amendment report for the application of a substantive … · 2019-11-27 · amendment report for...

Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the 140 MW Sutherland 2 Wind Energy Facility, Sutherland, Northern Cape Province

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Email notifications

Proof of email notifications sent on 3 October 2019:

From: Minnelise Levendal To: Minnelise Levendal CC: "Minnelise Levendal" BC [email protected]; [email protected]; [email protected]; Henning; Ontvangs; [email protected]; [email protected]; Phillip De Lange; [email protected]/[email protected]; Andiswa Sam; [email protected]; Makhosi Mthimkhulu; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Magdalena Kataryna Michalowska; [email protected]; [email protected]; [email protected]; [email protected]; Alana Duffell-Canham; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Kgaphola Mashudu(UPN); [email protected]; [email protected]; Ntoi Mosala(UPN); Schwartz Chantel (UPN); [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Muhammad Essop; [email protected]; Stanley Tshitwamulomoni; Wilma Lutsch; [email protected]; [email protected]; [email protected]; John Geeringh; [email protected]; Owen Peters; [email protected]; [email protected]; Justine Wyngaardt; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected](...) Date: 03 Oct 2019 17:17 Subject: JOINT NOTICE OF RELEASE OF DRAFT AMENDMENT REPORTS FOR COMMENTS FOR THE RIETRUG, SUTHERLAND AND SUTHERLAND 2 WIND ENERGY FACILITIES NEAR SUTHERLAND Attachments: CSIR Letter_Mainstream _General Letter Amendments_V1.pdf; Comment and Response Form_Mainstream_EGI_011019.pdf Dear Stakeholders and Interested and Affected Parties joint Notice of THE Release of draft amendment reports for COMMENT: Rietrug, Sutherland and Sutherland 2 wind energy facilities (WEFS) (DEA Reference Numbers: 12/12/20/1782/1/AM3; 12/12/20/1782/2/AM3; and 12/12/20/1782/3/AM3 RESPECTIVELY). Competent Authority: National Department of Environment, Forestry and Fisheries (DEFF) This e-mail correspondence serves to inform you of the release of the Draft Amendment Reports for comment to amend the Environmental Authorisations issued for the above-mentioned projects. On 25 August 2017, the National Department of Environmental Affairs (DEA) (now operating as the Department of Environment, Forestry and Fisheries (DEFF)) accordingly granted separate and amended Environmental Authorisations (EAs) for the Rietrug, Sutherland and Sutherland 2 WEFs (DEA Reference Numbers: 12/12/20/1782/1/AM2; 12/12/20/1782/2/AM2; and 12/12/20/1782/3/AM2). The Project Applicant is South Africa Mainstream Renewable Power Developments (PTY) Ltd (hereinafter referred to as Mainstream). As part of this Amendment Application, Mainstream wishes to apply for the following amendments:


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1. The amendment to the EA is to change the contact person and contact details of the holder of the

Environmental Authorisation for Mainstream. 2. Mainstream is proposing a change in turbine height and rotor diameter from 150 m turbine height and rotor

diameter to 200 m turbine height and rotor diameter. The proposed projects occur within the gazetted Renewable Energy Development Zone (REDZ) 2: Komsberg. Please note that although a joint notice is hereby released, separate applications and separate Draft Amendment Reports for each project have been submitted to DEFF for comment. In line with the above, as a registered Interested and Affected Party (I&AP) on the project database, you are hereby notified of the release of the Draft Amendment Reports for the proposed projects for a 30-day review period, which will extend from 4 October 2019 to 4 November 2019. Please find attached the following: Letter to I&APs; and Comment and Registration Form. Hard copies of the Draft Amendment Reports are available for public viewing at the Sutherland Library, Merweville Library and the Laingsburg Library. The Draft Amendment Reports can also be downloaded from the following website: https://www.csir.co.za/environmental-impact-assessment Kindly ensure that all comments are submitted to the CSIR Project Manager (details provided below) by 4 November 2019. Thank you and kind regards, Minnelise Levendal Pr. Sci. Nat. CSIR - Smart Places - Environmental Management Services PO Box 320, Stellenbosch, 7599 Tel: 021 888 2495 Fax: 021 888 2693 Email: [email protected]


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Proof of email notifications sent on 25 October 2019:

From: Minnelise Levendal To: Minnelise Levendal CC: "Minnelise Levendal" BC Rohaida Abed; [email protected]; [email protected]; [email protected]; Henning; Ontvangs; [email protected]; [email protected]; Phillip De Lange; [email protected]/[email protected]; Andiswa Sam; [email protected]; Makhosi Mthimkhulu; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Magdalena Kataryna Michalowska; [email protected]; [email protected]; [email protected]; [email protected]; Alana Duffell-Canham; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Kgaphola Mashudu(UPN); [email protected]; [email protected]; Ntoi Mosala(UPN); Schwartz Chantel (UPN); [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Muhammad Essop; [email protected]; Stanley Tshitwamulomoni; Wilma Lutsch; [email protected]; [email protected]; [email protected]; John Geeringh; [email protected]; Owen Peters; [email protected]; [email protected]; Justine Wyngaardt; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Andre Knoop; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected](...) Date: 25 Oct 2019 16:10 Subject: Reminder Re: JOINT NOTICE OF RELEASE OF DRAFT AMENDMENT REPORTS FOR COMMENTS FOR THE RIETRUG, SUTHERLAND AND SUTHERLAND 2 WIND ENERGY FACILITIES NEAR SUTHERLAND Attachments: CSIR Letter_Mainstream _General Letter Amendments_V1.pdf; Comment and Response Form_Mainstream_EGI_011019.pdf Dear Stakeholders and Interested and Affected Parties This email serves as a reminder to submit any comments you may have on the above-mentioned Draft Amendment Reports to me by 4 November 2019 as per the email below. Best wishes, Minnelise >>> Minnelise Levendal 03 Oct 2019 17:17 >>> Dear Stakeholders and Interested and Affected Parties joint Notice of THE Release of draft amendment reports for COMMENT: Rietrug, Sutherland and Sutherland 2 wind energy facilities (WEFS) (DEA Reference Numbers: 12/12/20/1782/1/AM3; 12/12/20/1782/2/AM3; and 12/12/20/1782/3/AM3 RESPECTIVELY). Competent Authority: National Department of Environment, Forestry and Fisheries (DEFF) This e-mail correspondence serves to inform you of the release of the Draft Amendment Reports for comment to amend the Environmental Authorisations issued for the above-mentioned projects. On 25 August 2017, the National Department of Environmental Affairs (DEA) (now operating as the Department of Environment, Forestry and Fisheries (DEFF)) accordingly granted separate and amended Environmental Authorisations (EAs) for the Rietrug, Sutherland and Sutherland 2 WEFs (DEA Reference Numbers: 12/12/20/1782/1/AM2; 12/12/20/1782/2/AM2; and 12/12/20/1782/3/AM2). The Project Applicant is South Africa Mainstream Renewable Power Developments (PTY) Ltd (hereinafter referred to as Mainstream). As part of this Amendment Application, Mainstream wishes to apply for the following amendments: 1. The amendment to the EA is to change the contact person and contact details of the holder of the Environmental Authorisation for Mainstream. 2. Mainstream is proposing a change in turbine height and rotor diameter from 150 m turbine height and rotor diameter to 200 m turbine height and rotor diameter.


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The proposed projects occur within the gazetted Renewable Energy Development Zone (REDZ) 2: Komsberg. Please note that although a joint notice is hereby released, separate applications and separate Draft Amendment Reports for each project have been submitted to DEFF for comment. In line with the above, as a registered Interested and Affected Party (I&AP) on the project database, you are hereby notified of the release of the Draft Amendment Reports for the proposed projects for a 30-day review period, which will extend from 4 October 2019 to 4 November 2019. Please find attached the following: Letter to I&APs; and Comment and Registration Form. Hard copies of the Draft Amendment Reports are available for public viewing at the Sutherland Library, Merweville Library and the Laingsburg Library. The Draft Amendment Reports can also be downloaded from the following website: https://www.csir.co.za/environmental-impact-assessment Kindly ensure that all comments are submitted to the CSIR Project Manager (details provided below) by 4 November 2019. Thank you and kind regards, Minnelise Levendal Pr. Sci. Nat. CSIR - Smart Places - Environmental Management Services PO Box 320, Stellenbosch, 7599 Tel: 021 888 2495 Fax: 021 888 2693 Email: [email protected]


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Proof of email notifications sent on 1 November 2019:

From: Minnelise Levendal To: Minnelise Levendal CC: "Minnelise Levendal" BC Rohaida Abed; [email protected]; [email protected]; [email protected]; Henning; Ontvangs; [email protected]; [email protected]; Phillip De Lange; [email protected]/[email protected]; Andiswa Sam; [email protected]; Makhosi Mthimkhulu; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Magdalena Kataryna Michalowska; [email protected]; [email protected]; [email protected]; [email protected]; Alana Duffell-Canham; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Kgaphola Mashudu(UPN); [email protected]; [email protected]; Ntoi Mosala(UPN); Schwartz Chantel (UPN); [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Muhammad Essop; [email protected]; Stanley Tshitwamulomoni; Wilma Lutsch; [email protected]; [email protected]; [email protected]; John Geeringh; [email protected]; Owen Peters; [email protected]; [email protected]; Justine Wyngaardt; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Andre Knoop; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected](...) Date: 01 Nov 2019 15:28 Subject: Reminder Re: JOINT NOTICE OF RELEASE OF DRAFT AMENDMENT REPORTS FOR COMMENTS FOR THE RIETRUG, SUTHERLAND AND SUTHERLAND 2 WIND ENERGY FACILITIES NEAR SUTHERLAND Attachments: CSIR Letter_Mainstream _General Letter Amendments_V1.pdf; Comment and Response Form_Mainstream_EGI_011019.pdf Dear Stakeholders and Interested and Affected Parties This email serves as a reminder to submit any comments you may have on the above-mentioned Draft Amendment Reports to me by Monday, 4 November 2019 as per the emails below. Best wishes, Minnelise >>> Minnelise Levendal 25 Oct 2019 16:10 >>> Dear Stakeholders and Interested and Affected Parties This email serves as a reminder to submit any comments you may have on the above-mentioned Draft Amendment Reports to me by 4 November 2019 as per the email below. Best wishes, Minnelise >>> Minnelise Levendal 03 Oct 2019 17:17 >>> Dear Stakeholders and Interested and Affected Parties joint Notice of THE Release of draft amendment reports for COMMENT: Rietrug, Sutherland and Sutherland 2 wind energy facilities (WEFS) (DEA Reference Numbers: 12/12/20/1782/1/AM3; 12/12/20/1782/2/AM3; and 12/12/20/1782/3/AM3 RESPECTIVELY). Competent Authority: National Department of Environment, Forestry and Fisheries (DEFF) This e-mail correspondence serves to inform you of the release of the Draft Amendment Reports for comment to amend the Environmental Authorisations issued for the above-mentioned projects. On 25 August 2017, the National Department of Environmental Affairs (DEA) (now operating as the Department of Environment, Forestry and Fisheries (DEFF)) accordingly granted separate and amended Environmental Authorisations (EAs) for the Rietrug, Sutherland and Sutherland 2 WEFs (DEA Reference Numbers: 12/12/20/1782/1/AM2; 12/12/20/1782/2/AM2; and 12/12/20/1782/3/AM2). The Project Applicant is South Africa Mainstream Renewable Power Developments (PTY) Ltd (hereinafter referred to as Mainstream). As part of this Amendment Application, Mainstream wishes to apply for the following


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amendments: 1. The amendment to the EA is to change the contact person and contact details of the holder of the Environmental Authorisation for Mainstream. 2. Mainstream is proposing a change in turbine height and rotor diameter from 150 m turbine height and rotor diameter to 200 m turbine height and rotor diameter. The proposed projects occur within the gazetted Renewable Energy Development Zone (REDZ) 2: Komsberg. Please note that although a joint notice is hereby released, separate applications and separate Draft Amendment Reports for each project have been submitted to DEFF for comment. In line with the above, as a registered Interested and Affected Party (I&AP) on the project database, you are hereby notified of the release of the Draft Amendment Reports for the proposed projects for a 30-day review period, which will extend from 4 October 2019 to 4 November 2019. Please find attached the following: Letter to I&APs; and Comment and Registration Form. Hard copies of the Draft Amendment Reports are available for public viewing at the Sutherland Library, Merweville Library and the Laingsburg Library. The Draft Amendment Reports can also be downloaded from the following website: https://www.csir.co.za/environmental-impact-assessment Kindly ensure that all comments are submitted to the CSIR Project Manager (details provided below) by 4 November 2019. Thank you and kind regards, Minnelise Levendal Pr. Sci. Nat. CSIR - Smart Places - Environmental Management Services PO Box 320, Stellenbosch, 7599 Tel: 021 888 2495 Fax: 021 888 2693 Email: [email protected] Response Pending: 161

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Proof of hand delivery to Western Cape Department of Environmental Affairs and Development Planning


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Letter of notification


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APPENDIX B.6: COMMENTS RECEIVED FOLLOWING THE RELEASE OF THE DRAFT AMENDMENT REPORT FOR COMMENT


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Eskom requirements for work at or near Eskom infrastructure.

1. Eskom’s rights and services must be acknowledged and respected at all

times.

2. Eskom shall at all times retain unobstructed access to and egress from its servitudes.

3. Eskom’s consent does not relieve the developer from obtaining the necessary statutory, land owner or municipal approvals.

4. Any cost incurred by Eskom as a result of non-compliance to any relevant environmental legislation will be charged to the developer.

5. If Eskom has to incur any expenditure in order to comply with statutory

clearances or other regulations as a result of the developer’s activities or because of the presence of his equipment or installation within the servitude restriction area, the developer shall pay such costs to Eskom on demand.

6. The use of explosives of any type within 500 metres of Eskom’s services shall only occur with Eskom’s previous written permission. If such permission is granted the developer must give at least fourteen working days prior notice of the commencement of blasting. This allows time for arrangements to be made for supervision and/or precautionary instructions to be issued in terms of the blasting process. It is advisable to make application separately in this regard.

7. Changes in ground level may not infringe statutory ground to conductor clearances or statutory visibility clearances. After any changes in ground level, the surface shall be rehabilitated and stabilised so as to prevent erosion. The measures taken shall be to Eskom’s satisfaction.

8. Eskom shall not be liable for the death of or injury to any person or for the loss of or damage to any property whether as a result of the encroachment or of the use of the servitude area by the developer, his/her agent, contractors, employees, successors in title, and assignees. The developer indemnifies Eskom against loss, claims or damages including claims pertaining to consequential damages by third parties and whether as a result of damage to or interruption of or interference with Eskom’s services or apparatus or otherwise. Eskom will not be held responsible for damage to the developer’s equipment.

9. No mechanical equipment, including mechanical excavators or high lifting machinery, shall be used in the vicinity of Eskom’s apparatus and/or services, without prior written permission having been granted by Eskom. If such permission is granted the developer must give at least seven working days’ notice prior to the commencement of work. This allows time for arrangements to be made for supervision and/or precautionary instructions to be issued by the relevant Eskom Manager



Note: Where and electrical outage is required, at least fourteen work days are required to arrange it.

10. Eskom’s rights and duties in the servitude shall be accepted as having prior right at all times and shall not be obstructed or interfered with.

11. Under no circumstances shall rubble, earth or other material be dumped within the servitude restriction area. The developer shall maintain the area concerned to Eskom’s satisfaction. The developer shall be liable to Eskom for the cost of any remedial action which has to be carried out by Eskom.

12. The clearances between Eskom’s live electrical equipment and the proposed construction work shall be observed as stipulated by Regulation 15 of the Electrical Machinery Regulations of the Occupational Health and Safety Act, 1993 (Act 85 of 1993).

13. Equipment shall be regarded electrically live and therefore dangerous at all times.

14. In spite of the restrictions stipulated by Regulation 15 of the Electrical Machinery Regulations of the Occupational Health and Safety Act, 1993 (Act 85 of 1993), as an additional safety precaution, Eskom will not approve the erection of houses, or structures occupied or frequented by human beings, under the power lines or within the servitude restriction area.

15. Eskom may stipulate any additional requirements to highlight any possible exposure to Customers or Public to coming into contact or be exposed to any dangers of Eskom plant.

16. It is required of the developer to familiarise himself with all safety hazards related to Electrical plant.

17. Any third party servitudes encroaching on Eskom servitudes shall be registered against Eskom’s title deed at the developer’s own cost. If such a servitude is brought into being, its existence should be endorsed on the Eskom servitude deed concerned, while the third party’s servitude deed must also include the rights of the affected Eskom servitude.

John Geeringh (Pr Sci Nat) Senior Consultant Environmental Management Eskom GC: Land Development



>>> Minnelise Levendal 04 Nov 2019 16:39 >>> Dear Ms Scott I hereby acknowledge receipt of your comments/email, included below, which I received via Dr Dlamini. Please note that your comments will be incorporated in the Comments and Responses Trails of the Final Amendment Reports for the Sutherland, Sutherland 2 and Rietrug Wind Energy Facilities. The Final Amendment Reports will be submitted to the national Department of Environment, Forestry and Fisheries (DEFF) [previously operating as the national Department of Environmental Affairs (DEA)] for decision-making. Please submit future correspondence regarding these amendment applications to me as I am the project manager and Environmental Assessment Practitioner of these projects. Many thanks and best wishes, Minnelise Minnelise Levendal CSIR, SMART PLACES (Environmental Management Services) PO Box 320 Stellenbosch 7599 Tel: + 27-21 888-2495 Cell: 083 309 8159 Fax: 021-888 2693 Email: [email protected] GO Green - Please consider the environment before printing this email



>>> Natasha Higgitt <[email protected]> 12 Nov 2019 16:26 >>> [The e-mail server of the sender failed SPF checks and maybe malicious (SPF Record)] Good afternoon, We are currently experiencing some technical problems with SAHRIS. As such, we are unable to review any cases or issue any comments. Our technical team is working on the problem and all stakeholders will be informed once the issue is resolved. Kind regards, From: Minnelise Levendal <[email protected]> Sent: Tuesday, November 12, 2019 3:19 PM To: Natasha Higgitt <[email protected]> Subject: Comments on the proposed Rietrug, Sutherland and Sutherland 2 Amendment Applications for Mainstream Dear Natasha I hope you are well. I am currently undertaking the subtantive amendment processes (third amendments) for amendments to the EAs for the proposed Rietrug, Sutherland and Sutherland 2 Wind Energy Facilities near Sutherland for Mainstream. Mainstream wishes to increase the turbine hub height and rotor diameter from 150 m to 200 m each. Mainstream also wishes to change the contact details of the holder of the EA. I attach the previous comments from SAHRA on the previous amendment applications. I would like to follow up on comments from SAHRA for the latest amendments (amendments 3). The Draft Amendment Reports have been released for public comment. Can you please advise on this matter. Please let me know if you require any additional information. Your response will be highly appreciated. Many thanks and kind regards, Minnelise

Minnelise Levendal (Pri Sci Nat) CSIR, Implementation Unit (Environmental Management Services) PO Box 320 Stellenbosch 7599 Tel: + 27-21 888-2495 Cell: 083 309 8159 Fax: 021-888 2693 Email: [email protected]







Natasha Higgitt Heritage Officer: Archaeology, Palaeontology and Meteorites Unit South African Heritage Resources Agency - A nation united through heritage - T: +27 21 462 4502/ 8660| C:+27 82 507 0378| F:+27 21 462 4509 E: [email protected] | 111 Harrington Street | Cape Town | www.sahra.org.za


http://pta-smg2.csir.co.za:32224/?dmVyPTEuMDAxJiZkMDhmMGMwOWIxMGVhMjQ0Yj01RENBQzEzN181NTYzN183NDYxXzEmJjI2NTczMDkwMzNjNjYxOD0xMzMzJiZ1cmw9aHR0cCUzQSUyRiUyRnd3dyUyRXNhaHJhJTJFb3JnJTJFemElMkY=

http://www.sahra.org.za/






APPENDIX B.7: COMMENTS AND RESPONSES REPORT (SUTHERLAND 2)

No. Raised by Comments Response

COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS: INTEGRATED ENVIRONMENTAL AUTHORISATIONS (ACKNOWLEDGEMENT OF APPLICATION)

1. Department of Environmental Affairs Mr Sabelo Malaza Chief Director: Integrated Environmental Authorisations Enquiries: Mr Herman Alberts Letter received via email Date: 28/08/2019

Dear Ms Levendal ACKNOWLEDGEMENT OF RECEIPT OF APPLICATION FOR AMENDMENT OF ENVIRONMENTAL AUTHORISATION ISSUED ON 10 NOVEMBER 2016 FOR THE 140 MEGAWATTS (MW) SUTHERLAND 2 WIND ENERGY FACILITY NEAR THE TOWN OF SUTHERLAND, WITHIN THE KAROO HOOGLAND AND THE LAINSBURG LOCAL MUNICIPALITY IN THE WESTERN CAPE AND THE NORTHERN CAPE PROVINCES The Department confirms having received the application for Amendment of Environmental Authorisation for the abovementioned project on 19 August 2019. Please note that your application for Amendment of Environmental Authorisation falls within the ambit of amendments to be applied for in terms of Part 2 of Chapter 5 of the Environmental Impact Assessment (EIA) Regulations, 2014, as amended. You are therefore referred to Regulation 32 of the EIA Regulations, 2014, as amended.

CSIR: Thank you for the letter of acknowledgement of receipt of the amendment application. The requirements in terms of Regulation 32 of the 2014 NEMA EIA Regulations, as amended, for a substantive amendment were adhered to.

The draft motivation report to be submitted must comply with the following:

(a) Public participation (i) Please ensure that comments from all relevant stakeholders

are submitted to the Department with the final report. This includes but is not limited to the Western Cape Department of Environmental Affairs and Development Planning, the Northern Cape Department of Environment and Nature Conservation, the Department of Forestry and Fisheries (DAFF), the provincial Department of Agriculture, the South African Civil Aviation Authority (SACAA), the Department of Transport, the Laingsburg Local Municipality, the Karoo Hoogland Local Municipality, the Department of Water and

CSIR: All the identified stakeholders were requested to provide comments on the Draft Amendment Report via letter 1 that was emailed on 3 October 2019. The notification was sent to all the stakeholders and Interested and Affected Parties on the database included in Appendix B.3. Follow up emails to remind stakeholders to submit comments were sent on 25 October 2019 and on 1 November 2019. Hard copies of the Draft Amendment report and electronic copies (USBs) were couriered to the Department of Environmental Affairs (Integrated Environmental Authorisations), the Department of Environmental Affairs (Biodiversity Conservation), the Western Cape Department of Environmental Affairs and Development Planning (DEA&DP and the Northern Cape



No. Raised by Comments Response Sanitation (DWS), the South African National Roads Agency Limited (SANRAL), the South African Heritage Resources Agency (SAHRA), the Endangered Wildlife Trust (EWT), BirdLife SA, the Department of Mineral Resources, the Department of Rural Development and Land Reform, and the Department of Environmental Affairs: Directorate Biodiversity and Conservation.

Department of Environment and Nature Conservation (DENC). Hard copies were also couriered to the Laingsburg, Sutherland and Merweville Public Libraries. Electronic copies of the report were couriered to the Karoo Hoogland and the Laingsburg local municipalities as well as the Namakwa and Central Karoo District Municipalities. Electronic copies of the report were couriered to the Department of Water and Sanitation (DWS, based in Bellville), the Northern Cape DWS, the Northern Cape Department of Agriculture, the Northern Cape Department of Transport and Public Works as well as the SKA office. Proof of courier waybills and proof of the emails sent are included in Appendix B.5 of the Final Amendment Report, together with proof of follow up reminders that were sent via email. Copies of the comments received are included in Appendix B.6 of the Final Amendment Report.

(ii) Please ensure that all issues raised, and comments received during the circulation of the draft report from registered l&APs and organs of state which have jurisdiction in respect of the proposed activity are adequately addressed in the final report. The Public Participation Process must be conducted in terms of Regulation 39, 40, 41, 42, 43 & 44 of the EIA Regulations 2014 as amended.

CSIR: All the issues raised, and comments received during the circulation of the draft report have been adequately addressed in this Comments and Response Report [(C&R), included as Appendix B.7 of the Final Amendment Report]. The comments received are included in Appendix B.6 of this Final Amendment Report. The Public Participation Process (PPP) has been conducted in terms of Regulation 39, 40, 41, 42, 43 & 44 of the EIA Regulations 2014 as amended. Please refer to section 2.2 and Appendix B of the Final Amendment Report for details on the PPP that was followed.

(b) Layout and Sensitivity Maps (i) All preferred turbine positions must be clearly numbered.

The turbine position numbers must be consistently used in all maps to be included in the final report.

CSIR: All the preferred turbine positions are clearly numbered in the Final Amendment Report i.e. this report – The turbine position numbers are consistent in all maps used.

(ii) A copy of the draft layout map must be submitted with the draft report. All available biodiversity information must be used in the finalisation of the layout map. Existing infrastructure must be used as far as possible e.g. roads.

CSIR: The draft layout map was submitted with the Draft and Final Amendment Reports – refer to Figures 1 and 13 of said reports. Existing roads were used as much as possible.



No. Raised by Comments Response The layout map must indicate the following:

The envisioned area for the wind energy facility; i.e. placing of wind turbines and all associated infrastructure should be mapped at an appropriate scale;

CSIR: The layout map includes the location of the proposed turbines and associated infrastructure (such as the laydown area, substation and Operational and Maintenance (O&M) building – refer to Figures 1 and 13 of the Final Amendment Report).

All supporting onsite infrastructure such as laydown area, guard house, control room, and buildings, including accommodation etc;

CSIR: The layout map includes the location of the on-site infrastructure (such as the laydown area, substation and Operational and Maintenance (O&M) building – refer to Figures 1 and 13 of the Final Amendment Report.

All necessary details regarding all possible locations and sizes of the proposed satellite substation, the main substation and internal powerlines;

CSIR: The layout map includes the internal roads and shows the areas where the substation will be developed – refer to Figures 1 and 14 of the Final Amendment Report. A new substation (with an approximate compound size of 90m x 120m) and a transformer will be constructed on site.

All existing infrastructure on the site, especially internal roads infrastructure;

CSIR: The layout map includes the internal roads – refer to Figures 1 and 14 of the Final Amendment Report.

The location of sensitive environmental features on site e.g. CBAs, heritage sites, wetlands, drainage lines etc. that will be affected by the facility and its associated infrastructure;

CSIR: The layout map has been overlaid with the sensitive environmental features on site, e.g. heritage features, drainage lines, wetlands and avifauna nests – refer to Figure 12 of the Final Amendment Report.

Buffer areas; and CSIR: The relevant buffer areas as identified by the specialists have been incorporated in the layout map (Figure 13 and 14). These include the visual buffer of 660 m, the Verreaux’s eagle nest buffers of X m, the buffers from the wetlands and the drainage lines.

All “no-go” areas. CSIR: No-go areas are indicated as areas of high and very high sensitivity



No. Raised by Comments Response on the layout map (see Figure 13 and 14). These areas have been excluded from the project layout.

(iii) The draft report must include an environmental sensitivity map indicating environmental sensitive areas and features identified during the assessment process.

CSIR: An environmental sensitivity map has been included in the Draft Amendment Report (Figure 13) and the Final Amendment Report (Figure 13). The map indicates the environmental sensitive areas and features identified during the assessment process. It includes areas of high and very high sensitivity that need to be avoided. These areas have been excluded from the project layout.

(iv) The draft report must include a map combining the draft layout map superimposed (overlain) on the environmental sensitivity map.

CSIR: The Draft and Final Amendment Reports include a site layout map which has been overlaid with the environmental sensitive features and buffers on site (see Figure 14). Areas of high and very high sensitivity are indicated on the map. These areas are excluded from the project layout.

(v) The draft report must clearly show the positions of the authorised turbines in relation to the proposed locations.

CSIR: The approved site layout has been overlaid to the proposed turbines locations/amendment and shows the sensitive features and buffers (see Figure 13). The amended layout plan is included in Figures 1 and 13.

(c) Specialist assessments

(i) You are requested to submit supplementary specialist assessments from the following specialists on the new layout with the draft motivation report:

Avifauna Heritage and palaeontology Botanical (flora and fauna) Noise Bat Visual

CSIR: Supplementary specialist assessments from the avifauna, heritage, Ecological (flora and fauna), noise, bat and visual specialists have been included in Appendix C of the Draft and Final Amendment Report. The inputs from the specialists are also included in section 4 of the Final Amendment Report. The feedback and conclusion from the specialists were that the proposed amendments do not alter the originally identified impacts, assessment of these impacts, impact significance or recommended management and mitigations measures. Additional mitigation measures were provided by the specialists (see section 4.3-4.8) and Appendix C of this report. These additional mitigation measures have been included in the updated EMPr located in Appendix D of this report.



No. Raised by Comments Response A summary of the impacts identified, and the significance ratings thereof as contained in the original approved Final EIA Report (ERM 2011) and in the subsequent Amendment reports (CSIR, 2016 and 2017) are provided in Table 15. The full impact assessment tables are available in Appendix A. These impacts have been deemed to be mitigatable and acceptable, since this project has received Environmental Authorisation from the DEA (now operating as DEFF) in 2012 and the amendment applications have been approved in 2016 and 2017. No additional impacts have been identified by the specialists to occur due to the amendments currently proposed. The specialists confirmed that the significance ratings of the impacts from the previous initial EIA undertaken by ERM (2011) and the subsequent amendment reports prepared by CSIR (2016 & 2017) are still applicable for this Amendment Application (see Table 15 of the Final Amendment Report). The specialists are therefore of the opinion that the proposed amendments can be authorised.

(ii) The EAP must ensure that the terms of reference for any identified supplementary specialist assessment includes the following: A detailed description of the assessment's

methodology; indication of the locations and descriptions of the development footprint, and all other associated infrastructures that they have assessed and are recommending for authorisations.

CSIR: The specialists have been consulted and provided with a Terms of Reference (ToR) which includes the assessment methodology (Appendix A of this report), the location and description of the development footprint and associated infrastructure that they have assessed and are recommending for authorisation.

Provide a detailed description of all limitations to the assessments. All specialist studies must be conducted in the right season and providing that as a limitation will not be allowed.

CSIR: The specialists confirmed that they do not have any limitations to their assessments for the proposed amendments. The assessments were conducted in the appropriate season, as relevant.

Please note that the Department considers a 'no-go' area, as an area where no development of any infrastructure is allowed; therefore, no development of associated infrastructure including access roads is allowed in the 'no-go' areas. Should the specialist

CSIR: The specialists identified areas of low, medium, high and very high sensitivity for the proposed Sutherland 2 WEF project area (Figure 13 in the Final Amendment Report). In addition, the specialist have also identified no-go areas - no turbines or any associated



No. Raised by Comments Response definition of 'no-go' area differ from the Departments definition; this must be clearly indicated. The specialist must also indicate the 'no-go' areas buffer if applicable.

infrastructure will be placed within these areas.

All specialist assessments must be final and provide detailed/practical mitigation measures and recommendations.

CSIR: The specialist assessments are final and provide detailed and practical mitigation measures and recommendations (please refer to Appendix C of the Final Amendment Report). These mitigation measures and recommendations have been included in section 4 and in the updated EMPr (Appendix D) of the Final Amendment Report.

Should specialist recommend specific mitigation measures for identified turbine positions, these must be clearly indicated.

CSIR: The specialists have not identified specific mitigation measures for identified turbine positions. Some of the specialists, e.g. avifauna and visual, have identified buffers of 660 m which were adhered to in the project layout – please refer to Figure 13 of the Final Amendment Report.

Clearly defined cumulative impacts and where possible the size of the identified impact must be quantified and indicated, i.e. hectares of cumulatively transformed land.

CSIR: The specialists have identified and assessed cumulative impacts-please refer to the specialist studies in Appendix C and section 4 of the Final Amendment Report.

A detailed process flow to indicate how the specialist's recommendations, mitigation measures and conclusions from the various similar developments in the area were taken into consideration in the assessment of cumulative impacts and when the conclusion and mitigation measures were drafted for this project.

CSIR: The cumulative impacts have been identified and have been assessed, rated and have informed the specialist recommendations and mitigation measures. Section 4 of the Final Amendment Report includes a list of the projects that were considered by the specialists in their cumulative assessments. The cumulative assessments are included in the specialist studies in Appendix C and in section 4 of the Final Amendment Report.

Identified cumulative impacts associated with the proposed development must be rated with the significance rating methodology used in the process.

CSIR: The cumulative impacts have been identified and have been assessed and rated with the assessment methodology used in the process-refer to the specialist studies in Appendix C and section 4 of the Final Amendment Report.



No. Raised by Comments Response The significance rating must also inform the need and

desirability of the proposed development. CSIR: The significance rating also informed the need and desirability of the proposed development. It is also important to note that the proposed project site is located within REDZ 2 (Komsberg REDZ), which supports the development of large-scale wind and solar energy developments. The proposed project is therefore in line with the national planning vision for wind and solar development in South Africa. All the specialists have recommended that the proposed amendments to the EA of the Sutherland 2 WEF be approved provided that the recommended mitigation measures are implemented. The mitigation measures are included in the EMPr and will be implemented during the design, construction, operation and decommissioning phases of the proposed Sutherland 2 WEF.

A cumulative impact environmental statement on whether the proposed development must proceed.

CSIR: The specialists have assessed the cumulative impacts and have concluded that the proposed amendments to the EA of the proposed Sutherland 2 WEF can be approved.

(iii) Should the appointed specialists specify contradicting recommendations, the EAP must clearly indicate the most reasonable recommendation and substantiate this with defendable reasons; and were necessary, include further expertise advice.

CSIR: The specialists have not provided contradicting recommendations in their reports. All the specialists concluded that the proposed amendments will not affect or change the assessment ratings contained in the original EIA (ERM, 2011). The specialists recommended that the proposed amendments can be approved. Additional mitigation measures provided by the specialists have been included in the EMPr (Appendix D of this Final Amendment Report). Where relevant, mitigation measures that have been identified by the specialists in this amendment application, which were not included in the original EA (10 November 2016) have been included in section 5 of the Final Amendment Report, i.e. the section which identifies which changes must be made to the EA. These recommendations and mitigation measures were also included in the Draft EMPr (Appendix D).



No. Raised by Comments Response (iv) The maps used within the specialist studies must comply

with comment b(i) of this comments letter. CSIR: The maps used in the specialist studies comply with the said comment i.e. All the preferred turbine positions are clearly numbered. The turbine position numbers are consistently used in all maps included in the Final Amendment Report.

(v) The specialist assessments must comply with all the latest industry guidelines.

CSIR: The specialist assessments, including the mitigation measures and recommendations are in line with applicable and most recent industry guidelines (see specialist assessments included in Appendix C). For example, the avifaunal study notes that the “Best Practice Guidelines for Avian Monitoring and Impact Mitigation at Proposed Wind Energy Development Sites in Southern Africa”, (Jenkins et al. 2011) revised in 2015, require that either all, or part of the pre-construction monitoring is repeated if there is a time period of three years or more between the data collection and the construction of the wind farm. This re-assessment is necessary in order to take cognisance of any changes in the environment which may affect the risk to avifauna, and to incorporate the latest available knowledge into the assessment of the risks. In order to give effect to this requirement, nest searches were repeated in June and July 2019 by Chris van Rooyen Consulting for this application to ensure up to date information on the breeding status of priority species at the proposed Sutherland 2 WEF. The avifaunal study also notes that two new sets of guidelines for avifauna have been published as indicated below. Since the original Bird Specialist Studies were completed in 2011 and 2016, the local knowledge with regard to the impacts of wind turbines on avifauna in South Africa has increased significantly with the experienced gained from operational wind farms, see for example (Ralston-Patton et al. 2017). This has also resulted in the publication of two new sets of guidelines, one for Cape Vultures (Pfeiffer et al. 2018) and one for Verreaux’s Eagles (Ralston-Patton, 2017).



No. Raised by Comments Response You are also advised that the Public Participation Process must be conducted as outlined in Chapter 6 of the EIA Regulations, 2014, as amended.

CSIR: The Public Participation Process (PPP) has being conducted as outlined in Chapter 6 of the 2014 NEMA EIA Regulations, as amended. Please refer to section 2.2 of this report and Appendix B for a description of the PPP that was undertaken to date and which will still be undertaken as part of this amendment application.

Further note that in terms of Regulation 45 of the EIA Regulations, 2014, as amended, this application will lapse if the applicant fails to meet any of the time-frames prescribed in terms of these Regulations, unless an extension has been granted in terms of Regulation 3(7} of the EIA Regulations, 2014, as amended.

CSIR: The prescribed timeframes are being adhered to. The Draft Amendment Report has been submitted to stakeholders for a 30-day commenting period which extended from 4 October 2019 to 4 November 2019. The Final Amendment Report is hereby submitted to DEFF within 90 days from the date that the Department received the application for this amendment, i.e. on 19 August 2019.

All documentation delivered to the physical address contained in this form must be delivered during the official Departmental Office Hours which is visible on the Departmental gate. EIA related documents (includes application forms, reports or any EIA related submissions) that are faxed; emailed; delivered to Security or placed in the Departmental Tender Box will not be accepted. Yours sincerely Mr Sabelo Malaza

CSIR: All the documentation pertaining to this application has been and will be delivered during the official office hours of the Department of Environmental Affairs.

COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS: INTEGRATED ENVIRONMENTAL AUTHORISATIONS (COMMENTS ON THE DRAFT AMENDMENT REPORT)

2. Department of Environmental Affairs Chief Directorate: Integrated Environmental Authorisations Mr Sabelo Malaza: Chief Director: Integrated

Dear Ms Levendal COMMENTS ON THE DRAFT REPORT FOR THE APPLICATION FOR AMENDMENT OF ENVIRONMENTAL AUTHORISATION ISSUED ON 10 NOVEMBER 2016 (AS AMENDED) FOR THE 140 MEGAWATTS SUTHERLAND 2 WIND ENERGY FACILITY NEAR SUTHERLAND WITHIN THE KAROO HOOGLAND AND THE LAINGSBURG LOCAL MUNICIPALITIES IN THE WESTERN CAPE AND THE NORTHERN CAPE PROVINCES The Environmental Authorisation (EA) for the above-mentioned project dated 10 November 2016, the application for amendment to the EA received by the Department on 19 August 2019, the acknowledgement

CSIR: During pre-construction bird monitoring done by Van Rooyen et al. in 2016 the presence of two active Verreaux’s Eagle nests was confirmed and a 3 km turbine free buffer areas around these were recommended in accordance with the BLSA guidelines specific to Verreaux’s Eagles (Ralston-Paton, 2017). A 2 km turbine free buffer area was recommended around an inactive Verreaux’s Eagle nest. Searches for new raptor nests were repeated by Chris van Rooyen Consulting during June and July 2019. A new active Verreaux’s Eagle nest was located at 32°39'50.76"S, 20°51'16.02"E and an inactive



No. Raised by Comments Response Environmental Authorisations Enquiries: Mr Herman Alberts Letter sent via email Date: 04/11/2019

letter dated 28 August 2019 and the motivation report dated 04 October 2019, refer. The Department has the following comments on the abovementioned amendment application: (a) Specific comments (i) This Department notes that the avifaunal specialist study by Jenkins (2011) identified one Verreaux's Eagle nest and recommended a 1.5km turbine free buffer area around the nest and a 500m turbine free buffer along the escarpment. The pre-construction monitoring by Van Rooyen et al (2016) confirmed three Verreaux's Eagle nests (two active and one inactive); recommending a 3km buffer around the active nests; and a 2km turbine free buffer along the inactive nest. It is further understood that two new nests (one active another inactive) were identified during the June and July 2019 search. The final amendment motivation report must clearly indicate the total number of nests on the property.

alternate nest of the same pair located at 32°39'43.41"S, 20°51'49.07"E. Although these nests are located further than 3 km away from the current lay-out, a pre-cautionary 3 km no-turbine buffer zone is recommended in case of potential future changes to the layout. These buffer areas were excluded from the buildable areas and were incorporated in the project layout as can be seen in Figure 13 and Figure 14.

(ii) The final amendment motivation report must include a revised layout map showing the 39 wind turbine locations, all the identified Verreaux’s Eagle nests (active and inactive) and its associated turbine free buffers as recommended by the avifaunal specialist.

CSIR: A turbine layout map is included in Figure 1 and Figure 14 of section 7 of the Final Amendment Report. The updated maps show 39 turbines, all the identified Verreaux’s Eagles nests (active and inactive) and its associated turbine free buffers.

(iii) The revised layout map referred to above must also indicate the location of all supporting onsite infrastructure such as laydown area, guardhouse, control room, and buildings, including accommodation etc.

CSIR: The layout map (Figure 1 and Figure 14) indicates all the supporting onsite infrastructure, including the laydown area, guardhouse, control room and buildings.

(iv) The final amendment motivational report must comply with the comments of this letter and the comments of the acknowledgment letter dated 28 August 2019.

CSIR: The Final Amendment Report complies with the comments from DEFF in the letter dated 4 November 2019 as well as the comments in the letter of acknowledgement from DEFF dated 28 August 2019 (the comments are included in no’s 1 and 2 of this comments and response report respectively).

(v) The EAP is required to provide a detailed list of all potential amendments to the EA, which should inter alia recommend

CSIR: A detailed list of all potential amendments to the EA, including the



No. Raised by Comments Response additional conditions that must be incorporated into the EA, provide amendments to the conditions of the EA by way of either removal and/or amendments as informed by the specialist's recommendations.

additional conditions that must be incorporated into the EA and amendments to the EA are included in section 5 of the Final Amendment Report.

(vi) The draft EMPr to be submitted with the final amendment motivation report must be updated to include the revised layout as per comment a(i) of this comment letter and incorporate all mitigation measures recommended by the specialists.

CSIR: The EMPr has been updated and includes the revised layout as per comment a(i) and also incorporates all mitigation measures as recommended by the specialists (as per their studies in Appendix C and also included in section 4 of this Final Amendment Report).

(vii) The applicant is required to comply with Regulation 39 (1) of EIA Regulations 2014, (as amended) and submit a written consent of the landowner for the amendment application.

CSIR: Landowners signed a Special Power of Attorney document to authorise Mainstream to sign EIA related documents on their behalf. This includes consent to the amendment application. These signed documents are included in Appendix F (Additional information) of the Final Amendment Report.

(viii) You are required to submit certified copies of all amendment’s decisions related to this development.

CSIR: A certified copy of the amendment decision for Amendment 2 of the Sutherland 2 WEF is included in Appendix F of this Final Amendment Report. An original commissioned Affidavit under oath undertaken by Mr Eugene Marais is included in Appendix F for the original EA and the Amendment 1 Decision as the original documents are not available. The Affidavit is included in Appendix F of this report.

(b) Public participation Process (PPP} (i) Please ensure that comments from all relevant stakeholders

are submitted to the Department with the final report. This includes but is not limited to the Northern Cape Department of Environment and Nature Conservation, The Western Cape Department of Environmental Affairs and Development Planning; the provincial Department of Agriculture, the South African Civil Aviation Authority (SACAA), the Department of Transport, the Karoo Hoogland

CSIR: All the identified stakeholders were requested to provide comments on the Draft Amendment Report via letter 1 that was emailed on 4 October 2019. The notification was sent to all the stakeholders and Interested and Affected Parties on the database included in Appendix B.3. Follow up emails to remind stakeholders to submit comments were sent on 25 October 2019 and on 1 November 2019. Hard copies of the Draft Amendment report and electronic copies (USBs) were couriered to the Department of



No. Raised by Comments Response Local Municipality, the Laingsburg Local Municipality, the Department of Water and Sanitation (DWS), the South African National Roads Agency Limited (SANRAL), the South African Heritage Resources Agency (SAHRA), the Endangered Wildlife Trust (EWT), BirdLife SA, the South African Bat Assessment Association, the Department of Mineral Resources, the Department of Rural Development and Land Reform, and the Department of Environmental Affairs: Directorate Biodiversity and Conservation.

Environmental Affairs (Integrated Environmental Authorisations), the Department of Environmental Affairs (Biodiversity Conservation), and the Northern Cape Department of Environment and Nature Conservation (DENC). Hard copies were also couriered to the Laingsburg, Sutherland and Merweville Public Libraries. Electronic copies of the report were couriered to the Karoo Hoogland and the Laingsburg local municipalities as well as the Namakwa and Central Karoo District Municipalities. Electronic copies of the report were couriered to the Department of Water and Sanitation (DWS, based in Bellville), the Northern Cape DWS, the Northern Cape Department of Agriculture, the Northern Cape Department of Transport and Public Works as well as the SKA office. Proof of courier waybills and proof of the emails sent are included in Appendix B.5 of the Final Amendment Report, together with proof of follow up reminders that were sent via email. Copies of the comments received are included in Appendix B.6 of the Final Amendment Report. The comments and response report (this report) is included as Appendix B.7 of the Final Amendment Report.

• All original comments from I&APs are included in Appendix B.6 of the Final Amendment Report. Comments from I&APs are copied verbatim and are responded to clearly in this comments and responses report.

• Comments are responded to with adequate responses in the comments and responses report and not by merely indicating “noted”.

• Issues raised and comments received from registered l&APs and organs of state (including the Department's Biodiversity Section) are adequately addressed in the comments and responses report of the Final Amendment Report.

• Proof of correspondence with stakeholders as well as proof of attempts made to obtain comments from them are included in Appendix B.5 of the Final Amendment Report.

The Public Participation Process has been conducted in terms of



No. Raised by Comments Response Regulations 39, 40 41, 42, 43 & 44 of the EIA Regulations 2014, as amended (please refer to section 2.2 and Appendix B of the Final Amendment Report).

(ii) A Comments and Response Report (C&R) must be submitted with the final report. The C&R report must incorporate all comments for this application. The C&R report must be a separate document from the main report and the format must be in the table format as indicated in Appendix 1 of this comments letter. Please refrain from summarising comments made by l&APs. All comments from l&APs must be copied verbatim and responded to clearly. Please note that a response such as “noted" is not regarded as an adequate response to l&APs comments.

CSIR: The C&R (this report) is included as Appendix B.7 of the Final Amendment Report. The C&R report incorporates all comments received for this application. The C&R report is a separate document from the main report (Appendix B.7) and the format is in the table format as indicated in Appendix 1 of this comments letter. All comments from l&APs are copied verbatim and responded to clearly. Adequate responses have been provided and not merely indicating “noted.”

(iii) Please ensure that all issues raised, and comments received during the circulation of the draft report from registered l&APs and organs of state which have jurisdiction in respect of the proposed activity are adequately addressed in the final report. Proof of correspondence with the various stakeholders must be included in the final report. Should you be unable to obtain comments, proof should be submitted to the Department of the attempts that were made to obtain comments. The Public Participation Process must be conducted in terms of Regulation 39, 40, 41, 42, 43 & 44 of the EIA Regulations 2014 as amended.

CSIR: Issues raised and comments received from registered l&APs and organs of state during the commenting period of the Draft Amendment Report are adequately addressed in the C&R report of the Final Amendment Report. Proof of correspondence with stakeholders as well as proof of attempts made to obtain comments from them are included in Appendix B.5 of the Final Amendment Report. The Public Participation Process has been conducted in terms of Regulations 39, 40 41, 42, 43 & 44 of the EIA Regulations 2014, as amended. Please refer to section 2.2 and Appendix B of the Final Amendment Report for details on the Public Participation Process followed.

(vi) The final report must also indicate that this draft report has been subjected to a public participation process.

CSIR: The Final Amendment Report includes proof that the Draft Amendment Report has been subjected to a public participation process. Please refer to section 2.2. and Appendix B of the Final Amendment Report for details on the Public Participation Process



No. Raised by Comments Response that was followed. Advertisements were placed in the Noordwester (local newspaper), the Cape Times and Die Burger (provincial) newspapers. Afrikaans advertisements were placed in the Noordwester and Die Burger, whilst an English advertisement was placed in the Cape Times. The newspaper advertisements provided the details of the project website (i.e. https://www.csir.co.za/environmental-impact-assessment ), as an indication of where information available on the project can be downloaded from. A copy of the text included in the newspaper advertisements is included in Appendix B.1 of this Amendment Report. Proof of placement of the newspaper advertisements are included in Appendix B.1 of this Final Amendment Report. Notice boards were placed at the locations shown in Table 1 of section 2.2 of the Final Amendment Report. A copy of the notice boards and photos taken as proof of placement thereof are included in Appendix B.2 of this Final Amendment Report. The Draft Amendment Report was made available and distributed to ensure access to information on the project and to communicate the outcome of specialist studies. Copies of the report were placed at the Sutherland, Laingsburg and Merweville local libraries for I&APs and stakeholders to access for viewing. Key authorities were provided with either a hard copy and/or USB of the Amendment Report via courier. The Draft Amendment Report was uploaded to the project website (i.e. https://www.csir.co.za/environmental-impact-assessment). Interested and Affected Parties and stakeholders were notified of the release of the Draft Amendment Report for comment via email on 4 October 2019. Follow up emails were sent on 25 October and 4 November 2019 to remind I&APs to provide comment.

(c) Layout & Sensitivity Maps (i) All preferred turbine positions must be clearly numbered.

CSIR: All the preferred turbine positions are clearly numbered in the Final

https://www.csir.co.za/environmental-impact-assessment





No. Raised by Comments Response The turbine position numbers must be consistently used in all maps to be included in the final report.

Amendment Report and the turbine position numbers are consistently used in all the maps in the Final Amendment Report.

(ii) The final report must include an environmental sensitivity map indicating environmental sensitive areas; features identified during the assessment process and associated buffers.

CSIR: An environmental sensitivity map indicating the sensitive areas and features and buffers identified during the assessment process is included in Figure 13 of the Final Amendment Report.

(iii) The final report must include a map combining the final layout map superimposed (overlain) on the environmental sensitivity map.

CSIR: An environmental sensitivity map overlain with the final layout map is included in Figure 14 of the Final Amendment Report

(d) Specialist assessments (i) The specialist must also include, whether or not the hub

height and rotor diameter is to be amended to "up to 200m" or "200m" as well as provide what their respective minimum and maximum rotor swept areas are be to, based on their assessments. The assessments must cover the entire range of turbines and not a specific turbine specification based on the amendment.

CSIR: The specialists indicated that the hub height and rotor diameter could be amended to “up to 200 m.” The bird and bat specialists recommended that a maximum of 39 turbines are deployed, if turbines with a hub height of up to 200 m and a rotor diameter of up to 200 m are deployed. Should smaller turbines be used, more turbines might be installed. If more than 39 turbines with these specifications are installed, then additional inputs and mitigation measures from the specialists would be required. The bat specialist recommends a three-pronged consideration when selecting the appropriate turbine technology for the wind farm:

• Turbine dimensions with a greater hub height (to increase lower blade tip height and reduce collision risk with lower flying species).

• Turbine dimensions with the smallest rotor diameter (to decreased total tip height and reduce collision risk with high flying species).

• Least number of turbines required to generate the total megawatt output of the facility.

(ii) The maps used within the specialist studies must comply with comment c (i) of this comments letter.

CSIR: The maps used in the specialist studies comply with comment c (i): The specialists were requested to number the turbines in their



No. Raised by Comments Response maps consistently with the numbering used in the other project maps. All the preferred turbine positions are therefore clearly numbered in the specialist reports and have been consistently used in all the maps in the report (including the specialist studies).

(iii) The EAP must provide confirmation that all specialists were provided with the same request of proposed amendments as well as ensure that the terms of reference for all the identified specialist studies must include the following: A detailed description of the study's methodology;

indication of the locations and descriptions of the development footprint, and all other associated infrastructures that they have assessed and are recommending for authorisations.

CSIR: The specialists have been consulted and provided with a Terms of Reference (ToR) which includes the assessment methodology (Appendix A of this report), the location and description of the development footprint and associated infrastructure that they have assessed and are recommending for authorisations.

Provide a detailed description of all limitations to the studies. All specialist studies must be conducted in the right season and providing that as a limitation will not be allowed.

CSIR: The specialists confirmed that they do not have any limitations to their assessments for the proposed amendments. The assessments were conducted in the appropriate season.

Please note that the Department considers a 'no-go' area, as an area where no development of any infrastructure is allowed; therefore, no development of associated infrastructure including access roads is allowed in the 'no-go' areas.

CSIR: The specialists have identified areas of low, medium, high and very high sensitivity for the proposed Sutherland 2 WEF project area (Figure 13 and Figure 14 in the Final Amendment Report). The specialists have also identified no-go areas. The proposed layout, which incorporates larger turbines, has been refined to include the buffer areas as provided by the specialists and has resulted in a reduced buildable area. The turbines, however, avoid all environmental features that were identified on site, avoid areas that were recommended by the specialists and adhere to the provisions included within the Environmental Authorisation issued. This has resulted in a reduced turbine buildable area, but the approved turbine layout will remain the same with the exception of four wind turbines. These wind turbines have been relocated within the remaining buildable area and the approved road layout plan. No development of turbines or any



No. Raised by Comments Response associated infrastructure will take place in no-go areas identified by the specialists (see Figure 13 and Figure 14). Based on the specialist studies outlined above and the findings thereof (see Appendix C of this report), a project sensitivity map has been produced (Figure 13) to show all the environmental features and their respective buffers (where applicable) that were identified by the various specialists have been adhered to. The map, in turn, was used to determine the remaining buildable area of the Sutherland 2 WEF.

Should the specialist definition of “no-go” area differ from the Department's definition; this must be clearly indicated. The specialist must also indicate the 'no-go' area's buffer if applicable.

CSIR: The specialists’ definition of “no-go” areas does not differ from that of the Departments’. The specialists have indicated no-go areas and buffers. These no-go areas and buffers have been used to inform the remaining buildable area and the project layout. All the specialists concluded that the proposed amendments will not affect or change the assessment ratings contained in the original EIA (ERM, 2011). The specialists recommended that the proposed amendments can be approved. Additional mitigation measures provided by the specialists have been included in the EMPr (Appendix D of this Final Amendment Report). Where relevant, mitigation measures that have been identified by the specialists in this amendment application, which were not included in the original EA (10 November 2016) have been proposed to be included in the EA (see section 5 of the Final Amendment Report).

All specialist studies must be final, and provide detailed/practical mitigation measures and recommendations, and must not recommend further studies to be completed post EA.

CSIR: The specialist studies included in Appendix C are final and include detailed and practical mitigation measures and recommendations. These mitigation measures and recommendations have been included in section 4 and in the updated EMPr (Appendix D) of the Final Amendment Report.

Should specialists recommend specific mitigation measures for identified turbine positions, these must be clearly indicated.

CSIR: The specialists have not identified specific mitigation measures for identified turbine positions. Some of the specialists, e.g. avifauna and visual, have identified buffers which need to be adhered to.



No. Raised by Comments Response These buffers have been included in the layout as seen in Figure 13 and Figure 14 of the Final Amendment Report.

Clearly defined cumulative impacts and where possible the size of the identified impact must be quantified and indicated, i.e. hectares of cumulatively transformed land.

CSIR: The specialists have identified and assessed cumulative impacts-please refer to the specialist studies in Appendix C and section 4 of the Final Amendment Report.

A detailed process flow to indicate how the specialist's recommendations, mitigation measures and conclusions from the various similar developments in the area were taken into consideration in the assessment of cumulative impacts and when the conclusion and mitigation measures were drafted for this project.

CSIR: The cumulative impacts have been identified and have been assessed and rated and have informed the specialist recommendations and mitigation measures. Section 4 of the Final Amendment Report includes a list of the projects that were considered by the specialists in their cumulative assessments. The cumulative assessments are included in the specialist studies in Appendix C and in section 4 of the Final Amendment Report.

Identified cumulative impacts associated with the proposed development must be rated with the significance rating methodology used in the process.

CSIR: The cumulative impacts have been identified and have been assessed and rated with the assessment methodology used in the process-refer to the specialist studies in Appendix C and section 4 of the Final Amendment Report.

The significance rating must also inform the need and desirability of the proposed development.

CSIR: The significance rating also informed the need and desirability of the proposed development. It is also important to note that the proposed project site is located within REDZ 2 (Komsberg REDZ), which supports the development of large-scale wind and solar energy developments. The proposed project is therefore in line with the national planning vision for wind and solar development in South Africa. All the specialists have recommended that the proposed amendments to the EA of the Sutherland 2 WEF be approved provided that the recommended mitigation measures are implemented. The mitigation measures are included in the EMPr and will be implemented during the design, construction, operation and decommissioning phases of the proposed Sutherland 2 WEF.

A cumulative impact environmental statement on whether the CSIR:



No. Raised by Comments Response proposed development must proceed. The specialists have assessed the cumulative impacts and have

concluded that the proposed amendments to the EA of the proposed Sutherland 2 WEF can be approved.

(iv) Should the appointed specialists specify contradicting recommendations, the EAP must clearly indicate the most reasonable recommendation and substantiate this with defendable reasons; and were necessary, include further expertise advice.

CSIR: The specialists did not provide contradicting recommendations in their reports. All the specialists concluded that the proposed amendments will not affect or change the assessment ratings contained in the original EIA (ERM, 2011). The specialists recommended that the proposed amendments can be approved. Additional mitigation measures provided by the specialists have been included in the EMPr (Appendix D of this Final Amendment Report). Where relevant, mitigation measures that have been identified by the specialists in this amendment application, which were not included in the original EA (10 November 2016) have been proposed to be included in the EA (see section 5 of the Final Amendment Report).

General • Please ensure that all mitigation recommendations are in line

with applicable and most recent guidelines.

CSIR: All the mitigation measures and recommendations are in line with applicable and most recent guidelines (see specialist assessments included in Appendix C). For example, the avifaunal study notes that the “Best Practice Guidelines for Avian Monitoring and Impact Mitigation at Proposed Wind Energy Development Sites in Southern Africa”, (Jenkins et al. 2011) revised in 2015, require that either all, or part of the pre-construction monitoring is repeated if there is a time period of three years or more between the data collection and the construction of the wind farm. This re-assessment is necessary in order to take cognisance of any changes in the environment which may affect the risk to avifauna, and to incorporate the latest available knowledge into the assessment of the risks. In order to give effect to this requirement, nest searches were repeated in June and July 2019 by Chris van Rooyen Consulting for this application to ensure up to date information on the breeding status of priority species at the proposed Sutherland 2 WEF.



No. Raised by Comments Response The avifaunal study also notes that two new sets of guidelines for avifauna have been published as indicated below. Since the original Bird Specialist Studies were completed in 2011 and 2016, the local knowledge with regard to the impacts of wind turbines on avifauna in South Africa has increased significantly with the experienced gained from operational wind farms, see for example (Ralston-Patton et al. 2017). This has also resulted in the publication of two new sets of guidelines, one for Cape Vultures (Pfeiffer et al. 2018) and one for Verreaux’s Eagles (Ralston-Patton, 2017).

You are further reminded to comply with Regulation 32(1)(a) of the NEMA EIA Regulations, 2014, as amended, which states that: "The applicant must within 90 days of receipt by the competent authority of the application made in terms of regulation 31, submit to the competent authority -

CSIR: The Final Amendment Report is hereby submitted to the Department of Environmental Affairs on 15 November 2019, i.e. within 90 days from the date of receipt of the application by the Department, i.e. on 19 August 2019.

(a) a report, reflecting-

(i) an assessment of all impacts related to the proposed change; (ii) advantages and disadvantages associated with the proposed

change; and (iii) measures to ensure avoidance, management and mitigation

of impacts associated with such proposed change; and (iv) any changes to the EMPr;

which report-

(aa) had been subjected to a public participation process, which had been agreed to by the competent authority, and which was appropriate to bring the proposed change to the attention of potential and registered interested and affected parties, including organs of state, which have jurisdiction in respect of any aspect of the relevant activity, and the competent authority, and (bb) reflects the incorporation of comments received, including

CSIR: An application for substantive amendment has been submitted to the Department of Environmental Affairs in terms of regulation 32 of GN. R.982. The Final Amendment Report contains:

i. an assessment of all impacts related to the proposed change - Please refer to section 4 of this report and the specialist inputs in Appendix C;

ii. advantages and disadvantages associated with the proposed change – Please refer to section 7 of this report; and

iii. measures to ensure avoidance, management and mitigation off impacts associated with such proposed change – Please refer to section 4 of this report, the specialist inputs in Appendix C and the EMPr in Appendix D; and

iv. any changes to the EMPr – Please refer to Appendix D of this report.

(aa) The Final Amendment Report has been subjected to a PPP as



No. Raised by Comments Response any comments of the competent authority."

reflected in section 2.2 and Appendix B of the Final Amendment Report. (bb) All comments received (including the comments from the Department of Environmental Affairs: Integrated Environmental Authorisations and Biodiversity Conservation) were included in Appendix B.6 of this Final Amendment Report. These comments were included and addressed in this C&R report (Appendix B.7).

Should there be significant changes or new information that has been added to the motivation report or EMPr which changes or information was not contained in the reports or plans consulted on during the initial public participation process, you are required to comply with Regulation 32(1)(b) of the NEMA EIA Regulations,2014, as amended, which states: "the applicant must, within 90 days of receipt of the application by the competent authority, submit to the competent authority - (b) a notification in writing that the report will be submitted within 140 days of receipt of the application by the competent authority, as significant changes have been made or significant new information has been added to the report, which changes or information was not contained in the report consulted on during the initial public participation process contemplated in sub regulation (1)(a) and that the revised report will be subjected to another public participation process of at least 30 days".

CSIR: No significant changes or new information has been added to the motivation report or EMPr, which was not contained in the reports consulted on during the initial PPP. Therefore, sub regulation 32(1)(ab) of the 2014 NEMA EIA Regulations does not apply and the Final Amendment Report is hereby submitted within 90 days from the date of receipt of the Application form by the Department of Environmental Affairs, i.e. on 15 November 2019.

In the event where sub regulation (1)(b) applies, the report, which reflects the incorporation of comments received, including any comments of the competent authority, must be submitted to the competent authority within 140 days of receipt of the application by the competent authority.

CSIR: Sub regulation 32(1)(b) of the 2014 NEMA EIA Regulations, as amended, does not apply as no significant changes or new information were added to the motivation report or EMPr which was not contained in the reports consulted on during the initial PPP. The Final Amendment Report is hereby submitted within 90 days from the date of receipt of the Application form by the Department of Environmental Affairs, i.e. on 15 November 2019.

Should you fail to meet any of the timeframes stipulated in Regulation 32 of the NEMA EIA Regulations, 2014, as amended, your application will lapse.

CSIR: The requirements and timeframes in terms Regulation 32 of the 2014 NEMA EIA Regulations, as amended, for a Substantive Amendment have been adhered to.



No. Raised by Comments Response You are hereby reminded of section 24F of the National Environmental Management Act, Act No 107 of 1998, as amended, that no activity may commence prior to an environmental authorisation being granted by the Department. Yours faithfully Mr Sabelo Malaza Annexure 1 Format for Comments and Response Trail Report:

CSIR: No activity associated with the proposed Sutherland 2 WEF will commence prior to an Environmental Authorisation being granted by the Department of Environmental Affairs.

COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS: BIODIVERSITY CONSERVATION

3. Department of Environmental Affairs: Directorate: Biodiversity Conservation Mr Stanley Tshitwamulomoni: Biodiversity Officer Control B: Biodiversity Conservation Enquiries: Ms Portia Makitla/ Thobekile Zungu Letter received via

Dear Ms Levendal COMMENTS ON THE DRAFT AMENDMENT REPORT FOR THE DEVELOPMENT OF THE 140 MW SUTHERLAND AND SUTHERLAND 2 WIND ENERGY FACILITIES, NORTHERN CAPE PROVINCE

• The Directorate: Biodiversity Conservation confirms having received the aforementioned draft Environmental Authorisation (EA) amendment Report for comments and does not have any objections to the proposed amendment.

• The final report must comply with all the requirements as outlined in the EIA guideline for renewable energy projects and the Revised Best Practice Guideline for Birds & Wind Energy for assessing and monitoring the impact of wind energy facilities on birds in Southern Africa.

Yours faithfully

CSIR: • Thank you for your comments on the Draft Amendment

Report for the Sutherland 2 WEF. It is noted that the Directorate: Biodiversity Conservation has no objections to the proposed amendment.

• The requirements in the EIA guideline for renewable energy projects and the revised Best Practice Guideline for Birds and Wind Energy Facilities for Birds & Wind Energy for assessing and monitoring the impact of wind energy facilities on birds in Southern Africa have been adhered to in the planning phase and will be adhered to in the construction and operational phases of the Sutherland 2 WEF. The Final Amendment Report also complies with the said guidelines.



No. Raised by Comments Response email Date: 07/11/2019

Mr Stanley Tshitwamulomoni

COMMENTS FROM ESKOM

4. Eskom Mr John Geeringh: Senior Consultant Environmental Management Eskom Transmission Division: Land & Rights Email Date: 08/10/2019

Please find attached Eskom requirements for infrastructure development near Eskom servitudes and infrastructure. Find also attached an updated setbacks document that the applicant must take into consideration due to the changes in turbine heights and size. Kind regards John Geeringh (Pr Sci Nat)

CSIR: Thank you for providing us with the Eskom requirements for infrastructure development near Eskom servitudes and infrastructure and for the updated setbacks document. The applicant will contact Eskom should any of the setbacks specified in the setbacks document be applicable to the development of the proposed Sutherland 2 WEF.

COMMENTS FROM THE BREEDE-GOURITZ CATCHMENT MANAGEMENT AGENCY (BCMA)

5. Breede-Gouritz Catchment Management Agency (BCMA) Mr Rudzani Makahane Email Date: 09/10/2019

Dear Minnelise I have noted that the two amendment regarding the subject matters above does not trigger any water use. If that is the case, our comments dated 14/08/2017 are still relevant. However, you may still advice if I have missed something which may warrant a different comments or input from BGCMA. Best Regards, Letter from BCMA (dated 14/08/2017) as referred to by Mr Makahane above:

CSIR: The amendment application itself does not trigger any water use. The comments from BCMA dated 14/08/2017 are included below for ease of reference. These comments are also included in Appendix B.6 of the Final Amendment Report.

BCMA Mr Phakamani Buthelezi Chief Executive Officer (CEO) Enquiries: Mr. M. Mthimkhulu

Letter from BCMA (dated 14/08/2017) as referred to by Mr Makahane above: Attention: S Johnston Dear Sir, COMMENTS ON BASIC ASSESSMENT REPORT FOR THE PROPOSED CONSTRUCTION OF ELECTRICAL GRID INFRASTRUCTURE TO SUPPORT THE SUTHERLAND 2 WIND ENERGY FACILITY, NORTHERN & WESTERN CAPE PROVINCES.

CSIR: The comments from BCMA dated 14/08/2017 are included below for ease of reference. These comments are also included in Appendix B.6 of the Final Amendment Report. A Water Use Licence Application (WULA) or General Authorisation (GA) will be applied for should the project receive preferred bidder status (as relevant).



No. Raised by Comments Response Letter via email Date: 14/08/2017

The above mentioned report, DEA reference number: 12/12/20/1782/AM1 for the above mentioned activity has reference. The Breede-Gouritz Catchment Management Agency (BGCMA) has the following comments:

1. No operation is allowed within 100m of a water resource or 1:100 year flood line whichever is the greatest. If the proposed activity falls within these criteria, you need to apply for water use license to ensure that the riparian ecological status of the water resource will not be negatively impacted. It is advisable to consider an alternative site.

CSIR: The applicant will apply for a water use licence should development falls within 100 m from a water course or 1:100 year floodline. This recommendation was included in the updated EMPr (in Appendix D) of the Final Amendment Report (see section 6.1.5). Additional measures for the protection of hydrological features on site are included in section 15 of the EMPr.

2. Please note that any development within 500m from the boundary of any wetland requires a water use license according to National Water Act (NWA) 1998 (Act No.36 of 1998).

CSIR: The applicant will apply to the Department of Water and Sanitation for a water use licence should any develop occur within 500m from the boundary of a wetland. This recommendation was included in the updated EMPr (in Appendix D) of the Final Amendment Report (see section 6.1.5). Additional measures for the protection of hydrological features on site are included in section 15 of the EMPr.

3. No water maybe abstracted from any surface water body and groundwater unless authorized by this Agency.

CSIR: No abstraction of any surface or groundwater will take on site unless it is authorized by the BCMA. This recommendation was included in the updated EMPr (in Appendix D) of the Final Amendment Report (see section 6.2.6). Additional measures for the protection of hydrological features on site are included in section 15 of the EMPr.

4. Where solid waste disposal is to take place on site, ensure that only non-toxic materials which have no risk of polluting the groundwater, are buried in designated approved areas at acceptable depths below ground level.

CSIR: A waste management plan will be implemented on site during the construction and operational phases of the wind farm as per section 16 of the EMPr. All operational waste (concrete, steel, rubbles etc.) is to be removed from the site and the waste hierarchy of prevention, as the preferred option, followed by reuse, recycling, recovery must be implemented, where possible. Other non-hazardous solid waste (e.g. packaging material) must be disposed



No. Raised by Comments Response of at a licensed landfill.

5. No surface, ground or storm water may be polluted as a result of any activities on the site.

CSIR: A stormwater management plan will be implemented on site as per section 11 of the EMPr. Stormwater run-off will be discharged away from the water courses (drainage channels, streams or dams). Effluent from construction site offices and staff facilities will be collected in storage tanks, which will be removed by a licensed sanitary contractor. Effluent from the batching plant will be contained within a bunded area and not be allowed to drain into water courses. Effluent will be recycled or removed. A protection plan of hydrological resources will be implemented on site during the construction and operational phases of the project as per section 15 of the EMPr.

6. The rehabilitation of the site must ensure that the final conditions of the site is environmentally acceptable and that there will be no adverse long term effects on the surrounding environment especially the water resources.

CSIR: The site will be rehabilitated in an environmentally sustainable manner to ensure that long term effects on the local environment are avoided. A re-vegetation and rehabilitation plan will be implemented on site following construction as per section 9 of the EMPr. Rehabilitation or ecological restoration during and after the construction phase will be undertaken with indigenous plants with input from a botanist with experience in restoration. The removal of vegetation must be minimised during construction and operation to reduce the risk of excessive open areas occurring. All disturbed sites must be rehabilitated as per section 8 of the EMPr (Plant rescue and protection plan).

7. Please note that all requirements as stipulated in the National Water Act (NWA) 1998(Act No. 36 of 1998) must be adhered to.

CSIR: All the requirements of the NWA will be adhered to during the construction and operation of the proposed Rietrug WEF.

8. Please note that this Agency reserves the right to amend and/or add to the comments made above in the light of subsequent

CSIR: This is acknowledged by the EAP.



No. Raised by Comments Response information received.

If you have any questions please don't hesitate to contact the official at the above mentioned details. Kind Regards Phakamani Buthelezi

CSIR: Ms Levendal contacted Mr Mthimkhulu to clarify certain matters pertaining to the comments received and will continue to do so should more questions arise.

COMMENTS FROM THE WILDLIFE FOR ALL TRUST

The Wildlife For All Trust (Komsberg Wilderness Private Nature Reserve) Becky Scott Director and Trustee wildlifeforall.org Date: 30/10/2019

The Wildlife For All Trust British Registered Charity No. 1006174 Dear Dr Dlamini We are a large nature reserve stuck in the middle of the Sutherland, Sutherland 2 and Rietrug Wind Energy Facilities. The so called "Environmental Impact Assessment" was a joke. With the exception of a biologist looking at our birds of prey, who did a good job, no other biologist or expert bothered to gain access to our reserve to speak to us as owners/managers. It was little more than a rubber stamping exercise. When work begins, if there is any significant disruption for Komsberg Wilderness Nature Reserve, including any of the wildlife, we will seek a legal injunction to halt any work. Likewise, if the wind turbines once functioning, cause any disruption to our wildlife, we will not hesitate to take legal action to have them moved further back from our boundary fence. We are experienced international biologists/conservationists. Our strong advice to you would be to make sure that any wind turbines are sufficiently distant from our boundary fence so as to minimise any risks of disruption. This will surely be best for yourselves (as any legal injunction will lead to delay and extra costs), as well as ourselves. Please acknowledge receipt of this email. Sincerely

CSIR: Minnelise Levendal (the Environmental Assessment Practitioner) acknowledged receipt of this email to Ms Becky Scott of the Wildlife for All Trust on 4 November 2019. The email from Ms Scott was received via the CSIR Director, Dr Dlamini. As required by the regulations, a selection of specialists was appointed to assess the impact of the proposed development on the site and surrounds, and included vegetation, ecological, avian, bat, heritage, socio- economic, visual and noise specialists. While the focus of the vegetation, ecological, avian, bat and heritage studies were on the properties within the project footprint, the socio-economic, visual and noise specialists focussed on impact of the development on the surrounding area (including the Komsberg Reserve). As indicated above, the potential impacts to noise and visual on the Komsberg Nature Reserve were assessed in detail by the noise and visual specialists who developed detailed modelling and photomontages respectively. The following mitigation measures were proposed to reduce the potential noise and visual impact to the Komsberg Nature reserve. Noise impact: The following mitigation measures were proposed, which reduced the post-mitigation significance of the impact to low:

• Create a buffer between the wind turbines and site boundaries in order to ensure that the daytime residual



No. Raised by Comments Response Becky Scott Director and Trustee

sound level beyond the boundaries is not exceeded by 7dB or more.

• Remove or relocate turbines to at least 700 m from dwellings in order not to exceed the 33dBA daytime residual sound level at dwellings by 7dB or more.

These mitigation measures were integrated into the site layout (Figure 13 and Figure 14) and were incorporated into section 6.1.9 (project planning and design phase) and section 6.2.10 (construction phase) of the EMPr. These sections are highlighted in yellow and underlined. Visual impact: Due to the proximity of the Komsberg reserve to the proposed REF, the pre-and post-mitigation visual impact was rated as high (ERM, 2011). The following mitigation measures were proposed specifically for the Komsberg Nature Reserve:

• A visual buffer zone of 700 m for the wind turbines from farmsteads and other rural dwellings;

• A visual buffer of 500 m for the wind turbines from the local district roads and external farm boundaries;

• The substation and O&M buildings to ideally be grouped in the same location to avoid the scatter of facilities in the open landscape.

• Cables to be located underground as far as possible; • The design of the buildings to be compatible in scale and

form with buildings of the surrounding rural area, and with the regional architecture;

• The internal access roads will not be located in drainage courses. The roads will generally follow the grain of the land, and their alignments fine-tuned to fit the topography; and

• Signage related to the enterprise to be discrete and confined to the entrance gates. No other corporate or



No. Raised by Comments Response advertising signage, particularly billboards, to be permitted.

These mitigation measures regarding the visual buffers were integrated into the site layout (Figure 13 and 14). The mitigation measures were incorporated into section 6.1.6 (project planning and design phase) and section 6.2.8 (construction phase) of the EMPr of the EMPr. These sections are highlighted in yellow and underlined. A buffer of 500 m for the wind turbines from the local district roads and external farm boundaries of the Komsberg Nature Reserve was applied. A 700 m buffer was also applied for the wind turbines from the farmsteads and other rural dwellings in order not to exceed the 33 dBA daytime residual sound level at dwellings by 7dB or more and to reduce the visual impact. The implementation of the mitigation measures outlined in the EIA (ERM, 2011) and the subsequent amendment reports and included in the EMPr (Appendix D) provide a basis for ensuring that the potentially negative impacts associated with the establishment of the proposed Sutherland 2 WEF are mitigated to acceptable levels, and that the positive impacts associated with the WEF outweigh the potential negative impacts on the surrounding area.

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