GROOT DRAKENSTEIN SEWER BASIC ASSESSMENT
SPECIALIST REPORT: AQUATIC STUDY
PREPARED BY:
Earl Herdien Pr.Nat.Sci. (Reg No. 400211/11) Senior Environmental Consultant (Water)
SSI – Engineering and Environmental Consultants
Tel: +27 (0) 21 9367600 Fax: +27 (0) 21 9367606
Tel (Direct): +27 (0) 21 9367692 Mobile: +27 (0) 73 019 4824
Email: [email protected] www.ssi-dhv.com
J31020 January 2012
DECLARATION OF INDEPENDENCE
I, __________________________________ as duly authorised representative of
________________________________ [reference to specialist’s employer], hereby confirm my
independence (as well as that of _______________________ [reference to specialist’s employer]) as a
specialist and declare that neither I nor _____________________ [reference to specialist’s employer]
have any interest, be it business, financial, personal or other, in any proposed activity, application or
appeal in respect of which Arcus GIBB was appointed as environmental assessment practitioner in terms
of the National Environmental Management Act, 1998 (Act No. 107 of 1998), other than fair
remuneration for worked performed, specifically in connection with the Environmental Impact
Assessment for the proposed [insert project name]. I further declare that I am confident in the results of
the studies undertaken and conclusions drawn as a result of it – as is described in my attached report.
Signature: ______________________________
Full Name:
Date:
Title / Position:
Qualification(s):
Experience (years/ months):
Registration(s):
EXECUTIVE SUMMARY
The Cape Winelands District Municipality has commissioned the Water Specialist Environmental
Consulting Service of SSI Engineering and Environmental Consulting to undertake an Aquatic
Ecological Study for the proposed Groot Drakenstein Bulk Sewer Pipeline.
The proposed development site investigated was in a predominantly good water quality state;
with a moderately transformed state for habitat integrity; and in a poor state for riparian
vegetation. In terms of the sampling site’s ecological importance and sensitivity it was assessed
as being high and classed as a D-class in respect to its overall ecostatus ecological management
category.
The impact of the proposed development is expected to be limited to the river crossing and can
be mitigated against. The following measures are recommended to mitigate likely impacts of the
pipeline construction:
No construction vehicles should be allowed within 15m of the berg river water edge,
except for those authorised to undertake activities applied for under section 21 c & i of
the National Water Act (Act 36 of 1998) and/or within the context of an endorsed Water-
Use License. Limited disturbance should be allowed within this buffer zone and as far as
possible the disturbed areas should be rehabilitated with vegetation characteristic of the
area’s biodiversity.
Where the pipeline route crosses the drainage lines, there should be minimal use of
machinery and disturbance within these areas should be kept to a minimum.
The rehabilitation and re‐vegetation of disturbed areas must take place during or
immediately after construction is complete. Only appropriate indigenous riparian
vegetation may be used for rehabilitation and re‐vegetation within the disturbed area.
Clearing or felling of all alien invasive trees should take place along the pipeline route.
Colonisation by alien invasive vegetation must be removed as soon as noted.
Clearing of debris and hard rubble associated with the construction activities should be
undertaken on completion of the pipeline construction activity.
Stormwater associated with the construction activities must be prevented from entering
the river as far as possible.
Other activities that may lead to elevated levels of turbidity must be minimised.
Contaminated run‐off from the construction site should be prevented from entering the
wetland areas and drainage systems. If possible construction activities should take place
during the low rainfall months when run off volumes will also be low.
Pipeline installation must not significantly obstruct the natural movement of water through
the surrounding landscapes’ soil profile (can result in localised damming and formation of
wet areas or ponds).
In conclusion, largely localised water quality impairment, flow modification and bed modification
associated impacts are likely to occur with the proposed construction phase. The maintenance
phase period of the proposed development only identifies impacts related to the physical damage
of the pipeline and associated impacts related to extreme events. The potential impacts identified
can be mitigated with the sound implementation of management measures and a compliance
audited environmental management programme.
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BASIC ASSESSMENT FOR THE PROPOSED GROOT DRAKENSTEIN SEWER
CONTENTS
Chapter Description Page
1 INTRODUCTION 3
1.1 Background 3
1.2 Legislative and Policy Context 4 1.2.1 NEMA and Environmental Impact Assessment Regulations 4 1.2.2 National Water Act, 1998 (Act No. 36 of 1998) 4
1.3 Development Alternatives 5
1.4 Assessment Methodology 8 1.4.1 Approach 8
(a) Study Area Review: 8 (b) Ground-truth Studies: 8 (c) Study Analysis: 8
1.4.2 Assumptions and limitations of the Study 8 1.4.3 Use of the Report 9
2 DESCRIPTION OF AFFECTED ENVIRONMENT (STUDY REVIEW) 10
2.1 Visual characteristics, climate, ecology and land uses 10
2.2 Freshwater Assessment of the Berg River 14 2.2.1 Water Quality/Macroinvertebrates 16 2.2.2 Index of Habitat Integrity 17 2.2.3 Riparian Vegetation Index 19 2.2.4 Ecological Importance and Sensitivity (EIS) 21 2.2.5 Overall Ecostatus and Recommended Ecological Management Category 22
3 ASSESSMENT OF IMPACTS 23
3.1 Potential Impacts 26 3.1.1 Construction and Operational Phases 26
3.2 Mitigation Measures 31 3.2.1 Construction 31 3.2.2 Operation 32
4 REFERENCES 33
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APPENDICES Appendix 1: Aquatics Study Field Survey
ABBREVIATIONS
BA Basic Assessment DEA Department of Environmental Affairs DWA Department of Water Affairs PPP Public Participation Process WULA Water Use License Application EMProg Environmental Management Program RHP River Health Programme SASS5 South African Scoring System version 5 IHAS Index of Habitat Assessment RVI River Vegetation Index IHI Index of Habitat Integrity EIS Ecological Importance and Sensitivity
PROVISION OF PROFESSIONAL AQUATIC ECOLOGICAL STUDY - PROPOSED GROOT DRAKENSTEIN BULK SEWER PIPELINE January 2012
1 INTRODUCTION
1.1 Background
The Cape Winelands District Municipality has commissioned the Water Specialist Environmental
Consulting Service of SSI Engineering and Environmental Consulting to undertake an Aquatic
Ecological Study for the proposed Groot Drakenstein Bulk Sewer Pipeline. As a result, an ecological
assessment has been undertaken to determine the current status of significant aquatic resources
potentially impacted by the proposed construction of a bulk sewer pipeline crossing and running-
along the Berg River, within the Groot Drakenstein area. In addition, potential construction impacts
and recommendations for undertaking the proposed development in compliance with relevant
environmental regulations are identified, assessed and discussed. The focus of the study aims to
provide a reference in terms of the National Environmental Management Act (1998), Environmental
Impact Assessment Regulations (2006 and 2010) and National Water Act (1998) Section 21
development considerations for water resource land-use and potential development impacts
associated with the construction and these regulations. The findings in this report will provide a
reference for input into the Basic Assessment (BA) of Arcus Gibb Engineering and Science as well as
the Information Questionnaire reference to the processing of the Water Use Licence Applications
(WULA) of Aurecon.
Figure 1: Earth Google image of the proposed development area (red line indicates the proposed development route).
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Task: Freshwater assessment and identification of impacts from the proposed development and the
provision of recommended mitigation measures
Conduct an assessment based on existing information for the area and contextualise
according to the focus of the proposed developments study.
Conduct a freshwater assessment, which includes mapping and descriptions of the
freshwater features in the proposed development footprint, GIS sensitivity analysis and
current state of the freshwater/wetland features within and related to the development
footprint.
Evaluate the proposed development activities for the various alternatives, the potential
impacts, and propose mitigation measures for the proposed development.
Write up findings and recommendations for the WULA submission to the relevant
authorities.
Write up findings and recommendations for the BA submission to the relevant authorities.
1.2 Legislative and Policy Context
This development aims to be in alignment with the guidelines and principals of the National Spatial
Development Perspective, the Development Facilitation Act, the Water Services Act, the Berg River
Internal Strategic Perspective, the National Water Act and the National Environmental Management
Acts, amongst others.
1.2.1 NEMA and Environmental Impact Assessment Regulations
In terms of undertaking an EIA process and in terms of compliance with NEMA, the proposed
development does involve ‘listed activities’, as defined by NEMA (Listed activities are activities, which
may have potentially detrimental impacts on the environment and therefore require environmental
authorisation from the relevant authorising body) as the proposed development construction activity
does falls within 32 meters of the Berg River margin.
1.2.2 National Water Act, 1998 (Act No. 36 of 1998)
The National Water Act guides the management of water in South Africa. The Act aims to regulate
the use of water and activities that may impact on water resources through the categorisation of
‘listed water uses’ encompassing water extraction and flow attenuation within catchments as well as
the potential contamination of water resources, where the Department of Water Affairs (DWA) is the
administering body in this regard.
In terms of the definitions provided from these regulations, activities included under Sections 21(c)
and 21(i) are (amongst others) the construction of roads, bridges, culverts and structures for slope
stabilisation and erosion protection. Infilling of floodplains is also considered by DWAF to be a
Section 21(i) activity. The Berg River "bed", "banks" and "watercourse" will be impacted with the
construction of the proposed pipeline. Listed activities require the approval of DWAF in the form of a
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Water Use Licence application. The proposed pipeline development will require a Section 21 (c) & (i)
Water Use Authorisation.
Section 22(3) of the National Water Act allows for a responsible authority (DWA) to dispense with the
requirement for a Water Use Licence if it is satisfied that the purpose of the Act will be met by the
granting of a license, permit or authorisation under any other law. This provision is rarely used but
should be discussed with DWA and provincial environmental officials (in a pre-application phase) to
ascertain whether compliance is necessitated, as the proposed development does fall within the
1:50yr or 1:100 floodlines.
1.3 Development Alternatives
The proposed development consists of bulk sewer pipeline infrastructure (approximately 5km of
‘heavy duty uPVC gravity sewer mains, approximately 600m of rising mains and related sewage
pumps), connecting the Pearl Valley Treatment Works with the wastewater from Portion 1 of Farm
1006 Meerlust. It has been identified as part of the proposed developments BA application that the
pipeline route will cross the Berg River main stream found within the project footprint.
Development alternatives are limited to pipeline installation: using a gravity fed system (preferred
alternative) or pressure pump system.
Excavations:
Most excavations will be done by machine, except in areas where hand excavations will be required.
One reason for hand excavations is restricted access for machinery.
Excavation material stockpiling:
Pipeline trench excavation will take place in accordance with specifications as per SABS 1200. All
working activities will be confined to the registered servitude area, with the exception being the
alternative agreement reached with the relevant property owner.
Stockpiling of excavated material will be restricted to the registered servitude area. To assist with
ensuring that stockpiling will be contained to the registered servitude area, the following actions are
proposed:
Contractor to submit programme to Engineer prior to construction, indicating length of trench
excavation segments and stockpiling areas.
Over-excavation to be limited to avoid unnecessary stockpiling of material. This will be
monitored by the Engineer on a continuous basis. In areas where stockpiling next to the
PROVISION OF PROFESSIONAL AQUATIC ECOLOGICAL STUDY - PROPOSED GROOT DRAKENSTEIN BULK SEWER PIPELINE January 2012
trench excavation in the registered servitude area is not possible due to restrictions on the
properties, an agreement will be reached with the relevant property owner regarding a suitable
area for stockpiling on the property.
Site access:
Access to the site will take place via existing roads.
Spoil site:
Unsuitable material from excavations (rocks, etc) will be disposed of at an approved landfill site. The
Contractor may make alternative arrangements, but it will have to be approved by the Engineer,
property owner as well as the ECO on the project.
River crossing:
There are different options with regard to the river-crossing for the pipeline:
Option 1 (shallow excavation option): A rising main will be installed up-stream of the existing
causeway with suitable gabions/rheno mattress protection. The proposed pipeline will be anchored to
the side of the causeway in a suitable fashion.
Option 2 (deep excavation option): The proposed pipeline will be installed in a trench next to the
causeway and protected with suitable gabions/rheno mattress elements.
Option 3 (pipe jacking): The proposed pipeline will be jacked underneath/across the riverbed. Pipe
jacking in areas where "spoelklippe" are present, as is the case of the river at the proposed site, will be
difficult to implement. Pipe jacking or drilling works best if the material is more or less homogeneous.
Option 4 (Steel pipe bridge): Pipeline to cross the river via a newly constructed steel pipe bridge
above the 50 year flood level of the river. This option is normally not taken, due to the visual aspects
of the steel structure.
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Figure 2: The proposed development layout plan (proposed pipeline in green
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1.4 Assessment Methodology
The methodology employed to determine the ecological reference conditions for the aquatic features
(Berg River) found within the proposed development footprint is the standard DWA accepted
ecological techniques and followed a project review, ground-truth studies, study analysis and EIA
contexualisation approach.
1.4.1 Approach
(a) Study Area Review:
A desktop review of the study area was undertaken to describe and provide a reference
for broad ecological habitats, veld types, endangered species, ecological sensitivity,
biodiversity patterns, connectivity, habitat and species priority listings (threatened and
vulnerable ecosystems) as well as broad catchment classification (streams and wetlands
within the catchment).
(b) Ground-truth Studies:
Vegetation descriptions and a wetland delineation map were undertaken according to the
Department of Water Affairs standard wetlands delineation guideline (DWA 2005).
River Health Assessments were undertaken according to the Department of Water Affairs
Standard River Health Indices assessment techniques for (DWA 1999):
o SASS5 (macro-invertebrate assessment from water quality study)
o IHAS (in-stream habitat assessment from water quality study)
o VEGRAII (riparian vegetation assessment)
o IHI (overall habitat integrity assessment)
o EIS (ecological importance and sensitivity assessment)
(c) Study Analysis:
Analysis of data collected was undertaken post field assessment and contextualised for
EIA input for construction and operational phases.
Findings and recommendations for Environmental Management Plans were also
contexualised.
1.4.2 Assumptions and limitations of the Study
Limitations and uncertainties often exist within the various techniques adopted to assess the
condition of ecosystems. The following limitations apply to the techniques and methodology
utilized to undertake this study:
Analysis of the freshwater ecosystems was undertaken according to nationally developed
methodologies as defined by Department of Water Affairs (DWA) as part of the national
River Health Programme (RHP) and will be undertaken at a rapid level (in field).
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Recommendations are made based on the river's functioning and site characteristics.
These recommendations are based on professional opinion as RHP developed
technologies are based on a qualitative assessment.
Seasonality and site condition may not always be favourable for undertaking the RHP
assessments and will result in assessments being descriptive and informative.
1.4.3 Use of the Report
This report reflects the professional judgment of its author. The full and unedited content of
this should be presented to the client. Any summary of these findings should only be
produced in consultation with the author.
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2 DESCRIPTION OF AFFECTED ENVIRONMENT (STUDY REVIEW)
2.1 Visual characteristics, climate, ecology and land uses
Visual
Situated on a valley within close proximity to the Paarlberg Reserve, the natural topography of the
site is flat, sloping gently towards the Berg River. The landscape is scattered with renosterveld and
fynbos vegetation amidst established stands of alien tree species and problematic weeds. Overall,
the Drakenstein Municipal area is classified as 60.9%1 no longer containing natural habitat. This is
mostly due to the fact that the area is largely used for agricultural purposes.
Figure 3: Ecological Importance and Sensitivity map of the Study Area (SANBI BGIS 2011)
1 SANBI, Landuse Decision Support (LUDS) Tool: Drakenstein Municipality Biodiversity Summary
(http://bgis.sanbi.org/municipalities/show-muni-summaries.asp?muni=WC023)
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Climate
From a climate perspective, Paarl receives on average about 657mm of rain per year and because
it receives most of its rainfall during winter it has a Mediterranean climate. The graph below (left)
shows the average monthly rainfall values for Paarl. The lowest rainfall (9mm) occurs in February
and the highest (121mm) in June. The average midday temperatures for Paarl range from 16.4°C
in July to 28.2°C in February.
Figure 4: Average rainfall (left) and temperature (right) graphs for the Paarl area (SA Explorer 2011)
Geology
The geology can be described as quaternary alluvium derived from a mix of the Table Mountain
sandstones and Cape Granite in the wetter vicinities of the site; and Quartzite over Cape Granite in
the larger extent of the site and landscape. There is a considerable depth of alluvial material that is
sandy and clay organics, overlying basement bedrock of Granite. The soil profile can be estimated
to lie between 0.8 m and 2 m deep with very few rocks and stones in the upper half (predominantly
clay with sandy organics on the surface horizon). Soil forming is dominated by the accumulation of
the organic material as a result of high water levels over the winter periods (possibly perched) and
vegetation erosion.
Ecology
After overlaying SANBI’s Western Cape Ecostatus GIS layer, the study footprint falls within the
Swartland Aluvium Fynbos which is classed as endangered and the study area falls within the
Boland Granite Fynbos which has an endangered class. The development site is in proximity to the
Paarlberg Nature Reserve of the Drakenstein Mountains and is occupied by a fynbos biome
covering 153764.6ha and 15 vegetation types (SANBI). The veld type is classified as critically
endangered (17767.7ha or 11.6%) and vulnerable (134.6ha or 0%) vegetation (See Figure 3:
Vegetation of the Drakenstein Municipal area1). However, the proposed pipeline lies predominantly
across the region which is classified as ‘area where no natural habitat is remaining’, apart from the
river and small pockets of habitat which are categorised as critically endangered. Therefore, this
site displays varying degrees of disturbance including cultivation, invasive alien species, and
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urbanisation. Consequently, this region has a moderate to high degree of vegetation
transformation.
Land-use
The land use practice in the foothill reaches of the Berg River, east of the N1 highway is
predominantly agricultural. Downstream of the N1 highway, the river has been significantly modified
by the peri-urban activities around Paarl, which consist of industrial sites and farming in the Berg
River channel.
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Figure 5: Vegetation of the Drakenstein Municipal area1
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2.2 Freshwater Assessment of the Berg River
The Study site was comprised of cultivated orchards and vineyards situated at the proposed Berg
River crossing point.
Table 1. Physical conditions of the Berg River at the sampling point
Geomorphological zone Foothill
Lateral mobility or entrenchment Confined
Channel form Simple channel
Channel pattern Single thread: medium sinuosity
Channel type cobble bed channel with some boulders
Dominant biotopes Run with shallow pools and riffles
Hydrological Type Permanent
Associated systems Floodplain
Figure 6. Location of the water crossing sampling site on the Berg River (Google Earth, 2011)
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Figure 7.Upstream View of the proposed upper sewer line crossing
Figure 8. View of the proposed sewer line crossing area (at present an artificial concrete bedrock
crossing point exists at this point).
Figure 9. Downstream view of the proposed upper sewer line crossing
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2.2.1 Water Quality/Macroinvertebrates
The South African Scoring System Version 5 (SASS5) was used to estimate the stream’s water quality
and aspects of its ecology, as the aquatic macro-invertebrate community contributes as a vital
component to riverine ecosystems (recycling the energy budget, etc.). In addition to contributing to
the biodiversity of the river, it also plays a role in the functioning of the river (food webs, water clarity,
etc.). Due to the differing sensitivities of the organisms (some tolerant, others sensitive), the
composition of the communities present can be used as an indicator to estimate of the water quality
and general river health at the sampling sites.
The results from the SASS5 survey (Appendix), would probably equate to a category C/B (largely
good to moderately modified – see Appendix, since flow is controlled by the Berg River Scheme just
upstream in Franschoek). This classification of the state of the river based on macroinvertebrates is
based on SASS data interpretation guidelines that were generated based on available SASS data that
was grouped into ecoregions and geomorphological zones. The spread of available data within the
ecoregions indicated a range of degree of impairment and allowed for the development of biological
bands that are linked to the river health categories (Figure 10).
Table 2. Results of SASS5 assessment on the Berg River ASPT = Average Score per Taxa
Site Date Total SASS Score
No. of taxa ASPT River Health
Category
Berg River September 2011 94 17 5.5 C/B
The macroinvertebrate sample from the Berg River consisted of moderate abundances of
macroinvertebrate families (see appendices) which are of a moderate sensitivity and prefer flowing
conditions. The site sampled at the upper section of the river is still largely natural, with a good
availability of suitable habitat and water quality.
Figure 10. Data interpretation guidelines for the South Western Coastal Belt – Upper zone, calculated
using percentiles for existing SASS5 data on rivers that are in the same eco-region (Dallas 2007)
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2.2.2 Index of Habitat Integrity The evaluation of Habitat Integrity (HI) provides a measure of the degree to which a river has been
modified from its natural state. The methodology (DWAF, 1999) involves a qualitative assessment of the
number and severity of anthropogenic perturbations on a river and the damage they potentially inflict
upon the system. These disturbances include both abiotic and biotic factors, which are regarded as the
primary causes of degradation of a river. The severity of each impact is ranked using a six-point scale
with 0 (no impact), 1 to 5 (small impact), 6 to 10 (moderate impact), 11 to 15 (large impact), 16 to 20
(serious impact) and 21 to 25 (critical impact).
The Habitat Integrity Assessment is based on assessment of the impacts of two components of the river,
the riparian zone and the instream habitat. Assessments are made separately for both components, but
data for the riparian zone are interpreted primarily in terms of the potential impact on the instream
component. The estimated impact of each criterion is calculated as follows:
Rating for the criterion/maximum value (25) x weight (percent)
The estimated impacts of all criteria calculated in this way are summed, expressed as a percentage
and subtracted from 100 to arrive at an assessment of habitat integrity for the instream and riparian
components respectively. The total scores for the instream and riparian zone components are then
used to place the habitat integrity of both in a specific habitat category (Table 3).
Table 3. Habitat Integrity categories (From DWAF, 1999)
CATEGORY DESCRIPTION SCORE (% OF
TOTAL)
A Unmodified, natural. 90-100
B Largely natural with few modifications. A small change in natural habitats and biota may have taken place but the ecosystem functions are essentially unchanged.
80-90
C Moderately modified. A loss and change of natural habitat and biota have occurred but the basic ecosystem functions are still predominantly unchanged.
60-79
D Largely modified. A large loss of natural habitat, biota and basic ecosystem functions has occurred.
40-59
E The loss of natural habitat, biota and basic ecosystem functions is extensive.
20-39
F
Modifications have reached a critical level and the lotic system has been modified completely with an almost complete loss of natural habitat and biota. In worst instances, basic ecosystem functions have been destroyed and changes are irreversible.
0
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Table 4. Index of Habitat Integrity Assessment results and criteria assessed at the sites
INSTREAM HABITAT INTEGRITY
Berg River Comment
Water Abstraction (Impact 1 - 25) 10
Run-of-river abstraction in upstream catchment
Flow Modification ( (Impact 1 - 25) 12
Upstream instream dam and off channel dams reduce medium to low flows and irrigation releases
Bed Modification (Impact 1 - 25) 10 Siltation
Channel Modification (Impact 1 - 25)
9 Some alteration of banks for flood protection (channel straitening)
Water Quality (Impact 1 - 25) 12
Adjacent farming impacts, septic tanks and interbasin transfer
Inundation (Impact 1 - 25) 5
Some inundation as a result of bed modifications
Exotic Macrophytes (Impact 1 - 25)
4 Few
Exotic Fauna (Impact 1 - 25) 5 trout
Rubbish Dumping (Impact 1 - 25) 8 Some littering
Instream Habitat Integrity Score 64.6
Integrity Class C
RIPARIAN ZONE HABITAT INTEGRITY
Vegetation Removal (Impact 1 - 25)
7 Some vegetation removal due to farming activities on banks
Exotic Vegetation (Impact 1 - 25) 11
Limited alien plant invasion due to farming disturbances
Bank Erosion (Impact 1 - 25) 6
Bank erosion due to removal of indigenous vegetation
Channel Modification (Impact 1 - 25)
9 Some bank modification and stabilisation by farming activities
Water Abstraction (Impact 1 - 25) 12 See comment above
Inundation (Impact 1 - 25) 5 See comment above
Flow Modification (Impact 1 - 25) 14 See comment above
Water Quality (Impact 1 - 25) 12 See comment above
Riparian Zone Habitat Integrity Score
61.48
Integrity Class C
From cross referencing the IHI with available literature, the IHI results have been adapted to provide a
higher confidence assessment from the initial field assessment. As a result, the instream as well as
riparian habitat integrity of the Berg River at the development area was calculated to be classed in a
moderately modified state. The impacts on the habitat are largely as a result of surrounding farming
activities, as well as the Berg River Dam in the upper reaches of the river. The urban are of
Franschoek has also significantly degraded the river in its foothill reaches.
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2.2.3 Riparian Vegetation Index
Riparian zones, as well as the impact assessment of riparian zones, rely exceedingly on the
interpretation of characteristic riparian vegetation: its function to stream condition and bank structure.
Considerations made in making this assessment encourage the rating of bank zonation, riparian
vegetation cover (in particular indicator and canopy species), riparian vegetation abundance, riparian
vegetation recruitment rates, the population structure of the riparian zone captured and the species
alpha and beta diversity. In turn, the facets that drives riparian zone ecology, is assessed with a
perceived reference state. This reference state is usually a pristine benchmark or one that has the
least heterogeneous factors impacting on its natural functionality (DWAF 2007). However, the purpose
of this assessment will not be to determine the impacts on the riparian zone to the reference state, but
to provide some suggestions on the degree of change the existing land-uses have placed on this
already impacted river segment.
The data collected in the field was analysed using the RVI method and the results are tabulated and
discussed from the set of Tables below (described as Sections A to D):
RVI = [(EVC)+((SI x PCIRS)+(RIRS))]
RVI = [(5)+((0.25(4x0.3(1x0.7))+(1)))]
RVI = 6.84 E –Poor
The major impacts found in this assessment are: the removal of riparian vegetation (previous
cultivation practice); the invasion of exotic trees and weeds over the site; flow modification (channel
straightening, abstraction and storage impacts) and over-abstraction practice (farm-dams and
irrigation). This can be discussed via referring to the conditions of the respective riparian zones in the
context of the degree of change from the riparian reference state:
Marginal Zone:
The riparian marginal zone was not comprised of any true riparian indigenous vegetation. Alien weedy
grasses –Spanish reed (Arundo donax), common grass (Cynodon dicotylon) and kikuyu grass species
(Pennisetum cladestinum and P. Seraceum) – were the only vegetation found in this zone besides the
alien weeping willow (Salix babylonica), black wattle (Acacia Mearnsii), castor oil (Ricinis communis)
and poplars (Populus spp.) amongst others.
Lower Zone/ Wetbank:
The lower zone was characterised by homogenous stands of alien tree species black wattle
(A.mearnsii), buckweed (Solanum elaeagnifolium), blue-gums, oaks and pines. A complete lack of
adequate riparian shrubs and tree species was evident.
Upper Zone/Dry bank:
The primary feature of this zone is weedy grasses species in the midst of mix cultivated orchards and
vineyards.
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Table 5. Intermediate River Vegetation Index categories (from Kemper, 2001)
RVI Score
Assessment class
Description
19-20 A Unmodified, natural.
17-18 B Largely natural with few modifications. A small change in natural habitats and biota may have taken place, but the ecosystem functions remain unchanged.
13-16 C Modified. A loss and change of natural habitat, biota and basic ecosystem functions have occurred.
9-12 D Largely modified. A moderate to large loss of natural habitat, biota and basic ecosystem functions have occurred.
5-8 E The loss of natural habitat, biota and basic ecosystem functions are extensive.
0-4 F
Modifications have reached a critical level and the system has been modified completely with complete loss of habitat and biota. In the worst instances, the basic ecosystem functions have been destroyed to the extent that changes are irreversible.
Ecological status: The ecological status of the site was analysed as Class E, RVI = 6.84 E –Poor
which indicates a large to extensively modified riparian zone state often associated with multiple
disturbances coming into the system. A large loss of natural habitat, biota and basic ecosystem
functions has occurred. This is primarily due to the impacts of land-use pressures over time onto the
system as well as the associated stream modification practice. This stream has lost most of its natural
ecological services it provides from the riparian zone’s perspective, but still has moderately good
instream habitat and some over-stabilisation of banks by large alien tree representation.
Table 6. The river health categories
Category Ecological Perspective Management Perspective
Natural (N) No or negligible modification Relatively little human impact
Good (G) Biodiversity and integrity largely intact Some human-related disturbance but ecosystems essentially in a good state
Fair (F) Sensitive species may be lost, with tolerant or opportunistic species dominating
Multiple disturbances associated with the need for socio-economic development
Poor (P) Mostly tolerant species; alien invasion,
disrupted population dynamics; species are
often diseased
High human densities or extensive resource
exploitation
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2.2.4 Ecological Importance and Sensitivity (EIS)
EIS considers a number of biotic and habitat determinants surmised to indicate either importance or
sensitivity. The determinants are rated according to a four-point scale. The median of the resultant
score is calculated to derive the EIS category.
Table 7. Definition of the four-point scale used to assess biotic and habitat determinants presumed to
indicate either importance or sensitivity
Four point scale
Definition
1 One species/taxon judged as rare or endangered at a local scale.
2 More than one species/taxon judged to be rare or endangered on a local scale.
3 One or more species/taxon judged to be rare or endangered on a Provincial/regional scale.
4 One or more species/taxon judged as rare or endangered on a National scale (i.e. SA Red Data Books)
Table 8. Ecological importance and sensitivity categories (DWAF, 1999)
EISC General description Range
of median
Very high Quaternaries/delineations that are considered to be unique on a national and international level based on unique biodiversity (habitat diversity, species diversity, unique species, rare and endangered species). These rivers (in terms of biota and habitat) are usually very sensitive to flow modifications and have no or only a small capacity for use.
>3-4
High Quaternaries/delineations that are considered to be unique on a national scale based on their biodiversity (habitat diversity, species diversity, unique species, rare and endangered species). These rivers (in terms of biota and habitat) may be sensitive to flow modifications but in some cases may have substantial capacity for use.
>2- 3
Moderate Quaternaries/delineations that are considered to be unique on a provincial or local scale due to biodiversity (habitat diversity, species diversity, unique species, rare and endangered species). These rivers (in terms of biota and habitat) are not usually very sensitive to flow modifications and often have substantial capacity for use.
>1- 2
Low/ marginal
Quaternaries/delineations that are not unique on any scale. These rivers (in terms of biota and habitat) are generally not very sensitive to flow modifications and usually have substantial capacity for use.
1
Table 9. Results of the EIS assessment for the Berg River at the assessed site
BIOTIC DETERMINANTS Score
Rare and endangered biota 1.5
Unique biota 1.5
Intolerant biota 2
Species/taxon richness 1.5
Aquatic Habitat Determinants
Diversity of aquatic habitat types or features 2
Refuge value of habitat type 2
Sensitivity of habitat to flow changes 2
Sensitivity of flow related water quality changes 2.5
Migration route/corridor for instream and riparian biota 3
Nature Reserves, Natural Heritage sites, Natural areas, PNEs 2
RATINGS 2.0
EIS CATEGORY Moderate to high
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2.2.5 Overall Eco-status and Recommended Ecological Management Category
The overall eco-status of the reach in this assessment degrades from a C or moderately modified state
to a largely modified state (D category) and has a moderate to high ecological importance and
sensitivity.
Table 10. Overall Eco-status scores for the Berg River at the sites assessed (score between
0=critically modified and 5=natural/unmodified)
River Reach Sampling
point
Bed modification 3
Flow modification 2.0
Introduced instream biota 3.5
Inundation 3.0
Riparian/ bank condition 2.5
Water quality modification 2.0
Habitat Integrity 2.7
Fish integrity 3.5
Invertebrate 2.5
Instream biotic integrity 3.0
INSTREAM HEALTH 2.8
Rip Veg Integrity 2.0
RIP ZONE INT 2.3
RIVER HEALTH SCORE 52
ECOLOGICAL CATEGORY
D
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3 ASSESSMENT OF IMPACTS
The objective of the assessment of impacts is to assess all the significant impacts that may
arise as a result of the proposed sewer development. Additional impacts may be identified
through the PPP to be incorporated as interested and affected party concerns.
ARCUS GIBB (PTY) Ltd. Environmental Assessment Practitioner (EAP) managing the
processing of the environmental authorisations for the proposed development’s scope, has
provided the following criteria to assess environmental impacts. This assessment criteria is
inline with best practice in environmental impact assessment (EIA) under the National
Environmental Management Act’s 2010 EIA Regulations.
For each of the two main project phases (construction and operation), the existing and
potential future impacts and benefits (associated only with the proposed development) should
be contexualised using the following criteria table.
Table 11. In line with the 2010 EIA Regulations, specialists are required to describe and
assess the potential impacts in terms of the following criteria:
Criteria Rating Scales Notes
Nature
Positive This is an evaluation of the type of effect the
construction, operation and management of the
proposed development would have on the
affected environment
Negative
Neutral
Extent
Low Site-specific, affects only the development
footprint
Medium Local (limited to the site and its immediate
surroundings, including the surrounding towns
and settlements within a 10 km radius)
High Regional (beyond a 10 km radius) to national
Duration
Low 0-3 years
Medium 4-8 years (i.e. full duration of construction
phase)
High More than 9 years to permanent
Intensity
Low Where the impact affects the environment in
such a way that natural, cultural and social
functions and processes are minimally affected
Medium
Where the affected environment is altered but
natural, cultural and social functions and
processes continue albeit in a modified way; and
valued, important, sensitive or vulnerable
systems or communities are negatively affected
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Criteria Rating Scales Notes
High
Where natural, cultural or social functions and
processes are altered to the extent that the
impact will temporarily or permanently cease;
and valued, important, sensitive or vulnerable
systems or communities are substantially
affected.
Potential for
impact on
irreplaceable
resources
Low No irreplaceable resources will be impacted.
Medium Resources that will be impacted can be
replaced, with effort.
High There is no potential for replacing a particular
vulnerable resource that will be impacted.
Consequence
(a combination
of extent,
duration,
intensity and the
potential for
impact on
irreplaceable
resources).
Low
A combination of any of the following
Intensity, duration, extent and impact on
irreplaceable resources are all rated low
Intensity, duration and extent are rated low
but impact on irreplaceable resources is
rated medium to high
Intensity is low and up to two of the other
criteria are rated medium
Intensity is medium and all three other
criteria are rated low
Medium
Intensity is medium and one other
criteria is rated high, with the
remainder being rated low
Intensity is low and at least two
other criteria are rated medium or
higher
Intensity is rated medium and at
least two of the other criteria are
rated medium or higher
Intensity is high and at least two
other criteria are medium or higher
Intensity is rated low, but
irreplaceability and duration are
rated high
High
Intensity and impact on
irreplaceable resources are rated
high, with any combination of
extent and duration
Intensity is rated high, with all of
the other criteria being rated
medium or higher
Probability (the
likelihood of the
impact
occurring)
Low It is highly unlikely or less than 50 % likely that
an impact will occur.
Medium It is between 50 and 70 % certain that the
impact will occur.
High It is more than 75 % certain that the impact will
occur or it is definite that the impact will occur.
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Criteria Rating Scales Notes
Significance
(all impacts
including
potential
cumulative
impacts)
Low
Low consequence and low
probability
Low consequence and medium
probability
Low consequence and high
probability
Low to medium
Low consequence and high
probability
Medium consequence and low
probability
Medium
Medium consequence and low
probability
Medium consequence and
medium probability
Medium consequence and high
probability
High consequence and low
probability
Medium to high High consequence and medium
probability
High High consequence and high
probability
CUMULATIVE IMPACTS – Type 1 (different types of impact on one receptor) and Type 2
(different developments on one type of receptor (e.g. ecology).
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3.1 Potential Impacts
3.1.1 Construction Phase
Impact - water quality impairment:
In a direct sense, water quality impacts by construction equipment, vehicles and material will
be a likely water quality impairment point source. From an indirect and non-point source,
runoff of building materials (e.g. cement) into the river during construction of the
pipeline/bridge is also possible.
Significance of impacts without mitigation:
A medium negative impact is expected, as impacts are localised and will be absorbed in the
run of the river, depending on the scale of impairment.
Proposed mitigation:
The water quality impacts during the construction phase in particular should be addressed
through the compliance of an Environmental Management Plan/Programme, implementation
of which is monitored by an on‐site Environmental Officer. Runoff from the construction site
should be prevented from directly entering the Berg River as far as possible by implementing
features such as the use of silt/sand traps and other measures. Construction should also
preferably take place during the drier months when run off is low.
A buffer refers to a riparian area adjacent to the water body that comprises of natural or near-
natural vegetation, designed to protect aquatic and riparian areas from the impacts associated
with various human activities. Buffers serve to reduce the levels of sediment and pollutants
from directly entering the rivers and wetlands. A buffer zone should therefore be adopted to
protect aquatic habitats from the impacts associated with any development.
Significance of impacts after mitigation:
Provided that the mitigation measures are effectively implemented, the water quality-related
impacts of the proposed development should be limited.
Impact - flow modification:
Infilling and compacting of soil layers covering the pipeline is likely to alter the sub‐surface
flow from the terrestrial surroundings to the river as well as the flow through the channel banks. This may cause the river flow to increase or be impeded. Nevertheless, the erosion potential of the river will be compromised and is likely to cause erosion at the point of infilling or downstream of such point. However, this is seen as a small surface area impact as well as only short term.
Significance of impacts without mitigation:
Low to Medium impact – this is due to the large size of the river and current homogenous
state of the river during this reach as a result of flow regulation by the Berg River Dam.
Proposed mitigation:
Due to the small section of the river being impacted by flow modification, some channel
straightening should be undertaken in the section, so as to not cause any erosion potential at
the development points within the banks or channel bed. If significant straightening of the
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channel is considered, the past flow velocity, volume and variability data would have to be
assessed so as to mimic and maintain as natural a flow regime post construction.
Significance of impacts after mitigation:
Low impact if the anti-erosion structures function properly.
Impact - loss of riparian habitat and bed/bank modification:
The loss of instream and riparian habitat and modification to the bed or banks of the stream, at
the proposed site and immediately downstream is highly likely.
Significance of impacts without mitigation:
Localised moderate to high impact – loss of aquatic habitat integrity and bed/bank modification
could be expected. This impact is expected to be small due to the already degraded state of
the river along the lower sections on the site (high alien vegetation presence and past
bank/bed modification practise). In addition, the disturbance of aquatic habitat during and after
the construction activities will provide an opportunity for invasive alien plants to establish
within the riparian zone. Furthermore, exposed banks can lead to channel being eroded and is
an undesirable impact that needs to be closely monitored.
Proposed mitigation:
During the construction phase of the project, the impact on the riparian zone of the river
system should be kept to a minimum, particularly in the channel margins and wetbanks.
Impacted areas should be re-vegetated as soon as incurred. No significant soil embankments
must become exposed for long periods as a result of run-of-river erosion potential and
potential freshets.
Any impacted areas within the riparian zone should be rehabilitated, specifically to re-vegetate
the area with suitable vegetation. It is desirable to maintain and re-establish a buffer strip of at
least 30m to protect the river from the impacts to the site. However, this should be addressed
in consultation with farming rights and farm management (as cultivation takes place in the
upper riparian zones).
Significance of impacts after mitigation:
Low to negligible impact –the impact could in fact have a positive impact for the riparian
vegetation which is already highly modified, should revegetation occur with representative
aquatic species.
Cumulative Impacts:
The cumulative impact is associated with upstream disturbances impacting on the proposed
site development and includes the regulated “new Berg River dam” as well as associated
surrounding agricultural and township land-uses. With effective implementation of the EMPr
and the recommended mitigation measures, the condition of the stream will be maintained at
an acceptable level. In the context of the proposed development’s potential impacts
cumulatively becoming realise, the effect would remain localised but will require rehabilitation
as soon as occurred.
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3.1.2 Operational Phase
It is the findings of this investigation that the potential direct and indirect ecological related impacts for the operational phases of the proposed development will be largely related to construction structures accidental deterioration or maintenance mismanagement.
Impact - water quality impairment
Due to the nature of the development (sewer), the potential for leaks and damage to the
pipeline is largely unlikely, but will provide a high water quality impact should any sewer water
leak into the river directly or indirectly during the operations phase of the development.
Significance of impacts without mitigation:
Very high negative impact as direct sewer water should not be allowed to be discharged into a
river system without pre-treatment to an acceptable DWA water quality standard.
Proposed mitigation:
Routing maintenance checks on the pipeline must be performed to check for leaks as part of the proposed development adopted Environmental Management Programme. Any such leaks must be repaired immediately and be handled as a disaster management priority. As part of EMP general maintenance work, any pollutants or rubble should be removed from
the river during the dry season so as to reduce the likelihood of pollution within the river. The
restoration of a good riparian buffer on areas where vegetation has been cleared will also
restore the ability of the river to restore water quality levels where impacted.
The following design features of the pipeline will further mitigate the risks of the sewer pipeline
bursting or leaking:
The pipe will be made of High Density Polyethylene (HDPE) with butt welded joints.
The pipe will be pressure tested upon completion of the installation to confirm the
integrity of the pipe’s strength/durability/leakage.
All other quality assurance criteria as specified by SANS 1200 will be adhered to.
Significance of impacts after mitigation:
Provided that the mitigation measures are effectively implemented, the water quality-related
impacts of the proposed development should be limited to an unlikely occurrence.
Cumulative Impacts:
The significance of cumulative impacts are not relevant to the operations phase.
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Table 12. Significance of impacts during construction
Impact Nat
ure
Extent Duration Intensity Impact on Ir-
replaceable
Resources
Con-
sequence
Probability Significance
without
mitigation
Mitigation Measure
(further detailed in the
‘Mitigation Measures’
section below)
Significance
with
mitigation
Confidence
Water quality im-pairment
-
neg
Local Short-
term
Medium
to high
Low Medium High Medium Best construction practise
and EMP implementation
in construction
Low High
Flow modifica-tion
-
neg
Site Medium-
term
Medium
to high
Low Low High Medium Restore bank and bed
profiles
Low High
Loss of riparian habitat and bed/bank modifica-tion
-
neg
Local Medium-
term
Medium Low Low High high Revegetating impacted
areas with appropriate
indigenous vegetation
Very low High
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Table 13. Significance of impacts during operation
Impact Nat
ure
Extent Duration Intensity Impact on
Irreplaceable
Resources
Conseque
nce
Probability Significance
without
mitigation
Mitigation Measure
(further detailed in the
‘Mitigation Measures’
section below)
Significance
with
mitigation
Confidence
Water quality impairment (leaks and pipe damage)
-
neg
Local medium Medium
to high
high High Low High Negative Regular maintenance
practice and EMP
implementation in
operation phases.
Disaster Management
monitoring during flooding
Low High
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3.2 Mitigation Measures
The following measures are recommended to mitigate likely impacts of the pipeline construction:
No construction vehicles should be allowed within 15m of the berg river water edge,
except for those authorised to undertake activities applied for under section 21 c & i of
the National Water Act (Act 36 of 1998) and/or within the context of an endorsed
Water-Use License. Limited disturbance should be allowed within this buffer zone and
as far as possible the disturbed areas should be rehabilitated with vegetation
characteristic of the area’s biodiversity.
Where the pipeline route crosses the drainage lines, there should be minimal use of
machinery and disturbance within these areas should be kept to a minimum.
The rehabilitation and re‐vegetation of disturbed areas must take place during or
immediately after construction is complete. Only appropriate indigenous riparian
vegetation may be used for rehabilitation and re‐vegetation within the disturbed area.
Clearing or felling of all alien invasive trees should take place along the pipeline route.
Colonisation by alien invasive vegetation must be removed as soon as noted.
Clearing of debris and hard rubble associated with the construction activities should be
undertaken on completion of the pipeline construction activity.
Stormwater associated with the construction activities must be prevented from entering
the river as far as possible.
Other activities that may lead to elevated levels of turbidity must be minimised. If
possible construction activities should take place during the low rainfall months when
run off volumes will also be low.
Pipeline installation must not significantly obstruct the natural movement of water
through the surrounding landscapes’ soil profile (can result in localised damming and
formation of wet areas or ponds).
Manholes, if possible, should be located as far as possible away from water features
and pipelines should be regularly monitored for spillages.
3.2.1 Construction
In terms of construction related mitigation measures, the compliance with an EMPr and related
audit for correct material use and disposal (via materials and disposal register) as well as the
implementation of environmental education to pipe-laying workers on a weekly basis is
strongly encouraged. In addition, an incident register should be kept on site for the duration of
the activity to provide a basis against to monitor. As a result, corrective action should take
place within the incident reporting framework and should consist of regular (weekly or bi-
weekly) water quality monitoring for the duration of the construction activity (just downstream
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of the river crossing point) using DWA approved measuring standards. Post construction, the
ECO should submit a site closure report to provide a basis for assessing any additional
rehabilitation requirements to the site.
3.2.2 Operation
During the operation of the sewer pipeline, e-coli variables must be assessed as part of a
monthly monitoring program. Also, linkages of this information to the municipal monitoring
programmes or Berg River Catchment Management agency should be established and
undertaken in terms of corporative governance and compliance monitoring initiatives.
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4 REFERENCES
Dallas, H. (2007). South African Scoring System (SASS) Data Interpretation Guideline,
Institute of Natural Resources and Department of Water Affairs and Forestry
.
Department of Water Affairs and Forestry. (1999). Resource Directed Measures for Protection
of Water Resources. Volume 3: River Ecosystems Version 1.0. Resource Directed Measures
for Protection of Water Resources, Pretoria, South Africa.
Department of Water Affairs and Forestry. (2005). A practical field procedure for identification
and delineation of wetlands and riparian areas. Pretoria.
Department of Water Affairs and Forestry. (2007). River Ecoclassification: Manual for
Ecostatus Determination (Version 2). Riparian Vegetation Response Index, Water Research
Commission Report Number KV 168/05. Pretoria.
The River Health Programme of South Africa (2004). State of Berg River. Department of
Water Affairs & Forestry, Pretoria.
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5 APPENDIX: ASSIGNING SIGNIFICANCE RATING TO IMPACTS DEFINITIONS
Nature
This is an evaluation of the type of effect the construction, operation and management of the
development would have on the affected environment. Would it be positive, negative or neutral?
Extent or scale
This refers to the spatial scale at which the impact will occur. Extent of the impact is described as: low
(site-specific - affecting only the footprint of the development), medium (limited to the site and its
immediate surroundings and closest towns) and high (regional and national).
Duration
The lifespan of the impact is indicated as low (short-term: 0-5 years, typically impacts that are quickly
reversible within the construction phase of the project), medium (medium-term, 6-10 years, reversible
over time) and high (long-term, 10-60 years, and continue for the operational life span of the
development).
Intensity or severity
This is a relative evaluation within the context of all the activities and the other impacts within the
framework of the project. Does the activity destroy the impacted environment, alter its functioning, or
render it slightly altered? The specialist studies must attempt to quantify the magnitude of the impacts
and outline the rationale used.
Impact on irreplaceable resources
This refers to the potential for an environmental resource to be replaced, should it be impacted. A
resource could possibly be replaced by natural processes (e.g. by natural colonisation from
surrounding areas), through artificial means (e.g. by reseeding disturbed areas or replanting rescued
species) or by providing a substitute resource, in certain cases. In natural systems, providing
substitute resources is usually not possible, but in social systems substitutes are often possible (e.g.
by constructing new social facilities for those that are lost). Should it not be possible to replace a
resource, the resource is essentially irreplaceable e.g. red data species that are restricted to a
particular site or habitat of very limited extent.
Consequence
The consequence of the potential impacts is a summation of above criteria, namely the extent,
duration, intensity and impact on irreplaceable resources.
Probability of occurrence
The probability of the impact actually occurring, based on professional experience of the specialist
with environments of a similar nature to the site and/or with similar projects. Probability is described as
low (improbable), medium (distinct possibility), and high (most likely). It is important to distinguish
between probability of the impact occurring and probability that the activity causing a potential
impact will occur. Probability is defined as the probability of the impact occurring, not as the
probability of the activities that may result in the impact. The fact that an activity will occur does not
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necessarily imply that an impact will occur. For instance, the fact that a road will be built does not
necessarily imply that it will impact on a wetland. If the road is properly routed to avoid the wetland,
the impact may not occur at all, or the probability of the impact will be low, even though it is certain
that the activity will occur.
Significance
Impact significance is defined to be a combination of the consequence (as described below) and
probability of the impact occurring. The relationship between consequence and probability highlights
that the risk (or impact significance) must be evaluated in terms of the seriousness (consequence) of
the impact, weighted by the probability of the impact actually occurring. The following analogy
provides an illustration of the relationship between consequence and probability. The use of a vehicle
may result in an accident (an impact) with multiple fatalities, not only for the driver of the vehicle, but
also for passengers and other road users. There are certain mitigation measures (e.g. the use of
seatbelts, adhering to speed limits, airbags, anti-lock braking, etc.) that may reduce the consequence
or probability or both. The probability of the impact is low enough that millions of vehicle users are
prepared to accept the risk of driving a vehicle on a daily basis. Similarly, the consequence of an
aircraft crashing is very high, but the risk is low enough that thousands of passengers happily accept
this risk to travel by air on a daily basis.
In simple terms, if the consequence and probability of an impact is high, then the impact will have a
high significance. The significance defines the level to which the impact will influence the proposed
development and/or environment. It determines whether mitigation measures need to be identified and
implemented and whether the impact is important for decision-making.
Specialists are also required to identify the following in their assessments:
Degree of confidence in predictions
Specialists were required to provide an indication of the degree of confidence (low, medium or high)
that there is in the predictions made for each impact, based on the available information and their level
of knowledge and expertise. Degree of confidence is not taken into account in the determination of
consequence or probability.
Mitigation measures
Mitigation measures are designed to reduce the consequence or probability of an impact, or to reduce
both consequence and probability. The significance of impacts must be assessed both with mitigation
and without mitigation.