cultural or spiritual values; 94. 6.7 Baseline Noise Assessment. Screening Noise Report: states in section 2.2 :"The Environment Conservation Act", .... which is clearly not applicable in this case, since the relevant act is actually NEM:PAA 2003 and Regulation 1061 as published in GG 28181 of 28 October 2005 and it is applicable in all the National Parks (in 2.5 it is stated that no noise control regulations exist for the Northern Cape) R 1061 states "22. Other activities; No person shall, without the written permission of a management authority a) use or cause to be used, any loud speaker or similar device or noisy equipment ......" Further on the specialist states: * "This assessment however could not identify receptors living within 2,000 meters from the proposed development (excluding the powerline). .... " see reg 43 (m) below which would specify what should be identified as "receptors". "43. General Prohibitions: No person shall in a special nature reserve, national park or world heritage site -(m) ....... in any way whatsoever cause any noise in a manner that is likely to disturb any species or Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: NEM: PAA et al: The issue of NEM: PAA and its regulations has been raised before by the commentator. We are aware of these instruments, but they do not affect the ways in which the impacts of the project are assessed. Because of the nature of the projectaffected environment the act and its regulations do influence the severity of the impacts and the mitigation measures to address the impacts. This is reflected throughout the EIA Report. We recommend that the commentator re-reads section 2.2 of the report, as well as section 2.5, to gain an understanding of the relevance of the ECA in the specific context of noise regulations. When EOH CES was appointed to complete the EIA process started by Aurecon all specialist studies undertaken thus far were carefully studied to determine their continued relevance or otherwise to the 40MW project. The noise study was found to be still relevant. Alleged fraud / damnation: We are not able to comment on the commentators’ allegations of fraud, nor on their assertion that they will be damned, since we are not able to find any statement by the specialist in his report that a public consultation process had been conducted prior to a public consultation process being conducted.
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No. Issue Raised by Response from CES EIA team or Hydro SA specimen or other person," * Thus, the statement above, from the executive summary (p iii) of the above report, shows that the terms of reference (ToR) are incorrect and this report must be rejected in its entirety! This report was published with the launch of the application in 2012 and the declaration by the specialist (bullet 8) states that a public participation process have been followed and that comments were considered, weeks before the public participation process was launched. This same report is now presented with a new declaration. If this does not constitute fraud, we'll be damned. 95. 6.8 Socio-economic Assessment revision 4 and DEIR 2.4 The Socio-economic environment The DEIR 6.8.3 (p98) states: ".... No concern has been raised regarding damage to existing graves, historical artefacts or areas of cultural significance to the Riemvasmaak Community." This statement proves that the concerns uttered during public meetings have not been considered and it is a red flag, eg. Riemvasmaak public meeting 6 August 2013: "4) Samango noted that some people were against the project at the last meeting and wanted to know if the community has given permission for the proposed project or if the meeting was an opportunity for the community to give permission. Samango also wanted to know if HydroSA had a financial plan and what the plan says in terms of job opportunities and ownership/ shareholding.........NT noted that this was a long process and that the numbers would be communicated to the community before any contracts were signed." This section of the document describes the need for social upliftment of the local communities, which is common/general knowledge. We have forwarded details of other types of renewable energy projects which would be of greater financial and continued employment benefit to the community and which can be achieved with skills training on the job and which does not have to be installed inside the National Park section, which is of great cultural significance to the community. Another factor which should be considered for the need of this specific project, is that one of the applicants; (Hydro Tasmania/Entura) had a century long era of building hydro Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 I EAP’s response: Meetings prior to our appointment: It is not possible for us to respond in an informed manner on the commentator’s observations on events that took place before we were appointed as environmental practitioner in the latter part of 2014. This is particularly so in respect of statements allegedly made by participants in meetings at which we were not present and in which we had no part. Accordingly we will not attempt to respond to the commentator’s comments relating to the various meetings held between the applicant and the RVM community. Entura: Similarly we will not respond to the commentator’s allegations concerning Entura’s motives for involving itself in the project (which were also raised at length in the commentator’s previous set of comments), nor will we comment on the estimates of the capital cost of the project. Lease agreement: We are able to confirm that a lease agreement has been signed between the RVM Community Development Trust and RVM Hydro 1 (see EIA Report section 2.6.1), and this indicates that the community are not averse to the project. Employment: The anticipated employment opportunities from the project are set out in section 4.3.2 of the EIA Report Project financing: There is no requirement in the funding arrangements for the Riemvasmaak Community Development Trust to contribute to the capital cost of the project, nor to provide funds if the project runs at a loss. This is explained in more detail in section 4.3.2 - Benefits to local communities – of the EIA
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No. Issue Raised by Response from CES EIA team or Hydro SA schemes, which are now complete and a "project" workforce of more than 300 (until recently), most of which are now redundant. It is a matter of record that Hydro Tasmania has a high debt ratio and have entered into speculative wind farm transactions which could lead to losses of about R 1000 million rand in five years. The cold fact is that this relentless drive to specifically build a hydro scheme inside the Augrabies Falls National Park, is to create continued employment for HT/Entura and the social needs of the community is a convenient shield behind which to hide the true motivation for the application. This pressing need is confirmed in a transcription of their Tasman Government Business Scrutiny Committee meeting (3 Dec 2013) and we suggest that in this case, the "social" motivations which are presented should be regarded with suspicion and should be rejected. We have submitted detailed comments to the AURECON in this regard, which have vanished from the record. (Facilitator doc 5, 8 & 12) In doc 8 we deal with the initial DENIAL that HT was involved with the application at all. 8.2.2.1 This paragraph from the specialist report, serves to confirm that the Riemvasmakers and other local inhabitants will not benefit from employment as is suggested elsewhere in documents. The contradiction in in order to remedy this specialist statement (DEIR p99 section 6.8.3) is quite extensive . The Riemvasmaak community will not accept that they may lose Melkbosrant if this project fails, because it would serve as security for the construction loan. Riemvasmaak public meeting 6 Aug 2013: "2) NT explained that the project is the bank’s security.(who lends the money) With regards to shareholding NT noted that at the moment HydroSA is looking at giving RVM 12 – 15% shareholding in the project." Which makes them a partner/shareholder in the project! Not an IAP. .....Could SANParks allow government land to be bonded against a loan for an unrelated activity and who would sign off on this perpetual security ?What type of guarantees would be provided by the applicant as security against default, which includes faulty design. The high construction cost with exceptional escalation (300 Report, which has been expanded to include an explanation of the concept of Non-Recourse Financing.
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No. Issue Raised by Response from CES EIA team or Hydro SA million ZAR, 600 million ZAR, 700-1000million ZAR, currently 1300 million ZAR, what next?)of the project is not considered (by the specialist) and its affordability to the community should be investigated as a legal requirement. Riemvasmaak is actually going to finance up to 15% of the project (as shareholders who must borrow the money) according to Theron. He is even lying about the lifespan of other RE technologies in order to encourage support for his own project. An alternative RE project will be much more affordable and profitable to the community. (He actually confirmed that a PV RE project will be paid off sooner than a hydro project. Theron states that the average flow of the Orange river is 150-200 cumec for (9 months of the year), which would satisfy most listeners concern regarding the availability of water to operate the HPP. HOWEVER, THIS IS NOT TRUE. He also stated that the project design takes a 1 in 1000 year flood into consideration, which is nonsense. His deceit is further illustrated with some quotes from the public meetings below: Extracts from Marchand Public meeting, 22 August 2013. 7. BK asked what the impacts on the natural environment would be as the area, especially Augrabies Falls National Park (AFNP), is a tourism destination. He wanted to know if any structures would be visible from the AFNP. NT noted that everything would be buried and only the switchyard would be constructed above ground at the powerhouse. NB notedthat a visual specialist has been appointed to assess the potential visual impact that the proposed project could have." "BK wanted to know if the proposed power station would be able to operate during very low flows and during floods. NT explained that the proposed project would use a maximum of 37 m3/s. He explained that the Orange River’s average flow is between 150 – 200 m3/s. NT noted that the low flow period is usually between June, July and August with approximately 30 m3/s of water flowing over the falls. He explained that the proposed project would only take water once 30 m3/s have been let through. NT further noted that the power station would be designed to withstand a 1: 1 000 year flood. He noted that the 1988 flood was not a 1: 1 000 year flood. NT explained that there would be three turbines and that turbines would
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No. Issue Raised by Response from CES EIA team or Hydro SA operate independently. He noted that the design is such that it could operate during low flows and would be shut down during really high flows." A major flood would cause extensive damage to the buried pipeline and cables and the roads and headpond will wash away. The cost of this proposal has escalated from R300 million to R 1300 million, with the addition of 20 MW turbines, because the other elements of the PROJECT are dimensionally the same as for the "original" 2x10 MW plants.(we have identified this flaw right from the start, which is why they changed the project design, in order to "escape" from their numerous errors). This massive construction cost escalation should be considered against the very low price which HT seems to be spending for its share, as is evidenced by our previous communications to the EAP. Vredesvallei 6 Aug 2013 2)NT explained that solar panels have a 20 year lifespan with the panels being paid off in the early years and then the panels have to be replaced. NT went on to explain that this means that you have to pay for new panels if you want to extend the lifespan for another 20 years. NT noted that it is almost the same for wind, but with hydropower you install the machinery once and it operates for 50 to 100 years As a closing argument we want to quote from the public meeting held in Vredesvallei 6 Aug 2013, where Malcolm Green (a lawyer) of Hydro Tasmania makes the following extremely exaggerated statement: MG explained that Hydro Tasmania has a young engineers program that takes in approximately 50 students each year and that they are planning to start something similar at RVM. MG also added that the current 50 students had been tasked with fundraising money that could be contributed to schools in the area and that this could hopefully be done while the process was still on-going. We have attempted to find details of this number, but now believe that it would be substantially less, maybe not even 10 per annum. The HT Government Business Scrutiny Committee Meeting for 2011 mentions 11 apprentices and although there would be a number of young engineers, the number was not
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No. Issue Raised by Response from CES EIA team or Hydro SA considered worth mentioning. 96. Tourism The assessment is clearly not attempting to address the very real risk to the tourism sector, because it is not part of the ToR and none of the tourism establishments in the area have actually been consulted about the potential impact on its operations and the number of jobs which could be at stake. Mr G Visser has also made the point during the recent public meeting, that many tourists who are visiting the National Park, do actually stay over at private establishments (like Riemvasmaak, Plato Lodge, etc.) in the area and any reduction in tourist numbers would be impacting on those operations, which is not considered in this assessment and which would drastically impact on employment in that sector, which is the third largest in South Africa. The number of jobs which could be lost permanently if tourism is affected would run into hundreds and it would also discourage further voluntary participation in the extension of the National Park to the west, which is a stated goal of the Park Management Plan. We have indicated to the project team (during public meeting) that there are people without any services, which should also receive consideration, not only from a RE project social responsibility perspective, but also by the municipal service providers. Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: Tourism: The risks to and impact on the tourism sector were assessed in the specialist report, in which it was observed that the national park was one of a number of tourist attractions in the area, and that any project-related impact would be felt most strongly by the park itself. The implication is that the health of the private tourism sector of the area is not exclusively linked to the national park Nevertheless, we recommend that the commentator should read Chapter 9 of the report (Tourism), and those parts of Chapter 10 (Impact Assessment and Mitigation) carefully before arriving at the conclusion about the potential impacts of the project on the private tourism sector in the general area. 97. The executive summary contains several incorrect statements; "Long term hydrological records indicate that sufficient water will be available in the Orange River to generate base load electricity for 80% of the time." This is a fatal flaw in the application which we have dealt with in detail above. The applicant has refused since early 2013 to provide us with a long term water balance determination, which is crucial and mandatory for a water license which would allow the diversion of 3,2 million cubic meters(MCM)/day or 1 200 MCM/a, away from the National Park. Mr. Theron has indicated (in media) that Kakamas will never experience load shedding again, because the Neusberg Project provides base load electricity, which is nonsense. Base load electricity is calculated on theoretical maximum demand for a large area/country and to make a broad statement that a tiny electric power plant (of whichever type), does provide Hannecke van Coppenhagen, Daberas, comment by e-mail, 09 June 2015 EAP’s response: Availability of water: The question of the availability of water in the river for the project and the need for a :”water balance” for the Orange River catchment are addressed in the response to Comment 80, submitted by the same commentator. The availability of water for the project has been confirmed by DWS, and we recommend that the commentator contact this department for details of the calculations that led to this conclusion. Benefits of power generated: The impacts of the power generated by the project are described in the response to Comment 43 above. These remarks have been included in the EIA Report in section 4.2.6. SANParks, RVM Community Development Trust and RVM Hydro 1: The relationship between the alleged management agreement between SANParks and the RVM Community
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No. Issue Raised by Response from CES EIA team or Hydro SA base load electricity for "X" thousand homes (based on average annual consumption) shows a complete lack of understanding of the subject matter and creates the wrong perception. He has also been proved wrong, since Kakamas experienced load shedding on the day of the public meeting. Land Ownership and Rights. The applicant's attempt to enter into a contract with a party where an existing relationship exists creates a conflict of interest and might be illegal. References to the National Parks Act, 57 of 1976 is outdated. The correct reference would be NEM:PAA 2003, Schedule 2 as in GN 236 of 2013, etc. The notion that only a temporary departure from the current zoning is required is most ridiculous because the activities are not even envisaged in the Siyanda EMF of 2008, which states that the riverine floodplains and riparian habitat cannot be developed (regardless of ownership). We hope that the department has any interest in finalising this application soon. The first step would be to instruct the applicants to provide a letter of consent from SANParks considering the consultant’s comment during the public meeting and a water balance determination which takes known future uses/allocations and transfers into account. The visual specialist states on p(i) that the applicant has obtained legal opinion indicating that the AFNP Management Plan may be revised. This is highly irregular and definitely not within the scope/rules of administrative procedures. We suggest that the department close this application to allow the legal process which the applicant intends to follow to run its course and that DWS should not accept a WULA, until the intentions are clear. We are also very concerned that these applicants, who are also operating the Kakamas Hydro Electric Project are operating it outside the EFR parameters which are set for the Augrabies area. We suggest that this application should now be closed as allowed for in the regulations, since the site alternatives being Neusberg and Boegoeberg, which have been identified during the Public Participation Process, has been granted environmental approval by the DEA. Development Trust and the actual lease agreement between RVM Hydro 1 and the RVM Community Development Trust is discussed in the Legal Opinion on land ownership and management, summarised in section 2.6.1. of the EIA Report, with the full text included as Appendix G-1. The question of temporary rezoning to facilitate the implementation of the project will be addressed with the appropriate regulatory authorities if and when the need arises. The final two paragraphs of the comment are recommendations as to how DEA and DWS should proceed with this application (close the application for environmental authorisation, refuse to accept the water use licence application, and so on), which we will leave to the departments to decide. Kobus and Hannecke van Coppenhagen – Daberas (Water Use Licensse Application Comments) 98. Sir, Kobus and Hannecke EAP’s response:
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No. Issue Raised by Response from CES EIA team or Hydro SA The letter of Edwin Jenkins of MBB Consulting Engineers (Pmb), dated 14 May 2015, refers; For the sake of clarity, we are stating that we are an Affected Party in the application of RVM 1 Hydro Electric Power (Pty) Ltd, for the erection of a hydro electric power station and the diversion of 38 cumec away from the Augrabies Falls (1 200 million cubic meters/annum) within a riverine floodplain wetland (NFEPA Map) inside the Augrabies Falls National Park(AFNP) and its associated buffer zones, as laid out in the AFNP Management Plan (2013-2023), which maps out the actual zoning plan and which was properly constituted (in terms of section 39 and 41 of NEM:PAA, Act 57 of 2003) and approved by the Minister of Environmental Affairs in Sept 2013. The voluntary incorporation of our land into the AFNP, on a long term (99 years) contract is dealt with on p 20 of same and has been ongoing since 2008. We hope that all the parties understand that this establishes a legitimate basis for our participation in all the procedures and processes related to the proposed activities and its short and long term impacts on the objectives and viability of the conservation effort of the National Park. Firstly, we do suggest that it is procedurally incorrect for the applicant to request a non-binding letter which should state that there is sufficient water in the resource for this activity to proceed with a competitive bidding process in the REIPPP round 5 and that it would be an administrative error of DWS to grant or issue such a letter. There is no documentary proof in the application to suggest that the quantity of water applied for (1 200 million cubic meters/a MCM/a) is actually available. Also, since it is not a schedule 1 water use and the applicants want to register a servitude on the property, which is legally managed by SANParks, it must be noted that its permission is required according to NEM:PAA 50(5), GN 528 and R1061. This documentary proof is not provided anywhere and since Niel Theron and Hydro Tasmania consider this as an eighty to one hundred year activity(media reports), the precautionary principle should be applied strictly and the application returned to the applicants. Thus, we do object to the granting of this request in the strongest terms possible, especially since the DEA has previously warned the applicants that the proposed van Coppenhagen, Daberas, comment by e-mail, 09 June 2015, comment sent to AB Abrahams DWS, Danie Smit, Howard Hendricks and Shawn Johnston This is a request for DWS to refuse the water use licence application (WULA) submitted by MBB Consulting engineers to DWS on behalf of the applicant. Since DWS has already issued a non-binding letter to the applicant, confirming water availability for the project we do not intend to respond to the commentator’s remarks.
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No. Issue Raised by Response from CES EIA team or Hydro SA activities are inappropriate for a National Park. Neither do the applicants (Hydro SA and Hydro Tasmania/ENTURA) have the consent of SANParks in terms of NEM:PAA(2003) 50(5), in order to obtain Environmental Authorization from DEA for such activities as listed in the related applications. Regulation 1061 (specifically prohibit activities related to water courses) and GN 528 (relating in this case to the participation of SANParks in water license applications which could affect its objectives) are also applicable in this (environmental authorization) case, over and above requirements of the National Water Act and its regulations. Many of the activities applied for, are specifically prohibited by the above (conservation) legislation. There are numerous other guidelines and planning documents which should also be taken into account, but since the applicant cannot provide proof of consent from SANParks, we insist that this application be returned to the sender. It should be noted as stated in our DEIR comments, that the applicants are not interested (public meeting) to obtain this legally required consent and because the Competent Authority is being informed in due time, of this lack of intent to comply with legislation, a cautious approach would prevent further procedural chaos. We beg the Competent Authority to refuse this flawed application outright and to revert to us as soon as possible in this regard. 99. Mr Abrahams, Our previous correspondence (below) refers; We need your conformation that DWS will not issue a "nonbinding letter" as requested by the applicants, which would allow them to engage in a bidding process, because the document would be misleading. We have provided a number of reasons over the 3 previous calendar years in correspondence (which was also forwarded for your attention), which would support our request. We would appreciate your response to this very urgent matter and would forward copies of the correspondence for your information, if required. Regards, Kobus & Hannecke van Coppenhagen 0836564498 Kobus van Coppenhagen, Daberas, comment by e-mail, 24 July 2015, comment sent to AB Abrahams DWS, Danie Smit, Howard Hendricks and Shawn Johnston Dear Mr van Coppenhagen Your e-mail is acknowledged with thanks. Please note that the application by RVM is handled by the Orange Proto-CMA, which is headed by the Acting CEO Mr Moses Mahunonyane. Mr Mahunonyane Can you please provide the necessary feedback to Mr Van Coppenhagen. Kind regards, Abe Abrahams
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No. Issue Raised by Response from CES EIA team or Hydro SA Lea Visser – Plato Lodge 100. Hi Shawn, I am not given my support to the Hydro Electric Power station project at the Augrabies Falls. I am totally against the project because this is our area and our Lodge(Plato Lodge) greatest tourist attraction. And to take a certain amount of water away from the falls is rediculous. Our population will definitely take off because of the difference in the water that fell over the falls. So therefor I am totally against this project. I am totally against the project because the falls is our greatest tourist attraction and the project are gonna have a great influence in the water flow of the falls. So they do not have my support. Regards Lea Visser Lea Visser, Plato Lodge, comment by email, 01 June 2015. Dear Mrs Lea Visser, Thank you for our submission relating to the proposed Hydro SA Riemvasmaak Run-Of-River Hydro Power Station EIA study and draft environmental impact assessment report. I hereby acknowledge receiving your comments on the draft report and will forward it to the environmental impact assessment practitioner. Thank you for our second submission relating to the proposed Hydro SA Riemvasmaak Run-Of-River Hydro Power Station EIA study and draft environmental impact assessment report. I hereby acknowledge receiving your comments on the draft report and will forward it to the environmental impact assessment practitioner. Sincerely, Shawn Johnston
EAP’s response: The commentator’s lack of support for the project is noted. Diversion of water: The impact of diverting water from the falls to the power station is addressed in detail in section 3.3 of the EIA Report. Lead To Business – Melanie Miles
101. Dear Sir, Your company is currently conducting a Environmental Basic Assessment Process Report for the RVM 1 Hydro Electric Power - 40 MW Hydroelectric Scheme on Orange River, Kai Garib Local Municipality, Riemvasmaak. Please could you forward me the BID for this application and register me as a Interested & Affected party? Thanking you in anticipation of a favourable response. Kindest Regards, Melanie Miles Content Researcher MelanieM@L2B.co.za
Melanie Miles, Lead To Bisiness, comment by e-mail, 28 April 2015.
Dear Melanie, Thank you for your e-mail. You have been registered and as a interested and affected party. Find attached the BID for the RVM Project. Sincerely, Shawn Johnston
Leon Marias – Lawson’s Birding, Wildlife and Custom Safaris
102. Hi Shawn. Just read in the SA Tourism Update about being registered as I&AP’s with respect to the HE power scheme at Augrabies. This is obviously a bad idea in terms of tourism, so how do we list our objections? Thanks, Leon Marais.
Leon Marias , Lawson’s Birding, Wildlife and Custom Safaris, comment by email, 14 August 2015.
Dear Mr. Leon Marais, Thank you for your e-mail. I have registered you as a interested and affected party on the Riemvasmaak Hydro Project Environmental Impact Assessment. Please send all of your concerns and objections to me directly. Sincerely, Shawn Johnston
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No. Issue Raised by Response from CES EIA team or Hydro SA Thanks Shawn. Are there any ‘stock’ concerns and objections you can supply It would just make it easier and quicker to list them. The impact on tourism potential would be the main cause for concern for us. Leon.
Thanks Shawn. Unfortunate reality is that most people who are not directly affected just don’t have the time to go through for such documents. If there was a quick way to lodge concerns, it would garner much more momentum. Regards, Leon. Luise Niemoller Coertzen and JHB van der Merwe - Pofadder Tourism 103. Dear Mr Johnston, I refer to your recent telecon with ms luise niemoller; due to her hardware problems still persisting, she requested us to follow up on the said communication on her behalf and request that as per your undertaking you forward 6 copies of the full EIA ( on cd) inclusive of all relevant documentation as discussed, to her following address LUISE NIEMOLLER, P O BOX 45, POFADDER, 8890; thank you. Groete / Regards Annas van der Merwe Annas van der Merwe, Van Der Merwe – Miller Incorporated, Pofadder, comment by e-mail, 27 April 2015. Dear Mrs Luise Niemoller, Thank you for your e-mail. Please note the 6 CDs have been sent to your post office box form our office. Sincerely, Shawn Johnston 104. Business development in Pofadder is mainly dependant on attracting tourist to our area. The flow of tourist and the subsequent future development of our area will be damaged beyound repair. The Augrabies Falls, 122km on the N14 from Pofadder, is the only known tourist attraction in the area of Pofadder. Tourist going through Pofadder are not interested in the Augrabies Falls with not “enough” water to make it impressive. The other main attraction of the Pofadder/Orangeriver area is it remoteness from development and natural state where people can escape to. This will be ruined if the falls are toucehed further by human/industrial hand. People living along the Orange River depend on fishing for food and the fishlife is already damaged. SMME development as requested by or required by the South African Government will be seriously hampered by damage to the tourism development of the area. And damage to the Luise Niemoller Coertzen and JHB van der Merwe - Pofadder Tourism, comment by e-mail, 23 June 2015. Dear Luise & Annas, Thank you for your comments. I hereby acknowledge receiving your comments and will be processing it into the comments and response report. Thank you for your participation and input. Sincerely, Shawn Johnston EAP’s response: Augrabies Falls and the Orange River: The project will not ruin either the Augrabies Falls or make it noticeably less impressive. Neither will it have any significant effects on the Orange River or its fish life. The project will not affect the remoteness of the Pofadder area. The impact on the falls and the river are set out in section 3.3 of the EIA Report, and are summarised in the response to Comment 8 above as follows: The impact of the project on the flow regime of the river is set out in section 3.3.1 of the EIA Report as follows:
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No. Issue Raised by Response from CES EIA team or Hydro SA Augrabies Falls will damage tourism development as well as SMME development amongst previously disadavantaged local people. Wihin all future meetings regardig the development the damage to the falls, the Orange River lower down in the Pofadder/Khai-Ma area will have to be brought to the table. Accommodation development during the current development area will stand as ghost town reminders of a foolish project against our area. Little cottag exists because of eco tourist in the Lower Orange River, therefore any negative impact in the lower Orange River will have a direct adverse effect on this and other small enterprises accommodating 2 to 3 persons per night. In an area where business opportunities are nearly non existent, the negative effect of the proposed development can never be redressed. Onseep River Camp is an eco tourist destination downstream from the Augrabies waterfalls (AWF). The AWF remains the foremost drawcard for tourism in the Lower Orange River area. The proposed project will impact negatively on the tourism industry as a whole and the smaller outfits like ORC will not be able to withstand such impact causing downscaling and even closure which leads to job loss and loss of financial benefit to the area. Thedamaging influence on the fish population downstream leads to the loss of interest of tourist in recrational fishing a main attraction at Orange River Camp.  For ±20% of the time no flow will be diverted into the tailrace:  For ±15% of the time (55 days) the river flows at or less than 30m³/s, so no flow will be diverted into the headrace and the HPP will not operate.  For ±5% of the time (18 days) the river flows at more than 800m³/s. At this flow rate it is anticipated that the sediment loads in the river will begin to increase to such an extent that sediment could be drawn into the headrace, and could result in damage to the turbines. No flow will be diverted into the headrace; power generation will be shut down to prevent damage to the turbines.  For ±45% of the time (165 days, or 5.4 months) river flows are between 30m³/s and 90m³/s, diverted flow will progressively increase from zero to 38m³/s, and the power station will operate at less than its installed generating capacity.  For ±35% of the time (128 days, or 4.2 months river flows exceed 90m³/s but are less than 800m³/s, diverted flow will be at a maximum of 38m³/s, and the power station will operate at its full design capacity This means that, during the time when flow will be diverted to the hydropower station, the percentage reduction in the flow rate over the falls will range from zero at a total river flow of 30 cubic metres per second (m3/sec) to 42.2% at 90m3/sec, falling to 4.2% when the river flow is at 800 m3/sec. The project will therefore never reduce the flow over the falls to a trickle. The flow regime over the falls can only be reduced to accord with the commentators; fears by improper management of releases from the very large dams upstream of Augrabies, and mismanaged and / or uncontrolled abstractions from the river for off-channel consumptive uses. Tourism: The assessment indicates that tourism and the SMME sector will not be significantly affected by the project. In particular, since the project will affect the flow regime of the river for a distance of about 10km from the diversion weir to a point about half way down the Augrabies Gorge, there will be no impact on the river further downstream, There will be no impacts on the river at Onseepkans or where it passes Pofader. Mariana Delport - DEDT registered Cultural and FGASA Level 2 Field Guide 105. The Augrabies Falls is one of South Africa’s Natural Wonders and has been preserved for many years. I have taken many Mariana Delport, DEDT registered Cultural and Dear Mariana, Thank you for your e-mail and registering as an interested and
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No. Issue Raised by Response from CES EIA team or Hydro SA overseas and local tourists to the park, and will be taking my next group of overseas tourists there in a bit more than 2 weeks’ time. These tourists are in awe when they hear and see the water fall and experience the pristine habitat and the wild life to be found in the park. Apart from the conservation status of the park it also provides lots of job opportunities for the local residents. Now greed seems to take over and a Natural Wonder is at stake. This can simply not be allowed! Please register me as an Interested and Affected Party. Regards, Mariana Delport FGASA Level 2 Field Guide, comment by email, 16 August 2015. affected party. You comments will be added to the issues and response report of the final environmental impact assessment report. Sincerely, Shawn Johnston EAP’s response: The commentator is referred to the response to Comment 104 above for a description of the effect of the project on the flow regime of the Augrabies Falls, and to section 3.3 of the EIA Report. Marinda Louw Coetzee 106. Hallo Shaun I would like to formally object to the proposed hydro-electrical project for the Augrabies region of the Orange River. 1) It would affect tourism to the Augrabies National Park 2) It would affect road usage, farming operations and water usage to the export grape farmers in the area 3) It might create jobs, but the local population might not have the required skill sets needed. This will mean that 'incomers' will settle in the area after the project is done and lead to a non-sustainable increase in the population. 4) It will cause destruction of the environment Please consider other option such as solar and wind power. If the project does go ahead, please ensure transparent tender process and thorough, well-advertised public participation processes and information sessions. Best regards marinda louw coetzee photographer / journalist +27(0)832787383 Marinda Louw Coetzee, comment by e-mail, 20 August 2015 Dear Mrs Marinda Coetzee, Thank you for your e-mail. I hereby acknowledge that you have been registered as an interested and affected party and that your comments and objections have been received. Sincerely, Shawn Johnston EAP’s response: Tourism: The assessment indicates that tourism and the SMME sector will not be significantly affected by the project. Road usage: There will be an increase in traffic in the project area during construction, but measures will be put in place to ensure that there is minimal disruption to local road users. Water: DWS has confirmed that there will be sufficient water to meet the project’s requirements during construction and operation. There will be no impact on other water users. Employment: The applicant is committed to maximising employment opportunities to local people, and offering training to maximise post-construction opportunities for further employment. Environment: The assessment has shown that, with diligent implementation of mitigation measures, the project can be developed and operated without unacceptable impacts on the natural environment. Public participation: An open and transparent public participation process has been conducted for the EIA phase of the assessment. Nathalie Tedder 107. Dear Shawn, Nathalie Tedder, 06 Dear Mrs Nathalie Tedder,
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No. Issue Raised by Response from CES EIA team or Hydro SA Please register me. Nathalie Tedder, 11 Ottawa Avenue, Cape Town, 8005 083 283 7099 June 2015, comment by e-mail. Thank you for your e-mail. I herby confirm that you have been registered as a interested and affected party. Sincerely, Shawn Johnston 108. Comments on the draft EIA for the proposed Hydropower Plants at Augrabies Falls, Northern Cape. Submitted by: Nathalie Tedder June 04 2015 We recognise the need to develop alternative energy production technologies in order to reduce our reliance on fossil fuels. We are, however, 100% opposed to developing any projects in pristine, wilderness areas and areas of ecological importance. Sites of less ecological significance should be investigated as a priority over sites of such a pristine and ecological sensitive nature. 1. Flawed Public Participation Process: We object in the strongest possible terms to the public participation process for the following reasons; a. The Augrabies Falls (Riemvasmaak) project is of national and international importance – Augrabies Falls is in a national park and is of importance to the whole country. Despite this, the consultants and developer have treated it as a local project and have only notified people in the immediate area. This has not changed with the appointment of the new consultants, CES, despite this view being expressed during the Scoping process. In terms of legislation, the following is required of a public participation process; • Develop “the understanding, skills and capacity necessary for achieving equitable and effective participation.” This would require some objective studies and, subsequently, an educational programme to develop understanding and capacity in the local community so that they truly understand what you propose, their rights and responsibilities and the true impact the project would have on their culture and lifestyle. It does not seem that this has been done. • “The interests, needs and values of all interested and affected parties” must be considered. It is clear that this has not been done. Please note it says “All” I&APs. • “Full participation therein must be promoted.” This project should have been advertised at a provincial and Nathalie Tedder, 06 June 2015, comment by e-mail. EAP’s response: We note the strong similarities between Ms Tedder’s comments - Nos 108 to 113 - and those submitted by Ms Kellet of the African Paddling Association and Gravity Adventures (Nos 1 to 15, which were also exactly duplicated in Mr Craig Eksteen’s submission, Comments Nos 28 to 34); in many cases the wording is identical. Where the wording is identical or very similar the response to Ms Kellet’s comment has been copied here. As noted previously, the response to Ms Tedder’s comments relate only to the proposal to develop a hydroelectric power project (HPP) – the Riemvasmaak HPP - using the natural head generated by the Augrabies Falls, as set out in the EIA Report currently under consideration. The possibility of an HPP being developed that uses the head generated by the Ritchie Falls has nothing whatever to do with the Riemvasmaak HPP, and this response does not address any aspect of such a project. We do not agree that the two sites are “irrevocably linked”. These comments not relevant to the issues at hand. Alternative sites: Alternative sites studied by the applicant are discussed in Chapter 5 of the EIA Report, where it is pointed out that there are few sites on South African rivers that are suitable for the generation of electricity without the need to construct large impounding reservoirs to generate the necessary head, such as, for instance, the Gariep and Van der Kloof dams, both of which have had, and will continue to have, a profound influence on the flow regime of the Orange River. In this context we note that DEA has recently granted environmental authorisation for another large instream dam, about 30m high, on the Orange River, to facilitate the generation of 22MW of power at the Rooikat HPP. Public participation process: The commentator’s objections are noted. The availability of the Draft EIAR was advertised nationally, provincially and locally in the Sunday Times (25th April), and Die Burger, Die Gemsbok and Die Volksblad (29th
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No. Issue Raised by Response from CES EIA team or Hydro SA national level with a meaningful public participation process. National and provincial tourism bodies as well as civil society should have been fully and meaningfully consulted. For these and other reasons, in our opinion, the public participation is fatally flawed and should be declared null and void and the process started from scratch. April), all as required by DEA. We believe we have conducted a consultation process that provides an opportunity to comment on the proposed project to anyone who wishes to do so. We believe we have fulfilled the legislated requirements in respect of a public participation process. 109. 2. Cumulative Effects: Individualised Scoping studies and EIA’s fail to recognise the cumulative effects of the various hydro schemes, dams and ‘flood control’ weirs being constructed and planned for the Orange. This applies particularly to the site identified at the Ritchie Falls near Onseepkans as the combined effect of this and the Augrabies Falls project will be to destroy two of the last remaining wilderness areas on the entire river. The combined effects of all of this construction need to be considered as a whole and proper consultation done. In our opinion, a Strategic Environmental Assessment is of vital importance before any projects progress any further. Nathalie Tedder, 06 June 2015, comment by e-mail. EAP’s response: Cumulative impacts: The cumulative effects of the development of structures in and on the Orange River are considered in section 7.6 of the EIA Report. It is important to note that the RVM HPP will not destroy the Augrabies Falls, neither will it have anyeffect on the river at Onseepkans. The commentator is referred section 3.3.1 of the EIA Report for details of the effect of the project on the flow regime of the falls. 110. 3. Transboundary River The Orange River is a transboundary river, whose basin is shared between Lesotho, South Africa, Botswana and Namibia and is goverened by various international agreements and administered by ORASECOM. None of these are referenced in the EIA and ORASECOM is not even listed as an IAP. In a similar vein, the National legislation of the participating countries requires water resources to be managed from a catchment approach i.e. from source to sea. In light of these proposed hydropower plants, a strategic assessment that assess the cumulative impacts of all of the proposed hydropower plants on the Orange river should be carried rather than the current process of individual site-specific assessments. Nathalie Tedder, 06 June 2015, comment by e-mail. EAP’s response: The Orange as an international river: We are aware of the status of the Orange River as an internationally-shared river, and of the various instruments that relate to its management. However, given that the proposed project will affect the flow regime of the river only between the diversion weir and the point at which the diverted flow is returned undiminished to the mainstem river, a distance af about 10km, mostly through the rocky gorge downstream of the Augrabies Falls, the project will not affect the downstream riparians, and will certainly not affect the upstream riparian, Lesotho). Accordingly there is no significant effect on the river that requires consultation with the other basin states in accordance with the SADC Protocol. The South African Department of Water and Sanitation is responsible for the management of the Orange River Basin in South Africa, and for administering water-related agreements between South Africa and Namibia. The department has not raised any objections to the project, and has written to the applicant confirming that sufficient water is available for the construction (3 years) and operational (20 years) phases of the project, should it be approved. The period of availability of water for operation relates to the maximum period of a water use licence, and not to the anticipated lifetime of the project, which may be of the order of 80 years or more..
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No. Issue Raised by Response from CES EIA team or Hydro SA 111. 4. Impact on Augrabies National Park and the Augrabies Falls Sense of Place and the Wilderness Experience – Augrabies Augrabies Falls is the Orange River’s highest waterfall and is classified as pristine wilderness. This will be negatively impacted by the proposed hydro plant as follows; During Construction All of the impacts of a major engineering project – in a national park!  Noise  Dust  Aesthetics  Sense of place  Wilderness character  Ecological effects All will be significant and no amount of mitigation will disguise the fact that the construction of this project will have a huge impact on the wilderness character of this site. The specialist studies claim that the impact will at worst be low to medium but this is impossible, given the nature of this site. After construction The permanent structures and power lines will be visible from various points in the park and cannot be disguised. Similarly, the noise generated by the project will definitely not be natural. The wilderness character will be permanently lost. Nathalie Tedder, 06 June 2015, comment by e-mail. EAP’s response: The commentator’s doubts about the credibility of the results of the impact assessment are noted. 112. 5. Socio Economic Impact and Ecotourism: Augrabies Falls The Riemvasmaak community (who own the land) support the project but it is clear that they have not been made aware of a number of very important points; 1. Of the 150-200 temporary jobs, only SOME will go to them. In fact, many will go to skilled workers and it is not clear how many Riemvasmaakers will be employed. 2. The jobs will be around for only three years. After that, only 1 job is guaranteed to go to a local person and that will be a skilled job 3. They will be shareholders in the company and will receive dividends – only if the company is profitable, nowhere does it say that if the company does not make money, that they will be responsible for the debt as well. Given the long term doubt around the sustainability of this project (given that global Nathalie Tedder, 06 June 2015, comment by e-mail. EAP’s response: Employment: The applicant is committed to maximising employment opportunities to local people, and offering training to maximise post-construction opportunities for further employment. Environment: The assessment has shown that, with diligent implementation of mitigation measures, the project can be developed and operated without unacceptable impacts on the natural environment. RVM Community Development Trust Shareholding: The details of the financial arrangements for the project are set out in section 4.3.2 - Benefits to local communities – of the EIA Report, which has been expanded to include an explanation of the concept of Non-Recourse Financing.
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No. Issue Raised by Response from CES EIA team or Hydro SA climate change predicts less water that is needed to run the power plant) 4. They are under the impression that the power generated will go their community and that they will no longer suffer electricity shortages. This is, of course, completely untrue but at no stage in the reports does it note that the consultants corrected their misunderstanding of the perceived benefits. The above points relate back to the public participation process which was not properly done. If it was, the community may not be as supportive as they are currently. Availability of electricity: No guarantees have been given to the Riemvasmaak community, or to anyone else in the project area, of an uninterrupted power supply when the project is implemented. The electricity generated by the project will be fed into the National Grid. A 40MW hydro plant connecting into the national grid Blouputs in the Northern Cape Province will have a positive impact on the stability of the South African Electricity Grid. While the small relative size of the units will have negligible impact on the overall system frequency stability, the units will provide significant local voltage support. This voltage support is mandated in the RPP Grid code for this sort of generating unit. The voltage support improves the efficiency of the local transmission and distribution network, makes solar PV facilities less prone to interruption due to voltage dips and enhances fault detection and clearing through higher local fault levels. All these effects provide a more secure, reliable and higher quality electricity supply for customers in the region. The presence of synchronous generation in a region can also facilitate faster system restart after blackouts and assist the supply authorities in system outage management. 113. 6. Conclusions Ritchie Falls and Orange Gorge: Given the many negative impacts identified above, we strongly recommend that further planning permission for this project be denied and that this area be given protected status as soon as possible to help prevent any such projects in the future. This is part of our country’s natural heritage and should not be handed over to a private company to generate profit for their own benefit and to our detriment.
Augrabies Falls: Given the national and international significance of the site, we recommend that this project be abandoned completely. Alternatively, given the fatally flawed consultation process, we recommend that this project be halted and started again from scratch.
Augrabies Falls and Ritchie Falls projects and all other proposed projects along the length of the Orange River: Given the unknown cumulative effects of all of the various structures being planned for the Orange, including but not limited to
Nathalie Tedder, 06 June 2015, comment by e-mail.
EAP’s response: The commentators’; recommendations that the RVM HPP be abandoned are noted, together with the recommendation to DEA that an SEA be conducted relating to further development on the Orange River.
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No. Issue Raised by Response from CES EIA team or Hydro SA hydro-electric power stations, dangerous “flood control’ weirs etc, we recommend that a Strategic Environmental Assessment as well as a Reserve Assessment be conducted for the river as a whole. South African National Roads Agency – Rene de Kock 114. Good day Shawn, Thank you for your email. Please forward locality plan to me. Kind regards, Rene Rene de Kock, South African National Roads Agency Limited, Western Region, comment by e-mail, 28 April 2015. Dear Rene, Find attached requested locality maps. Sincerely, Shawn Johnston 115. Riemvasmaak Run-of-River Hydro Power Station Water Use Application
Dear Shawn, Thank you for your email. Kind regards, Rene
Rene de Kock, South African National Roads Agency Limited, Western Region, comment by e-mail, 28 April 2015.
Dear Rene, You are most welcome. Sincerely, Shawn Johnston
Wilderness Foundation – Angus Tanner 116. Good afternoon Shawn, Thank you for sending me the documents regarding the proposed HydroSA Riemvasmaak Hydro Project. The Wilderness Foundation was previously register as a IAP for this project in the beginning when the public stakeholder process was being handled by another company. I now see that we are not on the list of IAP’s according to the register attached to your mail. Can I re--‐register us as an interested and affected party with you? Thank you, Angus
Angus Tanner, Wilderness Foundation, Senior Manager, Conservation, comment by e-mail, 11 May 2015.
Dear Angus, Thank you for your e-mail. I have registered yourself and the Wilderness Foundation on the proposed HydroSA Riemvasmaak Hydro Project environmental impact assessment study. Please provide me with comments once you have reviewed the current draft environmental impact assessment report on the Coastal Environmental Services web site. I look forward to receiving your input on the proposed project. Sincerely Shawn Johnston

Africa Wild

Proposed hydro power station at Augrabies

Re: Augrabies nat, park under threat.

Re: Augrabies nat, park under threat.

Re: Augrabies nat, park under threat.

Re: Augrabies nat, park under threat.

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Re: Proposed Hydropower Station at Augrabies

Re: Proposed Hydropower Station at Augrabies

Re: Proposed Hydropower Station at Augrabies

Re: Proposed Hydropower Station at Augrabies

Re: Proposed Hydropower Station at Augrabies