appendix e: comments and responses report - Anchor Environmental

PROPOSED CONSTRUCTION AND OPERATION OF A WAVE ENERGY 

CONVERTER ADJACENT TO THE ABAGOLD FARMS, HERMANUS 

BASIC ASSESSMENT REPORT 

APPENDIX E: COMMENTS AND RESPONSES REPORT 

Prepared for: 

Department of Environmental Affairs 

On behalf of: 

Abagold 

Prepared by: 

Anchor Environmental Consultants (CC)

1 INTRODUCTION 

This public participation process is being conducted in accordance with the requirements provided in 

chapter 6 (regulation 54, 55, 56 and 57) of the EIA Regulations (G.N.R. 543 2010). Consultation 

between Anchor Environmental Consultants and authorities commenced in September 2011 with a 

meeting, and between Anchor Environmental Consultants and stakeholders in November 2011 with 

notices of the proposed project in two newspapers, written notices to neighbouring residents and 

businesses and sign boards on site (see section C of BAR). 

2 FIRST PHASE 

2.1. CONSULTATION WITH AUTHORITIES 

A meeting was held between the competent authority, the EAP and Abagold on the 13 th of 

September 2011. The minutes of this meeting are provided below. 

Document 

Type: 

Title: 

Draft Minutes 

EIA for the Abagold Wave Energy Converter (NEAS Reference: DEAT/EIA/0000505/2011, 

DEA Reference: 12/12/20/2045) 

Reference: AWEC 13/09/2011/1 

Date: 13 September 2011 

Venue: 

Time: 

DEA Offices, 315 Pretorius Street, Cnr van der Waalt and Pretorious Streets, Fedsure 

Forum Building,4th Floor South Tower 

12h00-13h00 

ATTENDANCE: 

Department of 

Environmental Affairs 

Abagold 

Anchor Environmental 

Coenrad Agenbach CA Pierre Hugo PH Barry Clark BC 

Takalani Maswime 

TM 

Sandile Vilakazi 

SV 

Nyiko Ngoveni 

NN 

No. Item Discussion 

1. Welcome and 

Introductions 

TM welcomed all present to the meeting and explained that the meeting had been 

set up at the request of Anchor Environmental for the purposes of allowing Anchor 

and Abagold to present information to DEA on the Abagold Wave Energy Converter 

(WEC) project and the application to apply Basic Assessment procedures to this


2. Description of 

the project 

and potential 

environmental 

impacts 

project rather than Scoping and Environmental Impact Reporting procedures. 

TM requested all present to introduce themselves and then handed the floor over to 

PH and BC to present their case. 

PH delivered two Powerpoint presentations the first on Abagold’s existing operations 

and the second on the proposed new Wave Energy Converter (WEC) project. 

Copies of these presentations delivered by PH are Annexed to these minutes. PH 

highlighted the fact that Abagold had been in business since 1985, first started 

exporting abalone in 1999, and currently had three operational abalone farms all in 

the precinct of the Hermanus Fishing Harbour, and a fourth farm under development. 

Abagold currently employs 320 staff and expects this to rise to 500 persons once the 

new farm is brought into production. He also highlighted the fact that energy costs 

were the greatest threats to the business at present, with electricity costs averaging 

R800 000 per month (R10 million per annum). PH explained that this was the 

primary motivation for investigating option for alternative energy and that the most 

promising of these was the generation of electricity from wave energy. 

In the second presentation on the proposed Abagold WEC, PH explained that 

Abagold would like to adopt a phased phased approach to the implementation of the 

project, starting with a pilot WEC able to generate approximately 750 kW and an 

effluent line turbine (a turbine fitted to the base of the existing seawater outfall) 

capable of generating a further 100 kW of electricity, and should this prove 

successful, that Abagold would like to go ahead with the construction of the main 

WEC capable of generating up to 3 MW of electricity. PH explained the mechanism 

through which electricity would be generated from the wave energy using the WECs 

(by allowing waves to push sea water into a reservoir constructed on the coast and 

how this water would be used to turn a series of turbines as it flowed back into the 

sea). PH explained that the project development site was on the seashore (public 

property) within the precinct of the Hermanus Harbour, but that potential visual 

impacts from the project were likely to be small given that the project infrastructure 

was not visible beyond the borders of the site on the landward side, and that no 

infrastructure would project above the existing skyline. 

BC explained that Anchor Environmental had been appointed as environmental 

assessment practitioner for the project. He explained that he had studied the project 

documentation and had identified the likely significant impacts of the project to be as 

follows: 

o 

o 

o 

Construction phase: (i) permanent but localised loss of a small amount 

of intertidal and shallow water coastal habitat within the footprint of 

the development site 

Operational phase: (i) permanent low intensity visual impacts 

Other potential impacts of the project such as impacts on water 

quality, noise pollution, waste generation were all of extremely low or 

negligible significance. 

BC explained also that he anticipated that two specialist studies would be required 

as part of the impact assessment, the first being a marine ecology impact study and 

the second being a visual impact assessment. 

BC explained that the project activities triggered listed activities included in both 

Listing notice 1 (R544) and Listing notice 2 (R545) and hence required that the 

applicant follow procedures for Scoping and Environmental Impact Reporting rather 

than a Basic Assessment process. However, BC mentioned that in his opinion the 

potential impacts of the project on the environment (including all other beneficial 

uses of the sea in this area), both in respect of the construction and operational 

phases, are likely to be easy to identify and quantify, are almost certainly of low


3 General 

discussion 

and questions 

regarding the 

project 

significance, and will be easy to communicate to and will be easily understood by 

interested and affected parties. As such, he felt that DEA, as competent authority 

assessing the application, should be able to reach a decision on the basis of 

information provided in a Basic Assessment report only without requiring a full 

scoping and Environmental Impact Reporting. In the light of this, he explained that 

he had advised Abagold to request permission to apply Basic Assessment 

procedures instead of S&EIR procedures to this project. Hence the request for this 

meeting between DEA, Abagold and Anchor. 

CA thanked PH and BC for their presentation. He then queried if the was likely to 

be any changes in the temperature of the water after it entered the reservoirs and 

before it was discharged back to the sea. 

PH explained that the residence time in the reservoirs would be too short to 

influence the temperature in anyway and that the speed at which it would flow over 

the turbines was too low owing to the large size of the turbines to have any 

measurable effect on the temperature. 

CA queried whether a permit was required from NERSA for the generation of 

electricity 

BC explained that Abagold were investigating this but suspected that no permit was 

required as Schedule 2 of the Electricity Regulation Act (2006) indicates that one is 

exempt from obtaining such a permit provided that the electricity generated was for 

own use only, which was the case in this instance. 

BC also explained that Abagold would need to secure permission from Minister: 

DEA to lease land below the high water mark of the sea for the proposed 

development and that a Coastal discharge permit would be required for the project 

but that no activities under the Waste Management Act or Air Pollution Act would be 

triggered by the proposed development. 

CA asked if any impacts to whales could be expected. 

BC mentioned that potential impacts on southern right whale populations that 

aggregate offshore of the site in winter (April to October of each year) were of 

concern but he did not think that they would be affected in any way by the project 

activities. Noise and water quality impacts are expected to be negligible and the 

development is not expected to encroach into the area used by the whale. 

Nonetheless it would be recommended that all construction activities be undertaken 

outside on this period. 

SV explained that BC would need to submit a formal application to the Department 

requesting to downgrade from S&EIR to Basic Assessment. She mentioned that BC 

would need to respond to the list of criteria that had been sent to him by TM to assist 

the Department to arrive at a decision on this matter. 

SV also explained that if permission was granted to downgrade to a Basic 

Assessment process that BC should not feel bound to following the Basic 

Assessment report format exactly but rather that he should present information on 

the nature of the project and the assessment of impacts in the most logical and easy 

to follow manner. She noted that a detailed description on the nature of the project 

should be provided with the Basic Assessment rpeort. 

CA suggested that it would be good to have a second project meeting on site after 

the EIA report has been submitted to the Department and that other relevant 

government agencies including DEADP, DEA : Oceans & Coasts and the 

local/district municipalities should be invited to attend the meeting. 

TM noted that owing to the fact that technology to be deployed in the project was 

new and would be unfamiliar to stakeholders, that a detailed assessment of the


potential impacts would be required and that in depth consultation with stakeholders 

would need to be undertaken. Key stakeholders to be consulted should include 

agencies such as the Wildlife and Environment Society of South Africa (WESSA), 

Conservation International, and Birdlife International. 

5 Closure The meeting closed at 13h00. CA thanked PH and BC for requesting the meeting 

and for the inputs. 

2.2. REGISTRATION OF INTERESTED AND AFFECTED PARTIES 

Authorities 

Department of Environmental Affairs and Development 

Planning 

Cape Nature 

Department of Environmental Affairs, Branch: Oceans & Coasts 

Overstrand Municipality 

Overberg District Municipality 

NGOs 

Overstrand Conservation Foundation 

Birdlife Africa 

Wildlife and Environment Society of South Africa 

Overberg Integrated Conservation Group (OICG ) 

Dolphin action and protection group 

Neighbouring landowners/tenants 

Beach Club 

Whale Bay Cascades 

Whale Rock Estate 

Aquafarm 

HIK Abalone 

Harbour Master 

Harbour Rock Restaurant 

Tuna Marine 

SPP Canning / Marifeed 

Lusitania 

Combined Abalone Processors 

Walker Bay Canners 

Hermanus Processing Services 

Hermanus Boat Club 

NSRI 

Quayside Cabin 

Hermanus Whale Cruises 

Southern Right Carters 

Solar Spectrum Whale Cruises 

Contact person 

Maboee Nthejane 

Landuse Advice Department / 

Alana 

Chumani Mangcu 

Liezel Bezuidenhout 

Francois Kotze 

Rob Fryer/Megan Campbell 

Pam Barrett 

Chris Galliers 

Francois Kotze 

Nan Rice 

Danie Van Deventer 

Willem van Zyl 

Louise 

Jacques du Plessis 

Gavin Johnson 

Willie Hill 

Francois Barnard 

Mark Raynard 

Kurt Matschke 

Charline October 

Abigail Kleinsmidt 

Francois du Toit 

Manie Martz 

Tjaart Oliver 

Henk Henn 

Mike 

Tommy Gelderblom 

Shaun/Gale 

Nina

Scuba Africa 

BS Divers 

Gecko Bar 

Other 

Berg 'n See 

Kleinmond Nature Conservation Society 

Berg 'n See 

Lubritech Marketing 

BS Divers 

Abagold 

Berg 'n See 

Whale Rock Estate Body Corperate 

Irvin & Johnson Ltd, Abalone Culture Division 


Manager | Irvin & Johnson Ltd | Walker Bay Canners 

Infoprop 

Private 

Berg 'n See 

Private 

HRA 

HIK Abalone Farm 

Private 

Berg 'n See 

Hermanus Ratepayers 

Aquafarm 

Abagold 

Accountant | Irvin & Johnson Ltd | Walker Bay Canners 

TWR Training 

Whale coast media 

Berg 'n See 

Private 

Relmar Holdings 


Mammal Research Institute 

PHS Consulting 

ANC 

Carnival pools 

Kleinmond Nature Conservation Society 


Overstrand Conservation Foundation 


Hermanus Ratepayers 

Overstrand Municipality 

Scientist: Land Use Advice| Scientific Services | Cape Nature 

ANC 

Irvin & Johnson Ltd, Abalone Culture Division 

Private 

Aron 

Boet Scheun / Venda 

Vorn 

Andre Visage 

Annette Mason 

Barnad Inez 

Bill Cummingham 

Boet Scheun 

Christiaan De Wett 

Christian Schumann 

Desmond Baard 

Dirkie Kotzé 

Dr Collie 

Francois du Toit 

Fredrich Venter 

G. Bulterman 

Gangale Rila 

Graham Palmer 

Grant McLachlann 

Greg Tutt 

Hennie Beekman 

Ian Banna 

Janine Blignaut 

Jaques Du Plessis 

Johan Hy 

Johan van der Berg 

John Annandale 

John Mathew 

Luelle Hugo 

Lynotn Wepener 

M.A. Raynard 

Matt Naylor 

Meredith Thornton 

Michelle Kruger 

N.R. Koff 

P. M. Schoeman 

Peter Muller 

R. Polleti 

Rob Fryer 

Rob Moffat 

Rodney Anderson 

S. Muller 

Samantha Ralston 

Simo Nodom 

Steyn Miller 

Tessa Spiro

2.3. DISTRIBUTION OF A BACKGROUND INFORMATION DOCUMENT 

A background information document was compiled and sent to all registered interested and affected 

parties, on the 29 th of November 2011 and to all parties registering thereafter.

2.4. PUBLIC MEETING 

A public meeting was held on the 25th of January 2012. The intention of the meeting was to provide 

interested and affected parties with background information and project details and provide 

opportunity for parties to ask questions and comment. The minutes of the meeting are provided 

below. 

EIA Public Participation Process 

Slot-Slope Wave Energy Converter 

MINUTES 

First public meeting 

The Auditorium at the Overstrand Municipality, Hermanus, 25 January 2012 

ANCHOR 

e n v i r o n m e n t a l 

ATTENDANCE 

Name 

Organisation 

Lynotn Wepener 

Private 

P. M. Schoeman Carnival pools 

Hennie Beekman 

Private 

G. Bulterman Private 

John Mathew 

Whale coast media 

Fredrich Venter 

Infoprop 

Boet Scheun 

BS Divers 

Jaques Du Plessis 

Aquafarm 

Graham Palmer 

Private 

Peter Muller 

Klmd Nat Cons Soc 

Tessa Spiro 

Private 

Bill Cummingham 

Lubritech Marketing 

Barnad Inez 

Berg 'n See 

Gangale Rila 

Berg 'n See 

Andre Visage 

Berg 'n See 

Christian Schumann 

Berg 'n See 

Luelle Hugo 

Berg 'n See 

R. Polleti Whale Rock Estate 

Dr Collie 


M.A. Raynard 


S. Muller Overstrand Municipality 

Matt Naylor 


Greg Tutt 

HIK Abalone Farm

Christiaan De Wett 

Grant McLachlann 

Ian Banna 

Johan Hy 

Rob Moffat 

Rodney Anderson 

Michelle Kruger 

Simo Nodom 

N.R. Koff 

Abagold 

HRA 

Berg 'n See 

Abagold 


Hermanus Rate Payers 

PHS consulting 

ANC 

ANC 

WELCOME AND INTRODUCTION 

Dr. Barry Clark (BC) of Anchor Environmental Consultants welcomed the interested and affected 

parties and introduced himself and Karen Tunley from Anchor Environmental Consultants and 

Christo du Plessis (CdP) and Dr. Pierre Hugo (PH) from Abagold. BC explained that Anchor 

Environmental Consultants had been appointed as the environmental assessment practitioner (EAP) 

for the project. BC then gave a presentation which is attached as Annexure 1 to this document. 

BC explained that the term Environmental Impact Assessment (EIA) refers to the process of 

identifying, predicting, evaluating and mitigating the biophysical, social, and other relevant effects of 

development proposals prior to major decisions being taken and commitments made. BC indicated 

that the objectives of an EIA were to (1) help the authorities to decide if the impacts of a potential 

development are acceptable or have to be mitigated in some way, (2) inform the design of 

appropriate monitoring, mitigation, and management measures, and (3) identify and assess 

potential alternatives. 

BC explained that an Environmental Authorization is required to commence a listed activity in terms 

of section 24 of NEMA and that an EIA must be submitted as part of the application. BC explained 

the difference between Basic Assessment (BA) and Scoping and EIA (S&EIA) whereby BA is applied to 

smaller scale activities contained in Listing Notice 1 and 3, the impacts of which are generally known 

and can be easily managed. Typically, these activities are considered less likely to have significant 

environmental impacts and, therefore, do not require a full EIA. S & EIA requires a thorough 

environmental assessment for activities contained in Listing Notice 2, which are those activities that 

(due to their nature and/or extent) are likely to have significant impacts that cannot easily be 

predicted. They are higher risk activities that are associated with potentially higher levels of 

pollution, waste and environmental degradation. BC indicated that the project activities triggered 

listed activities on both Listing notice 1 (R544) and Listing notice 2 (R545) and hence required that 

the applicant follow procedures for Scoping and Environmental Impact Reporting rather than a Basic 

Assessment process. However, BC explained that due to the fact that the potential impacts of the 

project on the environment (including all other beneficial uses of the sea in this area), both in 

respect of the construction and operational phases, are likely to be easy to identify and quantify, are 

likely to be low significance, and will be easy to communicate to and will be easily understood by 

interested and affected parties, the competent authority (Department of Environmental Affairs) had 

given permission to apply BA procedures instead of S&EIR procedures to this project. 

BC explained the steps taken in the BA process starting with the appoint of an EAP (Anchor 

Environmental Consultants), the application to the competent authority to commence an EIA (the 

was submitted in September 2011 and permission to conduct a BA instead of an S & EIA was grant in 

November 2011) and the basic assessment and public participation process which was indicated as

the point in the process at which the project was. BC indicated the public participation process had 

thus far entailed (1) notices being published in local and provincial newspapers (Cape Times, 

Hermanus Times), (2) signboards being posted at the site, (3) written notification being sent to 

organs of state, (4) an I&AP list being opened and maintained and (5) a BID being sent out to 

stakeholders on 28 Nov 2011. BC indicated that this public meeting was part of the public 

participation process and that all I&APs would have further chance to comment on the draft BA 

report which was to be distributed in late February 2012. 

BC indicated the likely impacts of the project to be as follows: 

Impacts to the marine ecology 

o Construction phase – Habitat loss (rocky intertidal and kelp forest) and disturbance 

to adjacent marine environment (water quality and noise) 

o Operational phase – Noise and Impacts of the turbines on fish 

 

 

Visual impacts – Impacts on visual, scenic, aesthetic and amenity values (including “sense of 

place”) during the construction and operational phase 

Socio-economic impacts – increases employment opportunities within Abagold and 

increases revenue generation 

BC explained that two specialist studies had been conducted as part of the impact assessment, the 

first being a marine ecology impact study and the second being a visual impact assessment. 

Question 1: How long will the Environmental Impact Assessment take 

BC: This may typically take 6 months 

Question 2: If there are any changes or extensions will there be another EIA 

BC: Yes anything beyond the scope of this application will need an environmental authorisation. 

Mr Christo du Plessis from Abagold delivered two Powerpoint presentations the first on Abagold’s 

existing operations and the second on the proposed new Wave Energy Converter (WEC) project. 

Both are attached in Annexure 2 of this document. 

CdP indicated that Abagold had been in business since 1985, first started exporting abalone in 1999, 

and currently had three operational abalone farms all in the precinct of the Hermanus Fishing 

Harbour, and a fourth farm under development. It was highlighted that Abagold currently employed 

320 staff and expected this to rise to 500 persons once the new Sulamanzi farm was brought into 

production. He also highlighted the fact that energy costs were the greatest threats to the business 

at present, with electricity costs averaging R800 000 per month (R10 million per annum). CdP 

explained that this was the primary motivation for investigating option for alternative energy and 

that the most promising of these was the generation of electricity from wave energy. 

In the second presentation on the proposed Abagold WEC, CdP explained that Abagold would like to 

adopt a phased approach to the implementation of the project, starting with a pilot WEC able to 

generate approximately 750 kW and an effluent line turbine (a turbine fitted to the base of the 

existing seawater outfall) capable of generating a further 100 kW of electricity, and should this prove 

successful, that Abagold would like to go ahead with the construction of the main WEC capable of 

generating up to 3 MW of electricity. CdP explained the mechanism through which electricity would 

be generated from the wave energy using the WECs (by allowing waves to push sea water into a

eservoir constructed on the coast and how this water would be used to turn a series of turbines as 

it flowed back into the sea). CdP explained that the project development site was on the seashore 

(public property) within the precinct of the Hermanus Harbour, but that potential visual impacts 

from the project were likely to be small given that the project infrastructure was not visible beyond 

the borders of the site on the landward side, and that no infrastructure would project above the 

existing skyline. 

Question 3: What is the length of each of the sloped walls 

CdP: The main WEC is approximately 180 m long, the pilot 40 m and the pump station assistance 

pond 32 m. 

Question 4: Will the turbines be developed locally or internationally 

PH: Locally. We have appointed mechanical and electrical engineers to work on this project. We 

want to do as much locally, preferably in Hermanus, as possible. If maintenance is needed in future 

we do want to have to fly out an international mechanic. There are eight different investigations 

ongoing. The turbine is being worked on here to make sure we have the manufacturing capability 

here. There is also a Stellenbosch student working on wave tanks. 

Question 5: If a reverse osmosis plant is to be developed could the slot slope tanks be used to supply 

seawater to the municipality 

PH: It is potentially an option. 

CdP: There is no copyright on the process or the technology anyone can pick this up and put it in 

place elsewhere. Students can use this as a working model for projects. 

Question 6: Abagold should be commended for the “keeping it local” approach. This is an extremely 

exciting project. However how will global warming and sea level rise impact upon this. 

PH: The design is modular and we could always add another layer to the top of the wall if it is 

needed. 

Question 7: Will the public be able to view the slot-slope WEC 

PH: This project should be recognised as a potential draw card for technical tourism too. It will be 

kept open for viewing. 

Question 8: Have you considered the potential impacts of the heat generated by the turbines 

BC: Similar very low head turbines have been used in rivers in Europe and no detectable heat 

difference in the water has been recorded. 

PH: These turbine operate at about 30b rpm, the heat produced at this speed should not be 

detectable. 

Question 6: How many permanent employees will be appointed to deal directly with the electricity 

generation 

PH: At least six. 

Question 7: Places like Koeberg have had issues with marine biofouling. How are you going to deal 

with this in the WEC 

PH: Ongoing maintenance will be required. For example it is likely that rafts of kelp may accumulate 

in the sump and need to be removed. There will be a road on top of the wall making this kind of 

maintenance feasible. In terms of biofouling, divers can go and physically scrape the walls and slots.

Accessibility has been brought into the planning and design of the WEC. 

Question 8: Will Abagold be completely independent of Eskom 

PH: If this runs at full capacity, yes. However Eskom will have to be used for backup. 

CdP: The use of this facility will free up electricity for other uses. This technology is a great scheme 

and sets a good example for the rest of the country. It is essentially a seed for other renewable 

projects. 

BC then indicated that the basic assessment report would be made available to interested and 

affected parties for a 40 day comment period prior to being submitted to the Department of 

Environmental Affairs. He also indicated that appeals could be made to DEA if interested and 

affected parties were not satisfied with the decision taken by the department. He then closed the 

meeting and indicated that there would be another 20 min available for informal discussion. A 

model of the development and a series of posters were displayed. The posters are provided in 

Annexure 3 of this document. 

2.5. COMMENTS FROM INTERESTED AND AFFECTED PARTIES AND RESPONSES 

from: Mark Anthony Raynard 

to: 

Karen Tunley 

cc: 

Barry Clark 

date: 6 March 2012 22:20 

subject: Re: Slot-slope Wave Energy Converter: first public meeting draft minutes 

Dear Karen and Barry 

Thanx for the mail and i hope u both are well and good.During the meeting 

I did not have any/no questions and went through the project and realised 

that it would in fact have an affect on our development and what we intent 

doing on our sites in Hermanus Harbour. 

The intended structure is envisaged to be right in front of our 

development and it would have a negative affect on our site in terms of 

our views and our economic sales model. 

The structure is cast with cement and it would have a 

devastating/destructive effect on the echology and what we are busy with 

at the sites and would in fact impact negatively on our business as a 

whole. 

The structure would in fact elevate the dangers of huge masses of water 

running in at a speed and put our whole development at risk by creating a 

springboard effect of such masses of water. 

The structure would in fact assist with the running sea water to be 

elevated onto our site and would cause destruction to our business and 

development. 

The proposed technology as well as the impact that it will have on the 

environment is unclear as well as unimaginable to us.It is proposed that 

the applicant present us with a detailed as well as practical examples of 

where this technology is/was applied ,under similar environmental 

conditions. 

It is also proposed that some specialist engineers be called to underwrite 

this experiment. Despite this, we believe that the risk of such an 

innovative experiment is too high, if we consider the delicate nature of

the area in terms of the number of abalone farms that s dependent on the 

pumping of daily fresh sea water,to keep their(high value) farms in 

operation.With a robust coast like ours,it is advisable that a more 

secluded spot or area be identified to do these types of experiments. 

Dispite the fact that we would not like to stand in the way of modern and 

strategic technology being applied, this proposed wall in front of our 

development will defnitely have a negative effect on our premises'view and 

it is likely to increase the risk and endanger our lives in case of a 

storm. 

This extend to which this will be bearable could only be estimated based 

on more practical simulations or practical examples of what it will look 

like. 

Please confirm that all my/our concerns are indeed noted and that it will 

form part of the document and application. 

Thanking u and trusting to hear from u. 

Kind regards 

Mark Anthony Raynard 

Tuna Marine (Pty) Ltd 

Relmar Kelp Industries (Pty) Ltd 

Relmar Holdings (Pty) Ltd 

2 Argon Road, Hermanus Business Park, Hermanus, 7200 

P.O.Box 527, Hermanus, 7200 

satelite fone: 

mobile: +27 73 664 8864 

email: markanthonyraynard@yahoo.com 

office: 071 697 8930 

fax : 086 546 3737 

Skype: markray5851 

ConferenceCall : +27 87825 0190, Code : 207508 # 

Website: www.relmarholdings.com 

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from: Karen Tunley karen@anchorenvironmental.co.za 

to: 

Mark Anthony Raynard 

cc: 

barry@anchorenvironmental.co.za 

date: 22 March 2012 16:06 

Dear Mark, 

Thank you for raising your concerns. I have addressed these below. 

1. The intended structure is envisaged to be right in front of our development and it would 

have a negative affect on our site in terms of our views and our economic sales model.

The proposed site is situated within a harbour / light industrial area. The rocky shore area is in a 

disturbed state and the adjacent coastal areas are developed and used for industrial purposes. The 

proposed development is not out of character with the surrounding land uses and should not detract 

from the overall aesthetics of the area. 

2. The structure is cast with cement and it would have a devastating/destructive effect on the 

echology and what we are busy with at the sites and would in fact impact negatively on our 

business as a whole. 

The design and construction specifications indicate that only precast concrete structures will be used 

in the marine environment and hence there are no significant concerns in terms of water quality as a 

result of the proposed development. 

The construction of all three alternatives will result in severe disturbance of the rocky intertidal and 

infratidal surfaces and associated macrofauna and flora will probably experience high levels of 

mortality. The intertidal rocky habitat at the proposed site is not particularly important in terms of 

biodiversity conservation for rocky intertidal biota. A low species diversity and abundance of fauna 

and flora is supported at this site compared to nearby sites. Furthermore all species, with the 

exception of the fine filamentous alga Centroceras clavulatum, found at this site were found at 

nearby sites. C. clavulatum occurs along the entire coast of South Africa and in Namibia. It is not an 

endangered or endemic species. The rocky shore does provide a food source and habitat to the 

African black oystercatcher. The loss of intertidal habitat will probably lead to a reduction of 

oystercatchers along this particular stretch of coast. However, the average density of oystercatchers 

recorded at this site previously was very low relative to other areas along the south Western Cape 

coast. The significance of the impact is expected to be low for all proposed alternatives. 

The development of solid structures and the alteration to the shape of the coastline may result in 

alterations to the nearshore wave regime. Mr Geoff Toms, a Senior Lecturer at the University of 

Stellenbosch, incumbent in The TNPA Chair of Port and Coastal Engineering, provided a letter of 

advice to AEC concerning the impact that the sloped walls and side walls of the dams may have on 

near-shore wave energy, currents and coastal erosion. The assessment of the impact is based on this 

advice. 

The dominant swell direction for this section of the coast is from the SW. As the wave fronts cross 

into shallower water within the bay the wave fronts bend and the wave crests turn from SW to 

approach locally from the S or even SSE. Shorter waves may cross the swells under some local wind 

conditions (e.g. SE winds). The combined effect of this wave approach is a turbulent local sea 

condition with reflections off the present shoreline rocks. The local angle of approach of 

predominant swells relative to the rocks is almost head-on (wave crests parallel to shore) at the 

proposed site. In the local area of the site there are no boat moorings and no beaches or structures 

and no access to the area for the general public. There are seawater intake and discharge structures 

for Abagold and two other abalone farms positioned on rocks, and the breakwater of the New 

Harbour is positioned similarly in an exposed area just north-east of the site. 

The currents in the area are very weak and mostly wind or wave driven. The local currents at the site 

will not be significantly affected by the implementation of any of the three alternatives and no 

undermining of structures or dangerous currents for bathers or navigation will occur. 

In the present situation (without the WEC), wave energy is taken from the incoming waves due to 

turbulent breaking on the rocks and some residual energy is reflected back to sea as waves radiated 

from the rocks. The sloping walls of the WEC will provide some extraction of wave energy with less 

turbulence and some reflection of residual wave energy will still occur in the form of seaward

adiated waves. The relative amounts of reflection or absorption with or without the WEC could not 

easily be determined. Typically on a rocky shoreline it is expected that 20-40% of the wave energy is 

reflected, while on a smooth slope this figure can increase to 40-60% depending mainly on the slope 

and the wave characteristics. It is expected that a reduced reflection would occur on a smooth 

porous slope with some energy extraction, not by turbulence, but by a WEC device. The resulting 

reflections may not be significantly greater than those of the present rocky shore. However, the 

wave reflection pattern from the WEC is likely to be more regular than that of the rocky shore 

because the wave crest impact lines with the device will be straighter than those of an irregular 

rocky shore. Due to oblique walls (in Alternatives (1) and (2)) there will be crossing lines of reflection 

which can accentuate the turbulence of the local area somewhat. 

Since the seabed is predominantly rocky it is not expected that erosion of the seabed will occur but 

there may be a slight redistribution of the sand pockets among the rock gulleys. Erosion of structures 

or coasts is not expected. The vessels entering the existing port or maneuvering towards it will not 

face 

3. The structure would in fact elevate the dangers of huge masses of water running in at a 

speed and put our whole development at risk by creating a springboard effect of such masses 

of water. The structure would in fact assist with the running sea water to be elevated onto our 

site and would cause destruction to our business and development. 

The harbour wall dolosse reach 6m above MSL and have a foot of 30m. Waves have breached this 

wall a few times over the last twenty years, even though the harbour wall is set at an angle to the 

prevailing waves. Relmar faces the waves directly and therefore, irrespective of whether the WEC is 

built, serious measures to prevent storm damage will have to be taken by Relmar. Abagold have 

proposed incorporating these in the planning of the WEC. 

4. The proposed technology as well as the impact that it will have on the environment is 

unclear as well as unimaginable to us.It is proposed that the applicant present us with a 

detailed as well as practical examples of where this technology is/was applied ,under similar 

environmental conditions. 

The impacts of the proposed technology are not unclear. A marine specialist report provides detail 

of the potential impacts of the development. Summary tables of the potential impacts and 

significance thereof are provided below. 

TABLE 1. SUMMARY OF THE POTENT IAL IMPACTS TO THE MARINE ENVIRONMENT AND THE SIGNIFICANCE THEREOF LIKELY TO 

OCCUR DURING THE CONSTRUCTION OF THE PROPOSED WECS. 

Potential Impact 

Direct losses of intertidal and infratidal biota in 

development footprint 

Barotrauma of marine fauna as a result of blasting 

(With mitigation) 

Noise disturbance to marine fauna 


Impaired water quality 


Alternative 

1 

Alternative 

2 

Alternative 

3 

Low Low Low 

Low Low Low 

Medium Medium Medium 

Low Low Low 

Pollution/litter during construction Low Low Low


TABLE 2. SUMMARY OF THE POTENT IAL IMPACTS TO THE MARINE ENVIRONMENT AND THE SIGNIFICANCE THEREOF LIKELY TO 

OCCUR DURING THE OPERATION OF THE PROPOSED WECS. 

Potential Impact 

Alternative 

1 

Alternative 

2 

Alternative 

3 

Heat and noise generation by turbine operation Very Low Very Low Very Low 

Fish mortality in turbines Very Low Very Low Very Low 

Permanent changes in nearshore wave regime patterns Very Low Very Low Very Low 

5. It is also proposed that some specialist engineers be called to underwrite this experiment. 

Despite this, we believe that the risk of such an innovative experiment is too high, if we 

consider the delicate nature of the area in terms of the number of abalone farms that s 

dependent on the pumping of daily fresh sea water ,to keep their(high value) farms in 

operation. With a robust coast like ours ,it is advisable that a more secluded spot or area be 

identified to do these types of experiments. 

This site has been chosen for its suitable characteristics. Not least of these is the fact that it is 

adjacent to the harbour with its light industrial zoning. 

The preferred phased approach is a precautionary one and the pilot plant in front of Abagold’s own 

farm will demonstrate the efficacy of the technology prior to the full scale project being 

implemented. 

6. Dispite the fact that we would not like to stand in the way of modern and strategic 

technology being applied, this proposed wall in front of our development will defnitely have a 

negative effect on our premises'view and it is likely to increase the risk and endanger our lives 

in case of a storm. 

Already discussed 

7. This extend to which this will be bearable could only be estimated based on more 

practical simulations or practical examples of what it will look like. 

Several detailed posters were displayed and explained at the meeting 

A three dimensional scale model has been available at public meetings and openly 

discussed and is constantly displayed at Abagold’s reception. 

Photos from the sea have been superimposed with designed structures and presented 

A professional visual impact assessment has been done and the report is available 

Please contact me if you have any further concerns or feel that yours have not been adequately 

addressed. 

Kind regards, 

Karen Tunley |senior consultant 

Anchor Environmental Consultants 

8 Steenberg House 

Silverwood Close 

Tokai

7945 

South Africa 

www.anchorenvironmental.co.za 

Tel: +27 21 701 3420 

Fax: +27 21 701 5280 

Peter M. Schoeman – Generally interested. Very exciting project. 

Graham Palmer – My interest is in the Economic development of Hermanus and in the general 

development of renewable energy sources. I am supportive of the initiative. I have concerns over the 

pollution of the coastline during construction, ie. The pouring of concrete etc in the surf zone. 

Mrs Annette Mason (Chairperson / Ward 9 delegate) – [interest in project] As a member of a coastal 

environmental society totalling 300-400 member, and as an elected member representing 

environmental interests and concerns on the Ward 9 committee. Views: A very desirable low 

pollution industry. Fully in favour of the “coffer dam and Kaplan turbine” suggestion as being an 

environmentally acceptable option. Very interested in the economic efficiency of a “wave energy” 

project. Would seem to enable continued employment and expansion of labour force – very 

desirable.

3 SECOND PHASE 

The second phase of public participation comprised a stakeholder comment period. The Draft BAR 

was distributed to authorities and made available for a 40 day comment period from 23 March to 2 

May 2012 in order to allow interested and affected parties (I&APs) and authorities an opportunity to 

comment on the Draft BAR. Copies of the full report were made available at the following locations: 

 

 

 

 

Hermanus public library; 

Abagold Offices, New Harbour , Hermanus; 

Offices of Anchor Environmental Consultants; and 

Website of Anchor Environmental Consultants (www.anchorenvironmental.co.za). 

Emails were sent to all registered stakeholders informing them of the availability of the Draft BAR 

and the comment period. 

Comments were received from stakeholder via email and two meetings, one with authorities and 

one with employees of neighbouring abalone farms. 

from: 

to: 

date: 

subject: 

Rowan Yearsley 

Karen Tunley 

Wed 2012/05/02 08:14 AM 

RE: Slot-slope wave energy converter: draft BAR available for comment 

Dear Karen 

I hereby submit the attached comment on behalf of Mr Jacques du Plessis of Aquafarm Development 

(Pty) Ltd. Please send us a receipt to acknowledge that you have received it. 

Regards 


Research & Development Manager: Abalone Division 

Terrasan Group Ltd , Mariculture Division, New Harbour, Hermanus 7200 

TEL: +27 28 312 4513 FAX: +27 28 313 2440 MOBILE: +27 72 636 1571 

Email: rowan@aquafarm.co.za 

A member of the TerraSan Group of Companies

Given the number of concerns raised by Aquafarm it was agreed that an additional meeting be held 

between Aquafarm, Abagold and Anchor Environmental Consultants. The minutes of the meeting 

are detailed below as well as a response to Aquafarm. 

Date: 8 June 2012 

Minutes 

Venue: 

Time: 

Aquafarm, Hermanus 

10h00-11h30 

ATTENDANCE: 

Aquafarm Abagold Anchor 

Environmental 

Jacques Du Plessis JDP Pierre Hugo PH Barry Clark BC 

Rowan Yearsley RY Christo Du CDP 

Plessis 

No 

. 

Item 

Discussion 

1. Welcome 

and 

Introduction 

s 

2. Issues of 

concern 

raised by 

Aquafarm 

PH agreed opened the meeting. He apologised for not including the 

Aquafarm sump and pumphouse on the site drawings for the WEC 

project. He indicated this was merely an oversight rather than a 

deliberate omission. He acknowledged that as an abalone farmer himself 

he was well aware of the importance of water quality on the farms. 

JDP outlined concerns that Aquafarm had with the proposed WEC 

project: 

o Insufficient detail provided on construction methods; 

o Potential impacts on water quality were not adequately addressed 

in the report (toxicity of newly cast concrete, blasting, sediment 

plumes, all represent risks to adjacent abalone farms); 

o Aquafarm water intake should be included on site plans along with 

key project infrastructure (coffer dams etc); 

o Impact on nearshore wave energy has not been adequately 

assessed, specifically impacts to Aquafarm pumphouse 

o Impact of blasting on infrastructure on other farms (e.g. seawalls); 

o Project EMP does not provide for sufficient consultation and liaison 

with neighbouring farms – more frequent meetings and 

notifications are required; and 

o Accumulation of debris (kelp and sediment) in the coffer dams and 

impact on water quality needs to be addressed 

He asked that each of these issues be address in more detail in the Basic 

Assessment report to enable them and other stakeholders to better

3 Discussion 

on key 

design 

features for 

the project 

understand the risks, and if necessary additional mitigation measures to 

be applied to mitigate the risks. 

BC suggested that they tackle these issues one by one such that a 

common understanding could be reached, and a way forward agreed to. 

All were in agreement with this proposal. 

PH acknowledged that not all aspects of the project were explained in 

detail in the BAR report. He proceeded to explain the key design 

features at the meeting: 

o The project combine 4 existing technologies: a slot-slope wall for 

capturing wave energy, one way valves on the back of the wall, a 

reservoir for smoothing water flows, and low head turbines. 

o He acknowledged that there were some risks to the environment 

and other beneficial uses thereof (notably water quality and altered 

wave dynamics) but was confident that these could be properly 

mitigated through the EIA process. 

BC explained the process that they had followed for the EIA to date. 

Anchor had appointed Prof Geoff Tomms from Stellenbosch University to 

assess potential impacts of wave dynamics while they (Anchor) had 

looked at impacts on water quality as part of the marine specialist study. 

Prof Tomms had indicated at the time when the original assessment was 

done that he was comfortable to provide a professional opinion on 

impacts of wave dynamics and that he felt it was not necessary to 

undertake full scale wave modelling at the time due to the nature of the 

project (he felt that impacts would be small). BC acknowledged though 

that Prof Tomms had not specifically considered impacts on the 

Aquafarm sump and pumphouse as these had not been reflected on the 

site plans he had been issued with. 

CDP suggested that they amend the site drawing to reflect these 

components and that they ask Prof. Tomms to come out for a second 

site visit to be undertaken with representatives from Aquafarm such that 

all concerns can be articulated directly to Prof. Tomms and that he can 

then make an assessment of the risks and agree on how these can 

effectively be mitigated. 

JDP explained that Aquafarm were particularly concerned about swells 

from the SW and S that may reflect off the E wall of the pilot WEC and 

run up against the Aquafarm boundary wall and into the pumphouse. 

BC agreed that he would ask Prof. Tomms to come out for a second site 

visit on a mutually convenient date. Everyone was comfortable with this 

approach. 

RY then highlighted Aquafarms concerns regarding water quality, 

particularly relating to casting of concrete in the sea and potential 

toxicity to farmed abalone. 

PH explained that they had no intention of pouring concrete directly into 

the sea and that there would be no direct contact between fresh 

concrete and seawater. He proceeded to give a detailed description with 

conceptual diagrams of how the coffer dams would be constructed.

PH explained that the coffer dams will be modular in the construction 

and would comprise a series of base units and pre-cast concrete units 

that would be slotted on top of these. Construction of the base units 

would start with a steel frame (termed a coffer dam in the BAR) with 

adjustable legs. This work would only be done under very clam 

conditions – when wave height was

JDP thanked PH for his explanation and agreed that potential impacts to 

water quality would be low if the methods as described were followed 

and that he wanted to see this detailed plan incorporated into the BAR. 

He also requested that adequate warning be provided to the 

neighbouring abalone farms regarding days when concrete would be 

poured. This would allow them to be on standby to turn off their intake 

pumps should there be an accident (i.e. fresh concrete released into the 

sea). He also suggested that casting be done when there was sufficient 

water movement to disperse any spilled concrete (i.e. perhaps avoid 

extremely calm conditions). He also suggested that the abalone farms 

could use their pumps to clear any contaminated water should this be 

necessary by pumping water directly to waste for a period of time. 

RY indicated he was also satisfied with the proposed construction 

method provided issues raised by JDP were adequate addressed. He 

indicated that it was very important that stakeholders were kept up to 

date on all proposed activities on a weekly or even daily basis. He 

suggested that a stakeholder forum be established through which all 

communications be directed. He indicated that weekly forum meetings 

would probably be adequate but this may need to be more frequent 

when concrete pouring, blasting or drilling was undertaken. He stressed 

that they would need advance warning for all these activities. 

JDP also expressed concern regarding impacts of blasting and how this 

may affect the integrity of their infrastructure (e.g. seawall). He indicated 

that he needed to see more detail on how, where and when this would 

take place. 

CDP explained that almost all blasting would take place above the water 

line and would follow similar protocols to blasting that was being 

undertaken for their existing Sulaimanzi project. He explained that there 

had been concerns or complaints about this owing to the fact that they 

were using Nonex rather that high explosive. JDP agreed with this. 

JDP asked if it would not be possible to move the pilot WEC further away 

from the Aquafarm site. Currently it is situated right on the border of 

their farm. 

CDP explained that this was the only suitable site for the pilot WEC as it 

was a small bay with exactly the right bottom profile and dimensions. 

There were no other suitable sites in the immediate area. He suggested 

that the construction work be undertaken in a stepwise manner and that 

they confirm with the stakeholder forum that all stakeholders were 

happy before proceeding to the next step of the process. 

RY indicated that he was still concerned about biofouling, and 

accumulation of debris in the reservoirs and how this would be cleared. 

He indicated that if biofouling material was simply scraped off the walls 

of the dam into the sea that this material could either accumulate in the 

area or be sucked into the Aquafarm sump and block the pump. He was 

also concerned that if debris was allowed to accumulate in the sump of 

the WEC reservoirs that this would decay and negatively affect water 

quality in the area. 

PH explained that the reservoirs would be cleaned of debris every few 

days. This would be undertaken at low tide and was possible as the floor 

of the reservoirs was at means ea level. He suggested also that they

could create deeper sump in the bottom of each of the reservoirs from 

which debris (kelp, sand and gravel) could be pumped using a gravel 

pump. This material would be disposed of on land (landfill). JDP and RY 

indicated that they were satisfied with this explanation. 

5 Closure The meeting closed at 11h30. PH thanked JDP and RY for attending the 

meeting and for their inputs. BC indicated that he would be in touch to 

arrange a site meeting with Geoff Tomms as soon as possible. RY 

requested that that Aquafarm be given an opportunity to have a look 

and comment on the revised BAR report before it was submitted to DEA. 

BC agreed that this was a good idea and undertook to do this. 

A second site vist was arranged for Prof. Geoff Toms to assess the impacts of altered wave energy 

and currents on the Aquafarm infrastructure as agreed in the meeting held on the 8 th of June 

between Aquafarm, Abagold and Anchor Environmental Consultants. 

Date: 2 July 2012 

Minutes 

Venue: 

Time: 

Aquafarm, Hermanus 

10h00-11h30 

ATTENDANCE: 

Aquafarm Abagold Anchor 

Environmental 

Rowan Yearsley RY Pierre Hugo PH Barry Clark BC 

Christo Du CDP Geoff Tomms GT 

Plessis 


1. Welcome 


Introductions 

2. Site 

inspection 

BC introduced GT to the other participants 

RY thanked everyone for attending 

PH produced copies of the revised site plans showing the location of the 

Aquafarm sump and pumphouse in relation to the proposed WEC 

infrastructure 

RY explained briefly Aquafarms concerns with the proposed WEC project 

and then suggested that everyone go out on site to have a look at how 

the WEC infrastructure would be oriented in relation to the existing 

infrastructure. All agreed. 

Everyone went out on site. PH explained and indicated how the various 

components of the WEC project would be aligned on site including the 

pilot, main and pump assistance ponds and the effluent line turbine. 

GT inspected all the relevant features and examined the orientation of 

the shoreline and WEC infrastructure in relation to the Abagold and

Aquafarm seawalls and the Aquafarm sump and pumphouse. He took a 

number of photographs of the site. He asked PH if he could provide 

heights of the various rocky promontories on the site and a number of 

questions relating to the dimensions of the infrastructure (height of the 

sloped and side walls of the WECs). He explained what impact he 

thought the WEC infrastructure would have on wave energy and water 

movement at the site. He indicated that he was only concerned about 

extreme storms and that his main concern related to the reflection of 

waves off the side of the pilot WEC up against the Abagold sea wall and 

from there towards the Aquafarm pumphouse during these events. He 

indicated that it may be necessary to place some large boulders against 

the base of the wall at this point to break up the waves and thus 

mitigate any potential impacts on the seawalls and the pumphouse. He 

indicated that he would amend his original report to reflect these 

findings. He also indicated that full-scale wave modelling may be 

required at a later stage to inform the minimum size of boulder required 

but that this was not warranted at this stage of the project. He was 

confident that mitigation of this nature would be effective. 

5 Closure The meeting closed at 11h30. PH and RY thanked everyone for 

attending the meeting and for their inputs. GT promised that he would 

prepare his report as quickly as possible. BC indicated that they would 

update the BAR accordingly, incorporating findings of GT study and 

other issues discussed at the two meetings with Aquafarm. He 

undertook to send a draft copy of the report to RY as soon as it was 

ready. 

from: Karen Tunley 

to: 

Jacques duPlessis and Rowan Yearsley 

date: Thu 2012/08/16 02:26 PM 

subject: RE: Comments on draft Basic Assessment Report for Wave Energy Converter - 

Aquafarm Development 

Dear Jacques and Rowan, 

Thank you for providing comment on the Draft BAR for the proposed development and operation of 

a slot-slope wave energy converter for Abagold. The minutes of the meetings held between 

yourselves, Abagold and Anchor are attached. The BAR and accompanying documents (Maine 

Specialist Report and Environmental Management Programme) have been revised to address these 

concerns. I have summarised the measures that have been taken to address your concerns below. A 

copy of the revised BAR will be sent to you shortly. 

1. Construction details. 

A more detailed description with illustrations of the construction activities has been 

provided in the marine specialist report and the BAR. This should help to clarify any 

confusion regarding coffer dams and the casting of cement in the marine environment and 

help to alleviate several concerns raised.

2. Water quality impacts to Abalone Farms 

Potential impacts of impaired water quality to neighbouring abalone farms has been 

assessed as a separate impacts in both the marine specialist report and the BAR. 

3. Management measures to mitigate potential water quality impacts have been included in 

the marine specialist report the BAR and the EMPr. 

The recommended measures are precautionary management measures to mitigate the 

severity of potential impacts by ensuring that personnel are available on site at each of the 

farms to manage the intake systems during blasting and the casting of cement. A monthly 

schedule of planned activities is to be made available by Abagold and discussed with all 

neighbouring abalone farms. During periods when casting and/or blasting activities are 

planned, weekly activity schedules indicating the proposed dates of casting and/or blasting 

activities must be provided to neighbouring abalone farms. At least one days notice 

regarding changes to this schedule must be issued to all potentially affected farms. 

Construction activities (notably casting and blasting operations) should be limited to week 

days to ensure that there are personnel on site at the other abalone farms to respond to any 

incidents that may occur. Prior agreement must be sought from other abalone farms for 

casting and blasting operations to be undertaken outside of these periods. (These measures 

are recommended in the marine specialist report and repeated in the BAR and EMPr). 

4. The position of Aquafarm’s water abstraction point has been indicated on the site diagrams. 

5. Professor Geof Tomms conducted a second site visit and revised his contribution to the 

marine specialist report such that the impacts of nearshore wave energy alteration on 

Aquafarm’s infrastructure, as a result of the WEC were considered and mitigation measures 

recommended. These recommendations are reflected in the marine specialist report the 

BAR and the EMPr. 

6. The EMPr has been amended such that an ECO is required to conduct weekly site 

inspections and be on site for all blasting and cement casting activities. No ECO has been 

appointed at this stage. It is likely that one will only be appointed once Abagold have 

received authorisation and secured a lease for the sea shore. 

7. The risk of the build up of organic matter within the WEC dams was addressed during the 

design phase of the project. The plans presented to Anchor by Abagold included actions to 

remove kelp and fouling organisms from the WEC dams during the operational phase. As 

such Anchor did not assess this as a potential impact. During the revision though this was 

added as a required management measure in the EMPr during the operational phase. 

I hope that you are satisfied with the amendments. 

Kind regards, 




Silverwood Close

Tokai 

7945 

South Africa 


Tel: +27 21 701 3420 

Fax: +27 21 701 5280 

From: Rowan Yearsley [mailto:rowan@aquafarm.co.za] 

Sent: 10 September 2012 09:03 AM 

To: 'Karen Tunley' 

Cc: 'Adri Claassen' 

Subject: AQF final comments on revised BAR for Wave Energy Converter 

Dear Karen 

We were approached by Abagold to discuss the revised BAR and asked to submit a final comment on 

this. Our final comment is attached. 

Regards 


Research & Development Manager: Abalone Division 

Terrasan Group Ltd , Mariculture Division, New Harbour, Hermanus 7200 

TEL: +27 28 312 4513 FAX: +27 28 313 2440 MOBILE: +27 72 636 1571 

Email: rowan@aquafarm.co.za 

A member of the TerraSan Group of Companies 

Important Notice 

Important restrictions, qualifications and disclaimers ("the Disclaimer") apply to this 

email. To read this, click on the following address or copy into your Internet browser: 

http://www.terrasan.co.za/disclaimer 

The Disclaimer forms part of the content of this email in terms of Section 11 of the 

Electronic Communications and Transactions Act, 25 of 2002.

From: 'Karen Tunley' 

Sent: 10 September 2012 09:05 AM 

To: Rowan Yearsley 

Cc: 'Adri Claassen' 

Subject: AQF final comments on revised BAR for Wave Energy Converter 

Hi Rowan, 

I have received your final comments. These will be included in the BAR to be submitted to DEA. We 

will make the necessary changes to the EMP. 

Kind regards, 

Karen Tunley |senior consultant

from: 

to: 

date: 

subject: 

Greg Tutt 

Karen Tunley 

Wed 2012/05/02 04:52 PM 


Hi Karen 

Herewith our comments on the draft BAR. 

On the whole we have no major issues with the BAR, but would like to request the following: 

During the construction phase, Abagold are to contact the neighbouring farms (especially 

HIK as we share the same sump site) prior to blasting to confirm that it suits the farms from 

a production and operational perspective 

Although the units will be precast, there will need to be pouring of some concrete, again we 

request timeous notification prior to the pouring of any concrete in and around the sump 

area. 

Abagold to ensure HIK access to the pumphouse at all times during construction. 

Construction as far as possible to be limited to weekdays only, to avoid crises over weekends 

when there are limited staff on site. 

Also are Anchor acting as the ECO If so are you the contact person 

regards 

Greg Tutt 

(Technical manager) 


Tel: 028-313 1055 

Fax: 028-312 2288 

Cell: 082 3644 876 

www.hik.co.za 

from: 

to: 

date: 

subject: 

Karen Tunley 

Greg Tutt 

Thu 2012/08/16 01:55 PM 


Dear Greg, 


a slot-slope wave energy converter for Abagold. The BAR and accompanying documents (Maine 

Specialist Report and Environmental Management Programme) have been revised to address these 

concerns. I have indicated below the measures that will be required of Abagold and the respective 

contractors as provided in the BAR:

1. Additional management measures were requested by the neighbouring abalone farmers 

and it is recommended that these measures be made mandatory. The recommended 

measures are precautionary management measures to mitigate the severity of potential 

impacts by ensuring that personnel are available on site at each of the farms to manage 

the intake systems during blasting and the casting of cement. A monthly schedule of 

planned activities is to be made available by Abagold and discussed with all neighbouring 

abalone farms. During periods when casting and/or blasting activities are planned, 

weekly activity schedules indicating the proposed dates of casting and/or blasting 

activities must be provided to neighbouring abalone farms. At least one days notice 

regarding changes to this schedule must be issued to all potentially affected farms. 

Construction activities (notably casting and blasting operations) should be limited to 

week days to ensure that there are personnel on site at the other abalone farms to 

respond to any incidents that may occur. Prior agreement must be sought from other 

abalone farms for casting and blasting operations to be undertaken outside of these 

periods. (These measures are recommended in the marine specialist report and 

repeated in the BAR and EMPr) 

2. HIK Abalone Farm extract water from the sea for operations on their farm via a 

pumphouse situated on the Abagold site. In order to ensure HIK Abalone Farm’s 

operations are not negatively disturbed access to the pumphouse must be granted to HIK 

Abalone Farm throughout the construction period. (This can be found within the EMPr) 

No ECO has been appointed at this stage. It is likely that one will only be appointed once Abagold 

have received authorisation and secured a lease for the sea shore. 

I hope that you are satisfied with these amendments. The Final BAR is to be submitted shortly to 

DEA as part of the application for authorisation. A copy of the Final BAR will be made available to all 

stakeholders. 

Kind regards, 

Karen Tunley |senior consultant

A meeting and site inspection between the authorities (DEA, Cape Nature and Overstrand 

Municipality), Abagold and Anchor Environmental Consultants was arranged to discuss the EIA 

process to date and going forward and to provide more clarity regarding the proposed project and 

the locality. The lease agreement mentioned in Cape Nature’s comments on the draft BAR above 

was discussed at this meeting. 

Date: 11 June 2012 

Minutes 

Venue: 

Time: 

Abagold, Hermanus 

10h00-11h30 

ATTENDANCE: 

Name Affiliation Abbreviation 

Takalani Maswime DEA TK 

Tierck Hoekstra Cape Nature: Area Manager, Overberg TH 

Penelope Aplon Overstrand Local Municipality PA 

Christo Du Plessis Abagold CD 

Barry Clark Anchor Environmental BC 


1. Welcome 


Introductions 

BC welcomed everyone to the meeting and thanked them all for taking 

the time to attend. BC explained that the meeting had been called at 

the request of the authorities (both DEA National and DEA: Oceans and 

Coasts had requested this meeting to give the various authorities 

responsible an opportunity to visit the site and discuss the project). 

When the meeting was due to start, a number of participants who had 

been invited to the meeting (notably DEA: Oceans & Coasts, Overberg 

District Municipality, DEADP) had not yet arrived, so it was agreed to 

wait a while to give them a chance to get there. 

After a further 20 minutes it was agreed to start as no one else had 

arrived. 

2. EIA process BC explained the process that had been followed for the EIA. He 

explained that an application had initially been submitted to DEADP and 

that they had been referred to DEA due to the nature of the project 

(electricity generation). DEA had agreed to downgrade the project from 

Scoping and EIA to Basic Assessment. A BA draft report had been 

circulated in March 2012. He also summarised potential impacts that 

had been identified in the report and responses that had been received 

from stakeholders. 

TH asked if an application for lease of the land had been submitted to 

Cape Nature. 

CDP explained that Niel Malan and other representatives from DEA: 

Oceans & Coasts had indicated that due to the nature of the project that

an application for lease of sea space would have to be made to the 

National Assembly rather than through the normal channels (in this case 

Cape Nature). He indicated that they had been advised to wait until the 

BAR had been submitted before initiating this process. 

TH felt this was very irregular and undertook to follow this issue up with 

the legal advisor at Cape Nature. 

TK queries if the project required approval from NERSA (National 

Electricity Regulator of South Africa). 

BC explained that they had invested this and that NERSA had confirmed 

that as the electricity was for own use only and would not be fed into 

the national grid that their approval was not required. 

TK asked about the status of the objection from Mark Raynard regarding 

visual impacts and impacts on wave energy. 

CDP explained that Mark Raynard had a lease on the seashore adjacent 

to the Abagold site which he proposed using to construct an abalone 

farm. Approval for this development had been issues several years ago 

but nothing had yet been done. He also explained that Mr Raynard was 

also investigating options for building a hotel on the landward side of 

the site next to the Abagold farm. 

BC explained that Anchor had commissioned both Visual and a Wave 

energy specialist studies as part of the EIA process. The Visual specialist 

(B. Oberholzer) had indicated that the proposed development was fully 

in keeping with the existing developments on the site (an industrial area 

within a commercial fishing harbour which including existing abalone 

farming infrastructure) and that potential visual impacts of the proposed 

project were considered to be low. The Wave energy specialist (Prof. G 

Tomms) has confirmed that the proposed infrastructure would not 

result in any increase in wave energy on the site and that if anything 

wave energy would be reduced due to the nature of the project 

(harvesting of wave energy for electricity generation). 

BC also explained that Aquafarm (another abalone farm on the W side of 

Abagold) had also expressed concern regarding impacts on wave energy 

and water quality and that these were being addressed in consultation 

with Aquafarm. 

PA asked about the various project components. 

CDP explained that the project comprised 4 components including a pilot 

WEC, the main WEC, a pump assistance pond and the effluent line 

turbine. He explained the function of each component and how it was 

designed to work. 

3 Site visit All meeting participants then went out on site for an inspection. 

CDP explained the proposed layout of all components of the project the 

infrastructure on the site and answered all question relating to this. 

5 Closure The meeting closed at 12h00. BC thanked all the participants for 

attending the meeting and promised that the final BAR report would be 

finalised as quickly as possible and would be sent to DEA.

from: 

to: 

date: 

subject: 

Karen Tunley 

Samantha Ralston 

Thu 2012/08/16 02:37 PM 


Dear Samatha, 


a slot-slope wave energy converter for Abagold. The BAR and accompanying documents (Maine 

Specialist Report and Environmental Management Programme) have been revised to address 

concerns raised by neighbouring abalone farms. 

A meeting and site inspection between the authorities (DEA, Cape Nature and Overstrand 

Municipality), Abagold and Anchor Environmental Consultants was arranged to discuss the EIA 

process to date and going forward and to provide more clarity regarding the proposed project and 

the locality. The lease agreement mentioned in Cape Nature’s comments on the draft BAR above 

was discussed at this meeting. Please find the minutes from this meeting attached. 

The Final BAR is to be submitted shortly to DEA as part of the application for authorisation. A copy of 

the Final BAR will be made available to all stakeholders. 

Kind regards, 




Silverwood Close 

Tokai 

7945 

South Africa 


Tel: +27 21 701 3420 

Fax: +27 21 701 5280

appendix e: comments and responses report - Anchor Environmental

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