APPLICATION FOR AMENDMENT OF ENVIRONMENTAL … filedraft impact assessment report application for amendment of environmental authorisation: erasmuspark mixed use township portion of

DRAFT IMPACT ASSESSMENT REPORT

APPLICATION FOR AMENDMENT OF ENVIRONMENTAL

AUTHORISATION: ERASMUSPARK MIXED USE

TOWNSHIP

PORTION OF THE R/E OF THE FARM WATERKLOOF 378 JR

GAUT: 006/19-20/E0111

Prepared for:

Atterbury Property Fund Managers (Pty) Ltd

AUGUST 2019

Erasmuspark Amendment Application: Gaut 006/19-20/E0111

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TABLE OF CONTENTS

1.0. INTRODUCTION AND BACKGROUND ............................................................................................................4

1.1. PURPOSE OF THE APPLICATION............................................................................................................................................. 4 1.2. PROPOSED AMENDMENTS ................................................................................................................................................... 4 1.3. APPLICATION PROCESS ....................................................................................................................................................... 4

2.0. THE PROJECT SITE ........................................................................................................................................4

2.1. GEOGRAPHICAL LOCATION OF THE SITE.................................................................................................................................. 4 2.2. SPATIAL ENVIRONMENTAL ATTRIBUTES OF THE SITE- ................................................................................................................ 8

2.2.1. Fauna and Flora .................................................................................................................................................. 8 2.2.2. Wetland ............................................................................................................................................................... 8

3.0. ALIGNMENT WITH APPLICABLE LEGISLATION AND POLICIES .........................................................................8

4.0. MOTIVATION FOR THE PROPOSED AMENDMENT ....................................................................................... 10

4.1. NEED AND DESIRABILITY- HOSPITAL .................................................................................................................................... 10 4.1.1 Accessibility ....................................................................................................................................................... 10 4.1.2 Local need for hospital facility .......................................................................................................................... 11 4.1.3 Socio economic impact ...................................................................................................................................... 11

4.2. THE BIO-RETENTION PONDS .............................................................................................................................................. 11 4.2. ADVANTAGES AND DISADVANTAGES OF THE PROPOSED AMENDMENT ...................................................................................... 12

5.0. PUBLIC PARTICIPATION PROCESS ............................................................................................................... 12

5.1. PROCESS TO BE FOLLOWED................................................................................................................................................ 12

6.0. IMPACT ASSESSMENT ................................................................................................................................ 13

6.1. METHODOLOGY USED ...................................................................................................................................................... 13 6.2. CRITERIA FOR RATING OF IMPACTS ..................................................................................................................................... 14 6.3. ASSESSMENT OF IMPACTS .................................................................................................................................................... 14

6.3.1 Pre-Construction phase ........................................................................................................................................... 15 6.3.2 Construction phase ................................................................................................................................................. 15 6.3.3. Operational phase ............................................................................................................................................. 17

7.0. AMENDMENTS TO THE EMPR .................................................................................................................... 20

8.0. ENVIRONMENTAL IMPACT STATEMENT ..................................................................................................... 20

List of Figures

Figure 1: Locality Map ............................................................................................................................................................. 5 Figure 2: Approved layout ....................................................................................................................................................... 6 Figure 3: Proposed layout ....................................................................................................................................................... 7 List of Tables

Table 1: Explanation of the methodology variables ............................................................................................................. 13 Table 2: Criteria for rating of impacts ................................................................................................................................... 14


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Table 3: Potential impacts and mitigation measures during the pre-construction phase ................................................... 15 Table 4: Potential impacts and mitigation measures during the construction phase .......................................................... 15 Table 5: Potential impacts during operational phase ........................................................................................................... 17

List of Annexes

Annexure 1: Environmental Authorisations .......................................................................................................................... 21 Annexure 2: Layout Plans ...................................................................................................................................................... 22 Annexure 3: Stormwater Management Plan ........................................................................................................................ 23 Annexure 4: Ecological Motivation for ................................................................................................................................. 24 Annexure 5: Draft EMPr ........................................................................................................................................................ 25


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1.0. INTRODUCTION AND BACKGROUND

1.1. Purpose of the application

Atterbury Property Fund Managers (Pty) Ltd have applied to the Gauteng Department of Agriculture and Rural Development (GDARD), the competent authority, for the amendment of the Environmental Authorisation (EA) referenced Gaut: 002/16-17/E0221, issued on 12 June 2017. This application has been issued with reference Gaut: 006/19-20/E0111.

The EA allowed for the development of a mixed-use township. The layout plans in the relevant annexures provides a clear illustration of the various development components with associated thresholds that will be established on the site. Since the authorisation was issued, the applicant has reconsidered the different types of development components proposed on the site, as influenced by the market in the short to long term, the site conditions on site. The applicant has concluded that the layout of the township needs to adjusted as well as identified a need for a hospital in the area.

1.2. Proposed amendments

This amendment application is therefore meant to amend the EA and associated approved layout plan by:

1. Swapping the position of residential and office development. This will allow offices to be located close the entrance to the precinct and adjacent to the shopping centre

2. development of a hospital on part of the site authorised for office development, and 3. updating of the EMPr in order to accommodate the proposed amendments.

Although the information currently available pertaining to the hospital indicates that facility will provide private health care facilities including a trauma centre, full details of the facility will only be available once an actual application for license is lodged with the relevant Department of Health.

1.3. Application process

This amendment application follows a Part 2 Amendment Process as per Regulation 31 and 32 of the Environmental Impact Assessment Regulations, 2014, promulgated in terms of the National Environmental Management Act, 1998. The process is a scaled down type of Impact Assessment in comparison to the normal Environmental Impact Assessment process; reasons being that a full EIA process had already been undertaken during the initial application of the Environmental Authorisation.

2.0. THE PROJECT SITE

2.1. Geographical location of the site

The application site is situated northwest of the N1, northeast of the R21 and south of Solomon Mahlangu

Drive. The proposed development is situated on the Remaining Extent of the Farm Waterkloof 378 JR, see

Figure 1 and for orientation through geographic information.

Figure 1: Locality Map

Figure 2: Approved layout

Figure 3: Proposed layout

2.2. Spatial environmental attributes of the site-

2.2.1. Fauna and Flora

According to the GDARD Conservation Plan Version 3.3, the entire site is designated as a Critical Biodiversity Area due to presence of natural grassland and its suitability as habitat for various threatened species of fauna and flora. As such, a huge part of the site has been excluded from development as it is considered to have potential characteristics suitable for preservation of continuous existence of sensitive flora and fauna species in the area. Continuous existence of these species is confined locally on the site and its immediate surrounding.

Studies conducted concluded that the area to be excluded from development (not affected by this application) can at best be described as rocky grassland rather than a rocky outcrop which has patches of intact grassland. The studies noted that historical anthropogenic activity in the area, including agriculture, development of roadways and substantial dumping of building rubble, the grassland and the primary grassland has been isolated and thus the small remaining sensitive grassland is under greater threat from the surrounding agents of change.

According to the studies, the sensitivity of the site is further threatened by alien invasive species, especially along the many footpaths criss-crossing the outcrop. With no connectivity with other natural grassland areas, the continued existence of a healthy vegetation unit is doubtful. Further, no Red List or Orange List species occur on the rocky outcrop.

2.2.2. Wetland

The area in the southern section of the site represents an unchannelled valley-bottom wetland. In terms of plant species composition, the wetland represents moist grassland dominated by grasses such as Setaria sphacelata, Sorghum bicolor and Sporobolus africanus, although sedges also occur in the HGM. The valley bottom wetland provides a distribution route for weeds and invading trees. Many of the usual weeds were recorded together with Eucalyptus camaldulensis (Red river gum), Xanthium strumarium (Large cocklebur) Datura stramonium and Flaveria bidentis.

According to the wetland assessment, the Ecological Importance and Sensitivity of this HGM unit is considered to be Low due to the impoundments, stands of alien invasive species, sedimentation and overgrazing that modified the area. These wetlands are not ecologically important and sensitive at any scale. The biodiversity of these Wetlands is ubiquitous and not sensitive to flow and habitat modifications. They play an insignificant role in moderating the quantity and quality of water that feeds the larger rivers of the area.

Except for the proposed bio-retention ponds which the Department of Water and Sanitation expressed preference for, the amendments do not affect the wetland and its buffer. However, the bio-retention ponds will be developed in such a way that part of the ponds lie within the buffer-zone but discharge outside of the 1:100 year floodline. The design of these structures (ponds and discharge areas) will enhance, rather negatively affect the buffer zone areas. The above is supported by an ecologist who notes that ‘the correct design and placement of bio-retention ponds within the buffer could in actual fact support greater diversity and species richness (Liu et al., 2014), due to the evidence observed on site of transformation of the floristic characteristics of the valley bottom wetlands (Exigo Sustainability, 2016). Studies have found bio-retention ponds had a significant increase in plant and invertebrates’ taxa (Liu et al., 2014)’.

3.0. ALIGNMENT WITH APPLICABLE LEGISLATION AND POLICIES

This section provides a brief overview of some of the pertinent legislations, policies, guidelines as well as legal and administrative requirements applicable to the proposed development.


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The Constitution of the Republic of South Africa, 1996 The Constitution of the Republic of South Africa, 1996 makes a provision for access to health care services. Section 27. (1) of the Constitution states that “everyone has the right to have access to health care services, including reproductive health care”. Section 27. (3) further states that “no one may be refused emergency medical treatment”. The above constitutional principle applies to the proposed development of a hospital in the area in that there is a need for more health care facilities in the area to ensure that access within reasonable distance in terms of availability and as well as timeframe to get to a health care facility is realised. The National Health Act, 2004 The Act provides regulatory mechanism for national health and to provide uniformity in respect of health services by establishing a national health system which encompasses public and private providers of health services; and further provides varieties of health facilities and services for the population of the Republic that available resources can afford. The proposed development of a hospital in the area will enhance such objective contained in the National Health Act and this will be ascertained in the application and approval of the facility by the Department of Health. National Environmental Management Act No. 107 of 1998 (NEMA) The NEMA provides the overarching framework for environmental management and enables the promulgation of the Regulations for Environmental Impact Assessment. It sets out the principles that serve as a general framework for environmental management, a reference to which organs of state must exercise their functions and guide other laws concerned with the protection and/or sustainable management of the environment. The application takes into account the environmental and socio-economic conditions in compliance with the NEMA principles. The National Environmental Management: Biodiversity Act (Act 10 of 2004) The Act provides for the management and conservation of South Africa’s biodiversity within the framework of the NEMA. Areas of high biodiversity need to be protected. Although parts of the site had some ecologically sensitive areas, this has been addressed through the proposed offset in the form of a linked open space area. The proposed location of the hospital is not characterised by high biodiversity features. National Heritage Resources Act, 1999 (Act No. 45 of 1999 (NHRA) The Act aims to promote good management of the national heritage resources. According to the Act the South African Heritage Resources Agency (SAHRA) must be notified during the early planning phases of a project for any development that meet certain criteria. The Agency has been notified as required. Any artefacts uncovered during the construction phase will be reported to SAHRA. Environmental Impact Assessment Regulations, 2014 These regulate the procedure and criteria for the preparation, evaluation, submission, processing and consideration of, and decision on, applications for environmental authorisations and granting of requested amendments to environmental authorisation. The regulations aim to ensure the avoidance or mitigation of detrimental impacts on the environment, while supporting the optimisation of the positive environmental impacts emanating from identified activities. The amendment application falls within the ambit of the Regulations and should be processed in terms of what is provided for as Part 2 (two) amendment process; this report serves to meet requirements of Part 2 amendment process.


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Gauteng Provincial Environmental Management Framework, 2015 The EMF provides a guide for the protection and enhancement of environmental assets and natural resources along with development patterns to ensure sustainable development within the Province and further regulate potential conflicting land use activities through spatial environmental planning. The proposed amendment is in line with the provisions of the EMF objectives. The Gauteng Conservation Plan, 2011 The Gauteng Conservation Plan (C-Plan) is a provincial decision-support tool used for the protection of provincial ecosystems and associated biodiversity. The C-Plan acts as an information tool for conservation of sensitive areas as it can map important biodiversity areas. According to this plan, the site is situated within a critical biodiversity area. However, recent studies show that the site is not entirely sensitive as some areas have been degraded. Therefore, the proposal does not deviate from the provisions of this plan. Tshwane Region 3 Spatial Development Framework 2012 The site is located in Region 3 of the City of Tshwane Metropolitan Municipality. According to the RSDF, the site is within a mixed-use development zone where a combination of land uses such as a mix of commercial/residential/ industrial/retail/entertainment/institutional uses is proposed. Therefore, the proposed development is aligned with the provisions of the framework, particularly, the proposed hospital as an institutional development is aligned with the policy objective outlined in the RSDF. Tshwane Open Space Framework (TOSF) The TOSF aims to entrench understanding of the intrinsic value of Open Space and then to develop a visionary roadmap towards the creation of an exceptional open space network for the city and its people. According to Volume 3 of the TOSF, the TOSF can be defined as ‘a conceptualisation of interconnected open space that accommodates human and natural ecologies, systems and processes, developed to spatially manifest the open Space Vision. The proposed development, which includes the proposed hospital as well as open space component, subscribe to the concept envisioned in the TOSF. The sensitive portions of the site including the wetland corridor will be left as open space.

4.0. MOTIVATION FOR THE PROPOSED AMENDMENT

The section below describes the need and desirability as well as benefits of the requested amendment.

4.1. Need and desirability- Hospital

The proposed mixed-use development already has an environmental authorisation which was subsequently amended following the decision of the appeal process. The approved layout plan allowed for mixed use development, which included development of offices on Erf 2. Changes in the economic outlook, which changes determines economic potential for various development activities necessitated reconsideration of the initial plan to development offices as part of the development components on the site. As such, the applicant has decided to establish, on Erf 2 of the layout plan, a hospital instead of initially planned offices.

4.1.1 Accessibility

The proposed development site is eaily accesible in the area through exisitng off-ramps from N1 highway onto R21 highway and then from R21 highway onto Solomon Mahlangu Drive. There is also exisitng Van Ryneveld Avenue road (M28) and Bayside Road leading into the development’s internal roads; these roads will provide easy access to the


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proposed development and the hospital specifically. The proposed hospital will be well within easy access from all directions for the public. Further, it must be noted that traffic impact for the entire development has been undertaken during the initial EIA process and the proposed changes from offices to a hospital will not affect the then findings of the initial traffic count undertaken during the initial EIA process.

4.1.2 Local need for hospital facility

The area does not have a hospital within a radius of approximately 2 kilometres with only Mediclinic kloof as the closest health facility. Pretoria and Waterkloof specifically is an urban area and a hospital within a radius of approximately 1 kilometre will be sustainable because it will be within the reach of the public in the said radius as well as from outside such a radius. Therefore, there is need for the proposed hospital in the area.

4.1.3 Socio economic impact

It is now an accepted fact that if supply is high, there is a potential benefit (“socio-economic”) spilling over to consumers and in this case, there will be potential competition for higher standard for such facilities in the vicinity. The development of hospital in the area means that public will not be travelling longer distances (more than approximately 2 kilometres) for such services as the facility is now within their reach, thus prompting other facilities in the immediate vicinity to up the standard of services. The introduction of National Health Insurance and associated financing system will also be significant regarding availability and accessibility of health care facilities such as hospitals in South Africa and in this case, in the vicinity of areas in Pretoria.

4.2. The bio-retention ponds

While the initial development concept, specifically the stormwater management approach required the traditional pipe-discharge point structures, discussions with the Department of Water and Sanitation suggested that that bio-retention ponds should be considered instead discharge points. Because discharge points are sometimes associated with poor management and potential for erosion and clogging up of affected wetland systems, the developer was encouraged to investigate the development of such ponds instead. These ponds have been included in the water use licence application which, according to the latest information received, would be issued shortly.

According to the engineers, the bio-retention ponds were designed with inputs from landscape architects and specifications provided by a wetland specialist to enhance biodiversity within the buffer zone. The following were taken into consideration:

• Ponds to be located and discharge outside the 1:100-year floodline;

• The bottom of the bio-ponds to be lined with topsoil to allow for revegetation and plants growth;

• Localised low points approximately 500mm deep to be created to simulate stagnant water of a wetland;

• Sides of the bio-retention ponds to be grassed or protected with a Bio-jute or similar product;

• The owner will take responsibility to maintain and clean the ponds.

According to the biodiversity specialist, not only would the bio-retention ponds “bolster” the effect of the buffer zone in management stormwater, but these ponds would contribute to biodiversity and aesthetic value of these open spaces. It is also worth noting that the proposed bio-retention ponds would also contribute to the enhancement of water quality, fulfilling the second objective of these structures.


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Figures 2 and 3 above illustrate how the proposed development in its entirety will interface with the natural environment that has been excluded from the development area as described in the respective legends. However, it should be considered that the geographic information (figure 2&3) was not prepared and designed specifically for this amendment application as the development area for the proposed hospital was determined and approved during the initial application for environmental authorisation, albeit as a different development component. The geographic information is merely to demonstrate the envisioned development and environment interface on the site.

4.2. Advantages and disadvantages of the proposed Amendment

Some of the main advantages associated with the proposed amendment include the following:

• The proposed development of hospital will:

o will result in a more employment generation which will in turn contribute to economic growth;

o bring health services facility closer to the public in the area; and

o Together with other development components, the hospital will enhance marketability of the area more

than it would have been for office development.

• The bio-retention ponds are likey to:

o support greater diversity and species richness associated with the wetland area;

o enhance the functioning of the wetland area while increasing surface water and vegetation in the area;

o enhance the development by providing an ecological area that is likely to attract birdlife and the value of

the open space area;

o lead to proper management of stormwater discharge and prevention of erosion of the riparian zone.

The proposed hospital has some disadvantages as identified below:

• The proposed hospital will generate traffic impact throughout the day but manageable count. This impact is not new as office establishment would have generated the same traffic count but mostly at peak hours of the morning and afternoon.

• Generation of medical waste.

• Visual impact on neighbouring residential areas; this will be addressed through design of the structures while taking into consideration that the area already has development structures at a height of 2 (two) storey. Therefore, while the hospital will introduce new visual impact in the area, the establishment of such impact (visual) already exist in the area and the hospital will attempt to enhance its aesthetic view.

5.0. PUBLIC PARTICIPATION PROCESS

5.1. Process to be followed

The proposed amendment will be advertised in the regional newspaper and site notices will placed at places or locations clearly visible to the public. Direct consultation with Interested and Affected Parties (I&APs) will be limited to I&APs that registered during the initial application for environmental authorisation as this is not a new application but amendment to the Environmental Authorisation issued on 12 June 2017. The Gauteng Department of Health, the Local Authority and the relevant councillor will also be consulted on this application. It should be noted that necessary application for approval/certificate in terms National Health Act will not be part of this application as that will be a separate process with the Department of Health.


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6.0. IMPACT ASSESSMENT

The assessment of impacts associated with the proposed amendment include the identification of the environmental impacts and then applying the assessment criteria to determine the significance of such impact. The assessment of construction phase will also be partly covered in this report as it was thoroughly done during the initially proposed offices on the subject development area and the impacts are not different; operational impact will also be addressed in this report.

Considering the above, the identification, assessment and rating of impacts is only focusing on potential new impacts

that were not assessed during the initial EIA process. For ease of reference, the report will also contain potential

significant impacts associated with construction phase and operation to illustrate that the impacts associated with the

initial development component (offices) and proposed changes (hospital) are similar.

6.1. Methodology Used

The potential environmental impacts associated with the proposed changes to the EA were evaluated according to the

nature, extent, duration, intensity, probability and significance of the impacts as explained below.

Table 1: Explanation of the methodology variables

• Nature: classification of whether the impact is positive or negative, direct or indirect.

• Extent: spatial scale of impact and classified as: O Site: the impacted area is the whole or significant portion of the site. O Local: Within a radius of 2 km of the construction site. O Regional: impacted area extends to the immediate, surrounding and neighbouring properties. O National: the impact can be of national significance. • Duration: Indicates the lifetime of the impact and is classified as: O Short term: The impact will either disappear with mitigation or will be mitigated through natural process in a span

shorter than the construction phase. O Medium term: The impact will last for the period of the construction phase, thereafter it will be entirely negated. O Long term: The impact will continue or last for the entire operational life of the development, but will be mitigated

by direct human action or by natural processes thereafter. The only class of impact which will be non-transitory. O Permanent: Mitigation either by man or natural process will not occur in such a way or in such a time span that

the impact can be considered transient. • Intensity: Describes whether an impact is destructive or benign; O Low: The natural, cultural and social functions and processes are not affected. O Moderate: Affected environment is altered, but natural, cultural and social functions and processes continue

albeit in a modified way. O High: Natural, cultural and social functions and processes are altered to extent that they temporarily cease. O Very High: Natural, cultural and social functions and processes are altered to extent that they permanently

cease. • Probability: Describes the likelihood of an impact occurring: O Improbable: Likelihood of the impact materialising is very low O Possible: The impact may occur O Highly Probable: Most likely that the impact will occur O Definite: Impact will certainly occur


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• Significance: Based on the above criteria the significance of issues was determined. The total number of points scored for each impact indicates the level of significance of the impact, and is rated as:

O Low: the impacts are less significant. O Medium: the impacts are significant and require attention; mitigation is required to reduce the negative

impacts. O High: the impacts are of great importance. Mitigation is therefore crucial. • Cumulative: In relation to an activity, means the impact of an activity that may not be significant but may

become significant when added to the existing and potential impacts eventuating from similar or diverse activities or undertakings in the area.

• Mitigation: Mitigation for significant issues is incorporated into the EMPr.

6.2. Criteria for Rating of Impacts

Table 2: Criteria for rating of impacts

Criteria for the rating of impacts

Criteria Description

Extent National Regional Local Site

Duration Permanent Long-term Medium-term Short- term

Intensity Very high High Moderate Low

Probability Definite Highly probable Possible Improbable

Points allocation 4 3 2 1

Significance Rating of classified impacts

Impact Points Description

Low 4-6 A low impact has no permanent impact of significance. Mitigation measures are feasible and are readily instituted as part of a standing design, construction or operating procedure.

Medium 7-9 Mitigation is possible with additional design and construction inputs.

High 10-12 The design of the site may be affected. Mitigation and possible remediation are needed during the construction and/or operational phases. The effects of the impact may affect the broader environment.

Very high 13-16 The design of the site is affected. Mitigation and possible remediation are needed during the construction and/or operational phases. The effects of the impact may affect the broader environment.

Status Perceived effect of the impact

Positive (+) Beneficial impact

Negative (-) Adverse impact

Negative impacts are shown with a (-) while positive ones are indicated as (+)

6.3. Assessment of Impacts

As the assessment relates to the amendment application, the identification and assessment of impacts focuses mainly on ‘new’ impacts or those considered different to the impacts assessed during the initial application process. Therefore, this assessment must be read in conjunction with the assessments undertaken during the initial application process and subsequent amendment process.


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Pre-construction impacts are similar to those that would have resulted from the implementation of the authorised development component. Therefore, except where emphasis is placed on particular impacts, no additional assessment was done for this application.

6.3.1 Pre-Construction phase

Table 3: Potential impacts and mitigation measures during the pre-construction phase

Aspect/impact Significa

nce

before

mitigati

on

Mitigation and Management Measures Significa

nce after

mitigatio

n

PERMIT REQUIREMENTS

Non-compliance with

legislative and policy

requirements

• All permits and legal requirements and policy directives must be complied with as required by authorities.

• Environmental induction for all construction staff on site to ensure that basic environmental principles are adhered to.

• A health and safety plan must be developed prior to the commencement of construction to identify and avoid work related accidents.

Fauna and Flora search • A search and rescue operation for threatened flora and fauna to be carried out before commencement of construction.

6.3.2 Construction phase

Table 4: Potential impacts and mitigation measures during the construction phase


nce

before

mitigati

on

Mitigation and Management Measures Significan

ce after

mitigatio

n

SITE ESTABLISHMENT

Site demarcation

• The Contractor shall erect and maintain permanent and/ or

temporary fences around the construction site. The construction

camp, material stores and lay-down areas should be screened

and sited as far as possible from the local roads.

• Disturbed areas rather than pristine or intact landscape areas should preferably be used for the construction camp

• The Contractor shall restrict all his activities, materials,

equipment and personnel to within the area specified


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nce

before

mitigati

on


ce after

mitigatio

n

Site access/routes

Poor control of vehicular movement and management of edge effects leading to impacts on environment and causing traffic congestion

• The main access points on the project site must be clearly sign-

posted and delivery areas must be communicated to all suppliers

and sub-contractors.

• Movement of all vehicles to remain on designated routes.

• The vehicles shall not exceed a speed of 40 km/h or less on gravel

or temporary roads on the site.

• No parking of construction vehicles along Simon Mahlangu or

Van Ryneveld Avenue or any existing public roads thereby

compromising vehicular movement along these routes and

causing traffic congestion.

Impact on sensitive

areas

• The sensitive areas must and will be fenced/cordoned off

with a fence that allows movement of fauna species

escaping development; access to the fenced off area must

be controlled to prevent unauthorised access. The only

access includes maintenance and/or emergency incidents in

the restricted area.

• It is important that fauna be deterred from the road surface

by putting up a barrier along either side of the road section

passing through the sensitive area. Natural vegetation along

the movement corridor must be retained to provide

temporary shelter. No strong lighting should be used near

the corridor and culverts.

• Alien invasive vegetation must be managed and/removed

on site as per specialist recommendations. It is

recommended that a site-specific Alien Invasive Species Plan

be commissioned for the effective eradication and

management of invasive species.

• An Ecological Management Plan must be compiled for the

management of the open space area and should include:

o Firebreak and burning management;

o Access control system;

o Environmental Awareness Plan during construction

phase of the development.


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nce

before

mitigati

on


ce after

mitigatio

n

Ablution facilities

• Inadequate and/or poorly positioned facilities leading to potential pollution and limited use

• Release of odours because of the chemical toilets on site.

• The Contractor shall provide suitable sanitary facilities at the

Contractor’s Camp and approved points around designated

work area to allow easy access for employees on site.

• The Contractor shall keep the toilets in a clean, neat and

hygienic condition.

• Toilets are to be emptied prior to builders’ holidays and

serviced once a week, to ensure that no odours originate

from this source and to ensure hygienic conditions for

employees.

Vegetation clearance

Loss of flora species

diversity and habitat

characteristics

affecting pollination,

increased run-off and

contribute to climate

change

• Vegetation clearance should preferably be phased rather

than clearing of the entire site at once.

• Removal of vegetation should be kept to a minimum;

• Areas that lost some vegetation due to effects of

development should be revegetated to reduce the size of

hard surfaces on the development, reduce amount and

velocity of run-off as well as contribute to climate change

reduction.

• Removal of invasive alien plant species must be in

accordance with Alien Invasive Management Plan.

6.3.3. Operational phase

Table 5: Potential impacts during operational phase

Aspect/impact Significance before mitigation

Mitigation and Management Measures Significance after mitigation

FAUNA AND FLORA AND OPEN SPACE MANAGEMENT

Loss of Fauna and

Flora

General human

interference and

impact leading to loss

of species diversity

and habitat

characteristics

• Areas that are bare need to be revegetated with indigenous

vegetation to prevent encroachment by alien invasive plant

species.

• The site is to be kept clear of invasive alien vegetation

species, in line with the Alien Invasive Management Plan.

• The use of pesticides and herbicides is to be limited to a

bare minimum and are to be strictly controlled, and limited

to only biodegradable, natural substances.


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• Maintain indigenous vegetation community on the Project

Site wherever possible.

• A palisade fence around sensitive area must be considered

to make provision for a link between soft surfaces on the

development site and the natural ecological system on the

sensitive area’s side. This will also allow movement of small

fauna species between the 2 (two) areas as they interface.

Lack of proper

management of the

open space area

• The entire south-western corner of the property will be

rehabilitated to return the area to a more natural condition

free of alien and invasive vegetation and less desirable

grassland species as stated in the previous EMPr submission

following the appeal decision on the matter.

• To protect this area, the proponent will:

- Develop and implement a detailed rehabilitation and

continuous management plan for the open space area;

- Have enough fire management infrastructure to prevent

excessive fire damage; and

- The overall management of the area must be overseen by

an appropriately qualified individual.

High rise structures

leading to visual

intrusion into

neighbouring

residential areas

• Although municipal plans in the area allows for high rise

building to a maximum of approximately 7 storeys, the

surrounding existing residential areas (Res 1) are not

adjoining the boundary of the proposed hospital erf and any

visual impact intrusion from that distance is very low.

• The proposed main development as well as existing

structures in the vicinity is also consisting of high-rise

structures.

Broader Visual

impact in the

vicinity

• As stated above, the development plans in the area permit

structures of more than 1 (one) storey; the existing

development around the dam near the R21/N1 interchange

is also double storeys too. Therefore, visual impact due to

high rise building in the area has been established and the

proposed hospital, depending on the number of floors, will

not be introducing a new impact in the area. However, the

building structures will be designed in a manner that

absorbs existing visual scenery in the area to reduce


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potential visual lighting that may be negative onto the open

space area and surrounding residential areas (existing and

proposed).

Risks associated

with poor

management of

health care waste

leading to possible

pollution (air, water,

soil and aesthetic)

thus causing

diseases, injuries.

• Impact must be minimized within the health facility itself

through proper waste management system to prevent

unnecessary entry into waste stream requiring disposal.

• The hospital facility must and will enforce implementation

of specific guidelines for the segregation, storage, collection

and movement of health care waste within the facility. This

will be done as it is a prerequisite for establishing and

operating a health care facility.

• Management of all types waste of waste from generation

to disposal / movement must be done in accordance with

national, provincial, regional and municipal regulations and

legislations.

• The facility and its practitioners shall comply with Booklet

12 on Guidelines for the Management of Healthcare Waste,

2016, by Health Professions Council of South Africa.

• All waste including health care risk waste must be packaged

in containers which are colour coded (Red, Orange, Blue,

Yellow, Black /Dark Green) and marked in accordance with

SANS 10248 -1.

• Applicant or persons in control of the hospital must ensure

health care risk waste is separated from general waste at

source.


that health care risk waste is segregated in accordance with

SANS 10248 -1.


that reusable containers are thoroughly cleaned and

decontaminated prior to reuse.


that containers and interim storage containers are labelled

in line with the Waste Classification and Management

Regulations.


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that health care risk waste storage area is-

o inaccessible to unauthorised persons;

o secured by use of locks on entry doors or gates or

container lids;

o protected from direct sunlight and rain;

o appropriately ventilated;

o vermin proof;

o provided with a spill containment and clean -up kit;

o provided with water to facilitate cleaning;

o resourced with appropriate wastewater management

system;

o provided with adequate space for storing clean and

dirty containers separately;

o clearly signposted with appropriate warning signs.

7.0. AMENDMENTS TO THE EMPR

The EMPr has been amended by including the impacts associated with the bioretention ponds and the operation of

the hospital. The amended EMPr is being submitted as part of this amendment process.

8.0. ENVIRONMENTAL IMPACT STATEMENT

The proposed amendment to the initial EA for purposes of changing the location of residential component, inclusion of hospital facility on part of the area initially authorised for offices as well as inclusion of bio-retention ponds will not result into significant detrimental environmental impacts that may not be managed to an acceptable level. This is because the environmental impact assessment rating in this report indicates that the impacts will be low after mitigation. Any other impacts such on traffic, services (water, sewer, stormwater) have already been determined in the initial EIA process and the findings were not significantly negative. Swapping of development component and the change from offices to a hospital does not change the then outcome of the initial EIA process (impacts ratings) as the development components (res, ffices and hospital) falls within one listed activity; and as such, their associated impacts are generally similar apart from medical waste associated with a hospital.

The mitigation and management measured proposed above in relation to health care waste are just a minimum; the proposed hospital facility shall comply with the various legislations, regulations, guidelines and norms and standard for effective management of day-to-day operation of the hospital as prescribed into those documents.


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Annexure 1: Environmental Authorisations

• Copy of a valid Environmental Authorisation

• Copy of MEC’s decision on appeal

• Copy of MEC’s clarification of his decision on appeal


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Annexure 2: Layout Plans

1. Approved Layout Plan 2. Proposed Layout Plan


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Annexure 3: Stormwater Management Plan


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Annexure 4: Ecological Motivation for

Bio-retention Ponds


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Annexure 5: Draft EMPr

Documents

APPLICATION FOR AMENDMENT OF ENVIRONMENTAL … filedraft impact assessment report application for amendment of environmental authorisation: erasmuspark mixed use township portion of