ENVIRONMENTAL MANAGEMENT PROGRAMME Golf Estate... · Olivewood Trade & Invest 23 (Pty) Ltd is reapplying for environmental authorisation for the construction of 102 housing units

ENVIRONMENTAL MANAGEMENT PROGRAMME

OLIVEWOOD GOLF AND COUNTRY ESTATE

Prepared for:

Olivewood Trade & Invest 23 (Pty) Ltd Olivewood, Schafli Road,

Chintsa East, 5257 082 503 2730

Prepared by:

EOH Coastal & Environmental Services EAST LONDON

25 Tecoma Street, Berea East London, 5214

043 726 7809

Also in Grahamstown, Port Elizabeth, Cape Town, Johannesburg and Maputo (Mozambique)

www.cesnet.co.za | www.eoh.co.za

October 2015

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

Environmental Management Programme – October 2015

EOH Coastal & Environmental Services Olivewood Golf And Country Estate 2

TABLE OF CONTENTS 1 INTRODUCTION..................................................................................................................... 3

1.1 Objectives of the EMPr .................................................................................................... 3 1.2 Form and function of an EMPr ......................................................................................... 4 1.3 Legal requirements .......................................................................................................... 5

2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT TEAM ............................................... 6 2.1 Dr Alan Carter ................................................................................................................. 6 2.2 Dr Greer Hawley .............................................................................................................. 7 2.3 Ms Rosalie Ann Evans .................................................................................................... 7

3 PROPOSED ACTIVITY........................................................................................................... 8 3.1 Description of proposed activity ....................................................................................... 8 3.2 Site Location.................................................................................................................... 8

4 SCOPE OF THE EMPR ........................................................................................................ 10 4.1 Layout of the EMPr ........................................................................................................ 10 4.1.1 Construction Phase ................................................................................................... 10 4.1.2 Operational and maintenance phase ......................................................................... 10

5 ROLES AND RESPONSIBILITIES ....................................................................................... 11 5.1 Applicant ....................................................................................................................... 11 5.2 Contractor ..................................................................................................................... 11 5.3 Environmental Control Officer ........................................................................................ 11

6 MITIGATION AND/OR MANAGEMENT MEASURES .......................................................... 13 6.1 General issues and mitigation measures ....................................................................... 13 6.1.1 Construction Phase ....................................................................................................... 13 6.1.2 Operational Phase ......................................................................................................... 15 6.2 Site specific issues and mitigation measures ................................................................. 15 6.2.1 Construction Phase ....................................................................................................... 15 6.2.2 Operational Phase ......................................................................................................... 17

7 ENVIRONMENTAL AWARENESS ....................................................................................... 19 8 COMPLIANCE WITH THE EMPR ......................................................................................... 20

8.1 Non-compliance and complaints .................................................................................... 20 8.2 Emergency preparedness.............................................................................................. 20 8.3 Incident reporting and remedy ....................................................................................... 21 8.4 Penalties ....................................................................................................................... 21

9 CLOSURE PLANNING ......................................................................................................... 22 9.1 Final site restoration ...................................................................................................... 22 9.2 Rehabilitation................................................................................................................. 22

10 REPORTING ......................................................................................................................... 23 10.1 Administration ................................................................................................................ 23 10.2 Good housekeeping ...................................................................................................... 23 10.3 Record keeping ............................................................................................................. 23 10.4 Document control .......................................................................................................... 23

11 CONCLUSIONS.................................................................................................................... 25 APPENDIX A ................................................................................................................................ 26



1 INTRODUCTION Olivewood Trade & Invest 23 (Pty) Ltd is reapplying for environmental authorisation for the construction of 102 housing units. The development will form part of the larger Olivewood Golf and Country Estate, authorised through an EIA process on the 10 January 2005 (Reference: 1/7/2/19/04). The proposed development consists of the construction of 102 houses. This development will include the following: • Private open space; • Sewage Treatment: technology, location and required pumping capacity; and • Solid Waste Management. The sewage produced by this portion of the Olivewood Golf and Country Estate will be treated onsite using activated sludge technology. The estimated volume to be treated is approximately 0.1Ml/day. This falls below the 2Ml threshold that requires authorisation.

Figure 1: Layout of the proposed development.

1.1 Objectives of the EMPr The EMPr has been compiled to provide recommendations and guidelines in order to minimise the environmental impacts during the construction phase and should be used for compliance monitoring during the construction phase of the Olivewood Golf and Country Estate. This EMPr informs all relevant parties [the Project Coordinator, the Contractor(s) and all other staff employed by Olivewood Trade & Invest 23 (Pty) Ltd at the site] as to their duties in the fulfilment of the legal requirements for the construction and operation of the golf and country estate with particular reference to the prevention and mitigation of anticipated potential environmental impacts.



The objectives of the EMPr are to:

ensure compliance with regulatory authority stipulations and guidelines which may be local, provincial, national and/or international;

identify a range of mitigation measures which could reduce and mitigate the potential impacts to minimal or insignificant levels;

detail specific actions deemed necessary to assist in mitigating the environmental impact of the project;

identify measures that could optimise beneficial impacts; and

ensure compliance with safety requirements.

1.2 Form and function of an EMPr An EMPr focuses on sound environmental management practices, which should be undertaken to minimise adverse impacts on the environment through the lifetime of a development. In addition, an EMPr identifies which measures will be in place or will be actioned to manage any incidents and emergencies that may occur during operation of the facility. As such, the EMPr provides specifications that should be adhered to, in order to minimise adverse environmental impacts associated with the operations of the development.

According to APPENDIX 4 of GN R 982, an environmental management programme must include: (a) Details of –

(i) The EAP who prepared the environmental management programme; and (ii) The expertise of the EAP to prepare an environmental management programme, including

a curriculum vitae; (b) A detailed description of the aspects of the activity that are covered by the draft environmental

management programme as identified by the project description; (c) A map at an appropriate sale which superimposes the proposed activity, its associated structures,

and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers;

(d) Information on any proposed management or mitigation measures that will be taken to address the environmental impacts that have been identified in a report contemplated by these Regulations, including environmental impacts or objectives in respect of –

(i) Planning and design; (ii) Pre-construction; (iii) construction activities; (iv) Rehabilitation of the environment after construction and where applicable post closure;

and (v) where relevant, operation activities;

(e) a description and identification of impact outcomes required for the aspects contemplated in (d). (f) a description of proposed impact management actions, identifying the manner in which the impact

management objectives and outcomes contemplated in paragraphs (d) and (e) will be achieved, and must, where applicable include actions to –

(i) Avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;

(ii) Comply with any prescribed environmental management standards or practices; (iii) Comply with any applicable provisions of the Act regarding closure, where applicable; (iv) Comply with any provisions of the Act regarding financial provisions for rehabilitation,

where applicable; (g) The method of monitoring the implementation of the impact management actions contemplated in

paragraph (f); (h) The frequency of monitoring the implementation of the impact management actions contemplated

in (f); (i) An indication of the persons who will be responsible for the implementation of the impact

management actions;



(j) The time periods within which the impact management actions contemplated in paragraph (f) must be implemented;

(k) The mechanism for monitoring compliance with the impact management actions contemplated in paragraph (f);

(l) A program for reporting on compliance, taking into account the requirement as prescribed by the regulations;

(m) An environmental awareness plan describing the manner in which – (i) The applicant intends to inform his or her employees of any environmental risk which may

result from their work; and (ii) Risks must be dealt with in order to avoid pollution or the degradation of the environment;

and (n) Any specific information that may be required by the competent authority.

1.3 Legal requirements The Contractor shall identify and comply with all South African national and provincial environmental legislation, including associated regulations and all local by-laws relevant to the project. Key legislation currently applicable to the design, construction and implementation phases of the project must be complied with. The list of applicable legislation provided below is intended to serve as a guideline only and is not exhaustive:-

The Constitution of the Republic of South Africa Act 108 of 1996

Environment Conservation Act 73 of 1989

National Environmental Management Act 107 of 1998

National Environmental Management: Protected Areas Act 57 of 2003

National Environmental Management: Biodiversity Act 10 of 2004

National Forests Act 43 of 1983

National Water Act 36 of 1998

Conservation of Agricultural Resources Act 43 of 1983

National Veld and Forest Fire Act 101 of 1998

Hazardous Substances Act 15 of 1973

National Heritage Resources Act 25 of 1999

Atmospheric Pollution Prevention Act 45 of 1965

National Environmental Management: Air Quality Act 39 of 2004

National Environmental Management: Waste Management Act 59 of 2008

Mineral and Petroleum Resources Development Act 28 of 2002

Health Act 63 of 1977

Occupational Health and Safety Act 85 of 1993

White Paper on the Conservation and Sustainable Use of South Africa’s Biological Diversity

All relevant provincial legislation, municipal by-laws and ordinances.



2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT TEAM According to APPENDIX 4 of GN R 982, an environmental management programme must include:

(a) Details of – (i) The EAP who prepared the environmental management programme; and (ii) The expertise of the EAP to prepare an environmental management programme, including

a curriculum vitae;

Environmental Consulting Company:

EOH Coastal & Environmental Services

25 Tecoma Street, Berea, East London Tel: (043) 726 7809 Fax: (043) 726 8352 e-mail: [email protected] www.eoh.co.za | www.cesnet.co.za Project team:

Dr Alan Carter

Dr Greer Hawley

Ms Rosalie Evans Coastal & Environmental Services (CES) was established in 1990 as a dynamic, rapidly growing specialist environmental consulting company. Recently, EOH Group of Companies has acquired the shares in CES. EOH is the largest provider of enterprise applications, technology, outsourcing, cloud and managed services. This integration will allow CES to combine EOH’s great reach and reputation with CES’s recognised excellence in environmental and social advisory services, thus maximizing CES’s strengths and comprehensive offerings in the environmental and social fields. EOH-CES has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Plans (EMPs), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes (www.cesnet.co.za). EOH-CES has been active in all of the above fields, and in so doing have made a positive contribution towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries.

2.1 Dr Alan Carter Alan is the executive of the CES East London Office. He holds a PhD in Marine Biology and is a certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years’ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP) and registered as an Environmental Assessment Practitioner under the Environmental Assessment Practitioners Association of South Africa (EAPASA).

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



2.2 Dr Greer Hawley Greer has a BSc degree in Botany and Zoology and a BSc Honours in Botany from the University of Cape Town. She completed her PhD thesis (Microbiology) at Rhodes University. Greer has been involved in a number of diverse activities. The core academic focus has been directed in the field of taxonomy both in the plant and fungal kingdom. Greer's research ranges from studying fresh and marine algae, estuarine diatoms, Restio species classification in the fynbos and forest vegetation and fungal species identification and ecology. Greer's study of fungi have also contributed towards an understanding of soil ecology and "below ground" ecology. She is currently working on numerous impact assessments at the East London branch.

2.3 Ms Rosalie Ann Evans Rosalie holds an honours degree in Geography and Environmental Studies and a BA Social Dynamics degree with majors in Geography and Psychology from Stellenbosch University. Rosalie's honours dissertation analysed the role of small grains in soil carbon sequestration in the agricultural sector of the Western Cape. Her academic focuses include renewable energy, GIS mapping, sustainable development and the interactions between humans and their environment.



3 PROPOSED ACTIVITY According to APPENDIX 4 of GN R 982, an environmental management programme must include:

(b) A detailed description of the aspects of the activity that are covered by the draft environmental management programme as identified by the project description;

(c) A map at an appropriate sale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers;

3.1 Description of proposed activity Olivewood Trade & Invest (Pty) Ltd is proposing the development of the Olivewood Golf and Country Estate and associated land uses and infrastructure. The development activities will include, but are not limited to: • 102 dwelling units; • Construction of the main entrance to the residential development; • Construction of a driving range and four holes of the golf course; • Construction of a rescue and rehabilitation nursery; and • Fencing around the perimeter of the entire property and the river front.

3.2 Site Location The proposed site is situated near Chinsta East and Chinsta West in the Eastern Cape Province. The site is bounded by the roads to Chinsta West and Buccaneers Retreat to the South West, the Chinsta River to the north east and the Schafli Road to the west. Figure 2, on the following page, is a map indicating the location of the Olivewood Golf and Country Estate.

Detailed description of listed activities associated with the project

Listed activities as described in GN R.983 Description of project activity that triggers listed activity

GN R983 32 The continuation of any development where the environmental authorisation has lapsed and where the continuation of the development, after the date the environmental authorisation has lapsed will meet the threshold of any activity or activities listed in this Notice, Listing Notice 2 of 2014, or Listing Notice 3 or Listing Notice 4 of 2014.

The development previously obtained environmental authorisation and this authorisation has lapsed.

GN R 983 27 Clearance of an area of 1 hectare or more, but less than 20 hectares of indigenous vegetation.

The development consists of an area that exceeds 1 hectare, but consists of less than 20 hectares of indigenous vegetation which will have to be cleared in order to complete this phase of the development.



Figure 2: Locality Map of the planned location of the proposed development near Chinsta East and Chinsta West in the Eastern Cape Province.



4 SCOPE OF THE EMPr In order to ensure a holistic approach to the management of environmental impacts during the construction and operation of the proposed golf and country estate, this EMPr sets out the methods by which proper environmental controls are to be implemented by the Applicant’s Project Manager and/or the Contractor and all other parties involved. The EMPr is a dynamic document subject to influences and changes as are wrought by variations to the provisions of the project specification.

4.1 Layout of the EMPr

The EMPr is divided into two phases of development. Each phase has specific issues unique to that period of the construction and operation of the golf and country estate. The impacts are identified and given a brief description. The phases of the development are identified below: 4.1.1 Construction Phase This section of the EMPr provides management principles for the construction phase of the project. Environmental actions, procedures and responsibilities as required during the construction phase are specified. These specifications will form part of the contract documentation and therefore the Contractor will be required to comply with these specifications to the satisfaction of the Applicant’s Project Manager and the Environmental Control Officer (ECO). 4.1.2 Operational and maintenance phase This section of the EMPr provides management principles for the operation and maintenance phase of the project. Environmental actions, procedures and responsibilities as required during the operation and maintenance phase are specified.



5 ROLES AND RESPONSIBILITIES According to APPENDIX 4 of GN R 982, an environmental management programme must include:

(i) An indication of the persons who will be responsible for the implementation of the impact management actions;

5.1 Applicant Olivewood Trade & Invest 23 (Pty) Ltd is the applicant and will therefore be the entity monitoring the implementation of the EMPr and compliance with the environmental authorisation. However, if the Applicant’s Project Manager appoints a Contractor to implement the project and hence implement the proposed mitigation measures documented in this EMPr on their behalf; the successful contractor’s responsibilities will be as stated in Section 5.2. The Applicant’s Project Manager must:

• Ensure that all third parties who carry out all or part of the Applicant’s obligations under the Contract comply with the requirements of this EMPr;

• Be responsible for obtaining any further environmental permits which are required for the design, construction and operation of the golf and country estate; and

• Ensure that the infrastructure is maintained and functional during the operational phase of the development.

5.2 Contractor The successful Contractor will:

Be responsible for the finalisation of the EMPr in terms of methodologies which are required to be implemented to achieve the environmental specifications contained herein and the relevant requirements contained in the environmental authorisation, if issued by DEDEAT;

Be responsible for the overall implementation of the EMPr in accordance with the requirements of the environmental authorisation, if issued by DEDEAT;

Ensure that all third parties who carry out all or part of the Contractor’s obligations under the Contract comply with the requirements of this EMPr;

Be responsible for obtaining any environmental permits which are required for the design, construction and operation of the Olivewood Golf and Country Estate.

5.3 Environmental Control Officer For the purposes of implementing the conditions contained herein, the Applicant’s Project Manager must appoint an Environmental Control Officer (ECO) for the contract. The ECO will be the responsible person for ensuring that the provisions of the EMPr as well as the environmental authorisation are complied with during the construction period. The ECO will be responsible for issuing instructions to the contractor where environmental considerations call for action to be taken. The ECO will submit regular written reports to the applicant, but not less frequently than once a month. The ECO will be responsible for the monitoring, reviewing and verifying compliance with the EMPr and conditions of the environmental authorisation by the Contractor. The ECO’s duties in this regard will include, inter alia, the following:

Confirming that all the environmental authorisations and permits required in terms of the applicable legislation have been obtained prior to construction commencing.

Monitoring and verifying that the EMPr, Environmental Authorisation and Contract are adhered to at all times and taking action if specifications are not followed.

Monitoring and verifying that environmental impacts are kept to a minimum.



Reviewing and approving construction method statements, where necessary, in order to ensure that the environmental specifications contained within this EMPr and environmental authorisation are adhered to.

Inspecting the site and surrounding areas on a regular basis regarding compliance with the EMPr, Environmental Authorisation and Contract.

Monitoring the undertaking, by the Contractor, of environmental awareness training for all new personnel on site.

Ensuring that activities on site comply with all relevant environmental legislation.

Ordering the removal of, or issuing spot fines for person(s) and/or equipment not complying with the specifications of the EMPr and/or environmental authorisation.

Undertaking a continual internal review of the EMPr and submitting any changes to the Applicant’s Project Manager and/or DEDEAT (in case of major changes) for review and approval.

Checking that the required actions are/were undertaken to mitigate the impacts resulting from non-compliance.

Reporting all incidences of non-compliance to the Applicant’s Project Manager.

Keeping a photographic record of progress on site from an environmental perspective and recommending additional environmental protection measures, should this be necessary.

Providing feedback on any environmental issues at site meetings. The ECO must have:

A good working knowledge of all relevant environmental policies, legislation, guidelines and standards;

The ability to conduct inspections and audits and to produce thorough, readable and informative reports;

The ability to manage public communication and complaints;

The ability to think holistically about the structure, functioning and performance of environmental systems; and

Proven competence in the application of the following integrated environmental management tools:

o Environmental Impact Assessment. o Environmental management plans/programmes. o Environmental auditing. o Mitigation and optimisation of impacts. o Monitoring and evaluation of impacts. o Environmental Management Systems.

The ECO must be fully conversant with this EMPr and the Environmental Authorisation (if issued) for the Olivewood Golf and Country Estate and all relevant environmental legislation. The Applicant’s Project Manager will have the authority to replace the ECO if, in their opinion, the appointed officer is not fulfilling his/her duties in terms of the requirements of the EMPr or this specification. Such instruction will be in writing and will clearly set out the reasons why a replacement is required and within what timeframe.



6 MITIGATION AND/OR MANAGEMENT MEASURES According to APPENDIX 4 of GN R 982, an environmental management programme must include:

(d) Information on any proposed management or mitigation measures that will be taken to address the environmental impacts that have been identified in a report contemplated by these Regulations, including environmental impacts or objectives in respect of –

(i) Planning and design; (ii) Pre-construction; (iii) construction activities; (iv) Rehabilitation of the environment after construction and where applicable post closure;

and (v) where relevant, operation activities;

(e) a description and identification of impact outcomes required for the aspects contemplated in (d). (f) a description of proposed impact management actions, identifying the manner in which the impact

management objectives and outcomes contemplated in paragraphs (d) and (e) will be achieved, and must, where applicable include actions to –

(i) Avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;

(ii) Comply with any prescribed environmental management standards or practices; (iii) Comply with any applicable provisions of the Act regarding closure, where applicable; (iv) Comply with any provisions of the Act regarding financial provisions for rehabilitation,

where applicable;

A variety of potential impacts are associated with the construction activities of this project. These impacts can be categorised as general construction related impacts as well as construction impacts specifically related to this site. General best practice rules to construction should be followed at all times. Maintenance guidelines are also provided for the operational phase of the development.

6.1 General issues and mitigation measures The following section focuses on general issues that may arise during the Construction and Operational Phase of a development. Mitigation measures have been provided to minimise the impacts of these issues. 6.1.1 Construction Phase AIR POLLUTION

Cleared surfaces should be dampened, where necessary and whenever possible, especially in dry and windy conditions to avoid excessive dust generation.

Any soil excavated, and not utilised for rehabilitation or infill, should be removed from site or covered and large mounds of soil should not be left behind after construction.

HAZARDOUS SUBSTANCE STORAGE & USAGE

Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practise must be adhered to. This applies to solvents and other chemicals possibly used in the construction process.

Oil trays must be placed under parked machinery to avoid soil contamination resulting from oil spills.

CONCRETE BATCHING o Concrete should not be mixed directly on the ground or during rainfall events when the

potential for transport to the storm water system is the greatest. o Concrete should only be mixed in the area demarcated for this purpose and on an

impermeable substratum.



o All areas affected during the Construction Phase should be rehabilitated.

HAZARDOUS CHEMICAL SPILLS o The individual responsible for or who discovers a spill must report the incident to the Project

Coordinator and/or Contractor as soon as reasonably possible. o The problem must be assessed and the following actions should be undertaken.

The immediate response must be to contain the spill. Depending on the nature and extent of the spill, contaminated soil must be either

excavated or treated on-site. This could involve the application of soil absorbent materials or oil-digestive powders to the contaminated soil.

If a spill occurs on an impermeable surface such as cement or concrete, the surface spill must be contained using oil absorbent materials.

Contaminated remediation materials must be carefully removed from the area of the spill so as to prevent further release of petrochemicals to the environment, and stored in adequate containers until appropriate disposal.

HAZARDOUS CHEMICAL STORAGE o Staff that will be handling hazardous materials must be trained to do so. o All hazardous chemicals must be properly stored in a secure, bunded and contained area.

WORKER HEALTH AND SAFETY

Firefighting equipment must be present on site at all times as per Occupational Health and Safety Act.

All construction foremen must be trained in fire hazard control and firefighting techniques and have operational fire-fighting equipment available on site at all times.

All flammable substances must be stored in dry areas which do not pose an ignition risk to the said substances.

No open fires will be allowed on site unless in an area that has been identified and demarcated for this purpose.

There must be no smoking near flammable substances.

All cooking must be done in demarcated areas that are safe in terms of runaway or uncontrolled fires.

Adequate sanitary and ablution facilities must be provided for construction workers.

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

Contaminated wastewater must be managed by the Contractor to ensure existing water resources on the site are not contaminated. All wastewater from general activities in the camp shall be collected and removed from the site for appropriate disposal at a licensed commercial facility.

WASTE MANAGEMENT

Littering by the employees of the Contractor must not be allowed under any circumstances. An integrated waste management approach must be implemented that is based on waste minimisation and must incorporate reduction, recycling, re-use and disposal where appropriate.

All waste must be removed from the site and transported to the closest licensed landfill site.

All hazardous waste materials must be carefully stored, and then disposed of offsite at the closest licensed hazardous landfill site.

SOCIO-ECONOMIC

A detailed complaints register must be kept on site.

Where possible unskilled job opportunities should be afforded to local community members.

RIVERS & STREAMS

No activities will be allowed to encroach into a water resource without a water use authorisation being in place from the Department of Water and Sanitation (DWS).

Any affected water bodies must be returned to their natural state after construction.



STORM WATER MANAGEMENT

The site must be managed in a manner that prevents pollution of drains, downstream watercourses or groundwater, due to suspended solids, silt or chemical pollutants.

Temporary cut-off drains and berms may be required to capture storm water and promote infiltration.

HERITAGE

If any graves or remains are exposed during construction phase, then all work in that area must be stopped and ECPHRA must be informed immediately.

6.1.2 Operational Phase

MAINTENANCE

The golf and country estate sewage and water reticulation pipes must be monitored regularly to detect possible leaks. If these are identified or reported by the public, immediate actions must be taken to prevent any further leaks.

Existing roads must be used, where possible, to avoid creating permanent tracks.

The site must be monitored for erosion and rehabilitated when necessary.

6.2 Site specific issues and mitigation measures The following tables list the possible issues specific to the Construction and Operational Phase of the Olivewood Golf and Country Estate project. Mitigation measures have been provided to reduce the negative impacts of these issues and, in some cases, to increase possible benefits. 6.2.1 Construction Phase

Issue Mitigation

Policy compliance

The developer must adhere to specifications in the EA and EMPr.

Erosion

Wind screening and stormwater control should be undertaken to prevent soil erosion.

All erosion control mechanisms must be maintained regularly.

Vegetation must be retained where possible to avoid soil erosion.

Construction must be phased in order to minimise the area of exposed soil at any one time.

Re-vegetation of disturbed surfaces must occur immediately after the construction activities are completed with indigenous vegetation.

Swathes or berms must be used below construction of houses on steep slopes.

Dust Generation

Vegetation should only be stripped as construction progresses. The time that stripped areas are exposed should be minimised wherever possible.

The sites must be re-vegetated as soon as possible during the construction phase, and indigenous trees, shrubbery and grass species must be retained wherever possible, for this purpose.

Exposed soils must be dampened whenever possible and especially in dry and windy conditions to avoid excessive dust generation.

Any soil excavated and not utilised for rehabilitation must be removed from site or incorporated into landscaping.



Issue Mitigation

Loss of indigenous vegetation

Clearing must be kept to a minimum.

The footprint of the residence must be demarcated and clearing restricted to this area.

Indigenous trees within the "garden" area must be retained where possible and only be removed for with approval from the home-owners association with good reason.

Indigenous bulbs and seedlings must be rescued and either used to re-vegetate the residential grounds or used elsewhere in the estate.

Sanitation

Adequate sanitary and ablutions facilities must be provided for construction workers

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

Portable toilets must not be located within 50 metres of any watercourse.

Inappropriate storage of building equipment and hazardous materials

The storage of potentially hazardous material must be controlled to reduce the risk of environmental contamination.

Drip trays must be placed under all machinery to avoid soil contamination.

All vehicles and machinery must be regularly maintained and in good working order to reduce the risk of contamination of soil and ground water.

All areas that have been contaminated during the construction phase must be rehabilitated.

Concrete batching

Cement and concrete must not be mixed directly on the ground, or during rainfall events when the potential for transport of pollutants to watercourses is the greatest. Cement and concrete must only be mixed in the area demarcated for this purpose and on an impermeable substratum.

All construction water and contaminated runoff must be directed away from drainage lines.

Disposal of construction material

Construction material must be removed to an approved, licenced off-site disposal site by a reputable waste services provider.

Noise pollution

Construction activities, which include the movement of construction vehicles and the operation of machinery, must be restricted to normal working hours (07:00am – 17:00pm).

Fires onsite could pose a threat to adjacent land users

Fires must be prohibited onsite during construction.

Any source of fire hazards must be removed.

The construction personnel must be educated regarding fire and fire management.

Fire extinguishers must be available onsite.

In order to reduce the risk of fires:

o All flammable substances must be stored in areas which do not pose an ignition risk to the said substances.



Issue Mitigation

o Smoking must not be permitted near flammable substances.

o All cooking must be done in demarcated areas that are safe.

The contractor must have operational fire-fighting equipment available on site at all times.

Poaching

All staff employed during construction must undergo environmental induction training.

No construction workers may reside onsite.

An appointed Environmental Control Officer or similarly qualified staff member of the Olivewood Golf and Country Estate must frequently monitor the areas around construction activities for snares.

6.2.2 Operational Phase

Issue Mitigation

Socio-

economic:

Visual

Vegetation could be planted to mitigate visual impacts and residents should be

encouraged to plant indigenous trees.

Waste

management

The Return Activated Sludge Sewage and Wastewater Treatment Plant must be

properly managed, maintained and operated.

There should be periodic inspections of the sewer system to identify any system

failure which could lead to contamination of the surrounding water bodies, e.g. the

estuary.

A waste management plan must be in place to ensure appropriate collection,

processing and disposal of solid waste. For example: An adequate backup plan should

be in place in cease of service delivery strikes.

A separation-at-source of waste should be considered as part of the home-owners

agreement in order to facilitate recycling and reuse.

Organic waste should be composted.

Water

Resource

Management

There should be effective monitoring and maintenance of all water reticulation

infrastructure to ensure no leakage.

Consumption of water by households should be monitored.

Water-wise practices should be listed and recommended to residences, such as use of

rainwater for non-potable water requirements.

Property owners should only be permitted to plant indigenous, water-wise plants in

their gardens.

The home owners association should develop garden guidelines to ensure water



Issue Mitigation

friendly gardens.

Traffic and

Transport

The effectiveness of traffic control measures must be monitored on an on-going basis

and appropriate remediation steps implemented if necessary. This may include

notifying the municipal authorities of the need for road reconstruction etc.

Stormwater

management

The effectiveness of the stormwater management measures must be monitored by

the home-owners association.

If the stormwater management measures put in place are deemed insufficient, a

qualified engineer must be approached to assist with additional storm water

attenuation mechanisms and remediation.

Houses must be re-vegetated rapidly by homeowners to reduce runoff.

Natural vegetation between the houses and stream will act as a natural retention/

attenuation structure.

A buffer of 50 metres must be maintained along all watercourses and no

development activities must occur within the watercourses.

In order for construction to take place within 50 metres of the watercourse,

authorisation must be received from DWS.



7 ENVIRONMENTAL AWARENESS According to APPENDIX 4 of GN R 982, an environmental management programme must include:

(g) The method of monitoring the implementation of the impact management actions contemplated in paragraph (f);

(h) The frequency of monitoring the implementation of the impact management actions contemplated in (f);

Contractors must ensure that their employees and any third party that carries out all or part of the Contractor’s obligations are adequately trained with regard to the implementation of the EMPr, as well as regarding environmental legal requirements and obligations. Environment and health awareness training programmes should be targeted at three distinct levels of employment, i.e. project manager, supervisor and labour. The appointed ECO must provide training and ensure that records of all training interventions are kept in accordance with the record keeping and documentation control requirements as set out in this EMPr.

The environmental training should, as a minimum, include the following:

Environmental legal requirements and obligations. The importance of conformance with all environmental policies. The environmental impacts, actual or potential, of their work activities. The environmental benefits of improved personal performance. Their roles and responsibilities in achieving conformance with the environmental policy and

procedures, including emergency preparedness and response requirements. The potential consequences of departure from specified operating procedures. The mitigation measures required to be implemented when carrying out their work activities. Details regarding floral/faunal species of special concern and protected species, and the

procedures to be followed should these be encountered during the construction of the bridge, main access roads, approach roads or construction camps.

The importance of not littering. The importance of using supplied toilet facilities. The need to use water sparingly. Details of and encouragement to minimise the production of waste and re-use, recover and

recycle waste where possible. Details regarding archaeological and/or historical sites which may be unearthed during

construction and the procedures to be followed should these be encountered.

Recommended Environmental Education Material is provided in Appendix 1



8 COMPLIANCE WITH THE EMPr

According to APPENDIX 4 of GN R 982, an environmental management programme must include: (j) The time periods within which the impact management actions contemplated in paragraph (f) must

be implemented; (k) The mechanism for monitoring compliance with the impact management actions contemplated in

paragraph (f);

A copy of the EMPr must be kept on site at all times during the construction period. The EMPr will be binding on all contractors operating on the site and must be included within the Contractual Clauses. It should be noted that in terms of the National Environmental Management Act No 107 of 1998 (Section 28) those responsible for environmental damage must pay the repair costs both to the environment and human health and the preventative measures to reduce or prevent further pollution and/or environmental damage (The ‘polluter pays’ principle).

8.1 Non-compliance and complaints The contractors must act immediately when notice of non-compliance is received from any government entity and corrective actions must be implemented. Complaints received regarding activities on the construction site pertaining to the environment must be recorded in a dedicated register and the response noted with the date and action taken. It is recommended that the Contractor institutes penalties for the following less serious violations and any others determined during the course of work as detailed below:

Littering on site. Lighting of illegal fires on site. Persistent or un-repaired fuel and oil leaks. Any persons, vehicles or equipment related to the Contractor’s operations found within the

designated “no-go” areas. Excess dust or excess noise emanating from site. Possession or use of intoxicating substances on site. Any vehicles being driven in excess of designated speed limits. Removal and/or damage to fauna, flora or cultural or heritage objects on site. Urination and defecation anywhere except at designated facilities.

8.2 Emergency preparedness The Contractor must compile and maintain environmental emergency procedures to ensure that there will be an appropriate response to unexpected or accidental actions or incidents that will cause environmental impacts, throughout the construction period. Such activities may include, inter alia:

Accidental discharges of polluting substances to water and land. Accidental exposure of employees to hazardous substances. Accidental fires. Accidental spillage of hazardous substances. Accidental toxic emissions into the air. Specific environmental and ecosystem effects from accidental releases or incidents.

These plans must include:

Emergency organisation (manpower) and responsibilities, accountability and liability. A list of key personnel and contact details. Details of emergency services available (e.g. the fire department, spill clean-up services, etc.). Internal and external communication plans, including prescribed reporting procedures where

required by legislation.



Actions to be taken in the event of different types of emergencies. Incident recording, progress reporting and remediation measures required to be implemented. Information on hazardous materials, including the potential impact associated with each, and

measures to be taken in the event of accidental release. Training plans, testing exercises and schedules for effectiveness.

The Contractor must comply with the emergency preparedness and incident and accident-reporting requirements, as required by the Occupational Health and Safety Act, 1993 (Act No 85 of 1993), the NEMA, 1998 (Act No 107 of 1998), the National Water Act, 1998 (Act No 36 of 1998) and the National Veld and Forest Fire Act, 1998 (Act No 101 of 1998) as amended and/or any other relevant legislation.

8.3 Incident reporting and remedy

If a leakage or spillage of hazardous substances occurs on site, the local emergency services must be immediately notified of the incident. The following information must be provided:

the location; the nature of the load; the extent of the impact; and the status at the site of the accident itself (i.e. whether further leakage is still taking place,

whether the vehicle or the load is on fire). Written records must be kept on the corrective and remedial measures decided upon and the progress achieved therewith over time. Such progress reporting is important for monitoring and auditing purposes.

8.4 Penalties Where environmental damage is caused or a pollution incident, and/or failure to comply with any of the environmental specifications contained in the EMPr, the developer and/or contractor will be liable.



9 CLOSURE PLANNING 9.1 Final site restoration The Contractor must clear and restore the site and ensure that all excess building material and construction debris is removed from site once the construction phase has been completed.

9.2 Rehabilitation The Contractor (landscape architect/horticulturist) will be responsible for the rehabilitation and re-vegetation of all disturbed areas earmarked for conservation during construction to the satisfaction of the Applicant’s Project Manager and/or the ECO.



10 REPORTING According to APPENDIX 4 of GN R 982, an environmental management programme must include:

(l) A program for reporting on compliance, taking into account the requirement as prescribed by the regulations;

10.1 Administration The Contractor must provide the Applicant’s Project Manager and/or the ECO with a written method statement, prior to the commencement of the construction phase, setting out the following:

The type of construction activity.

Locality where the activity will take place.

Identification of impacts that might result from the activity.

Identification of activities that may cause an impact.

Methodology and/or specifications for impact prevention for each activity or aspect.

Methodology and/or specifications for impact containment for each activity or aspect.

Emergency/disaster incident and reaction procedures.

Treatment and continued maintenance of impacted environment. New submissions must be given to the Applicant’s Project Manager and/or the ECO whenever there is a change or variation to the original. The Applicant’s Project Manager and/or the ECO should provide comment on the methodology and procedures proposed by the Contractor but they will not be responsible for the Contractor’s chosen measures of impact mitigation and emergency/disaster management systems.

10.2 Good housekeeping The Contractor shall undertake “good housekeeping” practices during construction. This will help avoid disputes on responsibility and allow for the smooth running of the contract as a whole. Good housekeeping extends beyond the wise practice of construction methods to include the care for and preservation of the environment within which the construction is situated.

10.3 Record keeping The Applicant’s Project Manager and/or the ECO will continuously monitor the Contractor’s adherence to the approved impact prevention procedures and the ECO must issue the Contractor a notice of non-compliance whenever transgressions are observed. The ECO should document the nature and magnitude of the non-compliance in a designated register, the action taken to discontinue the non-compliance, the action taken to mitigate its effects and the results of the actions. The non-compliance will be documented and reported to the Applicant’s Project Manager in the monthly report. These reports must be made available to DEDEAT when requested.

10.4 Document control The Applicant’s Project Manager and/or the ECO will be responsible for establishing a procedure for electronic document control. The document control procedure should comply with the following requirements:

Documents must be identifiable by organisation, division, function, activity and contact person.



Every document must identify the personnel and their positions, who drafted and compiled the document, who reviewed and recommended approval, and who finally approved the document for distribution.

All documents must be dated, provided with a revision number and reference number, filed systematically, and retained for a five year period.

The Applicant’s Project Manager and/or the Contractor must ensure that documents are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the EMPr are performed. All documents must be made available to the ECO and other independent external auditors.



11 CONCLUSIONS Although all foreseeable actions and potential mitigations or management actions are contained in this document, the EMPr should be seen as a day-to-day management document. The EMPr thus sets out the environmental and social standards, which would be required to minimise the negative impacts and maximise the positive benefits of the construction activities. The EMPr could thus change daily, and if managed correctly lead to a successful construction phase. All attempts should be made to have this EMPr available, as part of any tender documentation, so that the Applicant’s Project Manager and/or the Contractor are made aware of the potential cost and timing implications needed to fulfil the implementation of the EMPr, thus adequately costing for these.



APPENDIX A

PROPOSED ENVIRONMENTAL EDUCATION COURSE



HOW DO WE LOOK AFTER THE ENVIRONMENT?

• Report problems to your

supervisor/ foreman

• Team work

• Follow the rules in the EMP

WORKING AREAS

Workers & equipment must

stay inside the site

boundaries at all times



ANIMALS

• Do not injure or kill any

animals on the site

• Ask your supervisor or

Contract’s Manager to

remove animals found

on site

RIVERS & STREAMS

• Do not swim in or drink from

streams

• Do not throw oil, petrol, diesel,

concrete or rubbish in the stream

• Do not work in the stream without

direct instruction

• Do not damage the banks or

vegetation of the stream



SMOKING AND FIRE• Put cigarette butts in

a rubbish bin

• Do not smoke near

gas, paints or petrol

• Do not light any fires

without permission

• Know the positions of

fire fighting equipment

• Report all fires

• Do not burn rubbish or

vegetation without

permission

TREES AND FLOWERS

• Do not damage or cut

down any trees or plants

without permission

• Do not pick flowers



PETROL, OIL AND DIESEL• Work with petrol, oil & diesel in

marked areas

• Report any petrol, oil & diesel leaks or

spills to your supervisor

• Use a drip tray under vehicles &

machinery

• Empty drip trays after rain & throw

away where instructed

DUST

Try to avoid producing dust –

Use water to make ground &

soil wet



NOISE

• Do not make loud noises

around the site, especially

near schools and homes

• Report or repair noisy vehicles



EATING

• Only eat in demarcated

eating areas

• Never eat near a river

or stream

• Put packaging & leftover

food into rubbish bins

RUBBISH

• Do not litter – put all

rubbish (especially cement

bags) into the bins provided

• Report full bins to your

supervisor

• The responsible person

should empty bins regularly



TRUCKS AND DRIVING

• Always keep to the speed limit

• Drivers - check & report leaks

and vehicles that belch smoke

• Ensure loads are secure & do

not spill