black lite solar pv manufacturing facility scoping … solar clm 5.01.16/draft scoping... | ......

Black Lite Solar PV Manufacturing Facility

SCOPING REPORT

DEDEAT REF: EC/7/A/LN2/M/15-29

Prepared for:

Black Lite Solar (Pty) Ltd

17 Baker Street Rosebank

Johannesburg 2196

Telephone: +27 11 447 7651 Fax: +27 86 5838905

Prepared by:

EOH Coastal & Environmental Services

EAST LONDON 25 Tecoma Street

East London, 5201 043 742 3302

Also in Grahamstown, Cape Town, Johannesbug, Port Elizabeth and Maputo www.cesnet.co.za | www.eoh.co.za

January 2016

http://www.cesnet.co.za/

Black Lite Solar PV Manufacturing Facility – January 2016

EOH Coastal & Environmental Services Black Lite Solar PV Manufacturing Facility

This Report should be cited as follows: EOH Coastal & Environmental Services, Date: January 2016 Black Lite Solar PV Manufacturing Facility Scoping Report, EOH-CES, East London.

REVISIONS TRACKING TABLE

EOH Coastal and Environmental Services

Report Title: Black Lite Solar PV Manufacturing Facility Scoping Report Report Version: Draft Project Number: 163

Name Responsibility Signature Date

Alan Carter Reviewing report

Cherie-Lynn Mack Drafting report

Copyright This document contains intellectual property and propriety information that are protected by copyright in favour of EOH Coastal & Environmental Services (CES) and the specialist consultants. The document may

therefore not be reproduced, used or distributed to any third party without the prior written consent of CES. The document is prepared exclusively for submission to the Buffalo City Metropolitan Municipality in the

Republic of South Africa, and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.


EOH Coastal & Environmental Services Blacklite Solar PV Manufacturing

TABLE OF CONTENTS 1 INTRODUCTION ..................................................................................................................... 1

Background to the Study ................................................................................................. 1 1.1 Environmental Authorisation in South Africa .................................................................... 1 1.21.2.1 Listed activities triggered ............................................................................................. 2 Scoping Phase ................................................................................................................ 3 1.3 Nature and Structure of this Report ................................................................................. 4 1.4 Assumptions and Limitations ........................................................................................... 4 1.5 Details and Expertise of the Environmental Assessment Practitioner .............................. 4 1.6

2 PROPERTY DESCRIPTION AND ACTIVITY LOCATION ...................................................... 6 Property Locality .............................................................................................................. 6 2.1

3 PROJECT DESCRIPTION ...................................................................................................... 9 Introduction ...................................................................................................................... 9 3.1 The Product ..................................................................................................................... 9 3.2 The thin-film production process .................................................................................... 10 3.3 Basic Services ............................................................................................................... 11 3.43.4.1 Water and Electricity .................................................................................................. 11 3.4.2 Waste ........................................................................................................................ 11 How the listed activities are triggered by the development ............................................. 12 3.5

4 RELEVANT LEGISLATION .................................................................................................. 16 Relevant Legislation used in the Compilation of this Scoping Report ............................. 16 4.1

5 PROJECT NEED & DESIRABILITY ..................................................................................... 17 Support of Renewable Energy ....................................................................................... 17 5.1 Job creation and social impact....................................................................................... 17 5.2 Maximising local content ................................................................................................ 17 5.3 Alignment with SA Government policy ........................................................................... 17 5.4 Staffing and skills transfer .............................................................................................. 18 5.5

6 PROJECT ALTERNATIVES ................................................................................................. 19 Reasonable and Feasible Alternatives ........................................................................... 19 6.1 Fundamental Alternatives .............................................................................................. 19 6.2 Incremental Alternatives ................................................................................................ 19 6.3 No-Go development ...................................................................................................... 19 6.4

7 PUBLIC PARTICIPATION .................................................................................................... 24 Notification of Interested and Affected Parties ............................................................... 24 7.17.1.1 Public Participation .................................................................................................... 24 7.1.2 Newspaper advertisement ......................................................................................... 24 7.1.3 On-site Notice ............................................................................................................ 24 7.1.4 Stakeholder Notification Letter ................................................................................... 24 7.1.5 Background Information Document that was Circulated to Interested and Affected Parties/Stakeholders ............................................................................................................. 25 7.1.6 Proof of Notification ................................................................................................... 34 7.1.7 Stakeholder and I&AP database ................................................................................ 35 7.1.8 Issues Raised by I&APs............................................................................................. 36

8 DESCRIPTION OF THE ENVIRONMENT ............................................................................. 13 The Bio-Physical Environment ....................................................................................... 13 8.18.1.1 Current land use ........................................................................................................ 13 8.1.2 Topography ............................................................................................................... 13 8.1.3 Geology ..................................................................................................................... 13 8.1.4 Watercourses and Wetlands ...................................................................................... 13 8.1.5 Air Quality .................................................................................................................. 13 Vegetation and Floristics ............................................................................................... 15 8.28.2.1 South African National Biodiversity Institute ............................................................... 15 8.2.2 Eastern Cape Biodiversity Conservation Plan ............................................................ 15 Socio-Economic Profile.................................................................................................. 15 8.38.3.1 Population ................................................................................................................. 15 8.3.2 Economy ................................................................................................................... 15 8.3.3 Employment ............................................................................................................... 16



9 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED ....................................... 18 Possible Environmental Issues and Impacts .................................................................. 18 9.1

10 PLAN OF STUDY FOR EIA PHASE ..................................................................................... 19 Scope and Intent of the EIA Phase ................................................................................ 19 10.1

10.1.1 Specialist Studies .................................................................................................. 19 10.1.2 Environmental Impact Report (EIR) ....................................................................... 19 10.1.3 Issues and Response Trail..................................................................................... 20 10.1.4 Environmental Management Programme (EMPr) ................................................... 20 10.1.5 Record of Decision of Environmental Authorisation and Appeals Process ............. 20

The Public Participation Process ................................................................................... 20 10.210.2.1 Public Review Of The Draft Scoping Report (DSR) ................................................ 20 10.2.2 Public Review Of The Draft Environmental Impact Report (DEIR) ......................... 20 10.2.3 Notification Of Environmental Authorisation (EA) ................................................... 21

Environmental Impact Report (EIR) ............................................................................... 21 10.310.3.1 Structure of the EIA Report .................................................................................... 21

Specialist Studies .......................................................................................................... 22 10.410.4.1 Air Emissions Inventory (EXIGO) – If required by the Air Quality Officer ................ 22

Methodology for assessing the significance of impacts (Including Specialist Studies) ... 22 10.5

LIST OF FIGURES Figure 1.1 Locality of the site within Zone 1A of the ELIDZ. ................................................................................. 1 Figure 1.1: The EIA Process flow chart .................................................................................................................. 3 Figure 2.1. The site for the proposed plastics refining facility is indicated in red. Surrounding landmarks

include the East London Airport, and the ELIDZ Zone 1 A. .......................................................................... 6 Figure 2.2: Photographs of the proposed site. ....................................................................................................... 7 Figure 3.1: Structure of a CIGS device. CdS is used optionally and some CIGS cells contain no cadmium at

all. .................................................................................................................................................................... 10 Figure 3.1. Proposed facility layout. ...................................................................................................................... 13 Figure 3.2: Overview of the main process steps to manufacture a CIGS thin film solar module. .................... 15

LIST OF TABLES Table 1.1: Listed activities triggered by the facility. 2 Table 2.1. Property locality and associated attributes. 6 Table 4.1: Environmental legislation considered in the preparation of the Scoping Report 16 Table 6.1: The alternatives for the proposed Black Lite Solar PV Manufacturing Facility 20



LIST OF ACRONYMS The following acronyms have been used in this report:

BCMM Buffalo City Metropolitan Municipality

BID Background Information Document

CA Competent Authority

CBA Critical Biodiversity Area

CES Coastal & Environmental Services

DEDEAT Department of Economic Development, Environmental Affairs and Tourism

DSR Draft Scoping Report

DWS Department of Water and Sanitation

EAP Environmental Assessment Practitioner

ECPHRA Eastern Cape Provincial Heritage Resources Authority

EIA Environmental Impact Assessment

EIR Environmental Impact Report

EMPr Environmental Management Programme

GN Government Notice

I&AP Interested and Affected Party

MEC Member of the Executive Council

NEMA National Environmental Management Act

NDP National Development Plan

PoS Plan of Study

PPP Public Participation Process

SAHRA South African Heritage Resources Agency

SSC Species of Special Concern


EOH Coastal & Environmental Services Black Lite Solar PV Manufacturing

1 INTRODUCTION

Background to the Study 1.1 Black Lite Solar (Pty) Ltd (Black Lite) proposes to establish a solar photovoltaic (PV) module manufacturing facility in the East London Industrial Development Zone (ELIDZ). The ELIDZ has an existing Environmental Authorization (EA) for light industry issued in 2001 for the transformation of land. The current facility requires additional authorisation based on environmental triggers not covered in that EA. The site proposed for the facility falls within Zone 1A of the ELIDZ, on erf number 60935 within the Buffalo City Metropolitan Municipality (BCMM) (Figure 1.1).

Figure 1.1 Locality of the site within Zone 1A of the ELIDZ. The construction and operation of the facility triggers activities listed under the EIA regulations (2014), and the Air Quality Act (AQA) regulations (2013). As such, an application form for authorisation of the EIA activities has been submitted to the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) in October 2015. An additional application has been made to the Air Quality Officer at the BCMM for authorisation of the activities listed under the AQA regulations. EOH Coastal and Environmental Services (CES) have been appointed by Black Lite as the Environmental Assessment Practitioner (EAP) to secure the necessary environmental authorisations.

Environmental Authorisation in South Africa 1.2 The regulation and protection of the environment within South Africa occurs mainly through the application of various items of legislation, within the regulatory framework of the Constitution (Act 108 of 1996).



The primary legislation regulation for Environmental Impact Assessments (EIA) within South Africa is the National Environmental Management Act (NEMA, Act 107 of 1998). NEMA makes provision for the Minister of Environmental Affairs to identify activities which may not commence prior to the authorisation from either the Minister or the provincial Member of the Executive Council (MEC). In addition, NEMA provides for the formulation of regulations in respect of such authorisations. The EIA regulations (2014) allow for a Basic Assessment process for activities with limited environmental impact (listed in GN R. 983 and GN R.985, as amended in 2014) and a more rigorous two-tiered approach to activities with potentially greater environmental impact (listed in GN R. 984, 2014). This two-tiered approach includes both a Full Scoping and EIA process. 1.2.1 Listed activities triggered The proposed development activities trigger the need for a Full Scoping and EIA process under the Regulations of 2014 (Government Notices No. R. 983, R. 984 and R.985). The listed activities that have been applied for are provided in Table 1.1 below. Table 1.1 also lists the activities requiring authorisation in terms of AQA and the Waste Act. Both of these Acts use the EIA process as described in GN R982 as the main tool for assessment of the potential impact of the triggered activities. As such, this Scoping Report is compiled to fulfil the requirements of all licensing authorities. Table 1.1: Listed activities triggered by the facility.

ACTIVITIES TRIGGERING LICENCE REQUIREMENTS

Legislation Listing Description Scope of EIA

NEMA Regulations 2014 (GNR 983)

14 The development of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 m3.

Basic Assessment

NEMA Regulations 2014 (GNR 984)

28 Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004

Full scoping and EIA

Air Quality Act Regulations (GNR 893)

Category 7.1

Inorganic Chemicals Industry Production and or use in manufacturing of ammonia, fluorine, fluorine compounds, hydrogen cyanide and chlorine gas.


Category 7.2

Inorganic Chemicals Industry Production, use in production or recovery of antimony,

arsenic, beryllium, cadmium, chromium, cobalt, lead,

mercury and or selenium, by the application of heat.


The facility proponent is initially required to submit a report detailing the scoping phase (Scoping Report), and set out the terms of reference for the EIA process (Plan of Study for EIA). This is then followed by a report detailing the EIA phase (EIR). The competent authority will issue a final decision subsequent to their review of the final EIR. A flow diagram outlining the EIA process is shown in Figure 1.1. The competent authority, that must consider and decide on the application for authorisation in respect of the activities listed in Table 1.1, is the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) for the EIA, and the BCMM Air Quality Officer for the AQA triggers.



Figure 1.1: The EIA Process flow chart

Scoping Phase 1.3 The Scoping Phase is designed to determine the “scope” of the subsequent Environmental Impact Assessment (EIA), conducted in fulfilment of the application for authorisation. The overall aim of the Scoping Phase is to determine the environmental issues and impacts associated with the proposed housing development that require further investigation in an EIA. The purpose of scoping is therefore to identify:

Issues

Impacts

Alternatives

Contextualise Proposed Development

Pre-Application Planning (Determine assessment process using NEMA, 1998 and G/N 983, 984 and 985 of 2014)

Adopt the Scoping & Environmental Impact Assessment Process

Submit Application to Relevant Authority

Conduct Public Participation Process

Scoping Report and Plan of Study for the EIA

Public Review of Scoping Report and Plan of Study of the EIA

Authority Review of Scoping Report and Plan of Study of the EIA

Accept

Request Amendment

s

Conduct Environmental Impact Assessment. Compile EIR and EMP

Public Review of EIR and EMP

Authority Review of EIR and EMP

Accept

Request Amendments

Issue Environmental Authorisation and notify applicant of conditions and appeal provisions

Notify I&APs of Environmental Authorisation and appeal provisions

Consider Appeals if any



An integral part of the Scoping Phase is the initial public participation process (PPP). This process ensures that all possible interested and affected parties (I&APs) are informed of the proposed activity and are provided with an opportunity to comment and identify issues.

Nature and Structure of this Report 1.4 This report fulfils the requirement of the EIA Regulations (2014) for the documentation of the Scoping Phase. The structure of this report is based on APPENDIX 2 of GN No. 982, of the Environmental Impact Assessment Regulations (2014), which clearly specifies the required content of a Scoping Report.

Assumptions and Limitations 1.5 This report is based information that is currently available and, as a result, the following limitations and assumptions are implicit–

The report is based on a project description taken from design specifications provided by the proponent.

Descriptions of the natural and social environments are based on limited fieldwork and available literature. More information will be provided in the EIA phase.

Details and Expertise of the Environmental Assessment Practitioner 1.6 In fulfilment of the above-mentioned legislative requirements, the details of the Environmental Assessment Practitioner (EAP) that prepared this draft scoping report as well as the expertise of the individual members of the study team are provided below. EOH Coastal & Environmental Services (CES) was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Plans (EMPs), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes (www.cesnet.co.za). CES has been active in all of the above fields, and in so doing have made a positive contribution towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries. We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning Dr Alan Carter Alan holds a PhD in Plant Sciences and is a Certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has over 20 years of experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP) and is a certified ISO14001 Environmental Management Systems Auditor.

In terms of APPENDIX 2(2) of the EIA Regulations (2014), a Scoping Report must contain all the information necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include– (a) Details of– (i) The EAP who prepared the report; and (ii) The expertise of the EAP to carry out scoping procedures

http://www.cesnet.co.za/



Dr Cherie-Lynn Mack Principal Environmental Consultant, holds a PhD and MSc (with distinction) degrees in Environmental Biotechnology, with a BSc degree in Microbiology and Biochemistry. She has postgraduate research experience in industrial and domestic wastewater treatment technologies, with particular emphasis on the coal and platinum mining industries. Her interests lie in the water sector, with experience in ecological reserve determination and water quality monitoring and analysis. She has experience in water quality analysis and industrial wastewater treatment research. Cherie-Lynn is registered as a professional scientist with SACNASP. Exigo – Air Emissions Modelling (if required) The company started off in 1999 as an individual owned Closed Corporation that operated under the AGES brand. The core focus of the business at its start was that of ground water and ground water supply consulting. Building from this speciality, and responding to a shifting industry, an environmental sustainability unit was later established. Exigo now has an Africa–wide reach and has established a strong network of partners across the industry and is trusted to deliver the most innovative, flexible solutions, whilst mitigating risks and optimising economic benefit.



2 PROPERTY DESCRIPTION AND ACTIVITY LOCATION

Property Locality 2.1 The site proposed for the facility is located within Zone 1A of the East London Industrial Development Zone, on erf number 60935 (East London), within the BCMM. Figure 2.1 indicates the property in relation to landmarks in the general vicinity. Table 2.1 lists property attributes such as the 21 digit Surveyor General code, the size of the property and the GPS co-ordinates or the four corners of the site.

Figure 2.1. The site for the proposed facility is indicated in red. Surrounding landmarks include the East London Airport, and the ELIDZ Zone 1 A. Table 2.1. Property locality and associated attributes.

Attribute Property

21 digit SG code C02300040006093500000

Size 15 205.16 m2

North corner 33° 03’ 23.76” S; 27 °51‘19.46” E

ELIDZ

Zone 1 A

In terms of APPENDIX 2(2) of the EIA Regulations (2014), a Scoping Report must contain all the information necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include

b) The location of the activity, including – (i) The 21 digit Surveyor General code of each cadastral land parcel;

(ii) Where available, the physical address and farm name; (iii) Where the required information in terms of (i) and (ii) is not available, the coordinates of

the boundary or properties; c) A plan which locates the proposed activity or activities applied for at an appropriate scale;



East corner 33° 03’ 20.61” S; 27° 51’ 26.47” E

South corner 33° 03’ 25.24” S; 27° 51’ 29.21” E

West corner 33° 03’ 28.43” S; 27° 51’ 22.47” E

Property Owner East London Industrial Development Zone

Dominant grassland with scattered Acacia natalitia

Figure 2.2: Photographs of the proposed site: Dominant grassland with scattered Acacia natalitia



Figure 2.3: Current status of sites adjacent to the proposed facility site.

Oceanwise (Pty) Ltd Aquaculture

Vacant

Vacant

Vacant

Vacant

Vacant

Vacant



3 PROJECT DESCRIPTION

Introduction 3.1 Black Lite is proposing to develop a solar PV panel manufacturing facility using thin-film Copper Indium Gallium Selenide (“CIGS”) technology to supply the South African, African and global market. The facility will be located in the ELIDZ, who will provide the factory buildings on the basis of a long-term lease. The process lines including auxiliary equipment will utilise proven CIGS technology to be obtained from a leading German equipment manufacturer, Manz AG, on a comprehensive turnkey basis. To be developed in a single phase, the plant is intended to have a final output of 165 MW per annum at full production capacity.

The Product 3.2 A solar cell, or photovoltaic cell, is an electrical device that converts the energy of light directly into electricity by the photovoltaic effect, which is a physical and chemical phenomenon. It is a form of photoelectric cell, defined as a device whose electrical characteristics, such as current, voltage, or resistance, vary when exposed to light.

Assemblies of solar cells are used to make solar modules which generate electrical power from sunlight. A solar array generates solar power using solar energy.

Figure 3.1. From a solar cell to a PV system (https://en.wikipedia.org/wiki/Photovoltaic_system)

In terms of Section APPENDIX 2(2) of the EIA Regulations (2014), a Scoping Report must contain all the information necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include

d) A description of the scope of the proposed activity, including – (i) All listed and specified activities triggered;

(ii) A description of the activities to be undertaken, including associated structures and infrastructure;

https://en.wikipedia.org/wiki/Light

https://en.wikipedia.org/wiki/Electricity

https://en.wikipedia.org/wiki/Photovoltaic_effect

https://en.wikipedia.org/wiki/Physical

https://en.wikipedia.org/wiki/Chemical

https://en.wikipedia.org/wiki/Solar_module

https://en.wikipedia.org/wiki/Sunlight

https://en.wikipedia.org/wiki/Solar_power

https://en.wikipedia.org/wiki/Solar_energy



Solar cells are typically named after the semiconducting material they are made of. These materials must have certain characteristics in order to absorb sunlight. Some cells are designed to handle sunlight that reaches the Earth's surface, while others are optimized for use in space. Solar cells can be made of only one single layer of light-absorbing material (single-junction) or use multiple physical configurations (multi-junctions) to take advantage of various absorption and charge separation mechanisms.

A CIGS cell is a thin-film solar cell used to convert sunlight into electric power. It is manufactured by depositing a thin layer of copper, indium, gallium and selenide on glass or plastic backing, along with electrodes on the front and back to collect current. Because the material has a high absorption coefficient and strongly absorbs sunlight, a much thinner film is required than of other semiconductor materials.

Figure 3.1: Structure of a CIGS device. CdS is used optionally and some CIGS cells contain no cadmium at all.

The most common device structure for CIGS solar cells is shown in the diagram (Figure 3.1). Soda-lime glass of about of 1–3 mm thickness is commonly used as a substrate, because the glass sheets contain sodium, which has been shown to yield a substantial open-circuit voltage increase, notably through surface and grain boundary defects passivation. A molybdenum (Mo) metal layer is deposited (commonly by sputtering) which serves as the back contact and reflects most unabsorbed light back into the CIGS absorber. Following molybdenum deposition a p-type CIGS absorber layer (described in more detail in Section 3.3) is grown by one of several unique methods. A thin n-type buffer layer is added on top of the absorber. The buffer is typically cadmium sulfide (CdS) deposited via chemical bath deposition. The buffer is overlaid with a thin, intrinsic zinc oxide layer (i-ZnO) which is capped by a thicker, aluminum (Al) doped ZnO layer. The i-ZnO layer is used to protect the CdS and the absorber layer from sputtering damage while depositing the ZnO:Al window layer, since the latter is usually deposited by DC sputtering, known as a damaging process. The Al doped ZnO serves as a transparent conducting oxide to collect and move electrons out of the cell while absorbing as little light as possible.

The thin-film production process 3.3

The most common vacuum-based process is to co-evaporate or co-sputter copper, gallium, and indium onto a substrate at room temperature, then anneal the resulting film with a selenide vapour. An alternative

https://en.wikipedia.org/wiki/Semiconducting_material

https://en.wikipedia.org/wiki/List_of_semiconductor_materials

https://en.wikipedia.org/wiki/Sunlight

https://en.wikipedia.org/wiki/Solar_panels_on_spacecraft

https://en.wikipedia.org/wiki/P-n_junction

https://en.wikipedia.org/wiki/Multi-junction

https://en.wikipedia.org/wiki/Multi-junction

https://en.wikipedia.org/wiki/Thin-film_solar_cell

https://en.wikipedia.org/wiki/Copper_indium_gallium_selenide

https://en.wikipedia.org/wiki/Absorption_coefficient

https://en.wikipedia.org/wiki/Cadmium_Sulfide

https://en.wikipedia.org/wiki/Cadmium

https://en.wikipedia.org/wiki/Soda-lime_glass

https://en.wikipedia.org/wiki/Milimetre

https://en.wikipedia.org/wiki/Glass_sheet

https://en.wikipedia.org/wiki/Molybdenum

https://en.wikipedia.org/wiki/Sputtering

https://en.wikipedia.org/wiki/Back_contact

https://en.wikipedia.org/wiki/P-type_semiconductor

https://en.wikipedia.org/wiki/N-type_semiconductor

https://en.wikipedia.org/wiki/Cadmium_sulfide

https://en.wikipedia.org/wiki/Chemical_bath_deposition

https://en.wikipedia.org/wiki/Zinc_oxide

https://en.wikipedia.org/wiki/Aluminum

https://en.wikipedia.org/wiki/Vacuum

https://en.wikipedia.org/wiki/File:CIGSdevice.JPG



process is to co-evaporate copper, gallium, indium and selenium onto a heated substrate. This alternative is used in the Black Lite facility.

In the Black Lite system, the elements Cu, In, Ga, and Se are evaporated from resistively heated linear sources to form a multi-crystalline layer of the quaternary Cu(In,Ga)Se2 semiconductor absorber material on the Mo coated and P1 patterned substrate. Substrates are loaded onto specially designed high temperature resistant carriers. The carrier-substrate stack enters one of the CIGS coaters. Inside the CIGS coater, substrates are heated up following a defined temperature – time profile while moving towards the coating section of the machine and are subsequently coated with a few micrometers of CIGS using linear evaporation sources of Cu, Ga, In and Se.

Basic Services 3.4 3.4.1 Water and Electricity Both water and electricity will be provided by the ELIDZ from their existing services network. There is no requirement for additional interaction between the applicant and the BCMM with regard to securing access to these services. 3.4.2 Waste Liquid Process water from the glass cleaning equipment is subject to mechanical filtration in the equipment. This water can be discharged into the sewage system without further treatment. Process water generated in chemical processes like CBD or the gas scrubber is purified in a separate sewage water treatment system part of the factory facility equipment. The untreated waste water from chemical processes may contain the following chemicals or constituents: • Metal Ions (Cd, Zn, also Cu, In, Ga, Mo) • Metal salts (sulphates, acetates, selenides, hydroxides, sulphides) up to 0.05 mol/l. • Ammonium hydroxide (NH4OH) and dissolved NH3 up to 1 mol/l. • Thiourea (CH4N2S), organic decomposition and reaction products, also complex building agents up to 1 mol/l • Solid CdS, solid ZnS

Various small articles may be contained like small plastic parts or small metal parts like screws or washers. Therefore an appropriate filter or mesh will be needed.

Waste water might contain minor quantities of other substances. For the alkali process water from CBD the following treatment system is proposed: • A storage tank to store and homogenize the incoming process water. The storage tank provides redundancy for down events of the process water treatment system and should be sized to bridge up to 2 days down of the process water treatment system. • A neutralization to adjust to the pH to allow for optimum removal (blow off) of ammonia • A catalytic conversion system that oxidizes ammonia to nitrogen and water (exhaust from neutralization, alternatively the exhaust may be treated in the gas scrubber serving the CBD process equipment) • An oxidation system to remove thiourea • A vacuum distillation system that reduces the volume by a factor of 25 – 35 • A residual concentrated process water storage (discharged as special waste or forwarded to recycling) • A feedback loop of clean water from vacuum distillation to the water supply Part of the waste water can be recovered as DI water and recycled to the DI water system or alternatively it can be used to compensate evaporation losses in the gas scrubber system.



The total volume of wastewater to be treated per day is far less than the threshold of 2 Ml/day, above which the system would also require Environmental Authorisation. All sewage wastewater will be disposed of directly to the existing sewage system at the ELIDZ, which links into the BCMM treatment and disposal reticulation.

Solid

All solid waste will be collected in a central storage area, after which a waste removal contractor will remove the waste from the premises for disposal at the relevant licensed landfill site. It is anticipated that No

hazardous waste will be generated, and in that case, the solid waste would be directed to the Roundhill Solid

Waste Site in Berlin, outside East London.

How the listed activities are triggered by the development 3.5

EIA Regulations (2014) listed activities GN R 983: 14 The development of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 m3.

Currently the exact volumes to be stored on site, but a number of chemicals used in the manufacturing process are considered dangerous. These include, but may not be limited to:

Sulphuric acid

Ammonia

Nitric Acid

Sodium Hydroxide

GN R 984: 28 Commencing an activity which requires an Atmospheric Emissions Licence in terms of Section 21 of the NEM: Air Quality Act (2004).

See below

GN893 published in terms of Section 21 of the NEM: Air Quality Act Category 7.1 Inorganic Chemicals Industry Production and or use in manufacturing of ammonia, fluorine, fluorine compounds, chlorine and hydrogen cyanide

Ammonia is used as a chemical during chemical bath deposition. This is where the CdS buffer layer is deposited onto the CIGS absorber layer.

Category 7.4 Inorganic Chemicals Industry Production, use in production or recovery of antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, mercury and or selenium, by the application of heat.

Selenium is one of the elements comprising the thin film absorber itself. As indicated in Section 3.3, this absorber layer is generated by evaporative heating of the respective elements.



Figure 3.1. Proposed facility layout.



Figure 3.2: Overview of the main process steps to manufacture a CIGS thin film solar module.



4 RELEVANT LEGISLATION

Relevant Legislation used in the Compilation of this Scoping Report 4.1 Table 4.1 below summarises the legislation relevant to the proposed facility. Table 4.1: Environmental legislation considered in the preparation of the Scoping Report

Title of Environmental Legislation, Policy or

Guideline Implications for Proposed Black Lite Solar PV Manufacturing Facility

Constitution Act (108 of 1996)

Obligation to ensure that the proposed development will not result in pollution and ecological degradation; and Obligation to ensure that the proposed development is ecologically sustainable, while demonstrating economic and social development

National Environmental Management Act (NEMA) (107 of 1998)

The developer must be mindful of the principles, broad liability and implications associated with NEMA and must eliminate or mitigate any potential impacts. The developer must also be mindful of the principles, broad liability and implications of causing damage to the environment. The developer must also comply with the EIA Regulations (2014) in the terms of the Act which specifies when an environmental authorisation is required and the nature of the EIA process

National Environmental Management: Waste Act (59 of 2008)

The purpose of this Act relates to the proper disposal of waste. The Act also provides for the waste related activities where a Waste Licence is required. This includes the recycling and refining of waste.

National Environmental Management: Air Quality Act (39 of 2004)

This Act requires that listed activities be operated within the conditions of an Air Emissions License, which has implications related to emissions monitoring and minimisation.

The following regulations and other plans/programmes, etc. are also relevant to the current application:

The EIA Regulations (GNR 982, 983, 984 and 985, 2014)

The Air Quality Act Regulations (GNR 893, 2013)

The BCMM Spatial Development Framework

The ELIDZ Environmental Management Framework


e) A description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process;



5 PROJECT NEED & DESIRABILITY

Support of Renewable Energy 5.1 Renewable energy technologies are an increasingly important source of global energy and one of the key technologies is solar PV which is modular in nature and easily expandable and transportable. PV modules require minimal maintenance, have long service lifetimes, and make use of free fuel, being the sun. Africa is particularly rich in solar energy potential, with most of the continent enjoying an average of more than 320 days per year of bright sunlight and experiencing irradiance levels of almost 2,000 kWh per square meter annually. This compares favourably with the rest of the world, in particular 1,500 kWh for the USA and 1,000 kWh for Europe. This makes South Africa's local resource one of the highest in the world. The Integrated Resource Plan (“IRP”) published by the Department of Energy (”DoE”) in South Africa in 2012 identifies a requirement for at least 9.6 GW of renewable capacity to come from PV systems by 2030. To date, the DoE has allocated 10GW to be purchased from Solar PV Independent Power Producers (“IPPs”). To date, 2.3GW has been purchased by the DoE in its Renewable Energy Independent Power Producer Procurement Program (“REIPPPP”) in bid windows 1 to 4 with a remaining 7.7 GW still to be allocated in the further bid windows. Black Lite will be positioned to supply the solar PV projects under the REIPPPP.

Job creation and social impact 5.2 Once fully built, the Black Lite facility will employ 290 full-time staff in the manufacturing facility, comprising a highly skilled and experienced professional team and support staff. In addition, Black Lite will create 1,150 direct construction jobs and 1,000 indirect jobs, with further plans to incubate businesses in the region. Expansion of the PV module market will also create secondary opportunities for panel retailers, installers and maintenance providers.

Maximising local content 5.3

Maximising local content is an important objective of the REIPPPP and current plans are to achieve at least 75% local manufactured content during the production phase, thus meeting and exceeding South Africa’s local content and local procurement objectives as set out in the REIPPPP.

Alignment with SA Government policy 5.4 The Project has been designed for consistency with a number of energy and industrial development related policies promulgated by the Government of South Africa. These include:

To set up a local manufacturing facility for renewable energy, arising out of key commitments from the Green Economy Accord;

Providing incremental renewable electricity capacity aligned to the Integrated Resource Plan; and

Supporting various key National Development Plan (“NDP”) objectives, including: o Job creation, creation of black industrialists and investment in infrastructure (economy and

employment objective); o Rolling out an off-grid low income lighting solution and providing solar capacity for IPPs

(economic infrastructure objective);

In terms of APPENDIX 2(2) of the EIA Regulations (2014), a Scoping Report must contain all the information necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include

f) A motivation for the need and desirability for the proposed development including the need and desirability of the activity in the context of the preferred location;



o Integration of solar panels into building design (supporting environmental sustainability objective); and

o Promotion of exports into the continent, and partnering with local and global developmental financial institutions including the IDC (supporting South Africa’s presence in the region).

Staffing and skills transfer 5.5

Experienced, skilled and productive staff will be essential for the successful operation of the Black Lite solar module manufacturing facility. These human resource requirements are based on production capacity and local skills and a detailed training plan in Germany. The production line is well automated and requires relatively few employees. However, owing to the technical nature of the manufacturing process and relatively new technology, these employees are required to be skilled and well trained. This offers an opportunity for a high degree of skills and knowledge transfer to local employees. Black Lite has undertaken a human resource study with support from Manz in order to:

Identify staff requirements;

Develop a recruitment plan;

Develop a training plan; and

Determine training costs.

A requirement for 290 employees once the full CIGS manufacturing facility is operational. These staffing requirements are based on 24/7 operation mode of the facility with a 5 shift (12 hour shift duration) model on the Production floor and 2-3 shifts on a 5 day/week basis in the Engineering and Warehouse functions. The table below shows the staff requirements for the production facility as determined by Black Lite in consultation with Manz.

Staff

Executive Management 6

General Management 11

Admin 14

Engineer/Technician 72

Operator 187

TOTAL 290



6 PROJECT ALTERNATIVES One of the objectives of an EIA is to investigate alternatives to the proposed project. There are two types of alternatives: Fundamental Alternatives and Incremental Alternatives.

Reasonable and Feasible Alternatives 6.1 Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The no-go alternative must also in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. “alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to; -

a) the property on which or location where it is proposed to undertake the activity; b) the type of activity to be undertaken; c) the design or layout of the activity; or d) the option of not implementing the activity.

Fundamental Alternatives 6.2 Fundamental alternatives are developments that are totally different from the proposed project description and usually include the following: • Alternative property or location where it is proposed to undertake the activity. • Alternative type of activity to be undertaken. • Alternative technology to be used in the activity.

Incremental Alternatives 6.3

Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered with respect to the current wind farm project, including:

Alternative design or layout of the activity.

Alternative operational aspects of the activity.

No-Go development 6.4 The EIA process is obligated to assess the status quo (i.e. the “No-Go” option). The No-Go alternative provides the assessment with a baseline against which predicted impacts resulting from the proposed development may be compared. A “No-Go” alternative has been assessed for the proposed development.


h) A full description of the process followed to reach the proposed preferred activity, site and location within the site, including –

(i) Details of the alternatives considered;



Table 6.1: The alternatives for the proposed Black Lite Solar PV Manufacturing Facility

Alternative level Alternatives Advantages Disadvantages Reasonable

and feasible Further assessment

Comments

Property or location This refers to the fundamental location options, such as Greenfield vs. a Brownfield site, etc. and the environmental risks and impacts associated with such options.

Alternative location 1 - Current proposed site (Preferred alternative)

Located close to required service infrastructure such as water services, electricity supply, sanitation, etc.

Located in an area zoned for light industry.

Located within the ELIDZ, so access to additional support provided by the ELIDZ to its tenants.

Located close to major transportation options, e.g. harbour, airport, R72, and N2.

Site is currently untransformed, but within an industrial development zone, this will not be the case indefinitely.

YES YES The location of the site within a designated Industrial Development Zone is highly beneficial.

Alternative location 2 - None identified.

NA NA NA NA None

Type of activity This refers to the fundamental land use options, such as industrial, residential, infrastructure, farming, conservation, etc. and the environmental risks and impacts associated with

Alternative activity 1 – Solar PV Manufacturing (Preferred alternative)

Contribute to alleviating electrical energy shortages in South Africa

The potential to stimulate economic activity and jobs in the area

YES YES None

Alternative activity 2 – None

The land is located within an IDZ, so alternative land uses such as residential or agricultural use are precluded from occurring on the site.

NA NA NA None



Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comments

such options

Type of technology This refers to the fundamental technology options, such as energy generation from wind vs. coal fired power plant, etc. and the environmental risks and impacts associated with such options.

Alternative thin film technology 1 – CIGS (copper indium gallium selenide) (Preferred alternative)

Highest efficiency for large-scale outdoor installations

CIGS can be manufactured on low cost glass substrates which enables access to the largest PV markets, enables use of existing mounting systems, is compatible with existing photovoltaic system infrastructure

Visually intrusive

YES YES None

Alternative thin film technology 2 – CdTe (cadmium telluride)

The efficiency is on a par with CIGS thin film and close to the efficiency of multi-crystalline silicon as of 2013.

CdTe has the lowest Energy payback time of all mass-produced PV technologies, and can be as short as eight months in favourable locations.

Tellurium, of which telluride is the anionic form, is as rare as platinum in the earth’s crust, thus contributing to the high manufacturing cost.

The toxicity of cadmium may not be an environmental issue due to recycling opportunities at the end of the lifecycle; however , there

YES NO None

https://en.wikipedia.org/wiki/Energy_payback_time

https://en.wikipedia.org/wiki/Cadmium




Further assessment

Comments

are still uncertainties and the public opinion is sceptical towards this technology

Alternative thin film technology 3 – Amorphous silicon

Silicon-based devices exhibit fewer problems than their CdTe and CIGS counterparts such as toxicity and humidity issues with CdTe cells and low manufacturing yields of CIGS due to material complexity.

Additionally, due to political resistance to the use non-"green" materials in solar energy production, there is no stigma in the use of standard silicon.

The efficiency of an a-Si cell suffers a significant drop of about 10 to 30 percent during the first six months of operation.

NO NO None

Design or layout This relates mostly to alternative ways in which the proposed development or activity can be physically laid out on the ground to minimise or reduce environmental risks or impacts

Alternative layout 1

The layout proposed will be designed to ensure maximum manufacturing efficiency with minimal unnecessary impact on the environment.

YES YES None

Operational aspects

Alternative operational

The facility is designed to operate 24 hours per day, 7

YES YES None




Further assessment

Comments

This relates mostly to alternative ways in which the development or activity can operate in order to reduce environmental risks or impacts

activity 1 (Preferred alternative)

days per week.

No-go option This refers to the current status quo and the risks and impacts associated to it.

Existing activities on site include:

None

Untransformed land within an existing industrial development zone

Will remain relatively undisturbed until another tenant is found to develop the site.

YES YES None



7 PUBLIC PARTICIPATION

Notification of Interested and Affected Parties 7.1 7.1.1 Public Participation Public consultation is a legal requirement throughout the EIA process. Developers are required to conduct public consultation throughout the Scoping and EIR phase. Formal EIA documents are required to be made available for public review and comment by the proponent, these include the Project Brief, Scoping Report and Terms of Reference for the EIA, the draft and final EIA reports and the decision of the Waste and Environmental Authority. The method of public consultation to be used depends largely on the location of the development and the level of education of those being impacted on by the project. Required means of public consultation include:

Site notice(s)

Newspaper advertisements

Letter of Notification and information to affected landowner(s), stakeholders and registered I&APs (Proof: e-mail, fax, registered letters to DEDEAT)

Background Information Document (BID) distribution

Focus group site meeting (Attendance and meeting minutes)

Authority and Stakeholder engagement. 7.1.2 Newspaper advertisement The proposed activity was advertised in the Daily Dispatch (), which detailed the proposed development and provided Interested & Affected Parties (I&AP’s) with the opportunity to register. Copy of advert placed in the Daily Dispatch 7.1.3 On-site Notice

7.1.4 Stakeholder Notification Letter



(ii) Details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents.

(iii) A summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them;



7.1.5 Background Information Document that was Circulated to Interested and Affected Parties/Stakeholders



7.1.6 Proof of Notification



7.1.7 Stakeholder and I&AP database

Organisation Name E-mail

Stakeholders

BCMM Air Quality Officer Alan McIntyre [email protected]

BCMM Environmental Manager Jane Katushabe [email protected]

BCMM Municipal Manager Andile Fani [email protected] [email protected]

BCMM Planning Hans Shluter [email protected]

BCMM Sanitation Mark Westerberg [email protected]

ELIDZ Johan Burger [email protected]

ELIDZ Chris Ettmayr [email protected]

DEDEAT Briant Noncembu [email protected]

DEDEAT Akhona Mvuza [email protected]

Ward Councillor (Ward 46) Nontsikelelo Priscilla Peter [email protected]

Border-Kei Chamber of Business Les Holbrook [email protected]

ELIDZ Tenants

Voestalpine Stamptec South Africa Michael Blechinger [email protected]

MC Synchro Keith Thompson [email protected]

Feltex Caravelle Darryl Meyer [email protected]

IAC Feltex Dieter Kriegisch [email protected]

Feltex Fehrer Alistair Murray [email protected]

Feltex Trim Tony Hiscock [email protected]

Molan Pino John Flanegan [email protected]

ASP Clinic Dr. Trollop [email protected]

Johnsons Control Gregory Kriedemann [email protected]

Marius Coetzee [email protected]

Tracy Van Helsdingen [email protected]

TI Automotives Fuel Systems Bruce West [email protected]

TI Automotive Systems SA (PTY) Ltd Carlos Da Fonseca [email protected]

Linde & Viemann Gehard Gericke [email protected]

Seda Terrance Mtola [email protected]

Joe Ntsomi [email protected]

UTI Jimmy Lee [email protected]

UTI – Sun Couriers Charles Johnson [email protected]

UTI – Material Handling Geoff Sampson [email protected]

VDS Ronnie Gerber [email protected]

TAC Neville Thungavel [email protected]

Auto Carrier Paulus de Wilzen [email protected]

Pure Ocean Andre Bok [email protected]

Ocean Wise Frans-Johan van Dyk [email protected]

Zinzi Dubula - Nowa [email protected]

Matla Diamond Chia-Chao Wu [email protected]

Sunningdale Neil Van Rensburg [email protected]

Karen Boy [email protected]

Kromberg & Schubert Cobus Kotze [email protected]

Froetek SA Werner Bendisch [email protected]

MSC Barbara Taylor [email protected]

EC NGO Coalition NGO Rooks Moodley [email protected]

ECITI Mncedi Mgwigwi [email protected]

Collectall Jonathan Earl [email protected]

Chemin Matthew Speelman [email protected]

mailto:[email protected]


mailto:[email protected]%20%[email protected]

mailto:[email protected]%20%[email protected]






























Avumile Business Investments Vumile Mtyobele [email protected]

Langa Energy Patrick M. Nawa [email protected]

Kubela Meladi Abraham [email protected]

ABET Dumisani Rheme

[email protected] / dumisani [email protected]

RG Brose Automotive Components Piet Strydom [email protected]

CSIR Mandla Sodladla [email protected]

Boysens James Tarr [email protected]

Master Artisan Willie Gresse [email protected]

New Shelf /Dimension Data Mr Mangaliso Radebe [email protected]

BCM Mr X Wonono [email protected]

Zizi Consulting/ Pokopela No-Olie Olivia Sigidi olivia.sigidi@ ziziconsulting.co.za

Milltrans Johan Stapelberg [email protected]

Murray & Roberts Nick Lotter [email protected]

Big foot Dion Naidoo [email protected]

Fox tech Ikhwezi Leigh Briggs [email protected]

7.1.8 Issues Raised by I&APs Issues raised by I&APs and responses by the EAP and/or proponent responses are detailed in the Issues and Response trail below. TO BE COMPLETED AT THE CLOSE OF THE PUBLIC REVIEW PERIOD



mailto:dumisani@

mailto:dumisani@







8 DESCRIPTION OF THE ENVIRONMENT

The Bio-Physical Environment 8.1 8.1.1 Current land use The land is currently unused and undeveloped. It is within the fenced area of the East London Industrial Development Zone. As well as the EA generated if this application is approved, the facility will also be required to comply with the existing EA for the ELIDZ, as described in the Introductory Chapter. 8.1.2 Topography The topography of the site is generally flat, with a mild slope from south to north. 8.1.3 Geology The physical features of the site are typical of the BCM coastline where dolerite outcrops occur (e.g. Kwelera, Gonubie, West Bank, Igoda, Christmas Rock) with the majority and remainder of the geological formations being primarily calcareous sandstones of the Algoa Group. A few deposits of grey and grey/red mudstone of the Beaufort Group also occur but are limited in their extent (e.g. Keiskamma, Gulu, Winterstrand, Gonubie). The marine origin of these formations results in the high salinity of groundwater found in the Amatole catchments and Fish River basin (BCMM State of Environment Report, 2014). 8.1.4 Watercourses and Wetlands The site lies between the Mvubukazi and Mngqenga Rivers, both small, temporary open/closed systems of less than 8 km. The boundary of the site is approximately 600 m from the Mngqenga River, and is separated from it by a number of vacant sites. No wetlands occur on site. 8.1.5 Air Quality East London receives an average of 593mm of rain per year, with most occurring in the summer months (Figure 8.1a). The monthly distribution of average daily maximum temperatures (Figure 8.1b) shows that the average midday temperatures for East London range from 20°C in July to 26°C in February. The region is the coldest during July when the mercury drops to 9.3°C on average during the night (SA Explorer, 2015). Figure 8.2 indicates average wind data based on observations taken over the past 15 years at the East London Airport. The dominant wind direction is from the East North East, switching to approximate Westerly winds at times.



(iv) The environmental attributes associated with the alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

A



Figure 8.1. Average rainfall and temperature patterns in East London.

Figure 8.2. Wind data for East London (www.windfinder.com)

a b



Ambient air quality monitoring in the Eastern Cape is only conducted in the NMBMM and BCMM by the respective municipalities, and in the two Industrial Development Zones (Coega and East London IDZ). The ELIDZ owns 1 monitoring station, and monitors SO2, NO2, PM10 and meteorology. In addition, the municipalities monitor CO and O3. The BCMM also monitors benzene. The resultant ambient air quality data indicates that air quality in the two Metropolitan Municipalities is relatively good. No exceedances of ambient air quality standard are recorded in BCMM, and only a few exceedances of the limit value for ozone (O3) and nitrous oxide (NO2) are recorded in NMBMM.

Vegetation and Floristics 8.2 8.2.1 South African National Biodiversity Institute Mucina and Rutherford (2006) have classified the vegetation type on site as Albany Coastal Belt. This vegetation type is distributed within 15 km of the coastline, from Kei Mouth to the Sunday’s River. Typically the land is dominated by short grasslands punctuated by scattered bush clumps or solitary Acacia natalitia trees. It is categorised as LEAST THREATENED. 8.2.2 Eastern Cape Biodiversity Conservation Plan The site is classified by the ECBCP as a Critical Biodiversity Area (CBA 2). However, the land has been rezoned and authorisation given for the construction and operation of suitable light industry within the ELIDZ. In fact, a significant number of facilities have been constructed and are currently operating within the ELIDZ.

Socio-Economic Profile 8.3 8.3.1 Population Based on the IDP, BCMM population has shown a steady growth over the years. It has grown from 704,855 in 2001 to 755,200 in 2011 (0.7% growth rate). The population demographic based on the 2011 census was 85% black, 7.71% white, 6.02% coloured, 0.83% Indian/Asian and 0.33% other. The gender distribution is 47.5% male and 52.5% female. Age distribution revealed that there is a relatively high youth component of the population, with 37.3% between the ages of 15 and 35. 8.3.2 Economy BCMM has the 2nd largest economy in the Eastern Cape after the Nelson Mandela Metro. The finance sector is the largest sector in BCMM, representing 29% of the total economy. This is followed closely by Community Services which accounts for 2%, manufacturing (17percent), trade (13%) and transport 8%. The contribution of agriculture (1%) and mining (0.4%) remains minimal. The size of the financial sector at BCMM can be attributed to the regional head offices of the finance institutions which are domiciled in East London. The strength of the community services sector can be attributed to the Provincial Government Head Offices in Bhisho as well as the regional offices of the government departments that are in East London. The manufacturing sector (which is based on automotive manufacturing) has been affected by the global recession as illustrated by the shrinking in size (8%) between 2008 and 2009. It should be remembered that this industry is based primarily on exports to global markets which were severely affected by the recession.



Trade was also affected by the recession as illustrated by the shrink (2%) between 2008 and 2009. This is because with loss of income through the job losses that come with a recession, there is less money for people to spend. The R30 billion which represents the GVA of BCMM for 2010 represents a 0.5% growth compared to 5% growth in 2009 (BCMM IDP 2015/2016). This can be attributed to the impact of the global recession. The community services sector employed about 30% of the employed in BCMM. This is followed by trade (23%) and manufacturing 18%. The finance sector, the largest sector by contribution, employs only 8% of those employed in BCMM. The households sector refers to employment around households and currently accounts for 8% of all jobs in BCMM. Construction accounts for about 6% of the total jobs, agriculture employs 2% of the employed.

Figure 8.1: Labour Market of BCMM 8.3.3 Employment BCMM has high levels of unemployment, at around 30% or 75,000 people, associated with much reliance on survival in the second informal economy. This is related to high levels of poverty (60% of all households earned less than R1600/ month in 2001) which in turn constraints BCM’s ability to deliver basic services in a sustainable manner. Significant service delivery backlogs exist, including an estimated 130,000 housing units being required in the period of 2007 – 2027. The main perceived weakness of the business environment are distance from markets/ customers, transport costs and congestion, and lack of government services. While the two main perceived strengths of the business environment are location being accessible to clients, customers and markets, and the accessibility to logistics infrastructure such as the port, airport, and highways. The constraints on business growth include the lack of available labour force skills and availability of finances. In addition to low levels of economic growth, unemployment is also linked to skills levels of the labour force. Literacy levels stayed stagnant between 1996- 2001 at 77% and 9.5% of the population having no education.



This challenge is seen by BCMM as one of the major contributors to systemic poverty and unemployment that the municipality experiences. With less than 10% of the population with no matric or post matric qualification and 37% with no schooling at all there is a need to energise efforts to improve education and skills development.

Figure 8.2: Unemployment Rates in BCMM 1996 to 2011



9 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED

Possible Environmental Issues and Impacts 9.1 Table 9.1 lists the environmental issues and resulting impacts that have been identified for the project development.

Issue Potential Impact Gaseous emissions

Gaseous ammonia is toxic and flammable. Incorrect storage

and handling could result in significant health and safety impacts (-)

Storage of hazardous materials

Leakage from storage tanks/areas could contaminate local environment (-)

Renewable Energy Investment Increased investment in solar energy in the local area (+)

Increased investment in solar energy in South Africa due presence of a local supplier (+)

Job creation in the sector/East London (+)

Other potential impacts that will be assessed include, but may not be limited to:

Resource use (energy, water, etc.)

Waste issues (storage, spillage, discharge)

Chemical usage

In terms of Section APPENDIX 2(2) of the EIA Regulations (2014), a Scoping Report must contain all the information necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include:

h) A full description of the process followed to reach the proposed preferred activity, site and location within the site, including – (v) The impacts and risks identified for each alternative, including the nature,

significance, consequences, extent, duration and probability of the impacts, including the degree to which these impacts –

Can be reversed

May cause irreplaceable loss of resources; and

Can be avoided, managed or mitigated (vi) The methodology used in determining and ranking the nature, significance,

consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives;

(vii) Positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

(viii) The possible mitigation measures that could be applied and level of residual risk; (ix) The outcome of the site selection matrix (x) If no alternatives, including alternative locations for the activity were investigated, the

motivation for not considering such; and (xi) A concluding statement indicating the preferred alternatives, including preferred

location of the activity.



10 PLAN OF STUDY FOR EIA PHASE

In terms of Section APPENDIX 2(2) of the EIA Regulations (2014), a Scoping Report must contain all the information necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include:

i) a plan of study for undertaking the environmental impact assessment process to be undertaken, including– (i) a description of the alternatives to be considered and assessed within the preferred site,

including the option of not proceeding with the activity.; (ii) a description of the aspects to be assessed as part of the environmental impact assessment

process; (iii) aspects to be assessed by specialists; (iv) a description of the proposed method of assessing the environmental impacts, including

aspects to be assessed by specialists; (v) a description of the proposed method of assessing duration and significance;

(vi) an indication of the stages at which the competent authority will be consulted; (vii) particulars of the public participation process that will be conducted during the

environmental impact assessment process; and (viii) a description of the tasks that will be undertaken as part of the environmental impact

assessment process; (ix) identify suitable measures to avoid, reverse, mitigate or manage identified impacts and to

determine the extent of the residual risks that need to be manages and monitored.

In line with the above-mentioned legislative requirement, this Chapter sets out the Plan of Study (PoS) for the EIA phase of the assessment. Consultation with DEDEAT will be on going throughout this EIA. However, it is anticipated that DEDEAT will provide relevant comment with respect to the adequacy of this Plan of Study for the EIA, as it informs the content of the EIR and sufficiency thereof.

Scope and Intent of the EIA Phase 10.1 This phase includes the following steps: 10.1.1 Specialist Studies The specialist studies include the specialist assessments identified in the Scoping Report and any additional studies required by the authorities. This requires the appointment of specialists to gather baseline information in their fields of expertise, and to assess the possible impacts and make recommendations to mitigate negative impacts and optimise benefits. The resulting information is synthesised into the Environmental Impact Report (EIR). 10.1.2 Environmental Impact Report (EIR) The main purpose of this report is to gather and evaluate environmental information, so as to provide sufficient supporting arguments to evaluate overall impacts, consider mitigation measures and alternative options, and make a valued judgement in choosing the best development alternative. The EIR is made available for public and authority review. The availability of the report is advertised in the local newspaper and is situated at an easily accessible location.



10.1.3 Issues and Response Trail The issues and response trial consists of the compilation of comments, issues and concerns raised by I&APs and the authorities as well as the relevant responses to these comments. 10.1.4 Environmental Management Programme (EMPr)

The EMPr informs the client and the technical team of the guidelines which will need to be followed during construction to ensure that there are no lasting or cumulative negative impacts of the construction process on the environment.

The standards and guidelines that must be achieved in terms of environmental legislation.

Mitigation measures and environmental specifications which must be implemented for all phases of the project in order to minimise the extent of environmental impacts, to manage environmental impacts and where possible to improve the condition of the environment.

Provide guidance through method statements that are required to be implemented to achieve the environmental specifications.

Define corrective action that must be taken in the event of non-compliance with the specifications of the EMPr.

Prevent long-term or permanent environmental degradation. In addition to this, the Public Participation Process is continued. As for the Scoping Phase, opportunity is provided for I&APs to voice concerns and issues regarding the project. At this stage the project details may have changed in response to the preliminary findings of the Draft Scoping Report. I&APs and key stakeholders are also given the opportunity to review the Environmental Impact Report before it is submitted to the authorities. 10.1.5 Record of Decision of Environmental Authorisation and Appeals Process Upon thorough examination of the EIR, the authority will either issue an authorisation, which either authorises the project or rejects it, or require further details to clarify certain issues. Should authorisation be granted, it usually carries Conditions of Approval. The proponent is obliged to adhere to these conditions. Once the authorisation has been issued, it is publicised and the public are given 20 calendar days from the issuing of the authorisation to lodge an appeal with the authorities. An appeal must be submitted within 30 days after the lapsing of the 20 day notice of intention to appeal.

The Public Participation Process 10.2

10.2.1 Public Review Of The Draft Scoping Report (DSR) All I&APs on the Register of I&APs will be notified in writing of the availability of the DSR for public review. The notification letter will provide details of the 30-day public comment period, the venues and websites where the report could be viewed, the contact details of the PPP consultant and how written comments on the DSR should be submitted, and details of the public meeting to present the DSR. 10.2.2 Public Review Of The Draft Environmental Impact Report (DEIR) All I&APs on the Register of I&APs will be notified in writing of the availability of the DEIR for public review. The notification letter will provide details of the 40-day public comment period, the venues and websites where the report can be viewed, the contact details of the PPP consultant and how written comments on the DEIR should be submitted, and details of the public meeting to present the DEIR.



10.2.3 Notification Of Environmental Authorisation (EA) Advertisements announcing the Environmental Authorisation will be placed in the same regional and local newspapers used to announce the project and the EIA. The adverts will be placed in the Daily Dispatch. The adverts will inform I&APs of the decision and where the decision can be accessed and will draw their attention to their right to appeal the decision and set out the appeal procedures.

Environmental Impact Report (EIR) 10.3 The Specialist Studies described below will inform the EIR. In addition, the EIR will gather any comments received from I&APs and determine whether it is necessary to increase the scope of work or amend the Terms of Reference for the specialists. The EIR will examine the ‘No-Go’ alternative along with the proposed development, as required in the EIA regulations. 10.3.1 Structure of the EIA Report In broad terms, the Environmental Impact Report (EIR) will have the following Table of Contents: EXECUTIVE SUMMARY AND ENVIRONMENTAL IMPACT STATEMENT PART ONE: INTRODUCTION AND DESCRIPTION OF ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1. Introduction 2. Brief Description of The Proposed Project 3. Environmental Impact Assessment process 4. Activities triggering the EIA process 5. The environmental study team 6. The environmental assessment process followed 7. Structure of the Report PART TWO: THE PROPOSED WASTE PLASTICS REFINING FACILITY 1 Project Overview 2 Alternatives 3 Technical Description of Preferred Options PART THREE: DESCRIPTION OF THE AFFECTED ENVIRONMENT 1. The Natural Environment 2. Socio-Economic Environment 3. The Policy, Legal And Administrative Environment

PART FOUR: ASSESSMENT OF THE ENVIRONMENTAL IMPACTS ASSOCIATED WITH THE HOUSING DEVELOPMENT 1. Impacts Associated with the Development 2. Conclusion

PART FIVE: ENVIRONMENTAL MANAGEMENT PLAN AND OVERALL RECOMMENDATIONS AND CONCLUSIONS



Specialist Studies 10.4 10.4.1 Air Emissions Inventory (EXIGO) – If required by the Air Quality Officer The Air Emissions Inventory study will assess the following:

Characterise the gaseous emissions from the facility in terms of type and volume

Identify potential environmental and health impacts related to the gaseous emissions

Assess the potential impacts as per the EOH-CES methodology

Methodology for assessing the significance of impacts (Including Specialist 10.5Studies)

Specialists are required to provide the reports in a specific layout and structure, so that a uniform specialist report volume can be produced. To ensure a direct comparison between various specialist studies, standard rating scales have been defined for assessing and quantifying the identified impacts. This is necessary since impacts have a number of parameters that need to be assessed.

Identified impacts will be assessed against the following criteria:

Temporal scale

Spatial scale

Risk or likelihood

Degree of confidence or certainty

Severity or benefits

Significance The relationship of the issue to the temporal scale, spatial scale and the severity are combined to describe the overall importance rating, namely the significance of the assessed impact. Table 10.1: Significance Rating Table

Significance Rating Table

Temporal Scale (The duration of the impact)

Short term Less than 5 years (Many construction phase impacts are of a short duration).

Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (From a human perspective almost permanent).

Permanent Over 40 years or resulting in a permanent and lasting change that will always be there.

Spatial Scale (The area in which any impact will have an affect)

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area.

Study area The proposed site and its immediate environs

Municipal Impacts affect BCMM, or any towns within BCMM.

Regional Impacts affect the wider district municipality or the Eastern Cape Province as a whole.

National Impacts affect the entire country.

International/Global Impacts affect other countries or have a global influence.

Likelihood (The confidence with which one has predicted the significance of an impact)

Definite More than 90% sure of a particular fact. Should have substantial supportive data.

Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring.



Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring.

Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

Table 10.2: Impact Severity Rating

Impact severity (The severity of negative impacts, or how beneficial positive impacts would be on a particular affected system or affected party)

Very severe Very beneficial

An irreversible and permanent change to the affected system(s) or party(ies) which cannot be mitigated. For example the permanent loss of land.

A permanent and very substantial benefit to the affected system(s) or party(ies), with no real alternative to achieving this benefit. For example the vast improvement of sewage effluent quality.

Severe Beneficial

Long term impacts on the affected system(s) or party(ies) that could be mitigated. However, this mitigation would be difficult, expensive or time consuming, or some combination of these. For example, the clearing of forest vegetation.

A long term impact and substantial benefit to the affected system(s) or party(ies). Alternative ways of achieving this benefit would be difficult, expensive or time consuming, or some combination of these. For example an increase in the local economy.

Moderately severe Moderately beneficial

Medium to long term impacts on the affected system(s) or party (ies), which could be mitigated. For example constructing a sewage treatment facility where there was vegetation with a low conservation value.

A medium to long term impact of real benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are equally difficult, expensive and time consuming (or some combination of these), as achieving them in this way. For example a ‘slight’ improvement in sewage effluent quality.

Slight Slightly beneficial

Medium or short term impacts on the affected system(s) or party(ies). Mitigation is very easy, cheap, less time consuming or not necessary. For example a temporary fluctuation in the water table due to water abstraction.

A short to medium term impact and negligible benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are easier, cheaper and quicker, or some combination of these.

No effect Don’t know/Can’t know

The system(s) or party(ies) is not affected by the proposed development.

In certain cases it may not be possible to determine the severity of an impact.

Table 10.3: Overall Significance Rating

Overall Significance (The combination of all the above criteria as an overall significance)

VERY HIGH NEGATIVE VERY BENEFICIAL

These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services, would be regarded by the affected parties as resulting in benefits with VERY HIGH significance.

HIGH NEGATIVE BENEFICIAL

These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light.



Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as people growing crops in the soil) would be HIGH.

MODERATE NEGATIVE SOME BENEFITS

These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant.

LOW NEGATIVE FEW BENEFITS

These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits of LOW significance to people who live some distance away.

NO SIGNIFICANCE

There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective, but is of NO significance in the overall context.

DON’T KNOW

In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people’s psychological perspective of the environment.

All feasible alternatives and the “no-go option” will be equally assessed in order to evaluate the significance of the “as predicted” impacts (prior to mitigation) and the “residual” impacts (that remain after mitigation measures are taken into account). Reason for the judgement will be provided when necessary.

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