FINAL BASIC ASSESSMENT REPORT Amanzimtoti Housing Development Application for Environmental Authorisation for The Proposed Amanzimtoti Housing Development on Portion 1 of 25, Portion 1 of 27 and Remainder of 27, Amanzimtoti, KwaZulu-Natal NEAS Ref: KZN/EIA/0000663/2017 December 2017 Prepared by ETC-Africa CC Po Box 522 Richards Bay 3900 South Africa Phone: +27 (72) 476 0396 Fax: +27 (86) 694 3174 [email protected]www.etc-africa.co.za On behalf of Sure Focus Twenty Two cc Lagoon Point 7 Mayville Terrace 2 4126 Kwa-Zulu Natal South Africa Phone: +27 (31) 904 1235
Transcript
FINAL BASIC ASSESSMENT REPORT
Amanzimtoti Housing Development Application for Environmental Authorisation for The Proposed Amanzimtoti Housing Development on Portion 1 of 25, Portion 1 of 27 and Remainder of 27, Amanzimtoti,
KwaZulu-Natal
NEAS Ref: KZN/EIA/0000663/2017
December 2017
Prepared by ETC-Africa CC Po Box 522 Richards Bay 3900 South Africa Phone: +27 (72) 476 0396 Fax: +27 (86) 694 3174 [email protected]
www.etc-africa.co.za
On behalf of Sure Focus Twenty Two cc Lagoon Point 7 Mayville Terrace 2 4126 Kwa-Zulu Natal South Africa Phone: +27 (31) 904 1235
SECTION A: DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER AND SPECIALISTS ............................................................................................................... 3
1. NAME AND CONTACT DETAILS OF ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP) ................................................................................................. 3 2. NAMES AND EXPERTISE OF REPRESENTATIVES OF THE EAP ................... 3 3. NAMES AND EXPERTISE OF SPECIALISTS ..................................................... 4
SECTION B: ACTIVITY INFORMATION ..................................................................... 5
1. PROJECT TITLE ................................................................................................... 5 2. PROJECT DESCRIPTION..................................................................................... 5 3. ACTIVITY APPLIED FOR IN TERMS OF NEMA, EIA REGULATIONS ............................... 6 4. ALTERNATIVES CONSIDERED ............................................................................... 7
4.5. No-go alternative ....................................................................................... 11
5. ACTIVITY POSITION ........................................................................................... 11 6. PHYSICAL SIZE OF THE ACTIVITY ................................................................... 13 7. SITE ACCESS ..................................................................................................... 13
8. ACTIVITY MOTIVATION ..................................................................................... 14 8.1. Socio-economic value of the activity ........................................................ 14
8.1.1. Quality of life impacts ............................................................................ 15
1. GRADIENT OF THE SITE.................................................................................... 26 2. LOCATION IN LANDSCAPE .............................................................................. 26 3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE ........ 27 4. VEGETATION .......................................................................................................... 27
4.1. Biome and vegetation type ....................................................................... 27
4.2. Species composition ................................................................................. 28
4.3. Protected species ...................................................................................... 28
4.4. Conclusions and recommendations made by vegetation ecologist ......... 28
4.5. Relocation of protected species ................................................................ 29
5. LAND USE CHARACTER OF SURROUNDING AREA ..................................... 29 6. CULTURAL/ HISTORICAL FEATURES ............................................................. 29
SECTION D: PUBLIC PARTICIPATION .................................................................... 30
1. ADVERTISEMENTS ............................................................................................ 30 2. COMMENTS AND RESPONSE REPORT .......................................................... 31 3. PARTICIPATION BY DISTRICT, LOCAL AND TRADITIONAL AUTHORITIES31 4. CONSULTATION WITH OTHER STAKEHOLDERS.......................................... 31
1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES ...................... 32 2. IMPACTS THAT MAY RESULT FROM PHASES OF CONSTRCUTION ................... 32 3. MITIGATION MEASURES................................................................................... 34 4. SIGNIFICANT RECOMMENDATIONS MADE BY SPECIALISTS ..................... 46 5. PROPOSED MONITORING AND AUDITING ..................................................... 48 6. ENVIRONMENTAL IMPACT STATEMENT ........................................................ 48
APPENDIX A. VEGETATION ASSESSMENT REPORT (UPDATED VERSION 2016) ............... 49 APPENDIX B. WETLAND IMPACT ASSESSMENT (2017) ................................................... 49 APPENDIX C. GEOTECHNICAL REPORT (2009) ................................................................ 49 APPENDIX C2. VALIDATION OF GEOTECHNICAL REPORT (2017) ..................................... 49 APPENDIX D. TRAFFIC IMPACT ASSESSMENT (UPDATED VERSION 2017) ........................ 49 APPENDIX E. CONFIRMATION OF CAPACITY TO PROVIDE SERVICES ................................ 49 APPENDIX F. LAYOUT .................................................................................................... 49 APPENDIX G. SITE PHOTOS ............................................................................................ 49 APPENDIX H. PUBLIC PARTICIPATION ............................................................................ 49 APPENDIX I. ENVIRONMENTAL MANAGEMENT PROGRAMME ........................................... 49 APPENDIX J. STORM WATER MANAGEMENT PLAN......................................................... 49 APPENDIX K. ENGINEERING PLANS, STORMWATER, SEWER AND ROADS ......................... 49 APPENDIX L. ENGINEERING PLANS, CROSS SECTION PLANS ........................................... 49 APPENDIX M. HYDROLOGIST’S LETTER REGARDING FLOODLINE ASSESSMENT ............... 49 APPENDIX N. DECLARATIONS AND CV’S OF EAP AND SPECIALISTS ................................ 49
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SECTION A: DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER AND SPECIALISTS
1. NAME AND CONTACT DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)
2. NAMES AND EXPERTISE OF REPRESENTATIVES OF THE EAP
Name of representative of the EAP
Education qualifications
Professional affiliations
Experience at environmental assessments (yrs)
Edward Rice MSc Conservation Biology
International Association of Impact Assessment (IAIA). Carbon Protocol of South Africa. Green Leaf Environmental Standard.
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Duncan Pritchard Bsc Geography International Association of Impact Assessment (IAIA). Carbon Protocol of South Africa. Green Leaf Environmental Standard.
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3. NAMES AND EXPERTISE OF SPECIALISTS
Name of specialist
Education qualifications
Field of expertise
Contribution to the basic assessment report
Title of specialist report
David Styles
MSc Environmental Management
Botany Vegetation Assessment
Report on vegetation on portion 1 of 25, 1 of 27 and rem of 27, Amanzimtoti
Ross Goode BSc Ecology Botany Vegetation report update
Portions 1 of 25, 1 of 27 & rem of 27, Amanzimtoti, KwaZulu-Natal, Vegetation Report Update (Appendix A)
Rowena Harrison Craig Widdows
MSc Soil Science PhD Ecology
Wetland ecologist Wetland ecologist
Wetland Impact Assessment
Wetland Impact Assessment for Proposed residential development comprising Portion 1 of 25, 1 of 27 and The Remainder Of 27 in Amanzimtoti, Ethekwini Metropolitan Municipality, Kwazulu-Natal (Appendix B
S Pather MSc Engineering
Geotechnical engineering
Geotechnical Investigation
Report to Sure Focus Twenty Two cc on the Results of a Geotechnical Investigation for the Proposed Residential Development Comprising Portion 1 of 25, 1 of 27 and the Remainder of 27 in Amanzimtoti, KwaZulu-Natal
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(Appendix C)
Andile Gqaji Bachelor of Science (Honours): Transportation Planning
Civil and traffic engineering
Traffic Impact Assessment
Traffic Impact Assessment Report for the EIA Application to develop 74 Residential Units, Ptn 1 of 25, Ptn 1 of 27 and Rem of 27 Amanzimtoti (Appendix D)
SECTION B: ACTIVITY INFORMATION
1. PROJECT TITLE
Proposed Amanzimtoti housing development on Portion 1 of 25, Portion 1 of 27 and Remainder of 27, Amanzimtoti, KwaZulu-Natal.
2. PROJECT DESCRIPTION
Sure Focus Twenty Two CC is proposing a cluster housing development with approximately 74 low-to-medium income houses on Portion 1 of 25, Portion 1 of 27 and Rem of 27 Amanzimtoti. The total area of these properties is approximately 9.4 hectares, with a development footprint of less than two hectares. The housing development will be divided into two separate portions; the “eastern portion” to be comprised of 46 residential units and “western portion” comprised of 28 residential units, totalling 74 units. The eastern portion will be accessed from Wanda Cele Road (formerly Old Main Road). The western portion will be accessed from Wade Road. Approximately 80% of the property will remain undeveloped, including;
• 64% to be registered as a conservation servitude, which includes the forested area identified as having high ecological value. This will be a no-go area for construction
• Approximately 10% to be used as the body corporate conservation area, identified as closed canopy indigenous forest and will be used for on-site relocation of protected species prior to construction
The applicant intends on donating full rights to use of the conservation servitude (64% of the property) to eThekwini Municipality to ensure it remains a conservation area, maintains
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the connectivity of the Durban Metropolitan Open Space System (DMOSS) corridor and could potentially be linked to the existing iLanda Wilds Nature Reserve, which follows the nearby Amanzimtoti River. The Municipality has indicated that negotiations around this can continue once the EIA process is complete and the layout is finalised. This donation is supported by the Department of Agriculture, Forestry and Fisheries who have asked to be included in future discussions around this matter. A 3m wide sewer servitude will be retained by the applicant to allow for maintenance of the sewer line which follows the edge of the development footprint on the western portion of the development and the north-eastern boundary of the property. The proposed development will include: • 74 residential houses
- The sectional title houses will be semi-detached single-story units. The houses (50 sqm in
area) will contain two bedrooms, a bathroom and an open-plan kitchen and lounge area. Each
unit will be fitted with a rain water harvesting tank for water conservation and to reduce
storm water runoff volumes and associated risks
• Associated services infrastructure - Internal sewerage reticulation with sump, pump and backup generator to transfer sewer from
the western portion to the eastern portion of the development of tie into existing municipal
sewer network
- Two access roads (one from Wade Rd and one from Wanda Cele Rd). Access roads,
driveways and internal roads will all be comprised permeable paving to reduce storm water
runoff volumes and associated erosion risks
- Electricity transmission, a substation and a miniature substation on the eastern portion and
western portion of the development respectively
- Storm water infrastructure to divert part of the development’s storm water runoff into the
municipal storm water network and part to be discharged into the environment via three
headwalls with rock mattress scour aprons to dissipate flow and prevent erosion.
In terms of Listing Notices 1 and 3 (GNR R983 and 985) promulgated in 2014 under The National Environmental Management Act (Act No. 107 of 1998), EIA Regulations 2014, listed activities will be triggered by this development and therefore it requires a Basic Assessment Report to be submitted to KZN Department of Economic Development, Tourism and Environmental Affairs.
3. ACTIVITY APPLIED FOR IN TERMS OF NEMA, EIA REGULATIONS
Listing Notice
Activity Description Relevance to the proposed activity
1 (GNR 983)
27 The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation.
The development will have an approximate 2 hectare footprint, much of which will require clearance of indigenous vegetation
3 (GNR 985)
12 The clearance of an area of 300 square metres or more of indigenous Vegetation (b) In KwaZulu-Natal: (iv) Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or
Site falls within critically endangered Interior South Coast Grasslands (KZN 7)
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prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004;
4. ALTERNATIVES CONSIDERED
Consideration of alternatives is an important element in the EIA process. “Alternatives” are defined in the NEMA EIA regulations, 2014 (GN 982 of 2014) as: “In relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to the: (a) property on which or location where the activity is proposed to be undertaken; (b) type of activity to be undertaken; (c) design or layout of the activity; (d) technology to be used in the activity; or (e) operational aspects of the activity; and includes the option of not implementing the activity.” The role of the EAP is therefor to provide a framework for sound decision-making based on the principles of sustainable development. Potential alternatives that were considered for the proposed Amanzimtoti Housing Development are detailed below.
4.1. Property alternatives No property alternatives were considered for the proposed development. The property was purchased specifically with this development in mind.
Figure 1. The preferred site for the proposed development. Property boundary in red
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4.2. Activity alternatives A variety of alternatives were considered in terms of the activity (type of development). These included; a commercial development (shops), residential units and a combination of the two. The preferred alternative is exclusively housing. The site is deemed most appropriate for housing for the following reasons:
• The site is zoned Special Residential.
• The site is laid out in the town planning scheme for conventional housing.
• The activity aims to address the need for low-to-medium income housing in the area.
• Amanzimtoti is identified in the South Spatial Development Plan as an appropriate area for residential densification
4.3. Design or layout alternatives Alternative Layout 1 (Fig. 2) was drafted in September 2016. Alternative layout 1 proposed 92 houses in total; 46 in each portion of the development. Although this layout was drafted with the primary forest edge in mind (thick grey line), it was based on a vegetation assessment done in 2009 and did not allow for a buffer between the forest edge and the development footprint. An update on this original vegetation assessment has since been conducted. The Preferred Layout (Fig. 3) was finalised in December 2017 and is the most recent layout alternative considered. The total number of units has been reduced from 92 to 74. The preferred layout has seen a significant reduction in the number of houses on the western portion of the property (accessed from Wade Road) from 46 to 28 houses. The number of houses proposed on the eastern portion (accessed from Wanda Cele Road) has remained at 46. The preferred layout takes into account:
- the forest edge or “developable area” as identified in the updated vegetation report
(Appendix A, dated December 2016), expanded to form the proposed conservation servitude
- the secondary forest identified in the original vegetation assessment, identified as a body
corporate conservation area
- the findings of the wetland assessment which concluded that the wetlands on the eastern
portion are artificial, with little ecological functionality in terms of the Present Ecological
State (PES) and Ecological Importance and Sensitivity (EIS).
This has resulted in the preferred layout having a reduced development footprint, and subsequently a reduction in the proposed number of residential erven and a reduced impact on the forested area of the property. A higher resolution copy of the layout is available as Appendix F.
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4.4. Technology alternatives Alternative technologies considered included:
4.4.1. Wastewater: Wastewater management alternatives considered were soakaway/French drain systems as well as using the Municipal sewer network. The preferred technology is to use the Municipal wastewater services as the geo-hydrological conditions on the site are not suited to soakaway pits. Sewer collectors, a sump and pump are required to transport wastewater from the western portion to the eastern portion from where it will connect to the existing wastewater network on Wanda Cele Road.
4.5. No-go alternative The no-go Alternative is the option of not undertaking the proposed housing development. The no-go option would contribute to the failure to meet the growing need for low-to-middle-income housing in the area. This may have long-term negatively repercussions on the socio-economic structure of the population of Amanzimtoti, including areas outside of the town planning scheme (i.e. the Malagazi, Kwamakhuta area) where there is a significant lack of formal housing with municipal services (running water, waste and wastewater infrastructure etc.). Of course, the no-go option would result in the site remaining undeveloped. This would result in 100% of the property remaining as part of the DMOSS (Durban Metropolitan Open Space System) where it fulfils various ecosystem services (providing clean air and water) and maintains the biodiversity of this ecosystem. Parts of the property are currently rife with illegal dumping and hunting. The no-go alternative would see these illegal activities continue.
5. ACTIVITY POSITION
The proposed Amanzimtoti Housing Development will be located on Portion 1 of 25, Portion 1 of 27 and Remainder of 27, Amanzimtoti, KwaZulu-Natal (Fig. 4 and 5). The site can be accessed from Wade Road or Wanda Cele Road (formerly Old Main Road) which continues northeast from the site, eventually meeting Moss Kolnick Dr, which continues past the Galleria Mall to the N2 highway (approximately 4.5 km from the site). The site is just 2.5 km (by road) northwest from the N2 at the Adams Road intersection. The site falls on the edge of the town planning scheme. The property and anything south east of it falls within Amanzimtoti’s urban area, northwest of the site is the peri-urban township area of Malagazi. Amanzimtoti is identified in the South Spatial Development Plan as an appropriate area for residential densification opportunities (SSPD, 2014).
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Figure 4. Location of the proposed site, on a local scale. Property boundary in red.
Figure 5. Location of the proposed site, on a regional scale
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6. PHYSICAL SIZE OF THE ACTIVITY
The proposed site is approximately 9.4 hectares. An area of 5.6 hectares was identified as ecologically important by the vegetation specialist (Appendix A) and as the minimum area to remain undeveloped for conservation purposes (Fig. 6). The area to remain undeveloped has since been expanded to 5.85 ha and will be registered as a conservation servitude (Fig. 13). A strip of closed canopy indigenous forest (secondary forest) on the eastern boundary, as identified in the original vegetation report (from 2009), will also remain undisturbed, apart from a narrow strip to be used as the access to the eastern portion of the development. This area will be maintained as the body corporate conservation area (Fig. 13). The development footprint of the eastern and western portions are 1.25 and 0.56 hectares respectively, resulting in a total development footprint of 1.81 hectares (19% of the total property size) (Fig. 6).
Figure 6. The proposed site, showing the eastern and western portions and the areas that are
due to remain undeveloped.
7. SITE ACCESS
The eastern portion of the proposed development will be accessed via Wanda Cele Road. There is the remnant of an entrance/driveway from a time when the property was a farm. The proposed access road will follow the route of this old access road (Fig. 7). There is an existing access to the western portion of the property. It can be seen as a dirt road on aerial images (Fig. 7). This access will need to be formalised (e.g. paved) for the sake of the proposed development. Internal roads within the proposed development will be 4 m in width and will be permeable paving to promote storm water infiltration.
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Figure 7. Access to the proposed development.
7.1. Traffic Impact A Traffic Impact Assessment was originally done in 2013. Due to the methodology used and date of this report, an updated report was requested. Another Traffic Impact Assessment was done in July 2017 (Appendix D). The report confirms that Wade and Wanda Cele Roads are wide enough to accommodate the anticipated increase in traffic flow caused by the proposed development. The minimum shoulder sight distance for a Stop Condition access point on a road with a design speed of 60 km/h is approximately 90.0 metres. Since the line of sight is in excess of 90 metres at the access point of the development site, the sight distance at the access point is adequate along Wanda Cele Road and Wade Road in both directions.
The traffic consultants further recommended that;
• The access gate be recessed by 6 m from the back of the boundary line to accommodate traffic turning off the road in to the development.
• The access will be designed in accordance with the eThekwini Transport Authority’s standards and specifications with a minimum width of six metres for two-way movement [this width need only be from the road to within the gates of the development. Internal roads will be 4 m thereafter].
• A total of 111 parking bays are to be provided on site to meet the parking demand for 74 Residential multi-units.
8. ACTIVITY MOTIVATION
8.1. Socio-economic value of the activity
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The socio-economic environment may be described as that part of the environment which has its origin or being in human activities i.e. social, economic, cultural and political objects and processes (DEAT, 1992). The socio-economic improvements which can be expected from the Amanzimtoti Housing Development are described below.
8.1.1. Quality of life impacts Quality of life may be best described in terms of value, standard of living, benefits and advantages that a given community may currently have or may receive in the future. The Amanzimtoti Housing Development can potentially have a significant positive impact on the local residents. The potential quality of life aspects and associated impacts include:
8.1.1.1 Employment opportunities: The construction phase is scheduled to last approximately 2 years and in this time labour will be required for construction activities. Where ever possible labour for construction should be sourced locally. This will ensure people in the area will receive an income from the construction phase. They will also learn construction skills that can be applied to future employment opportunities, thus making them more marketable in the work place. During the operational phase, the housing development is likely to create numerous employment opportunities in the form of domestic workers, maintenance staff and gardeners. No-go alternative: should the development not be approved the employment opportunities will not be realised.
8.1.1.2. Improved standard of living: It is important to bear in mind that many residents of the proposed housing development, particularly those from a lower income bracket, may be moving here from housing outside the urban edge. The present situation for many living in the township area of Malagazi includes:
• Limited access to potable water.
• Unsanitary sewerage disposal.
• Lack of waste removal services.
• Limited access to electricity. The proposed housing development will offer housing to those in the low-to-middle income bracket, which is within the urban edge and hence has many associated standard of living improvements. These include access to the municipal services mentioned above, which generally results in improved health and hygiene. In addition, being in an urban area positions residents closer to places of employment, resulting in shorter daily commutes and more employment opportunities. No-go alternative: should the development not be approved the standard of living for those due to move from informal housing/from outside the urban area will not be improved.
8.1.2. Densification of residential areas Amanzimtoti is identified as an appropriate area for residential densification in the South Spatial Development Plan (2014). The proposed development site is within a residential
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area and is zoned Special Residential.
8.2. Ecological value of the activity
The proposed development will obviously result in the loss of approximately 2 hectares of currently undeveloped land. Although the property falls within DMOSS, it is currently not afforded any formal protection. As such, illegal activities causing environmental degradation have spiralled out of control. These include;
• Hunting (with the aid of hunting dogs and traps),
• Operating earth moving equipment on site (Fig. 11).
Figure 8. Domestic refuse being dumped on site
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Figure 9. Dumping of garden refuse on site
Figure 10. Dumping of building rubble on site
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Figure 11. Operating earth moving equipment on site
The development will prevent unauthorised access and the illegal activities mentioned above. Much of the land intended for development is degraded or transformed. On both the eastern and western portions platforms (cut and fill) have been created in the past. This has obvious impacts on the ecological value of the land and has resulted in a high density of invasive alien plant species. This is explained in greater detail in the vegetation report (Appendix A). If the development is authorised, 5.85 hectares (approximately 64% of the property) will be fenced off and formally protected as a conservation servitude. This protected portion will include the areas of the property (specifically the dense valley vegetation) that have been identified as most ecologically valuable due to species composition and relative pristine state. A 10m buffer has been added around these ecologically valuable areas, to accommodate potential adverse edge effects (as per recommendations in the vegetation report update, Appendix A). Since submission of the draft BAR, the proposed conservation servitude area has been increased to include other areas outside of the development footprint. As requested, a sewer servitude (3 m wide) has been marked and has been excluded from the conservation servitude (see final layout, Appendix F). In addition, the area that was identified as “closed canopy indigenous vegetation” by Dave Styles in 2009 in the original vegetation report (Appendix AA) has been included in the Body Corporate Conservation Area. The Body Corporate Conservation Area, approximately 1 hectare in size, will fall between Wanda Cele Rd and the eastern portion of the development (Fig. 13). It is proposed that this area is maintained for conservation purposes (the responsibility of which will be the Body Corporate’s, as per the EMPr). This area will act as a refuge for indigenous flora and fauna. Prior to construction, any protected species that are within the development footprint will be relocated to the Body Corporate Conservation Area. As explained in the vegetation section of this report (Section 4), on-site relocation is the preferred method for removal of protected species. The proposed development will be comprised of:
- Development footprint, Eastern portion (1.25 ha) + Western portion (0.56 ha) = 1.81 ha; approximately 19% of the property
- Conservation Servitude = 5.85 ha; approximately 64% of the property - Body Corporate Conservation Area = 0.964 ha; approximately 10% of the
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property
All development activities will occur outside of the conservation servitude, except for the construction of two storm water headwalls and associated erosion control infrastructure that fall with conservation servitude. Protection of this valley will maintain connectivity of the DMOSS areas to the north and south of the site (Fig. 12). The applicant intends on donating the rights to full use of the conservation servitude to eThekwini Municipality. This will ensure long-term protection to the portion of land identified as ecologically important. There is potential for this conservation servitude to be linked to the existing iLanda Wilds Nature Reserve which runs along the Amanzimtoti River south of the site. Parts of this nature reserve serve as public open spaces for sport and recreational activities. Only undeveloped DMOSS land lies between the proposed conservation servitude and iLanda Wilds Nature Reserve, which are approximately 150 m apart (Fig. 13). If the rights to full use of the conservation servitude are, for any reason, not accepted by the municipality, the developer must implement environmental manage measures on this land. This responsibility would then lie with the body corporate during the operational phase (as per the EMPr, Sections 33-43). Clearing Invasive Alien Plants will be an important on-going requirement for maintaining the ecological health of this green space. As will monitoring and managing soil erosion and waste management (these mitigation measures are explained in greater deatail in the EMPr).
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Figure 12. Proposed developable area in relation to the DMOSS corridor. (Extracted from
vegetation report, Appendix A)
Figure 13. Location of proposed development and conservation servitude in relation to iLanda
Wilds Nature Reserve
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The Environmental Management Programme (EMPr), includes specific measures to ensure the construction and operation of the housing development has minimal adverse impacts on the ecological health of the site and surrounds. Some of the measures include:
• Only indigenous plants will be used for landscaping purposes.
• The site must be kept free of invasive alien plants
• Access to the protected portion of the property will be controlled.
• Sufficient waste management will be implemented to encourage recycling and reduce the risk of pollution to the surrounding environment.
• Stormwater management infrastructure must be correctly constructed and constantly maintained to reduce the risk of erosion and degradation of watercourses.
The no-go alternative will see the 9.4 hectares remain undeveloped. Unless actively prevented, the illegal activities resulting in environmental degradation shall continue.
9. APPLICABLE LEGISLATION The following legislation is relevant to the application:
• Constitution of South Africa: Act No 108 of 1996
• National Environmental Management Act: Act No 107 of 1998.
• National Environmental Management: Protected areas act
• Environmental Conservation Act: Act No 73 of 1989.
• National Heritage Resources Act: Act No 25 of 1999.
• KZN Heritage Act: Act 4 of 2008.
• National Water Act: Act No 36 of 1998.
• Hazardous Substances Act: Act No 15 of 1973.
• National Environmental Management: Act No 10 of 2004.
• National Environmental Management: Biodiversity Act 10 of 2004.
• Occupational Health and Safety Act: Act No 85 of 1993.
• Natal Nature Conservation Ordinance: Act No 15 of 1974.
• Subdivision of Agricultural Land Act: Act No 70 of 1970.
• Conservation of Agricultural Resources Act: Act No 43 of 1983.
• National Forests Act: Act No 84 of 1998.
• National Environmental Management: Waste Act: No. 59 of 2008.
10. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT These will be referred to in greater detail in the Environmental Management Programme (EMPr, Appendix F). An overview is provided below.
10.1. Solid waste management
The site falls within an area covered by municipal service provision. As such, municipal waste collection will be utilised. eThekwini Municipality’s Cleansing and Solid Waste Unit (DSW) have indicated that waste removal services can be made available once plans have been approved by council. Suitable areas for bins must be developed at both the Wade Road and Wanda Cele Road portions of the development (see correspondence in Appendix E). Solid waste is to be temporarily stored prior to municipal collection. The development will have two separate refuse rooms for solid waste storage; one along Wade Rd and the other
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on Wanda Cele Rd. The refuse rooms will be built to meet these recommended specification:
• Walled in by a 1.8m high wall • Doors to be minimum 1.2m wide • The doors must be solid so that the refuse is not visible or accessible to
vermin; • Each room must have a tap and floor level drainage gully (wash-down gully) • The gully must drain to the sewer and not to the storm-water system or to the
road • Stormwater from outside the refuse areas must not enter the gully • The gully is likely to be subject to blockage by spilt refuse. It is recommended
that a litter basket/catcher be installed to prevent blockages • If the storage area is roofed or if the storage area is in a room within a
building, adequate ventilation must be provided
10.2. Wastewater
10.2.1. Effluent No liquid effluent, other than normal sewerage, will be produced by the development. The development will require an internal waterborne sewer system that will connect to the existing eThekwini Water Services bulk sewer lines. A municipal sewer outfall exists along Wanda Cele Road. Correspondence with the municipality (Appendix E) indicates that they approve the application to provide this service, provided the proposed metro sewer line on Wanda Cele Road is constructed (which it now is). A sump and pump system will be required to transport effluent from the western portion of the development, along the north-eastern boundary of the property to connect with the sewer line on Wanda Cele Road. The sump and pump will be located on the north-eastern boundary, approximately 35m from the corner of the property/Wade Road (Fig 14). Since circulating the draft BAR, SiVEST amended the engineering (sewer, storm water and road) plans (Appendices K and L), which were in fact suited to an older layout of the development with more units. By raising the sewer line running around the edge of the western/wade Rd portion, the sump and pump were moved upslope from 70m from the road to 35m from the road, making it far more accessible and less risk to the drainage line in the valley. A 3m sewer servitude has been added along the length of the sewer line to allow access for maintenance and repair. The following will be included in the sewer pump station design:
• An automatic generator cross-over should mains power fail • Alarm system activated when the level of effluent in the pipes rises, indicating a
blockage or pump failure. Alert automatically sent to appointed contractor. • The sump will be designed to hold several days' capacity of effluent to allow
time to repair and maintain the system. • The pump and generator will be housed in a small enclosure with an
impermeable surface and bund walls (or similar secondary containment) large enough to contain at least 110% of the volume of fuel stored for the generator.
To reduce environmental impacts associated with installing this sewer line, HDPE sewer pipes with 160 mm diameter will be used. These heavy-duty pipes will be run above ground between concrete pillars. This way, minimal vegetation will be disturbed, there will be little risk of erosion, and the pipe can run horizontally from the western portion to the eastern portion of the development, thereby reducing the load on the pump. The total length of sewerage pipes for internal reticulation is 1047m.
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Figure 14. Sewer infrastructure for the western portion (Wade Rd) showing the sump, pump
and access from road via 3m wide servitude (image extracted from Engineering Plans,
Appendix K)
10.2.2. Storm water Where the gradient allows, storm water will drain into municipal storm water systems on Wade Rd and Wanda Cele Rd. Where storm water is diverted into the environment, headwalls will be in place and erosion control structures will be constructed. These will consist of rock mattress scour aprons (Fig. 15). The gabion structures are designed to dissipate the velocity of the flow and spread the runoff over a high surface area of rocks to allow for controlled infiltration and thereby preventing erosion. As sediment gets trapped between the rocks, vegetation will eventually establish on the mattresses. These structures are marked on the recently-updated engineering (storm water, sewer and roads) plans prepared by SiVEST (Appendix K and L). There will be one and two storm water outlets/erosion control structures on the eastern and western portions respectively. The number of inlets, outlets and pipe diameters of the storm water infrastructure are based on the flow calculations of the Storm Water Management Plan (Appendix J). Erosion was identified as a potentialy high risk associated with this development due the gradient of the valley. It is imperative therefore that measures are in place to reduce and control storm water run-off from the development footprint. The rock mattresses described above are highly effective at controlling the effects of storm water run-off. However, to further reduce potential erosion risks, the following have been included in the design of the housing development;
• Every unit will be fitted with a rain water harvesting tank to conserve water and reduce storm water volumes
• There will be no solid (concrete or tar) surface roads. As recommended in the Wetland Impact Assessment, permeable paving (Fig. 16) will be used throughout the development.
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Figure 15. Example of rock mattress scour apron to be constructed at storm water outlets. Very
effective means of dissipating flow velocity and reducing erosion risk
Figure 16. Examples of permeable paving to be used through the development to allow for
ready infiltration of storm water thereby reducing run-off and erosion risk. Images extracted
from Wetland Impact Assessment (Appendix B)
The EAP and engineers feel the above measures are more than adequate for addressing erosion risk associated with storm water run-off. Specific stipulation is made in the EMPr of close monitoring of storm water management infrastructure and signs of erosion, during construction phase (by the ECO) and operational phase (by the Body Corporate).
10.3. Emissions into the atmosphere
Very little in terms of emissions will be generated by the proposed development. During construction phase, dust and exhaust emissions are predicted from vehicles on the dirt road. If earth moving is to take place during winter months (when ground cover is reduced and the soils are dry) this may generate excessive dust. Considering the close proximity to residential properties, it is imperative that this dust be controlled. Where possible, clearing of vegetation should take place at a maximum of two months prior to building. Clearing of vegetation should take place sequentially on portions which will be
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built on next. This will avoid land being cleared of vegetation long before it will be built on. Plots cleared of vegetation are high risk in terms of dust generation and erosion. If the Environmental Control Officer deems dust an issue during construction, surface wetting can be considered as a means of controlling dust emission. Building materials of fine particles must be suitably protected from wind dispersion.
10.4. Generation of noise
Vehicles, construction and workers on site are likely to result in general disturbance and noise generation. It is an important impact to address and mitigate as the site is within close proximity to residential areas. During construction, building activity must be restricted to regular working hours during the week and is to be prohibited over weekends.
11. WATER USE
The development will not involve abstraction or discharge into/from any watercourse during construction and operational phases. The increase in hardened surfaces will result in a concentration of storm water run-off. A Storm Water Management Plan was drafted to address this (Appendix J). Since concern was raised regarding storm water runoff volumes, following circulation of the draft Basic Assessment Report, a number of features have been included in the proposed design and management of the development to mitigate storm water-related risks. These include:
- Use of permeable paving throughout the complex rather than cement or tar surfaces. This will increase infiltration of storm water and thereby reduce runoff volumes and potential erosion risks.
- Each unit have a storm water harvesting tank fitted to reduce the volume of storm water emanating from roofs.
- Temporary storm water infrastructure has been included as mitigation measures in the construction phase of the EMPr
- A combination of diversion into municipal storm water networks (wherever gradient has allowed) and discharge into the environment has been used for storm water management.
- Design recommendations were sought from engineers for suitable erosion control measures to be used at storm water headwalls. The most effective option (rock mattress scour aprons) have been included in the engineering plans and latest layout (Appendices F, K & L).
The following potential negative impacts relating to storm water run-off were identified during a Wetland Impact Assessment (Appendix B);
(i) Soil erosion and sedimentation; (ii) Pollution as a result of runoff from the development area entering into the
watercourse, and (iii) Disturbance within the area thereby increasing the encroachment of alien
invasive species. It is important that recommendations made by the wetland specialist and hydrologist (Appendices B and J) are adhered to in order to mitigate the above mentioned impacts. The discovery of surface water on the eastern portion of the property lead to the appointment of specialists to conduct a wetland impact assessment. The objective was to
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determine whether the wetness encountered was due to a wetland and whether this wetland was important in terms of its ecological role. It was discovered that the accumulation of water was the result of past cut and fill activity on the property (to create flat, developable platforms), which has exposed the underlying clay layer. This clay layer has formed an impermeable barrier to surface water, creating a ponding effect. The study concluded that “the seasonally inundated artificial wetlands provide no ecosystem goods and services to the larger catchment. Further to this, these areas do not provide sufficient ecological opportunities for indigenous floral and faunal species and can be considered to have a very low ecological importance. The removal of the artificial wetlands for the proposed development will not result in a net loss of wetlands within this catchment and it is recommended that the development proceed.” All water to be used for the development will be from the municipal supply. A Service Level Agreement is still to be obtained; however, a letter has been obtained from the water and sanitation unit of the municipality confirming they have capacity to provide bulk water services for the development (Appendix E).
11.1. Water use Licencing The Department of Water and Sanitation identified Section 21 c and i water use and therefore the need for a Water Use License Application. A pre-application meeting was held with the Department to discuss requirements. The applicant is aware that licensing is required before any construction can take place but wishes to finalise the Environmental Authorisation process before proceeding with the Water Use License Application.
12. ELECTRICITY SUPPLY Electricity for the proposed development will be supplied from the grid, via eThekweni Municipality’s Electricity Unit. A Service Level Agreement is still to be obtained but confirmation of capacity to supply electricity has been obtained (Appendix E).
13. ENERGY EFFICIENCY At this stage, no energy efficient technology is included in the proposed development.
SECTION C: SITE/ AREA/ PROPERTY DESCRIPTION
1. GRADIENT OF THE SITE The gradient of the site ranges from very flat platforms to steep valley slopes. The development footprint aligns with portions of the property that are flat. The western portion of the development will take place on an existing single platform. The eastern portion of the development will take place on a series of existing terraced platforms that decrease in altitude as one moves in a south westerly direction. These platforms are man-made; the result of cut and fill earth moving.
2. LOCATION IN LANDSCAPE The site straddles the upper reaches of a valley, through which a tributary of the
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Amanzimtoti River flows. As the crow flies, the site lies less than 2 km from the sea.
3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE
A geotechnical investigation was carried out by Geosure. Twelve inspection pits were excavated and soil samples were taken. The following finding are extracted from the Geotechnical Report (Appendix C):
- The geology of the site is characterised predominantly by fill and colluvial soils overlying weathered tillite bedrock of the Dwyka Group. Residual tillite soils are generally absent.
- Groundwater seepage was not encountered in any of the inspection pits during the course of the investigation. However, a shallow perched groundwater table is considered highly likely during periods of heavy rainfall and/or during the rainy season.
- The site is generally stable and suitable for development provided that the recommendations given in this report are adhered to.
Various recommendations have been made regarding the excavatability, foundation requirements and drainage. The report emphasizes the importance of surface and subsurface drainage to ensure the development is stable. The recommendations must be adhered to during construction and are addressed in the EMPr. Obviously, ensuring the site is geologically stable is as much an environmental concern as it is an engineering concern. As the Geotechnical report is dated 2009, Geosure carried out a site inspection in August 2017 to confirm the validity of the conditions in the original report. In a letter (Appendix C2) Geosure stated; “On the basis of our observations, it is considered that all observations, slope stability comments and development recommendations given in the above report by Geosure are considered to still apply to the site.”
4. VEGETATION Effort has been made to ensure the development is largely restricted to parts of the property which have been previously disturbed (the cleared platforms). As explained in the vegetation report update (Appendix A); “It is...evident that the areas that are under investigation for development, the platformed areas, have not become recolonised by sub climax/ climax vegetation but instead are mostly under alien vegetation and bare ground.” The edge of the primary coastal forest was re-assessed during the updated 2016 vegetation assessment. The forest and closed indigenous woody vegetation were afforded 10m buffers as was recommended by the specialist and approved by DAFF (See Appendix H for comments from DAFF on this matter). An initial vegetation study was conducted in 2009. This was updated in December 2016 to ensure any changes that have occurred to the vegetation in the past 7 years are detailed. The information below is extracted from the specialists’ reports and is simplified. Please refer to the reports for an in-depth description of the vegetation on site. See Appendix A for vegetation update report. The original vegetation assessment report is attached thereto as sub-Appendix A.
4.1. Biome and vegetation type The site falls within Northern Coastal Forest (FOz7) according to Mucina and Rutherford (2006) Vegetation Map. Least threatened in general, but still under threat on coastal dunes
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of KwaZulu-Natal (due to mining).
4.2. Species composition The vegetation on site can be categorised as follows:
• Primary Coastal Forest
• Closed indigenous woody vegetation outside the Primary Forest block
• Diffuse and scattered Millettia grandis-Melia azedarach trees
• Secondary grassland, infiltrated by alien species
• Platform Areas A total of 187 indigenous plant species that were recorded during this field survey, as well as 56 alien plant species. Ten (10) plant species are protected by Provincial Legislation and One (1) protected by Nationally Legislation were noted within the site.
4.3. Protected species Provincially protected species on site;
4.4. Conclusions and recommendations made by vegetation ecologist The potential developable site is considered to be degraded based on the presence and abundance of alien and pioneer species as well as permanent modification due to platforming and illegal dumping. The species that occur within the proposed developable area are primarily alien and indigenous pioneer forms, considered to be secondary successional communities. It is the opinion of the vegetation ecologist that the remainder of the site that is not primary forest be considered for development. The proposed development will prevent illegal dumping and if managed correctly, could prevent further degradation of the forest edge. If relocation of some of the protected species is required, a permit for their removal will need to be obtained from Ezemvelo KZN Wildlife (from provincially protected species) or DAFF (for Nationally protected species). Their removal should occur during the summer months and with due care, preferably by a qualified botanist or similarly qualified individual. The plants should be relocated into areas with the same aspect, soil conditions and elevation to ensure that the relocations are successful. In addition, the plants should be placed into good-sized holes that are at least twice the size of underground organs. It is very important for survival for underground organs not to be damaged and for plants to be watered for a period of time.
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Other recommendation made:
• Alien plants should be continued to be removed and managed, preferably mechanically and not chemically so as to have minimal ecological and biological impacts- for example on the wetland areas of site;
• Although a portions of the ERF is not recommended for development, it is possible and even encouraged to utilise these natural areas for recreation by way of natural walks, birding and possible picnic sites;
• Special attention should be given to protecting and enhancing the existing natural vegetation on site by incorporating the already established trees on site as part of the landscaping of the development. This will help to maintain a corridor of natural vegetation;
• In the event that any natural vegetation is required to be removed or destroyed, a vegetation specialist should be appointed to assist with the identification, recovery and relocation of the plant species by way of DAFF and Ezemvelo KZN Wildlife permit applications. The plants should then be utilised as part of the ongoing landscaping for the development.
4.5. Relocation of protected species There are three options available for removing listed protected species from the site prior to construction. These include;
• On-site relocation, • Off-site relocation, or • Off-setting by planting new individuals elsewhere (usually 5 per individual removed).
On-site relocation of protected species is the preferred option. Relocating individuals within the site will ensure higher survival rates as the biogeographical conditions are most similar to where the individuals are removed. This will improve the biodiversity and on-going ecological state of the area to where they are relocated. This will only take place following obtaining relevant permits for doing so from Ezemvelo KZN Wildlife (from provincially protected species) or DAFF (for Nationally protected species). Plants will be relocated to the Body Corporate Conservation Area (Fig. 13) on the eastern side of the development. Recommendations made by the vegetation specialist with regards to relocation of protected species must be adhered to, including:
- Removal must take place during summer months, by a qualified botanist or similar, - Plants must be placed in holes at least twice the size of the underground organs of
the plant - Following relocation plants must be watered to help establishment.
5. LAND USE CHARACTER OF SURROUNDING AREA
Land use within 500m of the site includes residential, education (primary school and pre-primary school), a place or worship and commercial use (shops and small businesses in Malagazi).
6. CULTURAL/ HISTORICAL FEATURES Based on site visits and information from the applicant, there appears to be no historical or culturally significant features on the property. There was a farm house on the eastern portion of the property but it has long since been demolished. The only noticeable remains are part of a retaining wall in the northeast corner of the property. Precautions will be
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included in the EMPr to ensure that if contractors find any artefacts on site it will be reported to the provincial heritage agency (Amafa) before any disturbance occurs.
SECTION D: PUBLIC PARTICIPATION
1. ADVERTISEMENTS Guidelines for public participation were followed according to section 24J of the National Environmental Management Act, 1998: (see Appendix E for photographs, adverts).
• A notice to register as an interested and affected party was advertised in the local newspaper, the South Coast Sun 24th February 2017.
• Neighbouring land owners were informed of the development.
• Ward Councillor was given background information on the development.
• A site visit was conducted with Department of Agriculture, Forestry and Fisheries.
• A meeting was held with eThekwini Municipality, Environmental Planning & Climate Protection Department representatives.
• A meeting was held with KZN Department of Economic Development, Tourism and Environmental Affairs, EIA Component representatives.
• Community organisations were contacted via email, direct contact and telephone.
• The draft Basic Assessment Report was made available at Amanzimtoti Library, with a notice on the public notice board indicating its whereabouts.
• All application documents and other background information was displayed and
publicly available on the ETC-Africa website at www.etc-africa.com/public-documents
• The following organisations or individuals registered as interested & affected parties
Name Title
Andre Beetge Ward 97 Councillor
Sobantu Ngidi Neighbour
Sobantu Ngidi Neighbour
Buhle Makhanya Neighbour
Musa Mzobe Neighbour
Philani Neighbour
Jonothan Feasey Owner of neighbouring business
Jaco Pienaar Neighbour
Mike Prachma Minister, Life Church, Amanzimtoti
Rico Life Church Staff and resident
Cathy Colley Amanzimtoti Sports Centre, Secretary
Craig Chamier Amanzimtoti Sports Centre, Chairman
John Arnold Resident
Angus Pyke Amanzimtoti Conservancy, Chairperson
Andrew Manning Chairperson of Toti Catchment Management Forum, Anglican Church
Siyabonga NP Buthelezi Scientific Manager: Water Quality Management
Department of Water and Sanitation Lwandle Sibango
Pongola-Umzimkulu Proto CMA : Water Quality Management
Department of Agriculture Forestry and Fisheries Ayanda Mnyungula Forestry Regulations and Support
Department of Agriculture Forestry and Fisheries
Nandipha Sontangane Forestry Regulations and Support
4. CONSULTATION WITH OTHER STAKEHOLDERS
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Letters were delivered to neighbours on Wade Road and a register was signed by neighbours on Wanda Cele Road. Evidence thereof can be found in Appendix H.
SECTION E: IMPACT ASSESSMENT
1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES Refer to Appendix H for full issues trail
2. IMPACTS THAT MAY RESULT FROM PHASES OF CONSTRCUTION
2.1. Impacts that may result from the planning and design phase The planning and design phase includes little onsite work or environmental risks, planning and design have largely been desktop exercises.
2.2. Impacts that may result from the construction/operational/decommissioning phases
The table below identifies the potential impacts identified for the construction, operation and decommissioning phases of the proposed Amanzimtoti Housing Development. The potential impacts are described and assessed for significance. Significance is assessed by scoring each impact based on four variables, including probability, severity, duration and spatial implications.
On the understanding that a significant impact is one which, whether in isolation or in combination with other impacts, could have a material influence on the decision-making process, including the specification of mitigation measures; significance in this report is scaled according to impact scores as follows:
• Low (scoring 9 or less)
• Medium (scoring between 10 and 15)
• High (Scoring 16 or more) The four variables, with their score criteria are detailed below: Frequency / Probability (FR) (Frequency or likelihood of activities impacting on the environment)
• 1: Almost Never / impossible
• 2: Very seldom / highly unlikely
• 3: Infrequent / Seldom
• 4: Often / Regular
• 5: daily / Highly regular Severity (SV) (Degree of change to the baseline environment in terms of reversibility of impact; sensitivity of receptor, duration of impact and threat to environment and health standards)
• 1: Insignificant / not harmful
• 2: Small / potentially harmful
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• 3: Significant / slightly harmful
• 4: Great / harmful
• 5: Disastrous / extremely harmful Duration (DR) (length of time over which activities will cause change to the environment)
• 1: One day to a month
• 2: One month to a year
• 3: One year to ten years
• 4: Life of project
• 5: Post closure Spatial Scope (SS) (Geographic overage)
• 1: Activity Specific
• 2: Site specific
• 3: Area
• 4: Regional
• 5: National
Nature of Impact Frequency Severity DR SS Impact Significance
Unm
itig
ate
d
Mitig
ate
d
Unm
itig
ate
d
Mitig
ate
d
Construction Phase
Traffic and access 5 4 2 2 3 3 12 Medium
Soil erosion 4 3 5 3 3 2 11 Medium
Groundwater Pollution 3 2 3 2 3 3 10 Medium
Surface Water 5 4 5 4 3 3 14 Medium
Noise and Disturbance 5 4 2 1 3 3 11 Medium
Destruction of Flora 5 2 5 3 3 1 9 Low
Disturbance of Fauna 4 2 3 1 3 2 8 Low
Health and Safety 5 3 4 2 3 1 9 Low
Waste and litter 5 3 3 2 2 2 9 Low
Visual Impacts 5 4 3 2 3 3 12 Medium
Total 33 23 23 13 23 19 78
Operational Phase
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Traffic and access 5 5 2 2 4 2 13 Medium
Soil erosion 3 2 3 2 4 2 10 Medium
Groundwater Pollution 2 1 3 2 4 3 10 Medium
Surface Water 5 2 5 2 5 3 12 Medium
Noise and Disturbance 4 4 1 1 4 3 12 Medium
Destruction of Flora 5 2 4 1 4 2 9 Low
Disturbance of Fauna 2 1 2 2 4 3 10 Medium
Health and Safety 3 1 3 1 4 2 8 Low
Waste and litter 5 5 5 4 4 4 17 High
Visual Impacts 5 5 2 2 4 3 14 Medium
Total 26 25 20 16 32 22 95
Decommissioning Phase
Traffic and access 3 2 2 2 2 3 9 Low
Soil erosion 5 4 5 3 5 2 14 Medium
Groundwater Pollution 5 3 5 3 2 3 11 Medium
Surface Water 5 3 5 4 5 3 15 High
Noise and Disturbance 5 4 4 3 2 3 12 Medium
Destruction of Flora 4 2 3 2 2 2 8 Low
Disturbance of Fauna 3 2 2 1 2 2 7 Low
Health and Safety 5 3 4 2 3 1 9 Low
Waste and litter 5 2 4 2 2 3 9 Low
Visual Impacts 5 4 4 3 5 3 15 Medium
Total 35 23 29 19 22 21 85
3. MITIGATION MEASURES
Mitigation means to make something less severe – this may be by implementation of practical measures to reduce, limit and eliminate adverse impacts. The potential environmental concerns have been considered and mitigation measures have been proposed. In many cases, the planning phase for the proposed development has already addressed potential impacts, particularly where specialist input has been fed into the design and planning. For example; the excavations and foundations for the
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development will be based on the geotechnical investigation findings, which will mitigate various potential environmental risks. The layout has taken into account sensitive vegetation and recommended buffers.
The mitigation measures below have been categorised according to impacts they address, during the construction and operational phases respectively. Further mitigation measures are presented in the Environmental Management Programme (Appendix I).
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Phase Mitigation measure
Traffic and access Construction Phase Vehicle access routes must be established and marked prior to
commencing on-site construction. It is recommended that poles and colourful (clearly visible) rope are used to mark the edges of the access roads to prevent gradual widening which commonly occurs on construction sites. Only the proposed accesses on both Wade Rd and Wanda Cele road (as per the approved layout) are to be used as access routes for the construction phase. Earthworks/stabilisation of roads must be carried out prior to heavy use the roads, especially the access from Wand Cele Rd where a retaining wall is required (see “Road 3” on Engineering Plans and Road Diagrams, Appendix K and L). Measures must be put in place (fencing/security) to prevent unauthorised access to the site, for the sake of safety, security and potential environmental degradation that may occur. Careful consideration must be made to traffic flow on Wanda Cele Rd. There are no pavements or verges here and this road experiences moderate traffic volumes. No construction vehicles are permitted to park on the roadside as this will disrupt traffic flow and endanger pedestrians. Access to the site (Wand Cele Rd portion) must be passable in time for first delivery of building materials to allow vehicles to move well beyond the road. Building materials must not be stored on road side on Wanda Cele Rd. This is less of an issue on Wade Rd, with a verge, easy site access and very low traffic volumes (being a dead-end road. Any damage to public or private roads caused by the Contractor during the construction phase will be repaired. Relating to construction of the entrance gate: Access will need to be recessed by 6 metres from the back of the boundary line to accommodate vehicles turning into the Wanda Cele Road entrance. Key responsibilities:
1. Site manager, under supervision of ECO - Ensure approved access roads are demarcated prior to heavy construction traffic.
2. Consulting engineer - Confirm stability of Wanda Cele Rd access prior to use by any vehicle exceeding 3 tons.
3. Site manager/ECO – daily inspection of access road demarcation and possible deviation of vehicles outside of roads/development footprint. Monthly audit check on this by ECO. Advise on other areas possibly requiring demarcation as no go area.
Operational Phase Internal road speed limits must be enforced. The electric gates must be kept in working order, to prevent traffic
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backing up into the road. Internal roads must be kept clear of leaves and sediment to prevent storm water inlets from becoming blocked. No street parking on Wanda Cele road is permitted as road reserve does not allow space. No off-road driving is permitted. Key responsibilities:
1. Body Corporate – to display speed limit signs, ensure gate is maintained and roads are regularly swept.
Soil erosion Construction Phase No go areas (edge of conservation servitude and body corporate
conservation area) must be physically demarcated with danger tape/rope/similar barrier throughout construction phase. This will deter activities on the steeper slopes where erosion is likely. Identification of no go areas must be included in Environmental Awareness Training for all on site personnel (carried out by contractor, following training with ECO). Correct stockpiling and stockpile location to avoid erosion. Stock piles should not be too high or too steep; generally, no steeper than 4:1 gradient. Stockpiles should be located around the perimeter of the project, away from the construction activity, but avoiding no go areas. Do not locate piles in or immediately adjacent to the drainage lines, or such that any runoff from the piles will end up in the valley/conservation servitude. Where it is not possible to move a top soil/raw material stockpile upland, place the soil behind a berm to prevent erosion. This is especially important on steep slopes. Silt fences must be used where there is a risk of top soil/raw materials being lost through run-off. The appointed Environmental Control Officer will be able to advise contractors on where and how these are to be installed. On areas susceptible to erosion, temporary storm water structures must be put in place during construction. These can include swales (which should be vegetated with grass), infiltration trenches (typically filled with gravel), detention ponds (excavated pond for temporary storage of storm water runoff), temporary seeding, mulching, surface roughening. The ECO should be consulted to advise on suitable temporary structures. Dirt tracks created by vehicles become compacted, reducing permeability and leading to surface runoff. Access roads and internal roads must be temporarily overlain with gravel during construction. This increases surface roughness, promoted
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infiltration, protects the soil surface from rainfall and runoff, and therefore greatly reduces the likelihood of erosion. Key responsibilities:
1. Site Manager – Must ensure all construction activity and staff movement is kept outside of no go areas
2. Site Manager - Must determine suitable locations for stockpiled materials.
3. ECO - monitor signs of erosion on slopes, access roads, internal roads and stock piles.
4. ECO – monthly monitoring of structural integrity and efficacy of storm water erosion structures (the rock mattress scour aprons) once installed. Report to consulting engineer should structures be damaged or ineffective.
Operational Phase Regular monitoring for signs of erosion throughout the complex and the scour aprons in the conservation servitude. Grass or other ground cover must be maintained on any open areas to protect the soil from erosion. Clearing of vegetation in the conservation areas (servitude and internal) must be prohibited. Key responsibilities:
1. Body Corporate – Must monitor erosion and appoint suitable contractor to rectify if erosion is encountered.
2. Body Corporate – Body corporate rules must prohibit clearing of vegetation anywhere other than within the development footprint.
Groundwater Pollution Construction Phase Secondary containment must be in place for all hazardous goods
stored on site. This can be in the form of a temporary bund area, trays or containers. Secondary containment must be large enough to contain 110% of the volume of goods stored. Hazardous goods (e.g. fuels and solvents) stored on site must be securely locked to prevent theft, and harm to persons or the environment through misuse. The relevant hazardous warning signs/stickers must be displayed. A spill response kit must be kept on site and accessible throughout construction period. Environmental awareness training must include prevention and response to hazardous spills. A suitable area must be designated for waste storage during construction, with specific accommodation for hazardous waste.
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Hazardous waste volumes are expected to be low for the development but may include empty paint tins, rags containing oil or solvents, spent oil etc. This waste is to be stored on a hardstand surface and protected from rain. Waste must be inaccessible to scavengers and unauthorised person. Hazardous waste may not be disposed of at any municipal landfill. Hazardous waste must be disposed of at a licensed facility. A third party can be used for removal and disposal of hazardous waste. A receipt or certificate of safe disposal must be kept by the site manager or ECO in the on-site environmental file. Vehicles and machinery to be kept well maintained and serviced to prevent fuel/oil spills. No servicing of vehicles is permitted on site. Drip trays must be in place for earth moving equipment, vehicles and generators kept on site. Key responsibilities:
1. Site Manager – must ensure correct waste storage areas are available from the start of the construction phase.
2. Site manager – Must maintain the on-site environmental file, including records of safe disposal of all hazardous waste collected.
3. Site manager and contractors – Are responsible for ensuring the day to day operating of equipment and machinery is done in such a way as to prevent hazardous spills; drip drays, secondary containment, vehicles maintained and serviced.
4. ECO – Must monitor monthly to confirm hazardous goods and hazardous waste are being correctly handled, stored and disposed of.
5. ECO – to include groundwater pollution prevention measures in environmental awareness training.
Operational Phase No hazardous chemicals (fuels, cleaning detergents etc) may be stored outside within the sectional title properties or body corporate grounds. Hazardous goods must be kept on hard stand surfaces, undercover and locked to prevent tampering. Key responsibilities:
1. Body Corporate – to include the above in body corporate rules and monitor residents’ compliance
Surface Water Construction Phase All mitigation measures mentioned above apply to surface water
as well as groundwater, as any contaminants on site will either infiltrate into groundwater or be removed with stormwater runoff, which will ultimately enter drainage lines and the Amanzimtoti
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River, or tributaries thereof. Construction of the sewer pipe bridge to be done under close supervision. Columns to be constructed as far on either side of the drainage line as structurally possible. Any cement mixing to be done for construction of this bridge must not take place in the drainage line. Apart from contaminants, surface water quality can be impacted by sedimentation resulting from erosion and subsequent runoff. As such, the erosion control measure listed above are of relevance to surface water preservation. A silt fence is a temporary sediment control device used on construction sites to protect water quality in nearby watercourses from sediment in stormwater runoff. Silt fences should be erected where vegetation has been removed on a slope water naturally drains (i.e. a disturbed drainage line). If erosion and sedimentation is deemed to be an issue during construction, temporary stormwater structures must be urgently implemented, such as those listed under erosion control measures above. Any mitigation measure that retains water, slows runoff velocity, and promotes infiltration will reduce sedimentation as well as erosion. All materials for construction must be sourced from sustainable and appropriately licenced stock (sand, stone etc.), as this will reduce the indirect impact of the development on surface water quality at the point of mineral extraction. Key responsibilities:
1. As per erosion and ground water sections above 2. Site manager – ongoing monitoring for signs of
erosion/sedimentation. Relaying information to ECO 3. ECO – Monthly audit must include thorough examination
of the perimeter of the development footprint (the steep slopes of the valley/conservation servitude) drainage lines, stockpiles and roads for signs of erosion.
4. ECO – Must be available to advise on immediate implantation of erosion control measures where necessary.
Operational Phase Roads must be kept clear of sediment to prevent water quality impacts through stormwater discharged into the environment. Regular monitoring of the sump, pump and generator for sewer reticulation is essential. A third party must be contracted to maintain and services the system. An automated alarm system must be in place to alert the body corporate of potential blockages or pump failure. The system must remotely notify the contracted party, with whom a 24/7 response arrangement is in place. Automatic generator switchover must be in place in case of main
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power failure. Stored fuels for the generator must be within secondary containment, undercover and locked. Key responsibilities:
1. Body Corporate – is responsible for appointing the contractor for maintaining the sewer system, and ensuring fuels are correctly stored.
Noise and Disturbance Construction Phase Construction is to be limited to standard working hours (07H00-
17H00) only. No construction may take place during weekends and public holidays. Construction vehicles will be fitted with standard silencers prior to the beginning of construction. Equipment that is fitted with noise reduction facilities (e.g. Side flaps, silencers etc.) will be used Dust suppression measures must be available if required; during windy, dry conditions or when high volumes of construction vehicles are expected on gravel access roads. Surface wetting will suffice for this development. No fires will be permitted for any purposes whatsoever. Lime, concrete and other powders must not be mixed during excessively windy conditions. Bulk earth moving must not coincide with windy conditions, especially during the dry winter season. A complaints register must be kept by the site manager in the environmental file. Any complaints received regarding noise, dust and other possible disturbances must be recorded in the complaints register. No activity is to occur on neighbouring land unless written consent and arrangements have been made with land owners prior to commencing the development. Key responsibilities:
1. Site manager – ensure working hours are adhered to. 2. Site manager – implement dust suppression measures
when required. 3. Site manager – Keep concise record of complaints
received and actions implanted to address the complaints. 4. ECO – to monitor on a monthly basis, review complaints
register and advise on additional mitigation measures.
Operational Phase Noise must be kept to reasonable levels so as to not disturb neighbour within and outside the complex. Loud music should not be played past 11pm unless permission from the body corporate
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is obtained in advance. Speed limits must be adhered to and unnecessary revving of vehicles is not permitted. Bon fires (burning of garden refuse) is not permit. Key responsibilities:
1. Body Corporate – to include the above in body corporate rules and enforce
Destruction of Flora
Construction Phase No go areas must be clearly marked and indicated to all contractors and on-site personnel (during environmental awareness training) to avoid disturbance to the conservation servitude and body corporate conservation areas. This is where there is highest biodiversity of flora. A suitably qualified person must be appointed to earmark and where necessary relocate protected plant species. These must be relocated to the body corporate conservation area on site. As per vegetation specialist’s recommendations;
- relocation must take place during summer, - holes must be at least twice the size of the plants’
underground organs and - plants should be watered following planting until
established.
Before removal of protected species, relevant licenses will need to be obtained. For nationally protected species, the issuing authority would be the Department of Agriculture, Forestry and Fisheries. For provincially protected species which may be encountered, a permit must be obtained from Ezemvelo KZN Wildlife. The listed invasive alien plants are to be controlled as stipulated by their category in the National Environmental Management: Biodiversity Act (10/2004): Alien and Invasive Species List, 2014. The applicant is responsible for clearing of invasive alien plants during the construction phase (to be monitored by the ECO). This responsibility applies to controlling invasive alien plants within the development footprint, in the body corporate conservation area, as well as the conservation servitude (until such time as the rights to this servitude are donated to the Municipality). Care must be taken once clearing of current vegetation has begun, as disturbance to the soil creates a habitat for opportunistic invasive plants, which can be detrimental to the ecological integrity of the area. Key responsibilities:
1. Contractor – to abide by rules regarding no go areas 2. Site manager – To ensure daily activities are kept within
development footprint
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3. Applicant – to appoint suitably qualified persons to control alien invasive plants
4. ECO – To monitor compliance with above and other measures in the EMPr
Operational Phase Fences around the conservation servitude and body corporate conservation area must be maintained to prevent access. No person is permitted to remove any plant from the conservation servitude or body corporate conservation area unless part of a management plan (i.e. for removal of alien plants). A suitably experienced company must be appointed to regularly clear invasive alien plants within the body corporate conservation area, and the conservation servitude (until such time that the municipality obtains full rights to use.) Key responsibilities:
1. Body Corporate – must maintain fencing, prohibit access to conservation servitude and appoint person/s to clear invasive alien plants.
Disturbance of Fauna Construction Phase No trapping/hunting is to be permitted on site, in the conservation
areas or on neighbouring land. All construction activity, storage of materials, movement of construction worker etc. must be restricted to the development footprint as per the layout. Any activity within no go areas is strictly prohibited and must be enforced. Waste must be correctly stored in a suitably constructed structure to prevent wildlife gaining access to waste. Any hazardous goods must be securely stored to prevent potential harm to fauna. Key responsibilities:
1. Contractor – to abide by rules regarding no go areas 2. Site manager – To ensure daily activities are kept within
development footprint 3. ECO – To monitor compliance with above and other
measures in the EMPr
Operational Phase Fences around the conservation servitude and body corporate conservation area must be maintained to prevent access. Strict rules regarding hunting or trapping wildlife must be included in body corporate rules Key responsibilities:
1. Body Corporate – Body corporate rules relating to above measures must be enforced.
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Health and Safety Construction Phase All relevant Health and Safety legislation as required in South
Africa should be strictly adhered to including the Occupational Health & Safety Act, 1993 (Act No. 85 of 1993). Personal Protective Equipment (PPE) must be provided for all on-site personnel. Potentially hazardous areas (i.e. trenches) must be demarcated and clearly marked. Sufficient toilets must be made available for workers during construction. The conditions of the Environmental Management Programme (refer to Appendix I) must be implemented and monitored. Key responsibilities:
1. Contractors – to ensure they comply with Occupational Health & Safety Act.
2. Contractors – to ensure all staff have PPE 3. Site manager – to ensure potential hazards on site are
marked. 4. ECO – To include review of all Heath and Safety
measures in monthly audit.
Waste and litter Construction phase All relevant legislation with regards to the National Environmental
Management: Waste Act, 2008 (Act 59 of 2008 must be adhered to. Ensure correct waste management, sorting and recycling of materials used for construction. Waste should be stored in scavenger proof bins. Bins must be secured in an area specifically designed, constructed and maintained for such purpose. No dumping of litter or construction rubble is permitted anywhere. Waste may only be disposed of at a licensed landfill. Hazardous waste may not be disposed of at any municipal landfill. Hazardous waste must be disposed of at a licensed facility. A third party can be used for removal and disposal of hazardous waste. A receipt or certificate of safe disposal must be kept by the site manager or ECO in the on-site environmental file. Key responsibilities:
1. Site manager- to ensure suitable waste collection points are provided and waste is stored as per EMPr.
2. Site manager- to ensure regular removal of waste from the storage area for disposal at a registered landfill or by a 3rd party in the case of hazardous waste.
3. Site manager- must obtain and file safe disposal certificates for hazardous waste
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4. ECO - To monitor and report on state of waste management practices
Operational Phase The complex, the body corporate conservation area and the verge/entrance must be kept clear of litter Refuse rooms are to be suitably maintained to contain litter, keep refuse dry and prevent access by scavengers. Recycling should be encouraged within the complex. Body corporate must ensure that refuse is neatly placed on kerb side for weekly municipal collection. Key responsibilities:
1. Body Corporate – to include the above in body corporate rules and maintain the refuse rooms
Visual Impacts
Construction Phase
Construction site must be kept clean and orderly at all times. No litter or rubble should be allowed to accumulate on site. No raw materials are to be stored on the verge or anywhere that may be visually offensive to neighbours or traffic. The entrance the development must be kept clean. Wanda Cele and Wade Road must be kept clean. Any sediment on the road emanating from the development site must be regularly swept up. Any complaints received regarding visual impact of construction activities must be recorded in the complaints register. Additional measure (e.g. screening with shade cloth) must be put in place should complaints be received. Key responsibilities:
1. Site manager – to ensure all measures necessary are in place to keep the site and adjoining roads clean.
2. ECO – Monitor and report on the state of the construction site and complaints register.
Operational phase The appearance of the housing development must be maintained. Body corporate rules must include the fact that the body corporate maintains the authority to advise a resident or owner to take necessary action for upkeep of the sectional titles; including keeping gardens maintained, free of litter and external walls clean. The entrance and access road must be kept in clean and litter free.
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Key responsibilities: 1. Body Corporate – body corporate rules must adequately
address the need for mitigating adverse visual impacts.
4. SIGNIFICANT RECOMMENDATIONS MADE BY SPECIALISTS
4.1. Geotechnical-related recommendations (from the Geotechnical Investigation Report, Appendix C):
• Based on the results of the fieldwork undertaken during this investigation, it is considered that this site is generally stable and suitable for development, provided that the recommendations given in this report are adhered to.
• The upper northern portion and the southeastern portions of the site comprise cut platforms with fill embankments. The fill embankments are not engineered (uncontrolled fill) and no development may take place on the fill embankments in their current state.
• The characteristics of the materials found on site and their suitability for use in construction is provided in Table 3 of the Geotechnical Report. Use of materials for construction purposes must follow the recommended uses accordingly.
• All earthworks should be carried out in a manner to promote stable development of the site. It is recommended that earthworks be carried out along the guidelines given in SANS 1200.
• Where natural ground slopes are steeper than 1 vertical to 6 horizontal, the fill must be benched into the slope. Benches should be 0,5m deep and 2,0m wide.
• Placement of fill layers should be undertaken in layers not exceeding 200mm thick when placed loose and compacted using suitable compaction plant to achieve 93% Modified AASHTO maximum dry density.
• Terraces should be graded to direct water away from the fill edges, and small earth bunds (walls) should be constructed along the crests of fills, to prevent overtopping and erosion of fill embankment slopes. These bunds should be a minimum 450mm wide and 300mm high.
• Cuts in weathered tillite bedrock should not exceed gradients of 1 vertical in 0,75 horizontal (53o). Inspection of cuts in weathered tillite by a competent engineering geologist or geotechnical engineer may indicate that the angle of cut batter slopes need to be varied locally to promote stability of the site.
• Foundation design recommendations as presented in the Geotechnical Report and in accordance with the National Home Builder’s Registration Council (NHBRC) must be adhered to.
• The most important factor in the stable development of the site is the control and removal of both surface and groundwater from the site.
• Earthworks and drainage measures should be designed in such a way as to prevent ponding of, or high concentrations of, stormwater or groundwater anywhere on the site, both during and after the development.
• The terrace should be shaped to a gradient to prevent water ponding on the surface and should be graded to direct water away from the fill edges and foundations.
• Where unsuitable subgrade material is present for road and parking construction, recommendations in terms of depth of cut and height of fills need to be adhered to.
4.2. Hydrological-related recommendations (from the Wetland Impact
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Assessment Report, Appendix B):
• Based on the findings of this assessment, the seasonally inundated artificial wetlands provide no ecosystem goods and services to the larger catchment. Further to this, these areas do not provide sufficient ecological opportunities for indigenous floral and faunal species and can be considered to have a very low ecological importance. The removal of the artificial wetlands for the proposed development will not result in a net loss of wetlands within this catchment and it is recommended that the development proceed.
• Attenuation of stormwater from the development site is important to reduce the velocity of runoff into the downstream wetland area.
• Attenuation measures during construction include but are not limited to - the use of sand bags, hessian sheets, silt fences, retention or replacement of vegetation and geotextiles such as soil cells which must be used in the protection of slopes.
• Long term attenuation measures are recommended in the design of the development and can include permeable paving; infiltration trenches or swales. Examples are given in the Report.
• Indigenous landscaping in open areas needs to be incorporated in the management plan.
• Do not allow surface water or storm water to be concentrated, or to flow down cut or fill slopes without erosion protection measures being in place.
• Vegetation clearing must be undertaken only in the areas to be developed and must not extend outside of the development footprint.
• The implementation of soft engineering measures, Sustainable Drainage Systems (SuDs) and Level Spreaders are recommended to mitigate the impacts associated with increased stormwater runoff.
• Level Spreaders are measures that reduce the erosive energy of concentrated flows by distributing runoff as sheet flow to stabilised vegetative surfaces. Further to this, they also promote the infiltration of surface water thereby causing filtering and improving water quality.
• It is also recommended that grassed swales be used with a few depressions into which the stormwater can be discharged.
• All waste generated during construction is to be disposed of as per an Environmental Management Programme (EMPr) and washing of containers, wheelbarrows, spades, picks or any other equipment that has been contaminated with cement or chemicals in the identified watercourses must be strictly prohibited.
• Proper management and disposal of construction waste must occur during the construction of the development.
• Waste disposal during the operational phase must ensure no litter or other contaminants on site are deposited in the downstream water resource environment.
• No release of any substance i.e. cement or oil, that could be toxic to fauna or faunal habitats within the watercourse.
• Spillages of fuels, oils and other potentially harmful chemicals must be cleaned up immediately and contaminants properly drained and disposed of using proper solid/hazardous waste facilities (not to be disposed of within the natural environment). Any contaminated soil must be removed and the affected area rehabilitated immediately.
• Ongoing alien plant control must be undertaken after the construction phase and during the operational phase. An ongoing management plan must be implemented for the clearing/eradication of alien species.
• It is recommended that indigenous species are planted in the garden/landscaped areas to control the spread of alien species outside of the development area.
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4.3. Other hydrological-related recommendations (from the Storm Water Management Plan, Appendix J):
• The housing development should take consideration of any area where dirty water flows through the site. These areas should be considered as critical areas. This is particularly important during construction. Drip trays should be used at all times and spill management kits should be readily available in the event of petro-chemical spillage.
• Where possible, oil should be recycled which would reduce the volumes on site. Road surfaces should be regularly cleaned to avoid the build-up of petro-chemicals.
• In the event of a severe storm, construction activities should be temporarily stopped to avoid spills and potential contamination.
• Plants should be planted and maintained in and around retaining walls to improve the structural stability of the site and to prevent erosion.
• Any clean water paths (gutters etc.) should not be directed into dirty water systems.
• Flow paths adjacent to roads and from houses must be adequately protected from erosion and roughened to decrease the kinetic energy of the flow to that of a pre-development state.
• Roads should be managed in such a way that infiltration is allowed in certain areas, this will aim to restore sustained contributions to the watercourse located in the centre of the site.
4.4. Other specialist recommendations (from the Traffic Impact Assessment Report, Appendix D and Vegetation Assessment Report, Appendix A):
Recommendations made by these specialists are included in the body of the Basic Assessment Report above; traffic-related recommendation under Section B7 (“Access”) and vegetation-related recommendations under Section C4 (“Vegetation”).
5. PROPOSED MONITORING AND AUDITING
Construction phase: It is recommended that monitoring be done by an appointed independent Environmental Control Officer through monthly construction monitoring and audits ensuring compliance with an Environmental Management Programme (EMPr), conditions of the Record of Decision and recommendation made by specialist and authorities. Operation phase: Post construction monitoring/audits should be undertaken annually for the first two years of operation to ensure the EMPr requirements have been met. Decommissioning phase: In the possible event of decommissioning, monitoring/audits should be undertaken monthly during the decommissioning process to ensure the EMPr requirements for decommissioning are being adhered to.
6. ENVIRONMENTAL IMPACT STATEMENT
It is the opinion of the EAP that the proposed housing development should be constructed. The footprint of the proposed development is largely limited to previously disturbed (platformed) land and/or areas currently impacted on by large-scale dumping, and
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unauthorised operation of earth moving equipment. Provided the mitigation measures in the Basic Assessment Report and the EMPr are adhered to, we envisage minimal adverse impacts to the portions of the property that are of high ecological importance. This opinion is based on information in this report and the specialist reports.
SECTION G: APPENDICES
APPENDIX A. VEGETATION ASSESSMENT REPORT (UPDATED VERSION 2016)
APPENDIX B. WETLAND IMPACT ASSESSMENT (2017)
APPENDIX C. GEOTECHNICAL REPORT (2009)
APPENDIX C2. VALIDATION OF GEOTECHNICAL REPORT (2017)
APPENDIX D. TRAFFIC IMPACT ASSESSMENT (UPDATED VERSION 2017)
APPENDIX E. CONFIRMATION OF CAPACITY TO PROVIDE SERVICES
APPENDIX F. LAYOUT
APPENDIX G. SITE PHOTOS
APPENDIX H. PUBLIC PARTICIPATION
APPENDIX I. ENVIRONMENTAL MANAGEMENT PROGRAMME
APPENDIX J. STORM WATER MANAGEMENT PLAN
APPENDIX K. ENGINEERING PLANS, STORMWATER, SEWER AND ROADS
APPENDIX L. ENGINEERING PLANS, CROSS SECTION PLANS
APPENDIX M. HYDROLOGIST’S LETTER REGARDING FLOODLINE ASSESSMENT
APPENDIX N. DECLARATIONS AND CV’S OF EAP AND SPECIALISTS
