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NEMA SECTION 24G EIA Report
DRAFT ENVIRONMENTAL IMPACT REPORT
APPLICATION FOR THE RECTIFICATION OF AN UNAUTHORISED
TENTED CAMP ON THE DUIWENHOKS RIVER, ‘KOENSRUST’ 502,
VERMAAKLIKHEID
14/2/1/D5/15/Duiwenhoks River, Riversdale
April 2013
Prepared by
CHARL DE VILLERS ENVIRONMENTAL CONSULTING
14 Bradwell Road VREDEHOEK 8001
Ph 083 785 0776 * skua@mweb.co.za * Fax 086 553 9256
in collaboration with
REGALIS ENVIRONMENTAL SERVICES
and
BOLANDENVIRO

NEMA SECTION 24G EIA REPORT
Contents:
Section A:
Activity Information
Section B:
Description of Receiving Environment
Section C:
Public Participation Information
Section D:
Need and Desirability
Section E:
Alternatives
Section F:
Preliminary Impact Assessment, Management, Mitigation and Monitoring
Section G:
Assessment Methodologies and Criteria, Gaps in Knowledge, under laying
Assumptions and Uncertainties
Section H:
Recommendations of the EAP
Section I:
Motivation for response to an emergency
Section J:
Appendices
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NEMA SECTION 24G EIA REPORT
Kindly note that:
1. This section 24G Environmental Impact Assessment (”EIA”) report must be completed for all section
24G applications in terms of the above Acts, by an independent Environmental Assessment
Practitioner (“EAP”).
2. This EIA report is current as of July 2012. It is the responsibility of the Applicant/EAP to ascertain
whether subsequent versions of the EIA report have been published or produced by the
competent authority.
3. An Independent EAP must be appointed to complete the section 24G EIA report on behalf of the
applicant; the declaration of independence must be completed by the independent EAP and
submitted with this EIA report. If a specialist report is required, the specialist will also be required to
complete the declaration of independence.
4. Two hard copies and one electronic copy (CD/DVD) of this report must be submitted.
5. The required information must be typed within the spaces provided. The sizes of the spaces
provided are not necessarily indicative of the amount of information to be provided. The space
provided extend as each space is filled with typing. A legible font type and size must be used when
completing the report. The font size should not be smaller than 10pt (e.g. Century Gothic 10). A
digital copy of the Section EIA Report is available on the Department’s website (details below).
6. The use of “Not applicable” in the EIA report must be done with circumspection.
7. No faxed or e-mailed EIA reports will be accepted.
8. Unless protected by law, all information contained in and attached to this EIA report will become
public information on receipt by the competent authority. Upon request, any Interested and
Affected Party (“I&AP”) should be provided with the information contained in and attached to this
EIA report. During any stage of the application process, the information contained in and attached
to it must be provided by the applicant / EAP.
9. This EIA report must be submitted to the Department at the postal address given below or by
delivery thereof to the Registry Office of the Department. Unnecessary delays will be incurred
should the application and attached information not be submitted to the correct address.
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NEMA SECTION 24G EIA REPORT
10. PROCESS TO BE FOLLOWED:
a) A section 24G Application Form constitutes the initiation of the Section 24G application
process. If you have failed to submit an application form, you may not proceed with the
compilation and submission of this EIA report until such time that a section 24G application
form has been submitted to the Department and subsequently acknowledged.
b) Once the information requirements in respect of the application have been met, a draft EIA
report, which must include an Environmental Management Programme (“EMP”), must first be
made available to the I&APs, including all the relevant State Departments that administer
laws relating to a matter affecting the environment, for comment for a period of 40 (forty)
calendar days. Unless otherwise indicated by the Department, a commenting period of at
least 21 (twenty-one) days must be provided to I&APs, including the relevant State
Departments, to comment on any additional information, documentation or reports
(including the final EIR), other than the draft EIR.
c) The draft EIA report must be submitted to the Department in order to meet the requirements
of section 24O of the NEMA. The Department will notify the State Departments of the 40 (forty)
day commenting after receipt of the draft EIA report.
d) Upon submission of the final EIA report, the competent authority will reconsider the application
and may undertake a site inspection or request such additional information as the competent
authority may require from the Applicant/EAP.
e) The Department will consider the final EIA report/additional information (if required) to
determine the administrative fine (not exceeding R1 million) and inform the applicant
accordingly. The fine must be paid within 60 days from the date of the fine notice. The
applicant is required to provide proof of payment of the fine to the Department.
f) In accordance with section 24G(2), the competent authority will then:
• direct the applicant to cease the activity, either wholly or in part, and to rehabilitate the
environment within such time and subject to such conditions as the Department may
deem necessary; or
• issue an environmental authorisation to the applicant subject to such conditions as the
Department may deem necessary.
11. Note, failure to comply with a directive calling for information to be submitted within a specified
period may result in the institution of appropriate legal action as is deemed necessary by this
Department and as provided for in the legislation.
12. A person failing to comply with a directive or contravening or failing to comply with a condition of
environmental authorisation is guilty of an offence and is liable on conviction to a penalty of a fine
not exceeding R5 million or to imprisonment for a period not exceeding ten years, or to both such
fine and such imprisonment.
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NEMA SECTION 24G EIA REPORT
DEPARTMENTAL DETAILS
DEPARTMENTAL REFERENCE NUMBER(S) (for official use)
Department of Environmental Affairs
and Development Planning,
Directorate: Environmental
Compliance & Enforcement,
Attention: Sub-directorate:
Section 24G Applications
Private Bag X9086
Cape Town, 8000
Registry Office
1 st Floor Utilitas Building
1 Dorp Street, Cape Town
Queries should be directed to the
Sub-directorate: Section 24G
Applications at:
Tel: (021) 483-8019
Fax: (021) 483-4033
File Reference number
(S24G)
File Reference number
(Enforcement), if applicable
File reference number (EIA),
if applicable:
File reference number
(Waste), if applicable:
File reference number
(Other):
ENV number:
14/2/1/D5/15/Duiwenhoks
River, Riversdale
DETAILS OF THE APPLICANT
Applicant Name: Koensrust Plase (Pty)Ltd
Contact Person Dr Francois du Plessis
RSA ID number 561213 5016 084
Trading name Koensrust Plase (Pty)Ltd
Company reg no 1981/006147/07
Postal address: c/o Norman, Wirth and Stephens, 2 nd floor, 50 Keerom Street
CAPE TOWN Postal code: 8001
Telephone: (021) 461 6692 Cell: 082 825 5210
E-mail: francois@dupmail.com Fax: (021) 461 6693
DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)
Environmental
Assessment Practitioner:
Charl de Villiers Environmental Consulting
Contact person:
Charl de Villiers
Postal address:
14 Bradwell Road, VREDEHOEK
Postal code: 8001
Telephone: ( 021) 461 2477 Cell: 083 785 0776
E-mail: skua@mweb.co.za Fax: (086) 553 9256
EAP Qualifications BA Hons; MPhil Environmental Management
EAP
Registrations/Associations
Certified Environmental Assessment Practitioner (EAPSA)
S24GEIAR/07/2012 5

NEMA SECTION 24G EIA REPORT
SECTION A: ACTIVITY INFORMATION
1. PROJECT TITLE
RECTIFICATION OF UNAUTHORISED TENTED CAMP ON THE DUIWENHOKS RIVER, ‘KOENSRUST’ 502,
VERMAAKLIKHEID
2. ACTIVITY DESCRIPTION
(Cross out the appropriate box “⌧” and provide a description where required).
(a)
Is/are the activity(ies) complete or is/are the activity(ies)
still to be completed Completed Incomplete
All work relating to the construction of the tented camp had been completed by November 2011.
(b) Is/was the project a new development or an upgrade of an
existing development Also indicate the date (e.g. 2 August
2010) when the activity commenced as well as the original date
New Upgrade
of commencement if the application is an upgrade.
The activities in question commenced in September 2010. They entailed adding wooden decks and
three canvas tents to an existing shed on the site that was erected in the 1990s.
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NEMA SECTION 24G EIA REPORT
(c) Clearly describe the activity and associated infrastructure commenced with, indicating what
has been completed and what still has to be completed. See Appendix B (Site plan) and
Appendix C (Photographs).
The unauthorised works that are the subject of this application commenced in September 2010 and
were concluded in November the next year.
In summary, the activities entailed clearing about 250 m 2 of vegetation to establish a tented camp
on private land next to the Duiwenhoks River 5 km downstream of Vermaaklikheid in the Hessequa
Municipality, Western Cape (Fig 1). The camp, which forms an integrated unit with the existing
wooden shed on the site, comprises 127 m 2 of wooden decking that supports three permanently
pitched canvas safari tents arranged in a row to the south. The deck houses an open ‘braai’ area
just south of the shed.
The tents are equipped with basic furnishings. There are four single beds in the tent closest to the
shed, and a double bed in each of the remaining tents. This additional infrastructure covers an area
of roughly 300 m 2 in extent. There is another sunken ‘braai’ place on the ground to the west of the
decking.
(d) Please provide details of all components of the activity and attach diagrams (e.g. architectural
drawings or perspectives, engineering drawings, process flow charts etc.).
Buildings YES NO
Provide brief description:
See above for a description of the tented camp. No permanent buildings (i.e. rigid, walled
structures with roofs) were erected.
Infrastructure (e.g. roads, power and water supply/ storage) YES NO
Provide brief description:
A wooden deck, 127 m 2 in extent, comprises the only infrastructure besides the three tents.
Processing activities (e.g. manufacturing, storage, distribution) YES NO
Provide brief description:
Not applicable.
Storage facilities for raw materials and products (e.g. volume and substances to be stored)
Provide brief description YES NO
Not applicable.
Storage and treatment facilities for solid waste and effluent
generated by the project
Yes
NO
Provide brief description
Not applicable.
(e) Other activities (e.g. water abstraction activities, crop planting
activities)
Provide brief description
Not applicable.
Yes
NO
3. PHYSICAL SIZE OF THE ACTIVITY
Indicate the physical spatial size of the activity as well as associated infrastructure
300 m
(footprints):
2
Indicate the area that has been transformed / cleared to allow for the activity as
≤250
well as associated infrastructure
Total area: 300 m 2
m 2
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NEMA SECTION 24G EIA REPORT
4. SITE ACCESS
Was there an existing access road YES NO
If NO, what was the distance over which the new access road was built Not
applicable.
m
Describe the type of access road constructed:
The only vehicular access to the ‘Koensrust’ tented camp is via a very steep jeep track that was
constructed in the 1990s and later hardened on CapeNature’s instruction. This work was completed
before the expiry of the Record of Decsion (30 September 2000) which authorised the upgrade of the
track. The track drops 173 m over 1.6 km and has an average gradient of 10.6%. It can only be
negotiated by four-wheel drive vehicles. The location of the track and an elevation graph are
included with the site plan in Appendix B.
5. SITE PHOTOGRAPHS
Colour photographs of the site and its surroundings (taken of the site and from the site), both before (if
available) and after the activity commenced, with a description of each photograph, must be
attached to this application. The vantage points from which the photographs were taken must be
indicated on the site plan, or locality plan as applicable. If available, please also provide past and
recent aerial photographs. It should be supplemented with additional photographs of relevant
features on the site. Date and source of photographs must be included. Photographs must be
attached as an appendix to this form.
6. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES
Please list all legislation, policies and/or guidelines that were or are relevant to this activity.
TYPE
DATE
LEGISLATION
ADMINISTERING
AUTHORITY
Permit/ license/
(if already
authorization/comment
obtained):
National Environmental
Management Act (107
of 1998) (NEMA), as
amended
Department of Environmental
Affairs & Development
Planning (DEA&DP)
Environmental Authorisation (in this
case, in terms of s 24G)
EIA Regulations 2010
promulgated in terms of
Section 24(5) of NEMA
as amended
DEA&DP
Environmental Authorisation
Land Use Planning
Ordinance 15 of 1985
Hessequa Municipality
Application for departure i.t.o. s 15 of
LUPO (pending)
Environment
Conservation Act 73 of
1989
Department of Environmental
Affairs & Development
Planning (DEA&DP)
Environmental authorisation of jetty,
slipway and access track – reference
25/4/100(2886). See Appendix E.
30 September 1998
EIA regulations
published i.t.o. ECA
DEA&DP
As above
73/1989
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NEMA SECTION 24G EIA REPORT
POLICY/ GUIDELINES
ADMINISTERING AUTHORITY
Guideline on interpretation of listed activities (June 2010)
Guideline on public participation (October 2011)
Guideline on alternatives (October 2011)
Guidelines for involving specialists in EIA processes (2005)
Guideline on need and desirability (October 2011)
Biodiversity Sector Plan for the Mossel Bay and Hessequa Municipalities
(2010).
W Cape PSDF: Rural land-use planning and management guidelines
(2009)
Dept of Environmental Affairs (DEA)
DEA&DP
DEA&DP
DEA&DP
DEA&DP
DEA&DP/CapeNature
DEA&DP
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NEMA SECTION 24G EIA REPORT
SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT
Site/Area Description
For linear activities (pipelines, etc.) as well as activities that cover very large sites, it may be necessary
to complete copies of this section for each part of the site that has a significantly different
environment. In such cases please complete copies of Section C and indicate the area which is
covered by each copy No. on the site plan.
Section C Copy No. (e.g. 1,
2, or 3):
N/A
1. GRADIENT OF THE SITE
Indicate the general gradient of the site(s) (cross out the appropriate box).
Flat Flatter than 1:10 1:10 – 1:5 Steeper than 1:5
2. LOCATION IN LANDSCAPE
Indicate the landform(s) that best describes the site (cross out (“⌧”) the appropriate box(es).
Ridgeline
Plateau
Side slope of
hill/mountain
Closed
valley
Open
valley
Plain
Undulating
plain/low
hills
Dune
Seafront
Other
If other, please describe
The tented camp is located at the base of one of several steep valleys that incise the limestone
escarpment directly east of the Duiwenhoks River between the feature known as ‘Die Hoek’ and the
mouth of the estuary at Puntjie. The Duiwenhoks River lies directly to the west of the limestone scarp
below which the tented camp is located. The scarp drops steeply to the river, from an altitude of
about 160 masl over a distance of a kilometre to virtually sea level in the channel of the Duiwenhoks
River. The tented camp is located on a narrow raised bench, about 20 m wide, between the base
of the scarp and the salt flats of the river. The access track and grassed area lie to the north-east.
3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE
3.1 GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (PRE-COMMENCEMENT)
Is the site(s) located on or near any of the following (cross out (“⌧”) the appropriate boxes)
Shallow water table (less than 1.5m deep) YES NO UNSURE
Seasonally wet soils (often close to water bodies) YES NO UNSURE
Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE
Dispersive soils (soils that dissolve in water) YES NO UNSURE
Soils with high clay content YES NO UNSURE
Any other unstable soil or geological feature YES NO UNSURE
An area sensitive to erosion YES NO UNSURE
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NEMA SECTION 24G EIA REPORT
3.2 GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (POST-COMMENCEMENT)
Shallow water table (less than 1.5m deep) YES NO UNSURE
Seasonally wet soils (often close to water bodies) YES NO UNSURE
Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE
Dispersive soils (soils that dissolve in water) YES NO UNSURE
Soils with high clay content YES NO UNSURE
Any other unstable soil or geological feature YES NO UNSURE
An area sensitive to erosion YES NO UNSURE
If any of the answers to the above are “YES” or “unsure”, specialist input may be requested by the
Department.
(Information in respect of the above will often be available at the planning sections of local authorities.
Where it does not exist, the 1:50 000 scale Regional Geotechnical Maps prepared by Geological
Survey may also be used).
4. SURFACE WATER
4.1 SURFACE WATER (PRE-COMMENCEMENT)
Indicate the surface water present on and or adjacent to the site and alternative sites (cross out (“⌧”)
the appropriate boxes)
Perennial River YES NO UNSURE
Non-Perennial River YES NO UNSURE
Permanent Wetland YES NO UNSURE
Seasonal Wetland YES NO UNSURE
Artificial Wetland YES NO UNSURE
Estuarine / Lagoonal wetland YES NO UNSURE
4.2 SURFACE WATER (POST-COMMENCEMENT)
Indicate the surface water present on and or adjacent to the site and alternative sites (cross out (“⌧”)
the appropriate boxes)
Perennial River YES NO UNSURE
Non-Perennial River YES NO UNSURE
Permanent Wetland YES NO UNSURE
Seasonal Wetland YES NO UNSURE
Artificial Wetland YES NO UNSURE
Estuarine / Lagoonal wetland YES NO UNSURE
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NEMA SECTION 24G EIA REPORT
5. VEGETATION AND/OR GROUNDCOVER
Please note: The Department may request specialist input/studies depending on the nature of the
biodiversity occurring on the site and potential impact(s) of the activity/ies. To assist with the
identification of the biodiversity occurring on site and the ecosystem status consult http://bgis.sanbi.org
or BGIShelp@sanbi.org. Information is also available on compact disc (“cd”) from the Biodiversity-GIS
Unit, Ph (021) 799 8698. This information may be updated from time to time and it is the applicant/
EAP’s responsibility to ensure that the latest version is used. A map of the relevant biodiversity
information (including an indication of the habitat conditions as per (b) below) and must be provided
as an overlay map to the property/site plan as an appendix to this form.
5.1 VEGETATION AND/OR GROUNDCOVER (PRE-COMMENCEMENT)
Cross out (“⌧”) the block and describe (where applicable) the vegetation types / groundcover
present on the site before commencement of the activity.
Indigenous Vegetation -
good condition – See
below.
YES
Indigenous Vegetation
with scattered aliens
NO
Indigenous Vegetation with
heavy alien infestation
NO
NOTE The following section only reports on habitat and vegetation-related features that are actually
present at the ‘Koensrust’ tented camp, which therefore excludes phenomena such as are soil, sports
fields and paved surfaces.
Vegetation types present prior to commencement
The fine-scale vegetation map for the Riversdale conservation planning domain (Vlok and De
Villiers, 2007; Maree and Vromans, 2010) indicates that a thicket-fynbos mosaic occurs in the area,
namely Vermaaklikheid Thicket-Limestone Fynbos. The tented camp is exclusively located in a
thicket clump (i.e. the fynbos element of this vegetation type is not locally present).
The Vegetation Map for South Africa, Lesotho and Swaziland (Mucina et al., (eds), 2005), which
depicts vegetation types at a much smaller scale (1:1 000 000) than the 1:50 000 biodiversity sector
plan for the Mossel Bay and Hessequa municipalites (Maree and Vromans, 2010), places the site on
a boundary between Eastern Rûens Shale Renosterveld and Cape Coastal Lagoons.
Ground-truthing by the botanical specialist, Jan Vlok, found that the national vegetation map had,
in fact, erred and that the site did not support renosterveld, but the aforementioned thicket-fynbos
mosaic (see the botanical assessment, Appendix G, as well as photographs in Appendix C of the
habitat and vegetation that occur at the site). The immediate environs of the site that was used to
develop the tented camp would have comprised, at most, about 1 350 m 2 of the thicket-limestone
fynbos vegetation type. The developable area is probably considerably less than this owing to the
proximity of the river and a steep slope directly to the south.
The camp is situated about 10 or 12 m from the edge of salt marsh component of the Duiwenhoks
River estuarine wetland. The National Water Act 36 of 1998 (section 1, ‘Definitions’) defines an
‘estuary’ as a “partially or fully enclosed body of water... which is open to the sea permanently or
periodically... and within which the sea water can be diluted, to an extent that is measurable, with
fresh water drained from land....” The tented camp is located above the terrestrial margin of the salt
marsh, in a fynbos-thicket mosaic; No activities therefore took place in an estuary as defined above.
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NEMA SECTION 24G EIA REPORT
Ecosystem status of affected vegetation
Eastern Rûens Shale Renosterveld is classified as Critically Endangered and Cape Coastal Lagoons
as not threatened by the national list of threatened ecosystems and ecosystems in need of
protection (DEA, 2011). This list has been gazetted in terms of section 52 of the NEM: Biodiversity Act
10 of 2004 and may therefore serve as a formal trigger for an application for environmental
authorisation in terms of Listing Notice 3 of the 2010 NEMA EIA regulations.
However, as previously noted, the national vegetation map edited by Mucina et al. (2005) has
incorrectly depicted the site as supporting renosterveld whereas, in fact, it supports a matrix of
limestone fynbos interspersed with discreet clumps of thicket. Neither of the vegetation units that
comprise this mosaic is threatened (Vlok 2013, Appendix G). Also see the Draft EMP, Appendix H, for
excerpts from the respective vegetation maps that support the conclusions of the botanist.
The ‘Koensrust’ tented camp is located exclusively in the thicket component of the Vermaaklikheid
Thicket-Limestone Fynbos mosaic, which is not threatened.
Ecological corridors and soil boundaries
The tented camp is located on the left bank of the Duiwenhoks River, about 5 km upstream from the
estuary. The river, tidal wetlands and riparian vegetation would form part of an important subregional
ecological corridor.
Cultivated land
There is a grassed area of some 2 300 m 2 which lies directly to the north of the shed on the site. This
lawn, which slopes relatively gently towards the river, is bounded by a kloof at its upper end which
contains an old earth dam that captures spring water from a local seep emerging from the
surrounding limestone. It is believe that this area may have been previously planted with
vegetables, which would explain the presence of the dam.
Building or other structure
The wooden, single-storey shed on the site, which serves as a boathouse, and storage and sleeping
space, was built in the 1990s. It has a floor area of about 95 m 2 and is about 20 m from the edge of
the salt marsh.
Distinctive soil conditions
The surrounds of the tented camp are dominated by cliffs and outcrops of limestone which, when
weathered, would produce alkaline soils with an elevated pH. Sediments in the river comprise mud
and sand, subject to alternating processes of erosion and deposition, fluctuating water levels (tides,
floods and droughts) and potentially wide ranges in salinity (Whitfield and Lubke, 1998). The salt
marsh component of the Duiwenhoks estuary has not been affected by the establishment of the
tented camp.
Veld dominated by alien species
According to the project botanist, the owners of the ‘Koensrust’ property have taken “exceptional”
measures to eradicate alien plants and maintain a “superb” fire management programme (Vlok
2013, p 7: Appendix G). Following the eradication of alien plants in the vicinity of the tented camp,
the natural spring has started producing so much water that there is an overflow from the earth
dam into the Duiwenhoks River. Overall, according to Mr Vlok ‘Koensrust’ “is an exemplary private
nature reserve” (Vlok 2013, p 7: Appendix G).
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NEMA SECTION 24G EIA REPORT
(a) Highlight the applicable pre-commencement biodiversity planning categories of all areas on site
and indicate the reason(s) provided in the biodiversity plan for the selection of the specific area as
part of the specific category.
Systematic Biodiversity Planning Category
If CBA or ESA, indicate the reason(s) for its selection
in biodiversity plan
The area in question is depicted as a buffer of an
aquatic CBA selected due to the potential
presence of seeps (there is a seep, which provides
water for the property, about 100 m to the southeast).
The adjacent channel and salt marsh/floodplain of
the Duiwenhoks River are depicted as a terrestrial
CBA in a mostly natural or near-natural condition. A
vegetation clump directly to the north of the
grassed area described above is also designated as
Critical
Biodiversity
Area
(CBA)
Ecological
Support
Area
(ESA)
Other
Natural
Area
(ONA)
No
Natural
Area
Remaining
(NNR)
a terrestrial CBA. Although located within the broad
precincts of the ‘Koensrust’ tented camp, these
thicket clumps were not affected by the tented
camp.
The CBAs in question were e selected on the
following grounds:
−
Criteria1: Vegetation type threshold
−
Criteria2: Edaphic interface
−
Criteria3: Significant wetland cluster
− Criteria4: Critically Endangered and
Endangered vegetation remnant
Criteria 4 is Not applicable owing to the incorrect
identification of vegetation – See 5.1 above,
‘Vegetation types’.
(b) Highlight and describe the habitat condition on site.
NOTE The ‘site’ has been defined as that portion of the ‘Koensrust’ terrain next to the Duiwenhoks River
that, hypothetically, could be developable. The area thus selected is defined by a notional 32 m
setback from the river, property boundaries and lawn. It excludes the milkwood thicket east of the
lawn. This leaves an area of about 3 440 m 2 , but probably considerably less if surveyed. About 40% of
this area (1 350 m 2 ) supported thicket, west of the shed. Previous use of the area now occupied by the
tented camp included the laying of a water pipe from the Oshoek kloof to Kleinfontein about 1.5 km
south-west of the ‘Koensrust’ camp site and, more recently, clearing the site of aliens, and picknicking
and braaing. The vegetation here had, consequently, been disturbed when the development
commenced but could still be considered to be in a ‘near natural’ condition compared to what had
prevailed previously. The lawn supports no indigenous vegetation.
S24GEIAR/07/2012 14

Habitat Condition
Percentage
of habitat
condition
class (adding
up to 100%)
NEMA SECTION 24G EIA REPORT
Description and additional Comments and
Observations
(including additional insight into condition, e.g. poor
land management practises, presence of quarries,
grazing/harvesting regimes etc).
Natural 0%
Near Natural
(includes areas with low to
moderate level of alien
invasive plants)
Degraded
(includes areas heavily
invaded by alien plants)
Transformed
(includes cultivation, dams,
urban, plantation, roads, etc)
40 % See above.
0%
60% See above.
(c) Complete the table to indicate:
(i) the type of vegetation, including its ecosystem status, that was previously present on the site;
and
(ii) whether an aquatic ecosystem was previously present on site.
Terrestrial Ecosystems
Ecosystem threat status as per the
National Environmental
Management: Biodiversity Act
(Act No. 10 of 2004)
Critically
Endangered
Endangered
Vulnerable
Least
Threatened
Aquatic Ecosystems
Wetland (including
rivers, depressions,
channelled and
unchanneled Estuary Coastline
wetlands, flats, seeps
pans, and artificial
wetlands)
YES NO
UN-
SURE
YES NO YES NO
(d) Please provide a description of the vegetation type and/or aquatic ecosystem present on site,
including any important biodiversity features/information identified on site (e.g. threatened species
and special habitats)
Please refer to the discussion above at section 5.1 of indigenous vegetation that occurs on the site,
and its ecosystem status. The site is situated within a mosaic of Vermaaklikheid Thicket-Limestone
Fynbos, not Eastern Rûen Shale Renosterveld (CR) as depicted the national vegetation map. Only the
thicket component of the former vegetation type was affected the construction of the tented camp.
This vegetation type is not classified as a threatened ecosystem.
S24GEIAR/07/2012 15

5.2 VEGETATION AND/OR GROUNDCOVER (POST-COMMENCEMENT)
NEMA SECTION 24G EIA REPORT
Cross out (“⌧”) the block and describe (where required) the vegetation types / groundcover present
on the site after commencement of the activity.
Indigenous Vegetation -
good condition – See
below.
YES
Indigenous Vegetation
with scattered aliens
NO
Indigenous Vegetation
with heavy alien infestation
NO
Vegetation types, after commencement
See above, section 5.1, for details about the extant vegetation type and its identification. At most,
250 m 2 of indigenous thicket vegetation was cleared to allow the establishment of the tented
camp. This represents about 18.5% of the thicket-limestone fynbos (1 350 m 2 ) that surrounds the site.
It would represent an infinitesimal percentage of the total occurrence of the vegetation type
described as Vermaaklikheid Thicket-Limestone Fynbos.
Ecosystem status of affected vegetation
Not threatened.
Ecological corridors and soil boundaries
See above. The botanical assessment (Vlok 2013, Appendix G) found that the removal of 250 m 2 of
non-threatened thicket would not have a measurable impact on landscape-scale ecological
processes. The development did not intrude into saltmarsh or floodplain vegetation. It would also
not have an impact on fire regimes as the surrounding vegetation was non-flammable thicket –
unlike, for example, fynbos which depends on fire to stimulate recruitment and retain species
richness (De Villiers et al., 2005, p 22).
Cultivated land
As above. The grassed area was not affected by the development.
Building or other structure
As above.
Distinctive soil conditions
As above.
Veld dominated by alien species
As above.
S24GEIAR/07/2012 16

(a) Highlight and describe the post-construction habitat condition on site.
NEMA SECTION 24G EIA REPORT
Habitat Condition
Percentage
of habitat
condition
class (adding
up to 100%)
Description and additional comments and bbservations
(including additional insight into condition, e.g. poor land
management practises, presence of quarries,
grazing/harvesting regimes etc).
Natural 0%
Near Natural
(includes areas with low to
moderate level of alien
invasive plants)
Degraded
(includes areas heavily
invaded by alien plants)
Transformed
(includes cultivation, dams,
urban, plantation, roads, etc)
32 %
0%
68%
The establishment of the tented camp reduced the extent of
relatively intact, near natural, thicket by 250 m 2 or 18.5% (i.e.
eight percent of the potentially developable area as outlined
above).
The establishment of the tented camp increased the
transformed component of the 3 440 m 2 developable area by
eight percent.
(b) How have the vegetation and/or aquatic ecosystem(s) present on site (including any
important biodiversity features identified on site (e.g. threatened species and special habitats)) been
affected by the commencement of the listed activity(ies)
The main findings of the botanist (see Vlok 2013; Appendix E) were that:
−
−
−
−
−
−
−
−
The tented camp was established in a non-threatened vegetation type;
There were no rare or threatened plant species present;
The removal of a maximum of 250 m 2 of thicket vegetation would not impact on the
functioning of landscape-scale ecological processes;
Fire management would not be affected as the vegetation was not fire-dependent;
The development did not have a direct impact on the Duiwenhoks River or floodplain
vegetation;
There was no indication that the indigenous vegetation at the existing slipway and jetty had
been recently degraded;
The property was well-managed with respect to invasive alien plants and fire; and, overall
It was highly unlikely that the expanded resort facility would contribute to environmental
degradation.
It can be concluded that the commencement of the unauthorised development of the tented
camp at ‘Koensrust’ has not had an adverse effect on any important biodiversity features, whether
locally, at a landscape scale or regionally. Neither would the camp contribute to environmental
degradation if the current type and standard of veld management were to be maintained.
S24GEIAR/07/2012 17

NEMA SECTION 24G EIA REPORT
5.3 VEGETATION / GROUNDCOVER MANAGEMENT
(a) Describe any mitigation/management measures that were adopted and the adequacy of these:
The owners of the ‘Koensrust’ property have taken “exceptional measures” to eradicate alien
vegetation and continue to maintain a “superb” fire management programme for the 964 ha
‘Koensrust’ farm (Vlok 2013, p 7; Appendix E). The Applicant remains committed to continuing these
programmes which are actively aimed at ecological rehabilitation of this coastal/estuarine
property. In fact, roughly a quarter of the farm constitutes CBAs (cf. Maree and Vromans, 2010)
which are subject to the management interventions outlined above.
6. LAND USE OF THE SITE (PRE-COMMENCEMENT)
Please note: The Department may request specialist input/studies depending on the nature of the land
use character of the area and potential impact(s) of the activity/ies.
Untransformed
Low density
Medium density
High density
Informal
area
residential
residential
residential
residential
Retail
Commercial &
warehousing
Light industrial
Medium industrial
Heavy
industrial
Power station
Office/consultin
g room
Military or police
base/station/compoun
d
Casino/entertainmen
t complex
Tourism &
Hospitality
facility
Open cast mine
Underground
mine
Spoil heap or slimes
dam
Quarry, sand or
borrow pit
Dam or
reservoir
Hospital/medic
al center
School
Tertiary education
facility
Church
Old age home
Sewage
treatment plant
Train station or
shunting yard
Railway line
Major road (4 lanes
or more)
Airport
Harbour Sport facilities Golf course Polo fields Filling station
Landfill or waste
treatment site
Mountain,
koppie or ridge
Other land uses
(describe):
Agriculture
Nature
River, stream or
Plantation
conservation
wetland
(historically)
area
Archaeologic
Museum Historical building Graveyard
al site
The site in question falls within the broader ‘Koensrust’ farm which is managed for
recreational and biodiversity purposes. The unauthorised activities took place in an
area over a water pipeline, and which has been used informally for picnicking and
camping since the early 1980s. The grassed area immediately adjacent to the site
was previously used for vegetable farming. The estuary of the Duiwenhoks River
defines the western boundary of the property.
S24GEIAR/07/2012 18

NEMA SECTION 24G EIA REPORT
(a) Please provide a description.
The riverside campsite at ‘Koensrust’ has been in private use since the early 1980s. Most of the
development on the property took place in the mid-to late 1990s. Infrastructure and facilities
established in this period included an access road, jetty, a wooden shed and gazebo, a slipway and
a pit Iatrine which is located behind the shed, about 50 m from the upper margin of the salt marsh.
The jetty, slipway and upgraded road were authorised by Cape Nature Conservation on 30
September 1998 in terms of the former Environment Conservation Act 73 of 1989 – see Section A(6),
‘Applicable legislation, policies and guidelines’. A copy of the record of decision with the reference
number 25/4/100(2886) is included in Appendix E.
Previously, about 2 300 m 2 of the property at the base of the local limestone scarp seems to have
been cleared for agricultural purposes (apparently vegetables were cultivated) and an earth dam is
still visible at the north-eastern extremity of this open grassed area. The dam is fed naturally by a seep
and provides water for domestic use. Water is filtered by an informal system of two 500 litre settling
tanks before flowing into a single, 2 500 litre tank, which supplies the campsite with potable water.
The property has been cleared of invasive alien plants – including dense stands of rooikrans Acacia
cyclops and Spanish reed Arundo donax, which previously infested the dam. Alien management is
ongoing, and appears to be very effective. The area occupied by the shed and newly-built tented
camp had also previously been under aliens, which have been removed.
A water pipeline, which conveys water from the Oshoek kloof to Kleinfontein about 1.5 km to the
south-west of the ‘Koensrust’ campsite, crosses the lower-lying parts of the ‘Koensrust’ property. The
pipeline servitude runs directly adjacent to the shed and through the area where wooden decking
was installed between September 2010 and November 2011.
It is the latter infrastructure and, potentially, three furnished tents that are the subject of this
application.
According to the Applicant, less than 250 m 2 of vegetation was cleared to establish the decking,
which forms a veranda on the riverside aspect of the shed and extends to the south (i.e. seawards)
for about 30 m. The total area of decking amounts to 127 m 2 . The deck houses an open ‘braai’ area
just south of the shed and supports three canvas tents arranged in a row to the south. The tents are
equipped with basic furnishings. There are four single beds in the tent closest to the shed, and a
double bed in each of the remaining tents.
This additional infrastructure covers an area of some 300 m 2 in extent. There is another sunken ‘braai’
place on the ground to the west of the decking.
The shed and tented camp are on raised ground that is separated from the terrestrial margin of the
estuary by a distinct slope some 1.5 m in height and therefore do not intrude into estuarine habitat.
7. LAND USE CHARACTER OF SURROUNDING AREA (PRE-COMMENCEMENT)
Cross out (“⌧”) the block that reflects the past land uses and/or prominent features that occur/red
within +/- 500m radius of the site and neighbouring properties if these are located beyond 500m of the
site. Please note: The Department may request specialist input/studies depending on the nature of the
land use character of the area and impact(s) of the activity/ies.
S24GEIAR/07/2012 19

NEMA SECTION 24G EIA REPORT
Untransformed
area
Retail
Power station
Open cast mine
Hospital/medic
al center
Sewage
treatment plant
Harbour
Low density
residential
Medium density
residential
High density
residential
Informal
residential
Commercial &
Heavy
Light industrial Medium industrial
warehousing
industrial
Military or police
Tourism &
Office/consultin
Casino/entertainmen
base/station/compoun
Hospitality
g room
t complex
d
facility
Underground Spoil heap or slimes Quarry, sand or Dam or
mine
dam
borrow pit
reservoir
School
Tertiary education
facility
Church Old age home
Train station or
Major road (4 lanes
Railway line
shunting yard
or more)
Airport
Sport facilities Golf course Polo fields Filling station
Landfill or waste
treatment site
Mountain,
koppie or ridge
Plantation
Agriculture
River, stream or
wetland
Museum Historical building Graveyard
Nature
conservation
area
Archaeologic
al site
Other land uses
(describe):
The ‘Koensrust’ farms encapsulates significant components of three of the major
natural environmental features that define the topography and character of the
coastline between Cape Infanta and the mouth of the Gourits River: the Indian
Ocean coastline and its characteristic half-heart bays; promontories and sandy
beaches; hilly coastal limestone forelands that delineate the coastline from the
intensively farmed Rûens and Riversdale plain; and deeply incised river valleys that,
in the case of the Duiwenhoks River, enters the sea via a permanently open estuary
at Puntje. This is a largely undeveloped landscape with a strongly defined and
regionally specific rural character.
8. LAND USE CHARACTER OF SURROUNDING AREA (POST-COMMENCEMENT)
Cross out (“⌧”) the block that reflects the current land uses and/or prominent features that occur(s)
within +/- 500m radius of the site and neighbouring properties if these are located beyond 500m of the
site. Please note: The Department may request specialist input/studies depending on the nature of the
land use character of the area and impact(s) of the activity/ies.
Untransformed
Low density
Medium density
High density
Informal
area
residential
residential
residential
residential
Retail
Commercial &
warehousing
Light industrial
Medium industrial
Heavy
industrial
Power station
Office/consultin
g room
Military or police
base/station/compoun
d
Casino/entertainmen
t complex
Tourism &
Hospitality
facility
Open cast mine
Underground
mine
Spoil heap or slimes
dam
Quarry, sand or
borrow pit
Dam or
reservoir
S24GEIAR/07/2012 20

NEMA SECTION 24G EIA REPORT
Hospital/medic
al center
Sewage
treatment plant
Harbour
Landfill or waste
treatment site
Mountain,
koppie or ridge
Other land uses
(describe):
Tertiary education
School
Church Old age home
facility
Train station or
Major road (4 lanes
Railway line
Airport
shunting yard
or more)
Sport facilities Golf course Polo fields Filling station
Nature
River, stream or
Plantation
Agriculture
conservation
wetland
area
Archaeologic
Museum Historical building Graveyard
al site
Please see above. The unauthorised development of the ‘Koensrust’ tented camp
has had no evident impact on the land-use character of the surrounding area.
S24GEIAR/07/2012 21

NEMA SECTION 24G EIA REPORT
SECTION C: PUBLIC PARTICIPATION
Please highlight the appropriate box to indicate whether the specific requirement will be undertaken or
whether deviation from such a requirement has been requested.
Has any public participation been done prior to this application, which the
Applicant/EAP feels can be considered to have fulfilled the requirements
outlined in the NEMA EIA Regulations, 2010
Please provide a description.
YES
NO
As indicated above at section A(6), the owners of the farm ‘Koensrust’ 502 have submitted a
departure application in terms of section 15 of the Land Use Planning Ordinance 15 of 1985 (LUPO) to
the Hessequa Municipality. The Applicant has indicated that it wishes to develop overnight tourism
facilities in an area of 1 500 m 2 . The application was advertised for comment on 17 August 2012. The
Hessequa Municipality has decided to withhold a decision on the departure application until the
NEMA process has been concluded (pers comm., Ms Jeanne Fourie, Town and Regional Planner,
Hessequa Municipality, 8 January 2013).
The Duiwenhoks Conservancy has objected to the application (letter to the Municipal Manager of
the Hessequa Municipality, 28 September 2012) on the grounds that: the intended use is not clear,
which may affect the zoning of the land; the existing tented camp on the property was potentially
illegal in terms of the NEMA EIA regulations; and there was a risk that domestic effluent could pollute
the Duiwehoks River.
CapeNature has also commented on the LUPO application (14-09-2012). In summary, CapeNature
stated that: the Applicant would have to enter a stewardship agreement with CapeNature if it
intended rezoning the land to Open Space 3; the tented camp had not been authorised in terms of
the NEMA EIA regulations and was therefore illegal; and the existing pit latrine had to be replaced
with a composting toilet or small bore sewerage plant (a ‘long drop’ and septic or conservancy
tanks were ‘not acceptable’).
Which State Departments were consulted
The LUPO application was made to the Hessequa Municipality. CapeNature submitted comment.
Details of Public Participation to be conducted in terms of the NEMA EIA Regulations, 2010:
1. Will all potential interested and affected parties be notified of the application by –
(a) fixing a notice board at a place conspicuous to the public at the boundary or on the fence of -
(i) the site where the activity to which the application relates is to be
DEVI-
YES NO
undertaken; and
ATION
DEVI-
(ii) any alternative site mentioned in the application; YES NO
ATION
(b) giving written notice to –
(i) the owner or person in control of that land if the applicant is not the
DEVI-
YES NO
owner or person in control of the land;
ATION
(ii) the occupiers of the site where the activity is to be undertaken and to
DEVI-
YES NO
any alternative site where the activity is to be undertaken;
ATION
(iii) owners and occupiers of land adjacent to the site where the activity is
DEVto
be undertaken and to any alternative site where the activity is to be YES NO
IATION
undertaken;
(iv) the municipal councillor of the ward in which the site and alternative
DEVsite
is situated and any organisation of ratepayers that represent the YES NO
IATION
community in the area;
S24GEIAR/07/2012 22

NEMA SECTION 24G EIA REPORT
(v) the municipality which has jurisdiction in the area; YES NO
(vi) any organ of state having jurisdiction in respect of any aspect of the
activity; and
YES NO
(vii) any other party as required by the competent authority; YES NO
(c) placing an advertisement in -
(i) one local newspaper; and
YES NO
(ii) any official Gazette that is published specifically for the purpose of
providing public notice of applications or other submissions made in YES NO
terms of these Regulations;
(d) placing an advertisement in at least one provincial newspaper or
national newspaper, if the activity has or may have an impact that
extends beyond the boundaries of the metropolitan or local municipality
YES NO
in which it is or will be undertaken.
DEVI-
ATION
DEVI-
ATION
DEVI-
ATION
DEVI-
ATION
DEVI-
ATION
DEVI-
ATION
NOTE The deviations are being sought in terms of sub-regulation 54(5) of GN R. 543 of 18 June 2010. The
respective deviations are motivated on the following grounds:
1(a)(ii)
1(b)(i)
1(b)(ii)
1(c)(ii)
1(d)
This application applies to a single site within the property ‘Koensrust’ 502 in the Riversdale
district. No alternative sites have therefore been contemplated.
The applicant is the owner of the land.
The applicant is the sole occupier of the site.
The impacts associated with the unauthorised activities in question are confined to the
boundaries of the Hessequa Local Municipality, which obviates the need to publicise the
application in an official Gazette.
As above. The application is confined to the boundaries of a local municipality.
2. What other Public Participation will be done
A preliminary, 21-day round of public participation was initiated, as a form of voluntary scoping, on 5
March 2013 with the distribution, by means of registered post, of a background information document
and invitation to addressees to register as interested and affected parties (see Appendix F). The
Duiwenhoks and Blombos conservancies registered as I&APs. Dr Charlie Boucher, of Puntjie, also asked
to be registered. No other responses were received. However, the Hessequa Municipality and
CapeNature’s Conservation Services Manager for the Hessequa section of the Garden Route business
unit, were approached individually for information pertaining to the unauthorised development at
‘Koensrust’, which is reflected above.
3. Provide a list of all the state departments that has been / will be consulted:
The following state departments have been notified of the application, and will be retained as
registered I&APs throughout the process:
−
−
−
−
−
CapeNature (Land-use Advisory Unit, George)
Hessequa Local Municipality
Eden District Municipality
Department of Water Affairs
Western Cape Department of Agriculture (LandCare Manager: Eden District).
S24GEIAR/07/2012 23

NEMA SECTION 24G EIA REPORT
Please note:
• A list of all the potential interested and affected parties, including the organs of State must be
opened, maintained and made available to any person requesting access to the register, in
writing.
• All comments of interested and affected parties on the Application Form and Additional
Information must be recorded, responded to and included in the Comments and Responses Report
attached as Appendix F to the report. The Comments and Responses Report must also include a
description of the Public Participation Process followed.
• The minutes of any meetings held by the EAP with interested and affected parties and other role
players which record the views of the participants must also be submitted as part of the public
participation information to be attached to the additional information/Environmental Impact
Report as Appendix F.
• Proof of all the notices given as indicated, as well as of notice to the interested and affected
parties of the availability of the draft Environmental Impact Report/Additional Information must be
submitted as part of the public participation information to be attached to the report as Appendix
F.
• Please be advised that the draft Environmental Impact Report/Additional Information must first be
submitted to the Department where-after it must be made available to the public and all State
Departments that administer laws relating to a matter affecting the environment for comment for a
period of 40 days. The applicant/EAP is required to inform this Department in writing upon
submission of the draft Environmental Impact Report/Additional Information to the relevant State
Departments. Upon receipt of this confirmation, this Department will in accordance with Section 24
O (2) & (3) of the NEMA inform the relevant State Departments of the commencement date of the
40 day commenting period or 60 days in the case of the Department of Water Affairs for waste
management activities which also require a license in terms of the National Water Act, 1998 (Act
No. 36 of 1998). Please be further advised that a commenting period of 21 days will apply to all
requests for comment on any information, documentation or reports (including the final
Environmental Impact Report/Additional Information) other than the draft report, unless an
alternative commenting period is specified by this Department.
S24GEIAR/07/2012 24

NEMA SECTION 24G EIA REPORT
SECTION D: NEED AND DESIRABILITY
Please Note: Before completing this section, first consult this Department’s Guideline on Need and
Desirability (October 2011f) available on the Department’s website
(http://www.capegateway.gov.za/eadp).
1. Was the activity permitted in terms of the property’s land use
rights at the time of commencement
YES NO Please explain
The property is apparently zoned as ‘Agriculture Zone I’, which permits ‘tourist facilities’ as a consent
use. This means that overnight facilities cannot be developed on such land until a formal departure
has been agreed to as a ‘consent use’ by the relevant municipal council which, in this case, would
be the Hessequa Municipality (applications for departures are regulated by section 15 of the LUPO
15/1985). However, the tented would appear to be legal under LUPO if it is only used for personal
purposes.
2. Was the activity in line with the following
(a) Provincial Spatial Development Framework (PSDF) YES NO Please explain
The site on which the activity is located lies outside any urban edge, within the terrestrial buffer of an
aquatic CBA, namely the Duiwenhoks River and floodplain. The unauthorised development does not
impinge on the latter habitats.
The affected land should be designated as a ‘Core 2’ spatial planning category as it comprises the
mapped buffer area for an aquatic CBA and would contribute to ecological connectivity. The
definitions, purpose and desired land uses for spatial planning categories and their conservation
planning equivalents are set out in the Western Cape Guidelines for Rural Land Use Planning and
Management (DEA&DP, 2009), which were drafted to guide rural land use in terms of the policy
objectives of the Western Cape Provincial Spatial Development Framework.
The unauthorised development would be consistent with the PSDF insofar as it is fully compatible with
the recommended land uses for ‘Core 1’ (CBA) SPCs: it entails low impact overnight
accommodation that meets the key requirements for the appropriate scale and form of such
developments (wooden structures, tents and raised boardwalks).
The broader property is subject to ecological management guidelines that include an effective alien
clearance programme.
(b) Urban edge / Edge of Built environment for the area YES NO Please explain
See above. The activity is located on former farmland at least 3 km from the nearest settlement
(Vermaaklikheid).
(b) Integrated Development Plan and Spatial Development
Framework of the Local Municipality (e.g. would the
approval of this application have compromised the YES NO Please explain
integrity of the existing approved and credible municipal
IDP and SDF).
The SDF for the Hessequa Municipality had not been finalised at the time of writing (April 2013) (pers
comm., Ms Jeanne Fourie, Town and Regional Planner: Hessequa Municipality, 8 April 2013). In the
absence of an approved SDF, this assessment has instead drawn on the Western Cape Guidelines
for Rural Land Use Planning and Management (DEA&DP, 2009) (see above).
S24GEIAR/07/2012 25

NEMA SECTION 24G EIA REPORT
The 2007-2012 IDP for the Hessequa Municipality (Final Draft, 2007; complied by CV Schröder, Deputy
Municipal Manager) notes that the natural environment and beauty of the municipality holds
significant potential for unlocking sustainable business and development opportunities through
tourism.
For example, the IDP reports favourably on sustainable nature-based tourism and an alternative to
more conventional tourism models (paragraph 3.3.2). The IDP also reflects its emphasis on
“developmental tourism” (p 34) that includes people previously excluded from tourism businesses
and promotes the sourcing of goods and services from local suppliers.
The lack of tourist attractions and public camping facilities at Vermaaklikheid are flagged for
attention in the IDP.
(d) Approved Structure Plan of the Municipality YES NO Please explain
The Western Cape Department of Environmental Affairs and Development Planning on 25 June 2012
gave notice that the former, 1991 guide plan for the Mossel Bay and Riversdale municipalities, was to
be withdrawn. The Hessequa Municipality consequently does not have approved urban and
regional structure plan in place ((pers. comm., Ms Jeanne Fourie, Town and Regional Planner:
Hessequa Municipality, 8 April 2013).
(e) An Environmental Management Framework (EMF) adopted by
the Department
(e.g. Would the approval of this application have compromised
the integrity of the existing environmental management priorities
YES NO Please explain
for the area and if so, can it be justified in terms of sustainability
considerations)
Not applicable: there is not an approved EMF that applies to the area in question.
(f) Any other Plans (e.g. Guide Plan) YES NO Please explain
Not applicable; please see D(2)(d) above.
3. Was the land use (associated with the activity for which
rectification is sought) considered within the timeframe
intended by the existing approved Spatial Development
Framework (SDF) agreed to by the relevant environmental
authority (i.e. was the development in line with the projects
and programmes identified as priorities within the relevant
IDP)
YES NO Please explain
Uncertain. There is not an approved SDF in place for the Hessequa Municipality, although the
unauthorised development would seem to be consistent with the provincial rural land-use planning
and management guidelines (2009).
4. Should development, or if applicable, expansion of the
town/area concerned in terms of this land use (associated
with the activity being applied for) have occurred here when
activities commenced
YES NO Please explain
‘Need’ is understood to mean requiring something because it is essential or very important, and
not just desirable. ‘Desirability’, in turn, refers to wanting or wishing for something owing to its
attractiveness, utility or necessity (cf. The New Oxford Dictionary of English, 1998). The DEA&DP
guideline on need and desirability (2010) suggests that ‘need’ refers to the ‘timing’ of a proposed
development, and ‘desirability’ to place. Jointly, the concepts raise critical questions about the
S24GEIAR/07/2012 26

contextual appropriateness of development, and the “wise use of land”.
NEMA SECTION 24G EIA REPORT
Here, the ‘need’ for a proposed development would depend on the degree of social or public
harm that would result from the development not going ahead. ‘Desirability’ can reflect both a
private desire that, if not met, will result in disappointment, as well as a more objective aspect –
namely, would a proposed development be strategically and contextually appropriate
This question is understood to address the desirability of the unauthorised development. It is not
the type of question that readily lends itself to a conclusive, either-or choice. Only a pre-emptive
environmental assessment process, undertaken before the development commenced and at an
appropriate environmental scale, could adequately determine if the location in question was the
most desirable one available from an environmental and strategic planning context. As indicated
above, the Hessequa Municipality currently finds itself in something of a planning vacuum, which
means that that is not really possible to evaluate the desirability of the unauthorised tented camp
in relation to the strategic spatial planning objectives of the municipality.
However, the development would appear to be potentially consistent with the provincial
guidelines for development in ‘Core 2’ SPCs. Its ecological impact is also considered to be within
acceptable bounds. The suitability of the sewerage system has, however, been called into
question.
5. Did the community/area need the activity and the associated
land use concerned (was it a societal priority) (This refers to
the strategic as well as local level (e.g. development is a
national priority, but within a specific local context it could be
inappropriate.)
YES NO Please explain
See above for a definition of ‘need’ insofar as it is applied to the situation at hand. While the
unauthorised development could potentially contribute to local job creation, for example, and help
to meet the recognised need for nature-based tourist accommodation at Vermaaklikheid, this would
be in the balance as long as the legality of the tented camp was called into question. For the
development to meet these two needs (which are considered to be important from a societal
perspective, if a limited scale), the tented camp would have to be ‘regularised’ – within acceptable
environmental parameters – in terms of the laws of the day.
6. Were the necessary services with adequate capacity
available (at the time of commencement), or was
additional capacity created to cater for the development
(Confirmation by the relevant Municipality in this regard must
be attached to the Application Form / additional
information as an appendix, where applicable.)
YES NO Please explain
The capacity of the existing pit latrine to meet the requirements of the unauthorised tented camp
has been questioned by some IA&Ps (see Section C above), and the Applicant has indicated its
willingness to replace the pit latrine with a septic tank (pers. comm., Mr Francois du Plessis, 6 April
2013). The tented camp can, at most, accommodate eight people overnight.
7. Is/was this development provided for in the infrastructure
planning of the municipality, and if not what was/will the
implication be on the infrastructure planning of the
municipality (priority and placement of services and
opportunity costs) (Comment by the relevant Municipality in
YES NO Please explain
S24GEIAR/07/2012 27

NEMA SECTION 24G EIA REPORT
this regard must be attached to the Application Form /
additional information as an appendix, where applicable.)
The area in question is not serviced by the Hessequa Municipality.
8. Was this project part of a national programme to address an
issue of national concern or importance
YES NO Please explain
The project was a private initiative, implemented by the owners of the ‘Koensrust’ property.
9. Did location factors favour this land use (associated with the
activity applied for) at this place (This relates to the
contextualisation of the land use on this site within its broader
context.)
YES NO Please explain
On the face of current provincial planning policy, the interpretation of the applicable biodiversity
sector plan, and the botanical assessment conducted by Mr Jan Vlok (Appendix G), the
unauthorised development would appear to be consistent with its broader land use context.
It also needs to be borne in mind that this part of the ‘Koensrust’ property was farmed previously and
has been used as an informal camp site since at least the 1980s. The site has also been cleared of
invasive alien plants by the current owners who, according to Mr Vlok, maintain a very effective alien
and fire management programme throughout the 964 ha property (the tented camp and its
potentially developable environs account for less than 0.4% of the entire ‘Koensrust’ property).
In short, the site already has a long-standing association with recreational use that is intimiately
bound to its proximity to the Duiwenhoks River. The major functional draw cards and enabling factors
in this regard – the access road, jetty and slipway – have been officially authorised, and limited
development that capitalises on these assets would seem to be a logical and reasonable
progression from the perspective of the Applicant. Such development would, of course, have to be
within acceptable limits of environmental change.
10. How did/does the activity or the land use associated with the
activity applied for, impact on sensitive natural and cultural
areas (built and rural/natural environment)
YES NO Please explain
Impacts arising from the unauthorised development of the tented camp at ‘Koensrust’ were
exclusively confined to the biophysical environment. Please see section B5.2 above.
In short, the botanical assessment concluded (Vlok 2013, p 7; Appendix G) that it was “highly unlikely
that the expanded resort facility (would) result in the degradation of the affected environment...”.
Indeed, the management of the broader ‘Koensrust’ property was making an active and
demonstrable contribution to the rehabilitation of the natural environment.
The botanical assessment did, however, recommend that the existing ablution facilities at the tented
camp (a pit latrine) should be upgraded to “an environmentally acceptable standard”. This was
also raised as an issue of concern by the Duiwenhoks Conservancy and CapeNature (see Section C
above). If this recommendation were carried out, it would mitigate and outweigh any potential
negative impact arising from the unauthorised construction of the tented camp (Vlok 2013, p 8;
Appendix G).
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NEMA SECTION 24G EIA REPORT
11. How did/does the development impact on people’s health
and wellbeing (e.g. in terms of noise, odours, visual character
and sense of place, etc.)
YES NO Please explain
None of the comments relating to the LUPO application expressed concern about social nuisances
or loss of visual character or ‘sense of place’. There is no evident reason to believe that this is or
would be an issue in future.
12. Did/does the proposed activity or the land use associated
with the activity applied for, result in unacceptable
opportunity costs
YES NO Please explain
The land in question is privately owned and access to the site where the unauthorised tented camp
is situated has been closely controlled for almost three decades. Development and use of the site to
date has therefore not translated into any opportunity costs to the public or any other interest.
13. What were the cumulative impacts (positive and negative)
of the land use associated with the activity applied for
YES NO Please explain
Cumulative impacts are rarely evident or identifiable at the site-specific scale. They also often
manifest themselves over time.
Ecologically, the unauthorised development of the tented camp at ‘Koensrust’ has in its own right
had a negligible impact on non-threatened vegetation, and none that can be measured in terms of
adverse changes to landscale-scale ecological processes. There is also no evidence to date that the
pit latrine on the site has resulted in contamination of the Duiwenhoks River. Overall, the botanical
assessment found that there had been no recent degradation of salt marsh vegetation at either the
jetty or the slipway on the property. In fact, alien and fire management on the property was of a
high standard (see Vlok, 2013; Appendix G).
However, if the Duiwenhoks estuary is viewed as a whole, the additive and synergistic effects of
numerous individual developments such as that at Koensrust may very well translate into
degradation of the affected ecosystem. To confirm this, however, would require a long-term
monitoring programme that is ideally linked to an estuary and land use management plan for
Vermaaklikheid and surrounds (see, for example, the submission on 25 May 2012 by Mr Bernard
Oberholzer to the Duiwenhoks Conservancy with respect to the desirability of a river management
plan, and local spatial development plan, for Vermaaklikheid and environs; this type of initiative is
viewed as both desirable and essential).
It is effectively impossible to identify cumulative impacts that may arise from an individual, smallscale
development. Cumulative impacts can certainly be predicted, but unless monitoring is
conducted at the appropriate functional, spatial and temporal scales, such predictions will be very
generalised and speculative in nature. The utility of identifying and predicting cumulative impacts
from the basis of a site-specific environmental assessment must therefore be questioned.
NOTE CapeNature and the Eden District Municipality are in the process of establishing a stakeholder
forum with the view of developing an estuary management plan for the Duiwenhoks River (pers.
comm., Pierre de Villiers, CapeNature, 8 April 2013). For further information, contact Pierre de Villiers,
co-ordinator of the C.A.P.E. Estuaries Programme at: Ph 021 866-8000; Cell 083 236 2924; e-mail
estuaries@capenature.co.za
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NEMA SECTION 24G EIA REPORT
14. Is/was the development the best practicable environmental
option for this land/site
YES NO Please explain
The ‘best practicable environmental option’ is “the option that provides the most benefit or causes
the least damage to the environment as a whole, at a cost acceptable to society, in the long term
as well as the short term....” (section 1, ‘Definitions’, NEMA 107/1998).
From the Applicant’s perspective, the piece of ground where the tented camp was established
represented a logical and attractive way of enhancing the amenity value of the site without causing
major environmental damage or locating the camp where it would be exposed to the elements and
relatively more visible from the Duiwenhoks River. The material and design of the tented camp are
identical to similar facilities in protected areas. However, unlike protected areas, the site was not
screened beforehand to determine its suitability for a development of this nature.
In the event, the clearance of non-threatened vegetation in order to build the deck amounted to
an impact of ‘very low’ negative significance (see Section 6.2 for the findings of the impact
assessment). The consequences of this impact would be reduced to ‘neutral’ significance if weighed
against the benefits that accrue to local biodiversity from a high standard of alien clearance and fire
management on the remainder of the farm ‘Koensrust’ 502.
If the societal benefits of the unauthorised development are slender, so are the costs. This may well
change for the better if the tented camp can be run as a formal, nature-based tourism destination.
Overall, more would be lost than gained if the camp were to be shut down, demolished and the site
rehabilitated. Environmentally, there would appear to be no evident justification for such a course of
action.
Also, no other, alternative, options that would meet the objectives of a tented camp such as this
have been proposed. In the circumstances the tented camp in its current location represents the
best practicable environmental option for enhancing the amenity value of the Duiwenhoks precinct
of the farm ‘Koensrust’ 502 at an acceptable environmental cost.
15. What are/were the benefits to society in general and to the local communities Please explain
The establishment of a tented camp that can house eight people overnight may contribute to two
new jobs, depending on occupation rates. The socio-economic impact would be slight, but not
unimportant for potential beneficiaries of such employment. More broadly, the facility could
potentially contribute to the attraction of Vermaaklikheid as a destination for nature-based tourism.
This would be in line with the development goals of the Hessequa Municipality and, if managed
according to the principles of ‘touch the earth lightly’ – as advocated by the provincial land-use
planning and management guidelines – the development would be a regional asset.
16. Any other need and desirability considerations related to the activity Please explain
There are no other readily-evident considerations relating to the need and desirability for the activity.
17. Please describe how the general objectives of Integrated Environmental Management as set out
in section 23 of NEMA were taken into account:
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NEMA SECTION 24G EIA REPORT
In summary, the general
objectives of IEM state the
environmental management
must:
How the general objectives of IEM were taken into account in the
development of the tented camp at ‘Koensrust’
−
Promote the integration
of the National
Environmental
Management (NEM)
Principles (i.e section 2,
NEMA 107/1998) with all
decisions which may
have a significant effect
on the environment
This objective applies to organs of state whose decisions would be
informed inter alia by the appropriate form of environmental inquiry
as prescribed by the NEMA EIA regulations. No environmental
assessment was undertaken prior to the unauthorised development
of the tented camp at ‘Koensrust’.
− Identify, predict and
evaluate potential
impacts on the
environment by
adhering to the
mitigation hierarchy so
as to minimise negative
impacts, maximise
benefits and promoting
compliance with the
NEM Principles
Although the development was not preceded by an environmental
assessment, its footprint was confined to an area not exceeding 300
m 2 , and it is well-integrated with existing facilities at the site. A
maximum of 250 m 2 of non-threatened vegetation was cleared to
make way for a wooden deck and tented camp that carry the
hallmarks of numerous such facilities in protected areas.
−
Ensure that the effects of
activities on the
environment are
adequately considered
before actions are taken
in connection with them
As above. Although the prescribed basic assessment process was
not undertaken prior the unauthorised development, which renders it
illegal in terms of the NEMA 107/1998, the effect of the development
would potentially be consistent with the findings and
recommendations of a pre-emptive environmental assessment.
− Ensure adequate and
appropriate opportunity
for public participation in
decisions that may
affect the environment
No public participation, other than that required by the LUPO
application process, was undertaken prior to the development of the
tented camp.
−
Ensure the consideration
of environmental
attributes
in
management and
decision-making which
may have a significant
effect on the
environment
The Applicant recognises the desirability of upgrading the existing
sewerage system to an environmentally-acceptable standard. The
Applicant has also demonstrated a practical commitment to
responsible environmental management through its long-standing
implementation of alien clearance and fire managements
programmes for the entire ‘Koensrust’ farm.
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NEMA SECTION 24G EIA REPORT
−
Identify and employ the
modes of environmental
management that are
best suited for ensuring
specific activities are
consistent with the NEM
Principles.
The prescribed basic assessment process applied to the
development in question. It was not pursued. However, key aspects
of the NEM Principles relating to particularly the management and
care of biodiversity are being enforced on an ongoing basis. This is
reflected in the botanist’s findings that the farm ‘Koensrust’ 502 is “an
exemplary private nature reserve” (Vlok 2013, p 7; Appendix G).
18. Please describe how the principles of environmental management as set out in section 2 of
NEMA were taken into account:
The national environmental management
principles must guide the actions of organs of
state whose decisions may significantly affect the
environment. They also provide guidance as to
what constitutes ‘sustainable development’
which emphasises the primacy of human needs
in environmental management. The principles
that are of particular relevance to this
application are those that require that
environmental management must:
Consistency of the unauthorised ‘Koensrust’
development with the national environmental
management principles.
−
Avoid, minimise or remedy disturbance of
ecosystems and loss of biodiversity
The unauthorised development of the tented
camp resulted in the loss of, at most, 250 m 2 of a
non-threatened vegetation type. Although the
loss of biodiversity was not avoided, it was
effectively minimised by the scale of the impact
and the non-threatened status of the affected
vegetation.
− Avoid degradation of the environment The development resulted in some loss of
vegetation, but would not contribute to the
degradation of the broader environment of the
‘Koensrust’ tented camp which, in the view of
the botanical assessment, was very well
managed from a biodiversity perspective.
− Avoid jeopardising ecosystem integrity The botanical assessment found that the removal
of indigenous vegetation in order to established
the tented camp at ‘Koensrust’ would not have
an impact on landscape-scale ecological
processes or the nearby Duiwenhoks River and
estuarine wetlands.
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NEMA SECTION 24G EIA REPORT
−
−
−
Pursue the best practicable environmental
option by means of integrated
environmental management
The participation of all interested and
affected parties in environmental
governance must be promoted
Ensure intergovernmental co-ordination and
harmonisation of policies, legislation and
actions relating to the environment.
It can be argued that this requirement could only
have been met by means of a risk-averse
process of planning and impact assessment. In
the absence of such a process, however, the
establishment of the ‘Koensrust’ tented camp
would appear to have been informed by the
desirability of containing the scale of
development, minimising its environmental
impact, and designing it from a ‘tread lightly’
perspective. All these elements would seem to
be present. Sewage management is the single
major outstanding issue.
Interested and affected parties were not
afforded the opportunity to participate in an
anticipatory and prescribed environmental
assessment process (in this case, a basic
assessment). A departure application to the
Hessequa Municipality i.to. of the LUPO 15/1985
did go through a public participation process,
but this did not obviate the Applicant’s
responsibility with respect to NEMA and the
NEMA EIA regulations and their mandatory
requirements for public participation.
The development of the site was not preceded
by such consultation and co-ordination.
−
Protect the environment as the people’s
common heritage
The Competent Authority will determine if the
unauthorised development at ‘Koensrust’
satisfied this requirement.
− Control and minimise environmental
damage
Regardless of its legal status, the tented camp on
the banks of the Duiwenhoks River at ‘Koensrust’
has demonstrated the Applicant’s de facto
commitment to minimising environmental
damage. The broader property benefits from a
highly effective alien clearance and fire
management programme. The Applicant has
also indicated its willingness to install an
environmentally-appropriate sewerage system
for the tented camp.
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NEMA SECTION 24G EIA REPORT
−
Pay specific attention to management and
planning procedures pertaining to sensitive,
vulnerable, highly dynamic or stressed
ecosystems
Whether the development of the tented camp
as it currently stands would have been
authorised after a basic assessment process is
impossible to predict. The affected terrestrial
ecosystem is not ‘sensitive’ from a biodiversity
pattern perspective, and neither is it vulnerable
to the type and scale of disturbance at
‘Koensrust’, nor highly dynamic nor stressed.
Landscape-scale ecological processes would be
unaffected. The salt marshes associated with the
estuarine wetlands and tidal flats of the
Duiwenhoks River do, however, constitute
dynamic, sensitive and potentially vulnerable
ecosystems which need to be protected against
contamination by sewage and trampling. The
latter would not seem to be of concern at
‘Koensrust’, but extra precaution is necessary to
ensure that the management of human waste
does not hold any risk for water or habitat quality
in the Duiwenhoks system.
8. SOCIO-ECONOMIC CONTEXT
8.1 SOCIO-ECONOMIC CONTEXT (PRE-COMMENCEMENT)
Describe the pre-commencement social and economic characteristics of the community in order to
provide baseline information.
The unauthorised development is confined to the privately-owned ‘Koensrust’ farm, which covers
an extensive limestone plateau and coastal terrain south of Vermaaklikheid. The site subject to this
application is highly inaccessible. Besides the fact that it may not be entered without the permission
of the owners, the tented camp can only be reached by boat or via a very steep track that is
limited to 4 x 4 vehicles. The broader ‘Koensrust’ farm effectively functions as a well-managed
private nature reserve. The farm employs five workers, and the workforce could be expanded
marginally if the tented camp were to be run on a commercial basis. The gate that controls
entrance to the tented camp is about 5 km by road from Vermaaklikheid.
8.2 SOCIO-ECONOMIC CONTEXT (POST-COMMENCEMENT)
Describe the post commencement social and economic characteristics of the community in order to
determine any change. Where differences between pre- and post-commencement exist, state which
are as a result of the activity(ies) for which rectification is being applied for.
The advent of the tented camp means that the ‘Koensrust’ camp site may occasionally host eight
campers. The camp would have a positive socio-economic impact if high levels of occupancy
could be sustained throughout the year. If this is the case, new employment opportunities are likely
to follow.
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NEMA SECTION 24G EIA REPORT
9. HISTORICAL AND CULTURAL ASPECTS
(a) Please be advised that if section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of
1999), is applicable to your development, then you are requested to furnish this Department with
written comment from Heritage Western Cape as part of your public participation process. Section
38 of the Act states as follows: “38. (1) Subject to the provisions of subsections (7), (8) and (9), any
person who intends to undertake a development categorised as-
(a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear
development or barrier exceeding 300m in length;
(b) the construction of a bridge or similar structure exceeding 50m in length;
(i) any development or other activity which will change the character of a site-
(ii) exceeding 5 000 m 2 in extent; or
(iii) involving three or more existing erven or subdivisions thereof; or
(iv) involving three or more erven or divisions thereof which have been consolidated within
the past five years; or
(v) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial
heritage resources authority;
(d) the re-zoning of a site exceeding 10 000 m 2 in extent; or
(e) any other category of development provided for in regulations by SAHRA or a provincial
heritage resources authority,
must at the very earliest stages of initiating such a development, notify the responsible heritage
resources authority and furnish it with details regarding the location, nature and extent of the
proposed development.”
(b) The impact on any national estate referred to in section 3(2), excluding the national estate
contemplated in section 3(2)(i)(vi) and (vii), of the National Heritage Resources Act, 1999 (Act No.
25 of 1999), must also be investigated, assessed and evaluated. Section 3(2) states as follows: “3(2)
Without limiting the generality of subsection (1), the national estate may include—
(a) places, buildings, structures and equipment of cultural significance;
(b) places to which oral traditions are attached or which are associated with living heritage;
(c) historical settlements and townscapes;
(d) landscapes and natural features of cultural significance;
(e) geological sites of scientific or cultural importance;
(f) archaeological and palaeontological sites;
(g) graves and burial grounds, including—
(i) ancestral graves;
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NEMA SECTION 24G EIA REPORT
(ii) royal graves and graves of traditional leaders;
(iii) graves of victims of conflict;
(iv) graves of individuals designated by the Minister by notice in the Gazette;
(v) historical graves and cemeteries; and
(vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act
No. 65 of 1983);
(h) sites of significance relating to the history of slavery in South Africa;
(i) movable objects, including—
(i) objects recovered from the soil or waters of South Africa, including archaeological and
palaeontological objects and material, meteorites and rare geological specimens;
(ii) objects to which oral traditions are attached or which are associated with living heritage;
(iii) ethnographic art and objects;
(iv) military objects;
(v) objects of decorative or fine art;
(vi) objects of scientific or technological interest; and
(vii) books, records, documents, photographic positives and negatives, graphic, film or video
material or sound recordings, excluding those that are public records as defined in section
1(xiv) of the National Archives of South Africa Act, 1996 (Act No. 43 of 1996).”
Is section 38 of the National Heritage Resources Act, 1999, applicable to the
development NOTE None of the ‘triggers’ for impact heritage assessment
and, potentially, permitting in terms of the NHRA 25 of 1999 listed in D(9)(a)
above applies to the ‘Koensrust’ tented camp
If YES,
Not applicable.
explain:
Did/does the development impact on any national estate referred to in
section 3(2) of the National Heritage Resources Act, 1999NOTE None of the
circumstances pertaining to the national estate listed at 9(b) above applies to
the ‘Koensrust’ site.
If YES,
Not applicable.
explain:
Was any building or structure older than 60 years affected in any
YES
way
If YES,
Not applicable.
explain:
YES NO
UNCERTAIN
YES NO
UNCERTAIN
UN-
NO
CERTAIN
Please Note: If uncertain, the Department may request that specialist input be provided.
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NEMA SECTION 24G EIA REPORT
SECTION E: ALTERNATIVES
Please Note: Before completing this section, first consult this Department’s Guideline on Alternatives
(October 2011) available on the Department’s website (http://www.capegateway.gov.za/eadp).
“Alternatives”, in relation to an activity, means different means of meeting the general purposes and
requirements of the activity, which may include alternatives to –
(a) the property on which, or location where, it is to undertake the activity/the activity was
undertaken;
(b) the type of activity to be undertaken;
(c) the design or layout of the activity;
(d) the technology to be used in the activity;
(e) the operational aspects of the activity; and
(f) the option of not implementing the activity.
The NEMA prescribes that the procedures for the investigation, assessment and communication of the
(potential) consequences or impacts of activities on the environment must, inter alia, with respect to
every application for environmental authorisation –
• ensure that the general objectives of integrated environmental management laid down in NEMA
and the National Environmental Management Principles set out in NEMA are taken into account;
and
• include an investigation of the potential consequences or impacts of the alternatives to the activity
on the environment and assessment of the significance of those potential consequences or
impacts, including the option of not implementing the activity.
The general objective of integrated environmental management is, inter alia, to “identify, predict and
evaluate the actual and potential impact on the environment, socio-economic conditions and
cultural heritage, the risks and consequences and alternatives and options for mitigation of activities,
with a view to minimising negative impacts, maximising benefits, and promoting compliance with the
principles of environmental management” set out in NEMA.
1. In the sections below, please provide a description of any considered alternatives and alternatives
that were found to be feasible and reasonable.
Please note:
• Detailed written proof of the investigation of alternatives must be provided and motivation if no
reasonable or feasible alternatives exist.
• Alternatives considered for a Section 24G application are used to determine if the development
was the best practicable alternative (environmenally, socially, economically) for the property.
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NEMA SECTION 24G EIA REPORT
(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative
impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives
exist:
The ‘Koensrust’ tented camp was established within an existing, privately-owned recreational site on
the banks of the Duiwenhoks River.
Rugged topography, a property boundary to the south and the river delineate the area that is
potentially available for development. The site is already equipped with a slipway, jetty and
boathouse that underscore its attractiveness as a location for water-based recreation and sport
fishing in a largely undisturbed natural setting. There are no other places on the farm ‘Koensrust’ 502
that readily lend themselves to equivalent recreational use and, particularly, enjoyment of the type
of estuarine environment that is afforded by the Duiwenhoks River at this particular location.
The farm ‘Koensrust’ 502 has a coastal frontage of roughly 2.4 km which is unsuitable for launching
small craft and unpleasant for camping owing to strong winds and a lack of drinking water. The
higher-lying portions of the farm, between the Duiwenhoks River and the coast, constitute a broken
limestone topography interspersed with pockets of sand. This terrain is exposed to the elements and
is naturally prone to fires, being a fynbos ecosystem. It holds none of the attractions or advantages of
the riverside side for boat-based recreation and camping.
The section of the property abutting the Duiwenhoks River is characterised by an expanse of lawn
that, potentially, could have served as an alternative site for the tented camp. This area is, however,
more exposed to the elements, highly visible from the river (unlike the tented camp, which is masked
by shrubs) and would generally be more obtrusive than the structures that were put up instead. It has
little of the ambience that is experienced at the tented camp, which is contained and imbued with
a very specific sense of place and identity.
In terms of biophysical impact, the lawn may very well have emerged as the desired place to site
the tented camp as this would not led to the destruction of indigenous vegetation. However, the
latter benefits would need to be weighed up against the suitability of the lawn for a campsite when
factors such as exposure to the elements, privacy and sense of place are taken into account.
(b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and
maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:
The only realistic activity alternative would be the ‘no go’ option, i.e. not having proceeded with the
establishment of the tented camp in the first place.
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NEMA SECTION 24G EIA REPORT
(c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts
and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:
Various objective factors limited the size of the tented camp. Most prominent are the location of the
shed, the steepness of the adjacent slope, density of vegetation towards the southern property
boundary, and the proximity of the edge of the saltmarsh to the west (about 12 m) which left about
300 m 2 that, potentially, could be developed (provided that indigenous thicket vegetation was
cleared to make way for a wooden deck). In the circumstances, and if the objective of the
Applicant was to integrate the tented camp with the wooden boathouse, the site that was
eventually chosen for this development was the only feasible one. Short of reducing the extent of the
deck (127 m 2 ), there are no apparent design or layout options for further mitigating the impacts of
the development in its current form or location.
(d) Technology alternatives (e.g. to reduce resource demand and resource use efficiency) to avoid
negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed
motivation if no reasonable or feasible alternatives exist:
The use of wooden decks and olive drab canvas tents to house visitors to protected areas is in wide
use in South Africa. These structures provide a very simple method for confining the impacts of
infrastructure and people to the decking, thereby helping to avoid degradation of adjacent habitats.
Examples of such elevated decks with canvas ‘safari tents’ can be found in the Tierkloof camp in
CapeNature’s Gamkaberg Nature Reserve near Calitzdorp in the Western Cape or the Orange Kloof
tented camp in Table Mountain National Park. Tents can be further shielded by shade cloth or wooden
slats.
In the circumstances, a tented camp designed along the latter lines appears to have been a very
reasonable one in the context of the ‘Koensrust’ site. However, the selection of sites for
accommodation and other infrastructure in protected areas is usually informed by a park or reserve
management plan that identifies and zone’s area, on the basis of biodiversity and other criteria, for
appropriate uses. High standards of management are also applied.
Such planning did not precede, at least formally, the establishment of the ‘Koensrust’ tented camp.
However, the technology that was selected is relevant to the constraints of the receiving environment
and the opportunities that it held for a development of this nature. The technology would also appear
to be consistent with the provincial guidelines for development in Core 2 SCPs, namely that scale and
form of development should be shaped by the receiving environment, that temporary structures (such
as decks and tents) be used, and good management practices must be followed.
Sources:
http://www.sanparks.co.za/assets/docs/conservation/park_man/knp-management-plan1.pdf
http://www.capenature.co.za/reserves.htmsm%5Br2%5D%5Bsubsection%5D=542&reserve=Gamkaber
g+Nature+Reserve
http://www.hoerikwaggotrail.org/accommodation/orange-kloof-tented-camps.html
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NEMA SECTION 24G EIA REPORT
(e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and
maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:
The only operational alternative that may need attention, if the unauthorised development is
approved, would be an alternative sewerage system that can accommodate the needs of up to
eight people and hold no risks of contamination to the Duiwenhoks River. The Applicant has
indicated its willingness to replace the existing pit latrine with a septic tank. CapeNature has
recommended that a composting toilet or small-bore sewerage plant be installed instead.
(f) The option of ceasing the activity (the refusal of the activity(ies) and/or rehabilitation of the site):
If the activity were to be refused, this would mean having to remove the tents, decking and all other
related infrastructure.
The residue would be an open area of some 300 m 2 that could still be furnished and equipped for
picnicking and braaing purposes. Tents could also be pitched there. Some recovery of thicket may
be expected if rootstocks have not been damaged – see Helme on post-disturbance recovery of
strandveld and dune thicket (De Villiers et al., 2005, pp 32-37).
If it is taken into account that the precincts of the jetty, slipway and shed represent an area of more
intensive if sporadic utilisation than the immediately, largely natural surrounds of this part of
‘Koensrust’ 502, and that such use is likely to persist, the tented camp may represent the best
practicable option for achieving a defensible balance between conservation and limited, low
impact development and recreational use.
The tented camp has the positive effect of containing visitor impacts to a dedicated facility, thereby
avoiding the type of degradation (specifically trampling and promotion of edge effects) that is
commonly experienced with informal campsites.
(g) Other alternatives to avoid negative impacts, mitigate unavoidable negative impacts and
maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:
There are no other readily apparent alternatives, besides those mentioned above, that would meet
the needs and objectives of the Applicant for this site.
(h) Please provide a summary of the alternatives investigated and the outcomes of such investigation:
Please note: If no feasible and reasonable alternatives exist, the description and proof of the
investigation of alternatives, together with motivation of why no feasible or reasonable alternatives
exist, must be provided.
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NEMA SECTION 24G EIA REPORT
There are no other readily apparent alternatives, besides those mentioned above, that would meet
the needs and objectives of the Applicant for this site.
Three alternatives will be considered for the purposes of the impact assessment:
1. Non-development of the tented camp;
2. Developing an identical camp on the adjacent lawn; and
3. The status quo, i.e. the current tented camp.
The assessment of impacts associated with three alternatives, two of which would be identical
except for their location on the site, gives the decision-maker a basis for making informed choices
about the environmental merits and demerits of the respective options. See Section F(6) below for a
comprehensive impact assessment that weighs up the respective environmental merits and demerits
of each alternative.
A summary table of the impact assessment is provided at Section 8.1.
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NEMA SECTION 24G EIA REPORT
SECTION F: PRELIMINARY IMPACT ASSESSMENT, MANAGEMENT,
MITIGATION AND MONITORING MEASURES
Please note, the impacts identified below refer to general impacts commonly associated with
development activities. The list below is not exhaustive and may need to be supplemented. Where
required, please append the information on any additional impacts to this application.
Please note: The information in this section must be duplicated for all the feasible and reasonable
alternatives (where relevant).
1. PLEASE DESCRIBE THE MANNER IN WHICH THE DEVELOPMENT HAS IMPACTED ON THE FOLLOWING
ASPECTS:
(a) Geographical and physical aspects:
Spatially, the unauthorised tented camp has had a negligible impact on the abiotic environment
(soils, geology, landforms, watercourses, seeps, etc). The tented camp has a footprint of about 300
m 2 . The total area of the ‘Koensrust’ farm is 964 ha. An estimated 3.4 ha of the ‘Koensrust’ property
next to the Duiwenhoks River may, potentially, be developable, but probably considerably less.
Using these figures, the tented camp represents, at most, 0.88% of the total developable area next to
the river, and 0.003% of the surface of the farm ‘Koensrust’ 502. The tented camp has had no impact
on the seep, which is situated more than 70 m away from the site
The unauthorised development and, potentially, broader precinct next to the Duiwenhoks River, may
be exposed to the effects of abiotic processes, namely flooding and the potential enhanced
permeability of what is understood to be a limestone substrate.
According to the Applicant (pers. comm. F du Plessis, 6 April 2012), the shed at the ‘Koensrust’
campsite has never flooded in the 20-odd years since it was constructed. The tented camp is built at
the same level of the shed which is an estimated 2 m above the terrestrial boundary of the salt
marsh. There are no evident signs that floods have reached the latter level (e.g. flood debris caught
in vegetation or gully erosion in the river bank). The tented camp would therefore appear to be
above the 1-in-20-year floodline. If the camp had instead been built on the lawn, but at the same
level of the shed, this location would also have provided sufficient defence against floods.
Limestone may be fissured, which means that effluent and pathogens may travel relatively rapidly
through the substrate into groundwater and, potentially, water bodies such as the Duiwenhoks River.
There are currently no grounds for concern in this regard, but an increase in the number of overnight
visitors may place more pressure on the current pit latrine and its ability to contain effluent.
The pit latrine is located about 50 m from the edge of the salt marsh, and about 7 m above it.
(b) Biological aspects:
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NEMA SECTION 24G EIA REPORT
Has the development impacted on critical biodiversity areas (CBAs) or ecological support
areas (CSAs)
If yes, please describe:
YES
NO
The development is located within the buffer of an aquatic CBA. The tented camp does not,
however, intrude into the CBA itself (see the botanical assessment by Vlok, 2013: Appendix G). No
other mapped biodiversity features have been affected the unauthorised construction of the tented
camp at ‘Koensrust’ (cf. Maree and Vromans, 2010 and the biodiversity overlay map, Appendix D).)
Has the development impacted on any populations of threatened plant or animal
species, and/or on any habitat that may contain a unique signature of plant or animal YES NO
species
If yes, please describe:
Please describe the manner in which any other biological aspects were impacted:
Please refer to section B(5.2) above, which reflects the finding of the botanical assessment. In
summary, the botanist found that the unauthorised establishment of a tented camp had not
impacted on rare or threatened plant species or the vegetation of the adjacent estuarine wetland.
The affected vegetation was not threatened, and the removal of a maximum of 250 m 2 of thicket
vegetation did not pose any threat to the maintenance of ecological process that function at a
landscape, supra-site scale. Salt marsh vegetation in the vicinity of the jetty and slipway had also not
shown signs of recent degradation. The programme to remove invasive alien plants from the
property was very effective, as was the fire management plan. Overall, the farm ‘Koensrust’ 502 was
being managed to a very high ecological standard.
(c) Socio-Economic aspects:
What was the capital value of the activity on completion R120 000
What is the (expected) yearly income or contribution to the economy that is/will be
generated by or as a result of the activity
R60 000
Has/will the activity contributed to service infrastructure YES NO
How many new employment opportunities were/will be created in the construction
phase of the activity
4
What was the value of the employment opportunities during the construction phase R40 000
What percentage of this accrued to previously disadvantaged individuals 50%
How was this ensured and monitored (please explain): Historically disadvantaged individuals were
employed as wage earners for the duration of a fixed-term construction project.
How many permanent new employment opportunities were/will be created during
the operational phase of the activity
1-2
What is the current/expected value of the employment opportunities during the first
10 years
R500 000
What percentage of this accrued/will accrue to previously disadvantaged
individuals
100%
How was/will this be ensured and monitored (please explain):
The economic viability of the tented camp will only become evident once the facility is fully
operational.
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NEMA SECTION 24G EIA REPORT
Any other information related to the manner in which the socio-economic aspects was/will be
impacted:
The ‘Koensrust’ tented camp may contribute to encouraging eco- or nature-based tourism in the
vicinity of Vermaaklikheid and, so doing, contribute to the creation of employment opportunities. This
will be firmly in line with the rural and developmental focus of the Integrated Development Plan of
the Hessequa Municipality.
(d) Cultural and historic aspects:
The site in question and its surrounds have been used for camping and picnicking purposes for at
least three decades and the base of the kloof that abuts the Duiwenhoks River appears to have
been farmed previously.
An earth dam that captures spring water is the only obvious remnant of agricultural use of this part of
the ‘Koensrust’ property. The dam has not been affected by subsequent development. There is also
a pipeline that conveys water from Oshoek, just to the north, to the historic Kleinfontein homestead
about 2 km to the south-west. There are no evident signs of earlier human habitation or culture (e.g.
middens or the remains of stone tools and other artefacts).
The Puntjie settlement and Kleinfontein farm were proclaimed as national monuments in April 1967
and the Kleinfontein homestead in September 1978. Neither of the latter elements of the national
estate has been affected by the unauthorised development subject to this application.
2. WASTE AND EMISSIONS
(a) Waste (including effluent) management
Did the activity produce waste (including rubble) during the construction phase YES NO
If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether
hazardous or not) and estimated quantity per type NOT APPLICABLE
M 3
Does the activity produce waste during its operational phase
NOTE The ‘activity’ in this context refers to the intended use of the currently
unauthorised infrastructure as a tented camp that provides overnight
accommodation to a maximum of eight visitors.
If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether
hazardous or not) and estimated quantity per type
YES
NO
Camping and fishing are the main activities that take place at the ‘Koensrust’ tented
camp. Visitor numbers seldom exceed eight persons at any one time, and the
campsite would, at most, be occupied for about 10 weeks per year. Such occupation
would mostly take place at holiday periods (December-January, April, June-July, and
September).
M 3
The campsite is serviced by a pit latrine located about 20 m uphill from the shed.
Wood ash is used to control odours. The Applicant has considered replacing the pit
latrine with a composting toilet, but apparently this technology does not work well in
coastal environments (this may be due to elevated levels of ambient humidity).
Instead, it has been proposed that the pit latrine be replaced by a more effective
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NEMA SECTION 24G EIA REPORT
and secure sewerage system.
Grey water from a shower and wash basin filter into a stone-lined soak away. All other
waste is stored in bins prior to removal to the waste collection point in Vermaaklikheid,
from where it is taken to a municipal dump. About three bags of waste are generated
each week when the campsite is fully occupied.
Where and how was/will the waste be treated / disposed of (describe)
See above.
Has the municipality or relevant authority confirmed that sufficient capacity exist for
treating / disposing of the waste (to be) generated by this activity(ies) If yes, provide
written confirmation from Municipality or relevant authority
Does/will the activity produce waste that is/will be treated and/or disposed of at
another facility other than into a municipal waste stream
If yes, has this facility confirmed that sufficient capacity exist for treating / disposing of
the waste (to be) generated by this activity(ies) Provide written confirmation from
the facility and provide the following particulars of the facility: NOT APPLICABLE
Does the facility have an operating license (If yes, please attach a copy of the
license.) NOT APPLICABLE
Facility name:
Contact person:
Postal address:
Postal code:
Telephone:
Cell:
E-mail:
Fax:
YES
YES
YES
YES
NO
NO
NO
NO
(b) Emissions into the atmosphere
Does/will the activity produce emissions that will be disposed of into the atmosphere YES NO
If yes, does it require approval in terms of relevant legislation YES NO
Describe the emissions in terms of type and concentration and how it is/will be treated/mitigated:
NOT APPLICABLE
3. WATER USE
Please indicate the source(s) of water for the activity by ticking the appropriate box(es)
Please indicate the source(s) of water for the activity by ticking the appropriate box(es)
NOTE The ‘activity’ in this context refers to the intended use of the currently unauthorised infrastructure
as a tented camp that provides overnight accommodation to a limited number of paying visitors.
Municipal
Water
board
Groundwater
(seep)
River, Stream,
Dam or Lake
Other
The activity did/does/will
not use water
If water was extracted from a groundwater source, river, stream, dam, lake or any other natural
feature, please indicate
the volume that was extracted per Approx. 12 m 3 (calculated at 50 litres/day for eight people
month:
over 30 days)
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NEMA SECTION 24G EIA REPORT
Please provide proof of assurance of water supply (eg. Letter of confirmation from municipality /
water user associations, yield of borehole)
Did/does the activity require a water use permit / license from DWA YES NO
If yes, please submit a certified copy of the water use permit/license or submit the necessary
application to Department of Water Affairs and attach proof thereof to this application, whichever is
applicable.
NOT APPLICABLE Water is taken from a local, seep-fed dam that has been in use for decades. Water
is taken exclusively for household purposes and therefore constitutes a permissible water use as
defined in Schedule I of the National Water Act 36 of 1998. No other aspect of the development
amounted to the ‘taking of water’ as defined by section 21 of the National Water Act 36 of 1998.
Describe the measures that were/ will be taken to reduce water demand, and measures to reuse or
recycle water:
An informal system of demand management is in place in that the property is fully occupied for, at
most, 20% of any year and water use for household purposes is therefore limited to these periods.
When the site is unoccupied, or if the 2 500 litre water tank runs over, the run-off drains into the
Duiwenhoks River.
4. POWER SUPPLY
Please indicate the source of power supply eg. Municipality / Eskom / Renewable energy source
The campsite is entirely independent of the electricity grid as it is serviced with renewable energy
technology in the form of roof-mounted solar panels, batteries for power storage and LED lights.
If power supply is not available, where will power be sourced from NOT APPLICABLE – See above.
5. ENERGY EFFICIENCY
Describe the design measures, if any that have been taken to ensure that the activity is energy
efficient: Please see above.
Describe how alternative energy sources have been taken into account or been built into the design
of the activity, if any: As above.
6. NEXT PAGE.....
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NEMA SECTION 24G EIA REPORT
6. DESCRIPTION AND ASSESSMENT OF THE SIGNIFICANCE OF IMPACTS PRIOR TO AND AFTER MITIGATION
Please note:
• While sections are provided for impacts on certain aspects of the environment and certain
impacts, the sections should also be copied and completed for all other impacts.
• Mitigation measures that were implemented and mitigation measures that are to be
implemented should be clearly distinguished.
Impacts identified during initial scoping
The following suites of impacts arising from the construction and operation of the tented camp have
been identified as being potentially significant, and are therefore taken forward into the impact
assessment phase:
−
−
−
Impacts on Critical Biodiversity Areas and other features important for biodiversity conservation;
Impacts on socio-economic aspects; and
Visual or noise-related impacts that may detract from a ‘sense of place’.
Additional issues may be raised by interested and affected parties when the draft environmental
impact report is published for comment.
Three alternatives are subjected to the impact assessment, namely:
−
−
−
The ‘no go’ option (i.e. the environmental implications of not having built the tented camp);
Locating the tented camp on the lawn directly to the north, instead of south of the shed; and
The ‘status quo’, i.e. the tented camp in its current form.
The potential impacts of the sewerage system are also assessed. The pit latrine at the ‘Koensrust’
tented camp long predates the latter structure and does not form part of this section 24G application.
However, the effect of increased visitor numbers on the ability of the latrine to safely manage human
waste has been identified as a potential issue of concern.
The relative environmental merits of maintaining the ‘status quo’, i.e. the pit latrine, or replacing it with
a septic tank are assessed to guide future planning on the best practicable method for dealing with
sewage at the tented camp.
6.1 Method of impact assessment and evaluation of impact significance
The following tables explain the criteria by which impacts are assessed (Table 6.1) and significance is
determined as a function magnitude, extent and duration of impacts (Table 6.2).
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NEMA SECTION 24G EIA REPORT
Table 6.1 Assessment criteria for the evaluation of impacts
CRITERIA CATEGORY DESCRIPTION
Extent or spatial
influence of impact
Magnitude of impact
(at the indicated
spatial scale)
Duration of impact
Regional
Local
Site specific
High
Medium
Low
Very Low
Zero
Short Term
Medium Term
Long Term
Vermaaklikheid and further afield
Duiwenhoks River/ beyond ‘Koensrust’ boundaries
Within ~100 m radius of site
Natural and/ or social functions and/ or processes are severely & irreplaceably altered (including
loss of habitat in CBA/FEPA selected in support of pattern targets or thresholds, including
habitat in CR or EN ecosystems and/or CR or EN plant and animal species)
Natural and/ or social functions and/ or processes are notably altered. but reversible (including
loss of habitat in CBA/FEPA selected in support of ‘best design’ or VU ecosystems and/or VU
plant and animal species)
Natural and/ or social functions and/ or processes are slightly altered.
Natural and/ or social functions and/ or processes are negligibly altered.
Natural and/ or social functions and/ or processes remain unaltered.
0-1 year
1-5 years
More than 5 years
Table 6.2: Definition of significance ratings
SIGNIFI-
CANCE
RATINGS
High
LEVEL OF CRITERIA REQUIRED
• High magnitude with a national or regional extent and long-term duration.
• High magnitude with either a regional extent and medium term duration or a local extent and long term duration.
• Medium magnitude with a national or regional extent and long-term duration.
Medium
• High magnitude with a local extent and medium term duration.
• High magnitude with a regional extent and short term duration or a site-specific extent and long term duration.
• High magnitude with either a local extent and short-term duration or a site-specific extent and medium term duration.
• Medium magnitude with any combination of extent and duration except site specific and short term or regional and long
term.
• Low magnitude with a regional extent and long term duration.
• Very low magnitude with any combination of extent and duration except national/regional and medium or long term.
Low
• High magnitude with a site-specific extent and short-term duration.
• Medium magnitude with a site-specific extent and short-term duration.
• Low magnitude with any combination of extent and duration except site specific and short term.
• Very low magnitude with a regional extent and long term duration.
Very low
• Low magnitude with a site-specific extent and short-term duration.
• Very low magnitude with any combination of extent and duration except regional and long term.
Neutral
• Zero magnitude with any combination of extent and duration.
Once the significance of an impact has been determined, the PROBABILITY of this impact occurring
as well as the CONFIDENCE in the assessment of the impact, are estimated using the rating systems
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NEMA SECTION 24G EIA REPORT
outlined in Tables 6.3 and 6.4 respectively. It is important to note that the significance of an impact
should always be considered in concert with the probability of that impact occurring.
Table 6.3 Definition of probability ratings
PROBABILITY RATINGS
Definite
Highly probable
Probable
Possible
Unlikely
Unknown
CRITERIA
Estimated greater than 95 % chance of the impact occurring.
Estimated 80 to 95 % chance of the impact occurring.
Estimated 20 to 80 % chance of the impact occurring.
Estimated 5 to 20 % chance of the impact occurring.
Estimated less than 5 % chance of the impact occurring.
Likelihood of impact not occurring cannot be demonstrably excluded
Having described the probability of an impact occurring, with what degree of confidence has this
prediction been made
Table 6.4 Definition of confidence ratings
CONFIDENCE RATINGS
Certain
Sure
Unsure
CRITERIA
Wealth of information on and sound understanding of the environmental factors potentially influencing the
impact.
Reasonable amount of useful information on and relatively sound understanding of the environmental factors
potentially influencing the impact.
Limited useful information on and understanding of the environmental factors potentially influencing this
impact.
The next step entails indicating the degree to which environmental impacts can be reversed or
‘undone’ with respect to a pre-disturbance standard.
Table 6.5 Reversibility of impacts
Rating
Irreversible
Partially reversible
Fully reversible
Description
Where the impact is permanent.
Where the impact can be partially reversed.
Where the impact can be completely reversed.
If impacts are not reversible, would this amount to some form of irreparable environmental loss, such as
features with pronounced intrinsic or use values, the achievement of biodiversity objectives, or
reduction in ecological resilience
Table 6.6 Risk of irreplaceable loss
Rating
Low
Medium
High
Description
Where the activity results in a loss of a particular resource but where the natural, cultural and social functions
and processes are not affected.
Where the loss of a resource occurs, but natural, cultural and social functions and processes continue, albeit in
a modified way.
Where the activity results in an irreplaceable loss of a resource.
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NEMA SECTION 24G EIA REPORT
NOTE Impacts associated with the construction, operation and decommissioning of the unauthorised
tented camp at ‘Koensrust’ are not assessed separately. The reasons for this are as follows:
1. The scale of the unauthorised development (entailing the removal of ≤250 m 2 of nonthreatened
thicket vegetation) and sound understanding of the responses of the receiving
environment means that impacts, and the effectiveness of measures for their mitigation, can
be predicted with a high degree of confidence. Splitting the impact assessment into the
construction, operation and decommissioning phases holds no additional advantage to this EIA
or the decision it must inform.
2. Construction phase impacts, other than the removal of indigenous vegetation, were
inconsequential. There is no evidence that noises generated by bush-cutting and carpentry on
this isolated property had been experienced as a public nuisance. All traces of constructionrelated
activities had been erased by the commencement of this environmental assessment
process, in December 2012.
3. Post-demolition recovery of the site is discussed in section 6.2.1 below.
6.2 Impact assessment tables
6.2.1 IMPACTS ON CRITICAL BIODIVESITY AREAS AND OTHER FEATURES IMPORTANT
FOR BIODIVERSITY CONSERVATION
Nature of Significant loss of biodiversity or ecological functioning in Critical Biodiversity
impact: Areas or Critical Ecological Support Areas that compromises the ability of these
areas to contribute to the achievement of systematically identified biodiversity
targets and thresholds.
Alternative 1
Alternative 2
Alternative 3
Magnitude of
impact
(The ‘no go’ option)
(Tented camp on lawn)
Before After Before After
mitigation mitigation mitigation mitigation
Nil Nil Nil Nil
(The status quo)
Before After
mitigation mitigation
Neutral to Neutral to
Very low (-) Very low(-)
Extent of impact Nil Nil Nil Nil Site-specific Site-specific
Duration of
impact
Nil Nil Nil Nil Long-term Long-term
Probability of
occurrence
Nil Nil Nil Nil Possible Possible
Reversibility of
impact
N/A N/A N/A N/A Partially Partially
Risk of irreplaceable
resource loss
Nil Nil Nil Nil Low Low
Cumulative
impact
Nil Nil Nil Nil Negligible Negligible
Confidence of
predictions
Certain Certain Certain Certain Certain Certain
Significance rating Nil Nil
Nil Nil Neutral to Neutral to
Very low (-) Very low (-)
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NEMA SECTION 24G EIA REPORT
Discussion
Removal of ≤250 m 2 of non-threatened thicket vegetation did not have an impact on rare or
threatened plant species and would not have an effect on ecological processes that function
beyond site and property boundaries at a landscape scale.
The site could be rehabilitated if the unauthorised infrastructure (primarily decking) were to be
demolished and removed. However, full recovery is unlikely. The site would probably still be used
for outdoor recreational purposes.
The highly-localised removal thicket vegetation is amply off-set by the high standard of
vegetation management that applies to the entire ‘Koensrust’ property.
Non-development of the tented camp, or locating it on the nearby lawned area, would have
no impact on biodiversity as defined above.
Mitigation measures
− The only mitigation measure would be to keep the immediately adjacent thicket clear of
invasive alien plants. The ‘Koensrust’ property has a long-standing and effective programme
of alien and fire management, and additional mitigation measures are therefore not
deemed necessary.
6.2.2 IMPACTS ON SOCIO-ECONOMIC ASPECTS
Nature of The extent that the development contributes to, detracts from, or results in no
impact:
change to socio-economic circumstances of the development and its
immediatte social environs.
Alternative 1
Alternative 2
Alternative 3
Magnitude of
impact
(The ‘no go’ option)
(Tented camp on lawn) (The status quo)
Before After Before After Before After
mitigation mitigation mitigation mitigation mitigation mitigation
Nil Nil Very low (+) N/A Very low (+) N/A
Extent of impact Nil Nil Local N/A Local N/A
Duration of
Medium
Medium
Nil
Nil
N/A
impact
term
term
N/A
Probability of
occurrence
Nil Nil Possible N/A Possible N/A
Reversibility of
impact
N/A N/A N/A N/A N/A N/A
Risk of irreplaceable
resource loss
Nil Nil N/A N/A N/A N/A
Cumulative
impact
Nil Nil Negligible Negligible Negligible Negligible
Confidence of
Relatively
Relatively
Certain Certain
Certain
predictions
sure
sure
Certain
Significance rating Nil Nil Very low (+) N/A Very low (+) N/A
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NEMA SECTION 24G EIA REPORT
Discussion
The Applicant has indicated the tented camp may create one or two new employment
opportunities, amounting to R500 000 in value over 10 years. Some positive knock-on or
multiplier effects could be expected with respect to improving the socio-economic wellbeing of
the affected employees and their dependents.
These benefits would of necessity be limited by the profitability of the tented camp and the
number of posts that its operation would be capable of sustaining. The overall socio-economic
impact is treated as positive, albeit of limited extent.
However, the contribution of facilities such as the tented camp at ‘Koensrust’ to establishing a
broader nature-based tourism economy at Vermaaklikheid is a question that merits wider
consideration in terms of local economic and spatial planning.
Mitigation measures
Mitigation measures do not come into question with this type of very small-scale, and highly
localised, economic development.
6.2.3 VISUAL AND/OR NOISE-RELATED IMPACTS THAT MAY DETRACT FROM A ‘SENSE
OF PLACE’
Nature of Construction activities in relatively remote and scenically attractive
impact: landscapes may detract from some individuals’ expectations regarding ‘sense
of place’, ‘naturalness’ or similar values.
Alternative 1
Alternative 2
Alternative 3
Magnitude of
impact
Extent of impact:
(The ‘no go’ option)
(Tented camp on lawn) (The status quo)
Before After Before After Before After
mitigation mitigation mitigation mitigation mitigation mitigation
Nil Nil Low (-) Low (-) Very low (-) Very low (-)
Nil
Nil Local Local Local Local
Duration of
impact
Nil Nil Short-term Short-term Short-term Short-term
Probability of
occurrence
Nil Nil Possible Possible Possible Possible
Reversibility of
impact
N/A N/A Partially Partially Partially Partially
Risk of irreplaceable
resource loss
medium medium medium medium
Low to Low to Low to Low to
Nil
Nil
Cumulative
impact
Nil Nil Negligible Negligible Negligible Negligible
Confidence of
predictions
Certain Certain Unsure Unsure Unsure Unsure
Significance rating Nil Nil Very low (-) Very low (-) Very low (-) Very low (-)
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NEMA SECTION 24G EIA REPORT
Discussion
Potential impacts on ‘sense of place’ (L. ‘genuis loci’ or the “guardian spirit of a place”) as a
result of noise and/or perceived impairment of the environmental aesthetic have not been
raised to date.
There is little doubt, however, that there are individuals and organisations that are deeply
attached to particular qualities that, for them are invested in the Duiwenhoks River,
Vermaaklikheid and surrounds that are broadly defined by the Rûens to the north, the Breede
River in the west and the Goukou River and Stilbaai to the east. The estuary of the Duiwenhoks
River, limestone hills, fynbos, thatch harvesters and their stacks, isolated and abandoned
farmsteads, the unique architecture of the dwellings at Puntjie, a wild and pristine coastline and
the archaeologically important Blombos caves all contribute towards creating a ‘genius loci’
that has great importance to them, and therefore must be protected.
Whether the establishment of the tented camp at ‘Koensrust’ has detracted from these and
other qualities invested in the affected landscape, and why this would be so, is a moot question.
The tented camp would, in its current location, possibly be less visible from the Duiwenhoks River
and the opposite bank than had it been built on the lawn that drops down towards the edge of
the salt marsh. If there is a visual impact, it would be slight and for most people boating on the
river, of short duration. There is, as far as can be established, no permanent habitation across the
river from ‘Koensrust’.
All in all, visual impacts that may be associated with the tented camp in its current location are
viewed as slight and of little consequence with regard to the ‘sense of place’ attached to the
broader environment. Noise-related impacts during construction would have been limited to the
clamour associated with carpentry and the assembly of a 127 m 2 wooden deck. The chances
that this would have been experienced as a nuisance of any substance by anybody are
practically nil.
In conclusion, it is believed that the unauthorised tented camp is in keeping with the quality and
characteristics of the affected environment and, therefore, does not detract from the ‘sense of
place’.
Mitigation measures
It is exceedingly difficult to predict and gauge people’s feelings about impacts on their ‘sense of
place’ and, therefore, to attach an accurate measure of significant to such impacts. In the
event, impacts arising from noise and visual intrusion have been obviated in the case of the
former and will only become evident once this draft report has been published for comment. At
this stage, no mitigation is recommended with respect to impacts on ‘sense of place’.
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NEMA SECTION 24G EIA REPORT
6.2.4 IMPACTS ON THE ABIOTIC ENVRONMENT: AQUATIC RESOURCES
Nature of
impact:
Magnitude of
impact
Extent of
impact
Duration of
impact
Probability of
occurrence
Reversibility of
impact
Risk of irreplaceable
resource loss
Cumulative
impact
Confidence of
predictions
Potential contamination of the Duiwenhoks River by leached, untreated
effluent when tented camp is fully occupied.
Alternative 1 (Pit latrine)
Alternative 2 (Septic tank)
Before mitigation
After mitigation
Very low (-)
Nil
Local
Nil
Short-term
Nil
Possible
Unlikely
Fully reversible
N/A
Low
Nil
Negligible
Nil
Sure
Sure
Significance rating Very low (-) Nil
Discussion
The environmental desirability of the existing pit latrine has been called into question, but its
construction did not entail a listed activity and it is therefore not subject to this s 24G application.
The installation of a 2 500 l (suitable for ≤10 persons) or 5 000 l (suitable for ≤20 persons) septic
tank would not trigger the requirements of the NEM: Waste Management Act 59/2008 as the
annual throughout of even the larger septic tank (ca. 1 095 m 3 p.a.) would be well below the 2
000 m 3 threshold prescribed by the latter Act. The latter annual throughout assumes full-time
occupation of the site by 20 people for a 365 consecutive days which is orders of magnitude
greater than the actual, anticipated use of the tented camp.
It would seem that concerns about the potential impacts of effluent contamination of the
Duiwenhoks River and estuary have arisen as a result of the submersion of septic and
conservancy tanks elsewhere along the river during floods. The type and siting of domestic
sewerage treatment facilities would clearly be of issue if these structures are located within the
floodplain. However, the shed at the campsite at ‘Koensrust’ has apparently never been
flooded in the 20-odd years of its existence. The shed is about 2 m higher than the salt marsh and
20 m from its terrestrial boundary. The pit latrine, in turn, is about 14 m above highest point of the
saltmarsh, and some 50 m from its edge.
Flood heights for this part of the Duiwenhoks River are not available. It can be assumed, though,
that it would take a flood of an exceptional and devastating magnitude to rise to the level of
the pit latrine. It could be argued that a smaller flood would hold an equal risk of precipitating
contamination if effluent had leaked from the pit latrine, infiltrated the limestone and thus
leached towards the river. The probability of such an incident occurring is regarded as
infinitesimal.
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NEMA SECTION 24G EIA REPORT
Mitigation measures
In the circumstances, it would appear that there is no compelling environmental reason to
immediately replace the existing pit latrine at the ‘Koensrust’ tented camp. There may well be
social and aesthetic grounds for doing so. Substitution of the pit latrine with a 2 500 l septic tank,
located at least 50 m from the edge of the saltmarsh, would dispel any residual concerns about
the potential contribution of the campsite to contamination of the Duiwenhoks estuary.
(d) Any other impacts: No other potential impacts have been identified.
Please note: If any of the above information is not available, specialist input may be requested.
7. SPECIALIST INPUTS/STUDIES AND RECOMMENDATIONS
Please note: Specialist inputs/studies that will be undertaken as part of this application. These
specialist inputs/studies must take into account the Department’s relevant Guidelines on the
Involvement of Specialists in EIA Processes available on the Department’s website
(http://www.capegateway.gov.za/eadp). A summary of all the specialist inputs/studies must be
provided with the additional information / Environmental Impact Report.
Specialist inputs/studies and recommendations:
A botanical assessment was undertaken by Mr Jan Vlok of Regalis Environmental Services. The terms
of reference for the botanical assessment were, in summary, to investigate the impacts of the
unauthorised development at ‘Koensrust’ on:
−
−
−
Vegetation;
Local habitats; and
Spatial surrogates for ecological processes.
Vegetation types and habitats would serve as surrogates for a biodiversity hierarchy incorporating
rare and threatened plants, threatened vegetation (or ‘ecosystems’ as defined by section 52 of the
NEM: Biodiversity Act 10/2004) and landscape-scale ecological processes.
The botanical assessment entailed a survey in January 2013 and the interpretation of field findings
with reference to:
− The Biodiversity Sector Plan for the Mossel Bay and Hessequa Municipalities (Maree and
Vromans, 2010);
− The Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape
(De Villiers et al., 2005);
− The Vegetation Map for the Riversdale Fine-Scale Planning Domain (Vlok and De Villiers,
2007); and
− The Vegetation of South Africa, Lesotho and Swaziland (Mucina and Rutherford (eds), 2006).
The findings of the botanical/biodiversity assessment are given comprehensive coverage in Section B
of this report. Also Vlok, 2013; Appendix G.
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NEMA SECTION 24G EIA REPORT
The key findings of the botanical/biodiversity assessment are:
−
−
−
−
−
−
−
−
The unauthorised establishment of a tented camp had not impacted on rare or threatened
plant species or the vegetation of the adjacent estuarine wetland.
The development had not resulted in loss of habitat in a Critical Biodiversity Area.
The affected vegetation type (‘ecosystem’) was not threatened, and the removal of a
maximum of 250 m 2 of thicket vegetation did not pose any threat to the maintenance of
ecological processes that function at a landscape, supra-site scale.
Salt marsh vegetation in the vicinity of the jetty and slipway had also not shown signs of
recent degradation.
The programme to remove invasive alien plants from the property was very effective, as was
the fire management plan.
Overall, the farm ‘Koensrust’ 502 was being managed to a very high ecological standard.
However, the existing ablution facilities at the tended camp had to be upgraded to an
environmentally-acceptable standard.
The positive impact of an upgraded sewage system would outweigh any negative impacts
associated with the development.
8. IMPACT ASSESSMENT
Briefly describe the impacts (as appropriate), significance rating of impacts, mitigation and
significance rating of impacts of the activity. This must include an assessment of the significance of all
impacts.
Please note: This is a preliminary impact statement. The Department may request specialist
input/studies depending on the type and nature of the impact(s) of the activity/ies.
8.1 SUMMARY OF IMPACT SIGNIFICANCE
Alternative 1
Alternative 2
Alternative 3
(The ‘no go’ option)
Before After
mitigation mitigation
(Tented camp on lawn)
Before After
mitigation mitigation
(The status quo)
Before After
mitigation mitigation
Impacts on Critical
Biodiversity Areas
Nil Nil Nil Nil
Neutral to
Very low (-)
Neutral to
Very low (-)
Socio-economic
impacts
Impacts that may
detract from a
‘sense of place’
Nil Nil Very low (+) N/A Very low (+) N/A
Nil Nil Very low (-) Very low (-) Very low (-) Very low (-)
Viewed overall, impacts associated with the unauthorised tented camp at ‘Koensrust’ have
‘very low’ negative significance with respect to biodiversity and the ‘sense of place’. Impacts on
biodiversity would be close to neutral if weighed against the positive contribution of the property
to responsible alien and fire management. The development may have a slightly positive socioeconomic
effect.
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NEMA SECTION 24G EIA REPORT
9. IMPACT SUMMARY OF ACTIVITY
Please fill in the table below, by crossing out (“⌧”) the appropriate box(es):
9.1 Socio-Economic Benefit Index (e.g. Municipal Infrastructure) ⌧
9.1.1
9.1.2
9.1.3
9.1.4
9.1.5
9.1.6
The development provides no direct social service to the affected community and
/or will have little, or no, positive impact on job creation and/or poverty alleviation in
the area; or
The development provides little direct social service to the affected community
and/or will have little, or minor, positive impacts on job creation and/or poverty
alleviation in the area; or
The development provides some social service to the affected community and/or will
have a possible positive impacts on job creation and/or poverty alleviation in the
area; or
The development provides a social service and/or will have a possible positive
impact on job creation and/or poverty alleviation in the area; or
The development provides an important social service and/or will have a measurable
positive impact on job creation and/or poverty alleviation in the area; or
The development provides an essential social service (immediately required/
emergency) and will have a measurable positive impact on job creation and/or
poverty alleviation in the area
X
Please provide motivation for the impact rating of the above impact index:
The development, if retrospectively authorised, may create one or two jobs and would play a small
role in boosting the attractiveness of Vermaaklikheid and the estuary of the Duiwenhoks River as a
destination for nature-based tourism. This is consistent with the objectives of the IDP for the Hessequa
Municipality.
9.2 Socio Economic Impact Index
9.2.1
9.2.2
9.2.3
The development will not give rise to any significant negative socio-economic
impacts; or
The development could give rise to negative socio-economic, but highly localised,
impacts
The development could give rise to significant negative socio-economic, and
regionalized impacts
X
9.2.4 The development could result in wide-scale socio-economic hardship.
Please provide motivation for the impact rating of the above impact index:
The socio-economic benefits associated with the development are marginal but positive.
9.3 Biodiversity Impact Index
9.3.1 The development will give rise to insignificant impacts on biodiversity; or X
9.3.2 The development could give rise to significant, but localised biodiversity impacts
9.3.3 The development could give rise to significant, but regional biodiversity impacts
9.3.4
The development is likely to permanently/ irreversibly transform/ destroy a recognised
biodiversity ‘hot-spot’ or threaten the existence of a species or sub-species.
Please provide motivation for the impact rating of the above impact index:
Loss of biodiversity associated with the development is of very low negative significance and would
be positively off-set by the overall contribution that the owners of the greater ‘Koensrust’ farm make
to alien and fire management.
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NEMA SECTION 24G EIA REPORT
9.4 Sense of Place (including visual) Impact Index
9.4.1 The development is in keeping with the surrounding environment X
9.4.2
9.4.3
9.4.4
The development is not in keeping with the surrounding environment and will have a
significant localised impact on the affected area's sense of place
The development is not in keeping with the surrounding environment, but will have a
significant regionalised impact on the affected area's sense of place
The development is completely out of keeping with the surrounding environment and
will have a significant impact on the affected area's sense of place
Please provide motivation for the impact rating of the above impact index:
The siting, design and building methods of the development are consistent with the guidelines for
such projects in Core 1 and Core 2 Spatial Planning Categories. Impacts on ‘sense of place’ would
be fleeting and, if they occurred, of very limited consequence.
9.5 Noise Impact Index
9.5.1 The development is unlikely to give rise to any significant noise X
9.5.2 The development may lead to significant noise pollution, limited to the site.
9.5.3
The development will give rise to significant noise pollution, affecting the surrounding
community
Please provide motivation for the impact rating of the above impact index:
Noise associated with construction was of limited duration. Noise that may be associated with the
ongoing operation of the tented camp as visitor facility is matter of good housekeeping. If noise has
not been an issue to date, there is little reason that it would be in future.
9.6 Pollution and Waste Impact Index
9.6.1 The development will not give rise to any significant quantities of waste or pollution; or X
9.6.2
9.6.3
9.6.4
The development could give rise to quantities of pollution or waste that could have
significant, but localised (immediate community and environment) impacts.
The development could give rise to quantities of pollution or waste that could have
significant, but regional (beyond immediate environment and community) impacts.
The development is likely to give rise to a significant quantity of prioritised pollutants or
waste streams (e.g. greenhouse gases, hazardous substances, radioactive waste,
etc.).
Please provide motivation for the impact rating of the above impact index:
The issue of pollution relates to the effectiveness of the sewerage system at the ‘Koensrust’ campsite.
The Applicant is mindful that this may be cause for concern (although this has not been
conclusively demonstrated) and would be prepared to replace the current pit latrine with a septic
tank.
Please note: Section 9 is to be completed after all specialist studies and input from Interested and
Affected Parties have been obtained.
10. OTHER MANAGEMENT, MITIGATION AND MONITORING MEASURES
(a) Over and above the mitigation measures described above, please indicate any additional
management, mitigation and monitoring measures.
No further mitigation measures are deemed necessary, and none is proposed.
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NEMA SECTION 24G EIA REPORT
(b) Describe the ability of the applicant to implement the management, mitigation and monitoring
measures.
There are three management objectives that need to guide the use and care of the ‘Koensrust’
tented camp:
−
−
−
Keeping the site and surrounds clear of invasive alien plants;
Preventing contamination of the Duiwenhoks River by untreated effluent; and
Operating the camp site in a socially harmonious fashion.
As to the first objective, there is an effective alien management programme in place for the entire
‘Koensrust’ property which is evidenced by the virtually alien-free condition of the camp site
precinct. Except for some Spanish reed in the dam and prickly pear against the steeper slopes, the
site is effectively pristine. The Applicant is committed to continuing implementation of its alien and
fire management programmes.
The risk of contamination of the Duiwenhoks River by effluent seeping from the existing pit latrine has
been raised as a concern, but not conclusively demonstrated. The pit latrine is well above the 1:20
year floodline and does not appear to be vulnerable to floods The Applicant has, however,
indicated that it is prepared to replace the pit latrine with a septic tank, thereby largely eliminating
any risk relating to such contamination.
There is no reason to believe that the behaviour of people who in future make use of the tented
camp and facilities will differ in any respect from previous conduct at the site which, on the face of it,
has been without incident or cause for complaint. As indicated previously, this is a matter of ‘good
housekeeping’ and does not need to be regulated.
Please note: A draft ENVIRONMENTAL MANAGEMENT PROGRAMME must be attached this report as
Appendix H.
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NEMA SECTION 24G EIA REPORT
SECTION G: ASSESSMENT METHODOLOGIES AND CRITERIA, GAPS
IN KNOWLEDGE, UNDERLAYING ASSUMPTIONS AND
UNCERTAINTIES
(a) Please describe adequacy of the assessment methods used.
The assessment method used by this environmental assessment reflects an approach that is in
widespread, established practice in South Africa. See the introductory paragraphs to Section F(6),
and sub-section 6.1 for a comprehensive explanation of the method of impact assessment and
evaluation.
(b) Please describe the assessment criteria used.
The assessment criteria are presented in Table 6.1. They have been modified to reflect the
environmental context within which the unauthorised development of the ‘Koensrust’ tented camp
took place, namely in that:
−
−
The ‘extent’ of impacts was adjusted to reflect local landmarks; and
The ‘magnitude’ of impacts was modified to make specific reference to impacts on Critical
Biodiversity Areas, Freshwater Ecosystem Priority Areas and threatened ecosystems.
(c) Please describe the gaps in knowledge.
There is – potentially – only one significant gap in knowledge, namely the capacity of the existing pit
latrine to safely cater for the needs of eight occupants of the tented camp. The risk of contamination
of the Duiwenhoks River is considered to be slight. However, the Applicant is prepared to give
practical effect to the ‘precautionary principle’ and, regardless of conclusive evidence that the pit
latrine holds any risk of polluting the river, to replace the pit latrine with a septic tank. This, it appears,
would satisfactorily bring closure to this issue.
(d) Please describe the underlying assumptions.
This environmental assessment has been undertaken on the assumption that:
−
−
−
−
−
All relevant issues of significant environmental concern have been adequately identified, or
will be identified once a draft environmental assessment report has been published for
comment by interested and affected parties;
It is demonstrably consistent with the national environmental management principles, the
duty of care and the general objectives of integrated environmental management insofar as
these apply to the circumstances of the unauthorised development;
The specialist botanical assessment gave adequate consideration to biodiversity pattern and
ecological processes, the potential occurrence of threatened ecosystems and Critical
Biodiversity Areas, and appropriately contextualised the impacts of the unauthorised
development in relation to the latter conservation categories as well as the type and
effectiveness of vegetation management on the broader property;
The Applicant has provided all the information that is relevant to this application, and that
such information is factually correct; and
The impact assessment methodology has been adequately informed by relevant
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NEMA SECTION 24G EIA REPORT
−
environmental considerations, ranging from the biophysical context of the unauthorised
development, the effects of the development relative to regional biodiversity and socioeconomic
goals, and the practical management of residual environmental impacts.
Lastly, the management recommendations would directly and effectively address key
residual impacts that may be associated with the unauthorised development.
(e) Please describe the uncertainties.
Other than the question of contamination arising from the pit latrine, there are no uncertainties that
would detract from the defensibility of this environmental assessment, and its findings and
recommendations. See the Applicant’s response to this uncertainty at section G(c) above.
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NEMA SECTION 24G EIA REPORT
SECTION H: RECOMMENDATIONS OF THE EAP
In my view (EAP), the information contained in this Application Form and the
documentation attached hereto is sufficient to make a decision in respect of the YES NO
activity applied for.
If “NO”, list the aspects that should be further assessed through additional specialist
input/assessment: NOT APPLICABLE
If “YES”, please indicate below whether in your opinion the applicant should be directed to cease
the activity or if it should be authorised:
Applicant should be directed to cease the activity: YES NO
Please provide reasons for your opinion: NOT APPLICABLE
If you are of the opinion that the activity should be authorised, then please provide any conditions,
including mitigation measures that should in your view be considered for inclusion in an authorisation.
The following requirements for mitigation should be included in an authorisation:
1. Current measures to clear the greater ‘Koensrust’ farm of invasive alien plants are supported
and must be specified as a condition of authorisation with respect to the tented camp and
its immediate precinct in the vicinity of the Duiwenhoks River; and
2. Replacement of the pit latrine with a septic tank with sufficient capacity to manage the
waste needs of 10 people should be incorporated as a recommendation in the
environmental authorisation.
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NEMA SECTION 24G EIA REPORT
SECTION I: MOTIVATION FOR RESPONSE TO AN EMERGENCY
This section is only applicable to instances where Section 24F (3) of NEMA applies. Please list all steps
that where taken in response to the emergency. NOT APPLICABLE
Please note: Section 30 of NEMA deals with the procedures to be followed for the control of
emergency incidents.
SECTION J: APPENDICES
The following appendices must, where applicable, be attached to this report:
Tick the
Appendix
box if
Appendix is
attached
Appendix A: Locality map Yes
Appendix B: Site plan(s) Yes
Appendix C: Photographs Yes
Appendix D: Biodiversity overlay map Yes
Appendix E:
Appendix F:
Permit(s) / license(s) from any other organ of state including service
letters from the municipality
Public participation information: including a copy of the register of
interested and affected parties, the comments and responses report,
proof of notices, advertisements and any other public participation
information as required in Section C above.
Yes
Appendix G: Specialist Report(s) Yes
Appendix H : Environmental Management Programme Yes
Appendix I: References Yes
Appendix J: Certified copy of Identity Document of Transgressor / Applicant Yes
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NEMA SECTION 24G EIA REPORT
DECLARATIONS
THE APPLICANT
I …………………………………., in my personal capacity or duly authorised as ………………………….
(state capacity) by …………….................................………………… thereto hereby declare that I:
• regard the information contained in this report to be true and correct, and am fully aware of my
responsibilities in terms of the Environment Conservation Act, 1989 (Act No. 73 of 1989) and the
National Environmental Management Act of 1998 (“NEMA”) (Act No. 107 of 1998), the
Environmental Impact Assessment Regulations (“EIA Regulations”) in terms of NEMA, and the
relevant specific environmental management Act(s), and that failure to comply with these
requirements may constitute an offence in terms of the environmental legislation;
• appointed the environmental assessment practitioner as indicated above, which meet all the
requirements in terms of Regulation 17 of GN No. R. 543, to act as the independent Environmental
Assessment Practitioner for this application;
• have provided the environmental assessment practitioner and the competent authority with
access to all information at my disposal that is relevant to the application;
• am fully aware of the administrative fine to be paid before a decision with respect to the
continuation of the listed activity(ies) for which rectification is sought will be made;
• will be responsible for the costs incurred in complying with the environmental legislation including
but not limited to –
o costs incurred in connection with the appointment of the environmental assessment
practitioner or any person contracted by the environmental assessment practitioner;
o costs incurred in respect of the undertaking of any process required in terms of this application;
o costs in respect of any fee prescribed by the Minister or MEC in respect of the regulations;
o costs in respect of specialist reviews, if the competent authority decides to recover costs;
o the provision of security to ensure compliance with the applicable management and
mitigation measures; and
o fine costs
• am responsible for complying with the conditions that might be attached to any decision(s) issued
by the competent authority;
• am aware that I may be issued with a directive and that I must comply with such a directive;
• have the ability to implement the applicable management, mitigation and monitoring measures;
• hereby indemnify, the government of the Republic, the competent authority and all its officers,
agents and employees, from any liability arising out of, inter alia, the content of any report, any
procedure or any action for which the applicant or environmental assessment practitioner is
responsible; and
Please Note: If acting in a representative capacity, a certified copy of the resolution or power of
attorney must be attached.
Signature of the applicant: ________________________________________________________________________
Name of company:________________________________________________________________________________
Date:________________________________________________
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NEMA SECTION 24G EIA REPORT
THE INDEPENDENT ENVIRONMENTAL ASSESSMENT PRACTITIONER (“EAP”)
I ……………………………………, as the appointed independent environmental practitioner (“EAP”)
hereby declare that I:
• act/ed as the independent EAP in this application;
• regard the information contained in this report to be true and correct, and
• do not have and will not have any financial interest in the undertaking of the activity, other than
remuneration for work performed in terms of the ECA , the NEMA, the Environmental Impact
Assessment Regulations and any specific environmental management Act(s);
• have and will not have any vested interest in the proposed activity proceeding;
• have disclosed, to the applicant and competent authority, any material information that have or
may have the potential to influence the decision of the competent authority or the objectivity of
any report, plan or document required in terms of the NEMA, the Environmental Impact Assessment
Regulations, 2010 and any specific environmental management Act(s);
• am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact
Assessment Regulations (specifically in terms of Regulation 17 of GN No. R. 543) and any specific
environmental management Act, and that failure to comply with these requirements may
constitute and result in disqualification;
• have ensured that information containing all relevant facts in respect of the application was
distributed or made available to interested and affected parties and the public and that
participation by interested and affected parties was facilitated in such a manner that all interested
and affected parties were provided with a reasonable opportunity to participate and to provide
comments;
• have ensured that the comments of all interested and affected parties were considered, recorded
and submitted to the competent authority in respect of the application;
• have kept a register of all interested and affected parties that participated in the public
participation process;
• have provided the competent authority with access to all information at my disposal regarding the
application, whether such information is favourable to the applicant or not; and
Note: The terms of reference must be attached.
Signature of the environmental assessment practitioner: _____________________________________________
Name of company: ________________________________________________________________________________
Date: _________________________________________________
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NEMA SECTION 24G EIA REPORT
THE INDEPENDENT PERSON WHO COMPILED A SPECIALIST REPORT OR UNDERTOOK A SPECIALIST PROCESS
I ……………………………………, as the appointed independent specialist hereby declare that I:
• act/ed as the independent specialist in this application;
• regard the information contained in this report as it relates to my specialist input/study to be true
and correct, and
• do not have and will not have any financial interest in the undertaking of the activity, other than
remuneration for work performed in terms of the ECA, the NEMA, the Environmental Impact
Assessment Regulations and any specific environmental management Act(s);
• have and will not have any vested interest in the proposed activity proceeding;
• have disclosed, to the applicant, EAP and competent authority, any material information that
have or may have the potential to influence the decision of the competent authority or the
objectivity of any report, plan or document required in terms of the NEMA, the Environmental
Impact Assessment Regulations and any specific environmental management Act(s);
• am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact
Assessment Regulations (specifically in terms of Regulation 17 of GN No. R. 543) and any specific
environmental management Act, and that failure to comply with these requirements may
constitute and result in disqualification;
• have ensured that information containing all relevant facts in respect of the specialist input/study
was distributed or made available to interested and affected parties and the public and that
participation by interested and affected parties was facilitated in such a manner that all interested
and affected parties were provided with a reasonable opportunity to participate and to provide
comments on the specialist input/study;
• have ensured that the comments of all interested and affected parties on the specialist input/study
were considered, recorded and submitted to the competent authority in respect of the
application;
• have ensured that the names of all interested and affected parties that participated in terms of the
specialist input/study were recorded in the register of interested and affected parties who
participated in the public participation process;
• have provided the competent authority with access to all information at my disposal regarding the
application, whether such information is favourable to the applicant or not; and
Note: The terms of reference must be attached.
Signature of the specialist:_________________________________________________________________________
Name of company: _______________________________________________________________________________
Date: _____________________________________________________________________________________________
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