FINAL BASIC ASSESSMENT REPORT - cape-eaprac.co.zacape-eaprac.co.za/projects/MOS243a Rheebok Bricks VSBK/Final Ba… · Rheebok Bricks – VSBK’s MOS43a/12 Cape EAPrac Final Basic

Cape Environmental Assessment Practitioners (Pty) Ltd Reg. No. 2008/004627/07

Telephone: (044) 874 0365 1st Floor Eagles View Building

Facsimile: (044) 874 0432 5 Progress Street, George

Web: www.cape-eaprac.co.za PO Box 2070, George 6530

D.J. Jeffery Directors L. van Zyl

FINAL BASIC ASSESSMENT REPORT for

RHEEBOK BRICKS VERTICAL SHAFT BRICK KILNS on

Portion 11 of the Farm Grootbrak River 142

In terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended & National

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

Prepared for Applicant: Rheebok Brick Holdings (Pty) Ltd

By: Cape EAPrac

Report Reference: MOS243a/12

Department Reference: 16/3/1/1/D6/31/0045/13

Case Officer: Mr Nicholas Kearns

Date: 6 January 2014

APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER: Cape EAPrac Environmental Assessment Practitioners

PO Box 2070 George

6530 Tel: 044-874 0365 Fax: 044-874 0432

Report written & compiled by: Dale Holder (Ndip Nat Con), who has 11 years’ experience as an environmental practitioner. Report reviewed by: Louise-Mari van Zyl (MA Geography & Environmental Science [US]; Registered Environmental Assessment Practitioner with the Interim Certification Board for Environmental Assessment Practitioners of South Africa, EAPSA); Committee Member of the Southern Cape International Association for Impact Assessments (IAIA). Ms van Zyl has over ten years’ experience as an environmental practitioner.

PURPOSE OF THIS REPORT: Decision Making

APPLICANT: Rheebok Brick Holdings (Pty) Ltd

CAPE EAPRAC REFERENCE NO: MOS243a/12

DEPARTMENT REFERENCE: 16/3/1/1/D6/31/0045/13

SUBMISSION DATE 06 January 2014

Rheebok Bricks – VSBK’s MOS43a/12

Cape EAPrac Final Basic Assessment Report

FINAL BASIC ASSESSMENT REPORT

in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended & National

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

Rheebok Bricks – VSBK’s Portion 11 of the Farm Grootbrak River 142

Submitted for: Departmental Review

This report is the property of the Author/Company, who may publish it, in whole, provided that:

Written approval is obtained from the Author and that Cape EAPrac is acknowledged in the publication;

Cape EAPrac is indemnified against any claim for damages that may result from any publication of specifications, recommendations or statements that is not administered or controlled by Cape EAPrac;

The contents of this report, including specialist/consultant reports, may not be used for purposes of sale or publicity or advertisement without the prior written approval of Cape EAPrac;

Cape EAPrac accepts no responsibility by the Applicant/Client for failure to follow or comply with the recommended programme, specifications or recommendations contained in this report;

Cape EAPrac accepts no responsibility for deviation or non-compliance of any specifications or recommendations made by specialists or consultants whose input/reports are used to inform this report; and

All figures, plates and diagrams are copyrighted and may not be reproduced by any means, in any form, in part or whole without prior written approved from Cape EAPrac.

Report Issued by: Cape Environmental Assessment Practitioners

Tel: 044 874 0365 PO Box 2070 Fax: 044 874 0432 5 Progress Street Web: www.cape-eaprac.co.za George 6530



ORDER OF REPORT Basic Assessment Overview

Basic Assessment Report

Appendix A : Location Map

Appendix B : Site Layout Plan

Appendix C : Site Photographs

Appendix D : Biodiversity Overlay Maps

Appendix E : Permits & Licences from Other Organs of State

Annexure E1 : Zoning Certificate

Annexure E2 : Atmospheric Emissions Licence

Appendix F : Public Participation

Appendix G : Specialist Reports

Annexure G1 : Air Quality Impact Assessment

Appendix H : Construction Phase Environmental Management Programme

Appendix I : Not Applicable (relevant to Waste Management Applications)

Appendix J : Additional Information

Annexure J1 : Landowner Consent

Annexure K2 : VSBK Operational Manuel



TABLE OF CONTENTS

BASIC ASSESSMENT OVERVIEW ............................................................................................ I 1. INTRODUCTION .................................................................................................................. I 2. LEGISLATIVE AND POLICY FRAMEWORK ....................................................................... I

2.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA, ACT 108 OF 1998) ....................... I

2.2 NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT (ACT 39 OF 2004). .............. III

2.3 ENVIRONMENT CONSERVATION ACT, 1989 (ECA) ............................................................ III

2.4 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (NEM:WA, ACT 59 OF 2008).... IV

2.5 NATIONAL WASTE MANAGEMENT STRATEGY .................................................................. IV

2.6 SANS 10400 APPLICATION OF THE NATIONAL BUILDING REGULATIONS ........................... IV

2.7 NATIONAL BUILDING REGULATIONS ................................................................................ IV

2.8 CONSERVATION OF AGRICULTURAL RESOURCES ACT (CARA) ......................................... V

2.9 NATIONAL VELD AND FOREST FIRE ACT (ACT 101 OF 1998) ............................................. V

2.10 NATIONAL HERITAGE RESOURCES ACT (ACT 25 OF 1999) ............................................... V

2.11 OCCUPATIONAL HEALTH AND SAFETY ACT (ACT 85 OF 1993) ......................................... VI

3. PROPOSED ACTIVITY ...................................................................................................... VI 3.1 DIFFERENT METHODS OF BRICK FIRING (DIFFERENT TYPES OF KILNS). .............................. VI

3.1.1 Intermittent kilns .................................................................................................. vi 3.1.2 Continuous kilns .................................................................................................. vi

3.2 OVERVIEW OF THE EXISTING BRICK FIRING ACTIVITIES (CLAMP KILNS). .............................. VI

3.3 OVERVIEW OF THE PROPOSED NEW BRICK FIRING ACTIVITIES (VSBK’S). ........................... VII

3.4 ENVIRONMENTAL BENEFITS OF VSBK’S VS CLAMP KILNS ................................................. XII

4. SITE DESCRIPTION AND ATTRIBUTES ......................................................................... XII 5. PLANNING CONTEXT ..................................................................................................... XIII 6. PROCESS TO DATE ...................................................................................................... XIV 7. NEED, DESIRABILITY AND FEASIBILITY ...................................................................... XVI

7.1 NEED AND DESIRABILITY QUESTIONS. ...........................................................................XVI

7.1.1 Need (Timing) .................................................................................................... xvi 7.1.2 Desirability (‘place’):.......................................................................................... xvii

8. SUMMARY OF IMPACTS ..............................................................................................XVIII 8.1 IMPACTS THAT MAY RESULT FROM THE PLANNING, DESIGN AND CONSTRUCTION PHASE .. XVIII

8.2 IMPACTS THAT MAY RESULT FROM THE OPERATIONAL PHASE ..........................................XIX

8.3 IMPACTS THAT MAY RESULT FROM THE DECOMMISSIONING AND CLOSURE PHASE ............. XX

9. CONCLUSION ................................................................................................................. XX

BASIC ASSESSMENT FORM .................................................................................................... 1

SECTION A: ACTIVITY INFORMATION .................................................................................... 1 1 PROJECT DESCRIPTION .................................................................................................. 1 2. PHYSICAL SIZE OF THE ACTIVITY ................................................................................... 4 3. SITE ACCESS .................................................................................................................... 5 4. DESCRIPTION OF THE PROPERTY ON WHICH THE ACTIVITY IS TO BE UNDERTAKEN AND THE LOCATION OF THE ACTIVITY ON THE PROPERTY ...................... 6



5. SITE PHOTOGRAPHS ....................................................................................................... 8

SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT ................................................ 9 1 SITE/AREA DESCRIPTION ................................................................................................ 9 2. GRADIENT OF THE SITE ................................................................................................... 9 3. LOCATION IN LANDSCAPE ............................................................................................... 9 4. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE ......................... 10 5. SURFACE WATER ........................................................................................................... 10 6. BIODIVERSITY ................................................................................................................. 12 7. LAND USE OF THE SITE ................................................................................................. 15 8. LAND USE CHARACTER OF SURROUNDING AREA ..................................................... 15 9. SOCIO-ECONOMIC ASPECTS ........................................................................................ 16 10. HISTORICAL AND CULTURAL ASPECTS ....................................................................... 17 11. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES ..................................... 19

SECTION C: PUBLIC PARTICIPATION ................................................................................... 23

SECTION D: NEED AND DESIRABILITY................................................................................. 29

SECTION E: ALTERNATIVES ................................................................................................. 34

SECTION F: IMPACT ASSESSMENT, MANAGEMENT, ......................................................... 36

MITIGATION AND MONITORING MEASURES ....................................................................... 36 1 DESCRIBE THE MANNER IN WHICH THE DEVELOPMENT WILL IMPACT ON THE FOLLOWING ASPECTS: ......................................................................................................... 36 2. WASTE AND EMISSIONS ................................................................................................ 38 3. WATER USE ..................................................................................................................... 43 4. POWER SUPPLY ............................................................................................................. 44 5. DESCRIPTION AND ASSESSMENT OF THE SIGNIFICANCE OF IMPACTS PRIOR TO AND AFTER MITIGATION ....................................................................................................... 44 6. SPECIALIST INPUTS/STUDIES AND RECOMMENDATIONS ......................................... 55 7. IMPACT SUMMARY ......................................................................................................... 55 8. OTHER MANAGEMENT, MITIGATION AND MONITORING MEASURES ....................... 55

SECTION G: ASSESSMENT METHODOLOGIES AND CRITERIA, GAPS IN KNOWLEDGE, UNDERLAYING ASSUMPTIONS AND UNCERTAINTIES ....................................................... 57

SECTION H: RECOMMENDATION OF THE EAP ................................................................... 59

SECTION I: APPENDICES ...................................................................................................... 60

DECLARATIONS ..................................................................................................................... 61 1. THE APPLICANT .............................................................................................................. 61 2. THE INDEPENDENT ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) .......... 62 3. THE INDEPENDENT PERSON WHO COMPILED A SPECIALIST REPORT ................... 63

REFERENCES ......................................................................................................................... 64



LIST OF FIGURES Figure 1: Summary of Basic Assessment Process Figure 2: Showing one of the existing Clamp Kilns at Rheebok Bricks. Figure 3 Showing a schematic cross section of a VSBK (Rowe,2012) Figure 4: Showing sections through a VSBK (Rowe, 2012). Figure 5: Showing a typical layout of a 6 Shaft VSBK (Rowe, 2012). . Figure 6: Showing the top of a single shaft of a VSBK. Figure 7: Showing Green Bricks being loaded into the top of a VSBK. Figure 8: Showing the exhaust fan that evacuates exhaust fumes to a single stack. Figure 9: Showing completely fired and cooled bricks that are removed from the

bottom of the shaft. Figure 10: Showing historical aerial photographs Figure 11: Showing existing building where VSBK’s will be housed. Figure 12: The building is currently used for air drying bricks before they are packed

into the clamp kilns. Figure 13: Showing existing access and internal roads that will be used. Figure 14: Showing the context of Rheebok Bricks within the landscape Figure 15: Showing proximity of the closest surface water bodies to the proposed

VSBK’s. Figure 16: Showing the location of the VSBK,s in relation to Freshwater Ecosystem

Priority Areas. Figure 17: Showing the proposed VSBK’s in relation to Critical Biodiversity Areas Figure 18: Showing the transformed nature of the site. Figure 19: Showing the proposed facility in relation to the surrounding land use. Figure 20: Showing newspaper adverts calling for the registration of Interested and

Affected Parties. Figure 21: Showing availability of Background Information Document on the Cape

EAPrac website.

LIST OF TABLES Table 1: NEMA 2010 listed activities for the Rheebok Bricks Table 2: Atmospheric emission activities in terms of the NEM:AQA (Government

Gazette No. 33064): Environment Conservation Act, 1989 (ECA) Table 3: Summary of Public Participation Process to date. Table 4: Public Participation Process chronology of events. Table 5: Ambient Air Quality Standards for SO2 and NOx Table 6: Ambient Air Quality Standards for PM10


Cape EAPrac i Final Basic Assessment Report

BASIC ASSESSMENT OVERVIEW

1. INTRODUCTION

The applicant, Rheebok Brick Holdings (Pty) Ltd, intends to replace their existing Clamp Kilns with Vertical Shaft Brick Kilns (VSBK’s).

Cape EAPrac has been appointed by Rheebok Brick Holdings (Pty) Ltd, hereafter referred to as the Applicant, as the independent environmental practitioner, to facilitate the Basic Assessment (BA) process required in terms of the National Environmental Management Act (NEMA, Act 107 of 1998) and the National Environmental Management: Air Quality Act for the proposed technological changes to this facility.

The purpose of this Final Basic Assessment Report is to describe the environment to be affected, the proposed project, the environmental process followed to date (focussing on the outcome of the public participation process and specialist studies), to present the findings and recommendations presented in the various specialist studies, and provide a description of how the development concept has been adjusted to consider the above. All this information is presented to the decision making authority in order for them to make an informed decision on the application.

2. LEGISLATIVE AND POLICY FRAMEWORK

The Project Proponent is required to comply with all necessary legislation and policies applicable to the above mentioned development (The changes in technology to their existing facility requires consideration of various pieces of legislation and policies). These include but are not limited to: 2.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA, ACT 108 OF 1998)

The current assessment is being undertaken in terms of the National Environmental Management Act (NEMA, Act 107 of 1998)1 . This Act makes provision for the identification and assessment of activities that are potentially detrimental to the environment and which require authorisation from the competent authority (in this case, the provincial Department of Environmental Affairs & Development Planning, DEA&DP) based on the findings of an Environmental Assessment.

In terms of the environmental regulations, A Basic Assessment process (shown in Figure 1 below) is required for the proposed technological improvements at Rheebok Bricks.

1 On 18 June 2010 the Minister of Water and Environmental Affairs promulgated new regulations in terms of Chapter 5 of the National Environmental Management Act (NEMA, Act 107 of 1998), viz, the Environmental Impact Assessment (EIA) Regulations 2010. These regulations came into effect on 02 August 2010 and replace the EIA regulations promulgated in 2006.


Cape EAPrac ii Final Basic Assessment Report

Figure 1: Summary of Basic Assessment Process

The listed activities associated with the proposed development, as stipulation under 2010 Regulations 544 are as follows:

Table 1: NEMA 2010 listed activities for the Rheebok Bricks

R544 Listed Activity Activity Description

28

The expansion of or changes to existing facilities for any process or activity which will result in the need for a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities.

Rheebok Bricks intend changing the technology used in firing bricks, from Clamp Kilns to Vertical Shaft Brick Kilns (VSBK’s). Even though they are not expanding their throughput capacity, this technological change requires a licence in terms of the National Environmental Management: Air Quality Act and as such, requires environmental authorisation in terms of this activity.

Before any of the above mentioned listed activities can be undertaken, authorisation must be obtained from DEA&DP. Should the Department approve the proposed activity, the Environmental Authorisation does not exclude the need for obtaining relevant approvals from other Authorities who have a legal mandate (for e.g. a license is also required in terms of the National Environmental Management: Air Quality Act (Act 39 of 2004) – see Section 2.2 below).

Principles contained in Section 2 of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended (NEMA), which, amongst other things, indicates that environmental management should:

In order of priority aim to: avoid, minimise or remedy disturbance of ecosystems and loss of biodiversity;


Cape EAPrac iii Final Basic Assessment Report

Avoid degradation of the environment and avoid jeopardising ecosystem integrity; Pursue the best practicable environmental option by means of integrated environmental

management; Protect the environment as the people’s common heritage; Control and minimise environmental damage; and Pay specific attention to management and planning procedures pertaining to sensitive,

vulnerable, highly dynamic or stressed ecosystems.

It is incumbent upon the proponent to show how the proposed activities would comply with these principles and thereby contribute towards the achievement of sustainable development as defined by the NEMA.

The National Environmental Management Act (NEMA, Act No. 62 of 2008) embraces the notion of sustainable development as contained in the Constitution in that everyone has the right:

to an environment that is not harmful to their health or well-being; and to have the environment protected for the benefit of present and future generations

through reasonable legislative and other measures.

NEMA aims to provide for cooperative environmental governance by establishing principles for decision-making on all matters relating to the environment and by means of Environmental Implementation Plans (EIP) and Environmental Management Programmes (EMPr).

2.2 NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT (ACT 39 OF 2004).

The key aim of this act is:

to regulate air quality in order to protect the environment by providing reasonable measures for the prevention of pollution and ecological degradation

to secure ecologically sustainable development while promoting justifiable economic and social development;

to provide for national norms and standards regulating air quality monitoring, management and control by all spheres of government;

for specific air quality measures; and for matters incidental thereto.

Ceramic Processes are listed in terms of this Act and as such, may not proceed without an Atmospheric Emissions Licence, in terms of the Act. The Eden District Municipality is the licencing authority in this regard.

Table 2: Atmospheric emission activities in terms of the NEM: AQA (Government Gazette No. 33064):

5 (7) The production of tiles, bricks, refractory bricks, stoneware or porcelain ware by firing, excluding clamp kilns.

2.3 ENVIRONMENT CONSERVATION ACT, 1989 (ECA)

The EIA regulations contained in the Environmental Conservation Act (ECA) have been replaced by NEMA. The contractor must comply with the draft regulations pertaining to noise as published in the province of Western Cape Provincial Extraordinary Gazette (as provision made in Section 25 of the ECA), as well as Section 24 of the ECA regarding waste management and Section 20 of the ECA dealing with waste management under Part IV, Control of Environmental Pollution.


Cape EAPrac iv Final Basic Assessment Report

2.4 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (NEM:WA, ACT 59 OF 2008)

NEM:WA was instituted to reform the law regulating waste management in order to protect health and the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecological sustainable development; to provide for institutional arrangements and planning matters; to provide for national norms and standards for regulating the management of waste by all spheres of government; to provide for specific waste management measures; to provide for the licensing and control of waste management activities; to provide for the remediation of contaminated land; to provide for the national waste information system; to provide for compliance and enforcement and to provide for matters connected therewith.

In short NEM:WA deals with the handling, treatment, processing, recycling, re-use and/or storage of both ‘general’ and ‘hazardous’ waste products. The activities proposed at Rheebok Bricks will not generate waste and as such will not require a licence in terms of the Waste Management Act.

2.5 NATIONAL WASTE MANAGEMENT STRATEGY

The National Waste Management Strategy presents the South African government's strategy for integrated waste management for South Africa.

It deals among others with: Integrated Waste Management Planning, Waste Information Systems, Waste Minimisation, Recycling, Waste Collection and Transportation, Waste Treatment, Waste Disposal and Implementing Instruments.

The provisions of the National Waste Management Strategy were considered and included in the Environmental Management Programme for Rheebok Bricks.

2.6 SANS 10400 APPLICATION OF THE NATIONAL BUILDING REGULATIONS

The application of the National Building Regulations contains performance parameters relating to fire safety, sanitation systems, moisture penetration, structural safety, serviceability and durability. It also takes into account how the above can be established to reflect social expectations in a manner which supports sustainable development objectives.

2.7 NATIONAL BUILDING REGULATIONS

The National Building Regulations and Building Standards Act as amended must be complied with. Rheebok Brick Holdings (Pty) Ltd must ascertain whether or not the activity requires building plan approval from the local authority.

This act addresses, inter alia:

Specifications for draftsmen, plans, documents and diagrams; Approval by local authorities; Appeal procedures; Prohibition or conditions with regard to erection of buildings in certain conditions; Demolition of buildings; Access to building control officers; Regulations and directives; and Liability.


Cape EAPrac v Final Basic Assessment Report

2.8 CONSERVATION OF AGRICULTURAL RESOURCES ACT (CARA)

The Conservation of Agricultural Resources Act aims to provide for the conservation of natural agricultural resources by maintaining the production potential of land, combating and preventing erosion and weakening or destruction of water resources, protecting vegetation and combating weeds and invader plant species.

The site is currently zoned and used for industrial purposes and is not deemed to constitute agricultural land. Notwithstanding this, the provisions in terms of erosion and protection of water resources have been considered and included in this document.

2.9 NATIONAL VELD AND FOREST FIRE ACT (ACT 101 OF 1998)

The purpose of the National Veld and Forest Fire Act is to prevent and combat veld, forest and mountain fires throughout the RSA and to provide institutions, methods and practices for achieving this purpose. Institutions include the formations of such bodies as Fire Protection Associations (FPA’s) and Working on Fire. The Act provides the guidelines and constitution for the implementation of these institutions as well as their functions and requirements.

All landowners are required in terms of this Act to prepare and maintain firebreaks on the boundary of their property and any adjoining land. Only the Minister may exempt a landowner from providing firebreaks.

In areas that are considered a high fire rise, especially in vegetation types that tend to be fire driven ecosystems, it is recommended that a fire management plan is put in place, or the owner becomes a member of the local FPA and fall under the umbrella of the regional fire management strategy.

Due to the completely transformed nature of the Rheebok Bricks facility, the site is not deemed to constitute a High Fire Risk in terms of wild fires.

2.10 NATIONAL HERITAGE RESOURCES ACT (ACT 25 OF 1999)

The purpose of the National Heritage Resources Act is to:

Introduce an integrated and interactive system for the management of the national heritage resources;

Promote good government at all levels, Empower civil society to nurture and conserve their heritage resources so that they may be

bequeathed to future generations; To lay down general principles for governing heritage resources management throughout

South Africa; To introduce an integrated system for the identification, assessment and management of the

heritage resources of South Africa; To establish the South African Heritage Resources Agency together with its Council to

coordinate and promote the management of heritage resources at national level; To set norms and maintain essential national standards for the management of heritage

resources in South Africa and to protect heritage resources of national significance; To control the export of nationally significant heritage objects and the import into South Africa

of cultural property illegally exported from foreign countries; To enable the provinces to establish heritage authorities which must adopt powers to protect

and manage certain categories of heritage resources;


Cape EAPrac vi Final Basic Assessment Report

To provide for the protection and management of conservation-worthy places and areas by local authorities; and

To provide for matters connected therewith.

The heritage impact has been assessed as part of this application. The facility does however not require approval in terms of the National Heritage Resources Act. Notwithstanding this, Heritage Western Cape has been identified as a key stakeholder who has been given an opportunity to provide input and comment on this process.

2.11 OCCUPATIONAL HEALTH AND SAFETY ACT (ACT 85 OF 1993)

The Act provides for the health and safety of persons at work and for the health and safety of persons in connection with the use of plant and machinery; the protection of persons other than persons at work against hazards to health and safety arising out of or in connection with the activities of persons at work.

In terms of this Act, a Health and Safety Officer and Protocol must be implemented on the site during construction. This process also furthermore recommends that an Operational Health and Safety plan be developed for this facility.

3. PROPOSED ACTIVITY

Rheebok Brick Holdings (Pty) ltd intends to replace their existing clamp kilns with VSBK’s. It is envisioned that this replacement process will roll out over a 5 year period. Rheebok Bricks are currently authorised to produce 12000 tons of bricks per month (a copy of this licence is attached in Annexure E2). This maximum production capacity will not be exceeded by replacing the Clamp Kilns with VSBK’s. This application is thus not to expand the existing facility, but merely improving the manufacture efficiency. In order to meet their existing licences capacity, Rheebok Bricks intends constructing and operating a maximum of 24 VSBK’s.

3.1 DIFFERENT METHODS OF BRICK FIRING (DIFFERENT TYPES OF KILNS).

Brick kilns can be broadly divided into two major categories:

Intermittent or batch processes Continuous processes

3.1.1 Intermittent kilns In intermittent kilns, bricks are fired in batches. The fire is allowed to die after a batch of bricks is fired and the bricks are allowed to cool down. Once the bricks cool down, the kiln is emptied. Then a new batch of bricks is again loaded and a new fire is ignited.

3.1.2 Continuous kilns In continuous kilns, once the fire is ignited, it keeps burning. The firing of bricks, loading of the bricks inside the kiln, cooling down and unloading of the bricks take place simultaneously in different parts of the brick kiln.

3.2 OVERVIEW OF THE EXISTING BRICK FIRING ACTIVITIES (CLAMP KILNS).

Rheebok Bricks currently fire their bricks using clamp kilns. The manufacture of Bricks in Clamp Kilns, as currently undertaken by Rheebok Bricks is listed under category 5, sub category 5.2 of the Air Quality regulations.


Cape EAPrac vii Final Basic Assessment Report

Rheebok Bricks were in possession of a Registration Certificate (RC) in terms of the previous legislation (Atmospheric Pollution Prevention Act). This RC was recently renewed and they are now in possession of an Atmospheric Emissions Licence (AEL) in terms of the National Environmental Management: Air Quality Act. Bricks made by shaping a plastic mass of clay and water, which is then hardened by drying and firing. Some fuel is placed into the body of each brick. The bricks are then packed into a pyramid shaped formation (The clamp). The clamp has a layer of coal packed at the bottom. This layer is set alight, it ignites the fuel in the base layer of bricks and progressively, each brick in the pack catches alight. The process entails the following key components:

Mining of aggregate (clay), Crushing & screening of aggregate, Blending and mixing of aggregate, Shaping of “green” bricks (extrusion), Drying, and Firing.

Figure 2: Showing one of the existing Clamp Kilns at Rheebok Bricks. 3.3 OVERVIEW OF THE PROPOSED NEW BRICK FIRING ACTIVITIES (VSBK’S).


Cape EAPrac viii Final Basic Assessment Report

The following information is sourced from the VSBK operational manual that was compiled by a number of international experts as follows: Mr. Heini Müller - VSBK technology expert, Skat, Nepal Dr. Soumen Maity - VSBK technology expert, TARA, India Mr. Suyesh Prajapati - Expert: (Energy and Environment) MinErgy Pvt. Ltd. Nepal Mr. Prabin Chhetri - VSBK coordinator SCP Project, Nepal Mr. Tobias Müller - VSBK construction and operation expert, Skat, Nepal Mr. Pieter du Toit - Cermalab S.A. (www.cermalab.co.za) Mr. John Volsteedt - Project Manager SA-VSBK South Africa, (sa-vsbk.org) Mr. Pieter Blake - Director Langkloof Bricks South Africa Mr. Nico Blake - Director Langkloof Bricks South Africa Mr. Jez Rowe - VSBK Construction and VSBK design expert, SA

Rowe Construction CC South Africa The VSBK (Vertical Shaft Brick Kiln) is a clay brick firing method which operates according to the counter-current firing principle; the air moving upwards and the bricks moving downwards.


Cape EAPrac ix Final Basic Assessment Report

Figure 3 Showing a schematic cross section of a VSBK (Rowe,2012) During regular operation the green bricks are stacked in pre-determined patterns into the opening on top of the shaft in the form of batches. Measured amount of coal is placed into the spaces between the brick setting of the batch. Each batch typically contains four layers of bricks set on edge in two distinct predetermined patterns. The fired bricks are unloaded from the bottom of the shaft at pre-determined intervals depending on the fire position and schedule. The shaft itself can be divided into three distinct sections. The top section is called ‘Preheating zone’. In this zone the green bricks are pre-heated by the hot exhaust gases rising up from the firing zone. The middle section is called ‘Firing zone’ where the actual firing of the bricks takes place at the required temperature including the uniform chemical reactions needed to give the green brick a dense permanent shape. The lower section is called ‘Cooling zone’ where the fired bricks cool down through the supply of fresh air which is being drawn from the bottom of the shaft.


Cape EAPrac x Final Basic Assessment Report

Figure 4: Showing sections through a VSBK (Rowe, 2012). Fuel is added in two forms; as internal fuel and as external fuel. Internal fuel is added to the product during the clay processing. Internal fuel utilised in a VSBK is mostly spiral or duff. External fuel in the form of sized coal (small nuts) is used to regulate the temperature and position of fire and is added into the spaces of the green brick batches at the top of the shaft. The VSBK’s at Rheebok Bricks will have a single point of exhaust emission the airflow inside a VSBK can be controlled by a fan extraction system (FES). The air required for fuel combustion enters via the bottom of the shaft and extracts the heat from the cooling bricks before reaching the firing zone. The hot gases rising from the firing zone, heat up the batches of green bricks above. The cooled gases then enter the exhaust extraction system through the flue ducts at a temperature of approximately 60°C - 130°C and into the outlet pipes at diagonally opposite corners of each shaft. The outlet pipes form part of the flue duct and exhaust extraction system.


Cape EAPrac xi Final Basic Assessment Report

The entire brick stack rests on support bars (which can be removed and inserted) which in turn are supported by a pair of horizontal support beams across the base of the arches in the unloading tunnel.

Figure 5: Showing a typical layout of a 6 Shaft VSBK (Rowe, 2012). Rheebok bricks intend installing a total of 24 shafts (i.e. four such units).

Figure 6: Showing the top of a single shaft of a VSBK. (Photo taken at Langkloof Bricks, Eastern Cape)

Figure 7: Showing Green Bricks being loaded into the top of a VSBK. (Photo taken at Langkloof Bricks, Eastern Cape)


Cape EAPrac xii Final Basic Assessment Report

3.4 ENVIRONMENTAL BENEFITS OF VSBK’S VS. CLAMP KILNS

There are numerous reasons why VSBK’s are deemed to be environmentally superior to traditional clamp kilns. A summary of these are as follows.

1. VSBK’s use significantly less fossil fuels (coal) per brick manufactured than clamp kilns. 2. The atmospheric emissions of VSBK’s are significantly lower than that of clamp kilns. 3. Because of the lower coal usage, emissions and use of fossil fuels are further reduced

as lower coal requirement means less freight (mostly long haulage) is required to get the coal to site.

4. VSBK’s emissions are through a single stack, while clamp kiln emissions are over a wide area.

5. Because the VSBK emissions are emitted through a single stack, monitoring and verification of emissions is possible.

6. Because of the single point source of emissions, additional gas cleaning equipment can be installed should the emissions standards not meet regulatory requirements (this is not possible with clamp kilns)

4. SITE DESCRIPTION AND ATTRIBUTES

The Study site is situated approximately 1.8km north of Tergniet. Please see Appendix A attached to this report showing the location of the proposed location of the VSBK’s within the existing brickworks..

The site proposed for the construction of the VSBK’s is irreversibly transformed and is currently used as a storage area to store and air dry “green bricks” before they are fired. The total area is under an existing roof and the substrate consists of engineered layerworks. The VSBK’s will be constructed under the existing structure which will be improved to be able to accommodate the VSBK’s.

Figure 8: Showing the exhaust fan that evacuates exhaust fumes to a single stack. (Photo taken at Langkloof Bricks, Eastern Cape)

Figure 9: Showing completely fired and cooled bricks that are removed from the bottom of the shaft. (Photo taken at Langkloof Bricks, Eastern Cape)


Cape EAPrac xiii Final Basic Assessment Report

Figure 10: Showing historical aerial photographs (2011 – top left, 2010 – top right, 2006 – bottom left and 2004 – bottom right) showing the historical transformation of the site. As can be seen from the photos, the site proposed for the installation of the VSBK’s has been transformed for an extended period.

According to the National Spatial Biodiversity Assessment, the vegetation on site would have historically consisted of Groot Brak Dune Strandveld, with an ecosystem status of Endangered. The site has however, already been irreversibly transformed though industrial development and as such, no remnants of this vegetation or any other vegetation type remains on the site.

Because of the nature of the transformation (i.e. that the site is hard surfaced and under roof) and has been used for industrial activities for many years) and the transformed nature of the surrounding area, it is highly unlikely that the site will ever revert to an ecologically functioning unit of Groot Brak Dune Strandveld. The facility is thus considered to have NO impact on terrestrial vegetation and habitat.

According to the National Freshwater Ecosystem Priority Areas (NFEPA) Plan, no important freshwater ecosystems occur on the site. The closest NFEPA’s are a Channelled Valley Bottomed Wetland situated approximately 380m north of the site and a flat bench situated approximately 350 m west of the site. The EAP, during a site inspection, verified that there are no other water resources in the vicinity of the VSBK’s. Due to the nature of the VSBK operation, they will not impact on any hydrological resource.

5. PLANNING CONTEXT

The property is zoned for industrial purposes and the construction and operation of this facility is deemed to be consistent with this zoning. The Mossel Bay Municipality Department of Planning has been registered as a key stakeholder in this process and has been given an opportunity to comment on this land use. Please see Appendix E, Annexure E1 for a copy of the zoning certificate for this property.


Cape EAPrac xiv Final Basic Assessment Report

6. PROCESS TO DATE

As part of the public participation process the following steps were taken to ensure compliance with the legislation and to allow ample opportunity for members of the public and key stakeholders to be involved and participate in the environmental process. Please see Appendix F for evidence and further details of this Public Participation process. The Public Participation Process has been undertaken according to the requirements of the new NEMA EIA regulations. The following requirements i.t.o the Draft and Final Basic Assessment have been undertaken and complied with in terms of Regulation 56: CHRONOLOGY OF EVENTS Please see table 3 below for a summary of the public participation to date. Table 3: Summary of Public Participation Process to date. DATE ACTION 18 July 2013

Notification was sent to the Landowner notifying him of the development proposal and the environmental process to be followed.

18 July 2013

Notifications were sent to neighbouring landowners informing them of the development proposal and the environmental process. They were automatically registered as Interested and Affected Parties

18 July 2013

The Mossel Bay Local Municipality (which have jurisdiction over the area) were notified and automatically registered as key stakeholders.

18 July 2013

Organs of state (including Mossel Bay Municipality: Technical Services, Mossel Bay Municipality: Town Planning, Mossel Bay Municipality: Environmental Management, Mossel Bay Municipality: Health, Western Cape Provincial Department of Health, Department of Environmental Affairs and Development Planning: Pollution Control, Department of Environmental Affairs and Development Planning: Air Quality Management, Eden District Municipality: Environmental, Eden District Municipality: Health, Eden District Municipality: Air Quality, Cape Nature and Heritage Western Cape) were notified and registered as key stakeholders

19 July 2013

Advert was placed in a regional newspaper, Die Suid Kaap Burger calling for the registration of Interested and affected parties.

19 July 2013

Advert was placed in a local newspaper, The Mossel Bay Advertiser calling for the registration of Interested and affected parties.

19 July 2013

Background information documents were placed at the Mossel Bay Municipal Library and the Mossel Bay Municipal Planning Departments.

19 July 2013

2 site notices were placed on the boundary of the property as well as on the proposed site of the development.

July 2013

A Stakeholder Register was opened and the details of all registered stakeholders entered for future correspondence.

17 October 2013

Draft Basic Assessment Report was made available for a 40 day review and comment period up until 26 November 2013

28 November 2013

Final Basic Assessment Report was made available for a 21 day comment period until 06 January 2014 (the period 15 December to 05 January was excluded from the reckoning of days)

NOTE Public participation information with regards to the availability of the Draft Basic Assessment Report and the final Basic Assessment Report is attached in appendix f of the report

Copies of the comments received and responses thereto are included in Appendix F of this report. The issues raised have been summarised into an issues and response table attached in Appendix F of this report.

NEWSPAPER ADVERTS


Cape EAPrac xv Final Basic Assessment Report

Two newspaper adverts calling for registration of interested and affected parties were placed in the Mossel Bay Advertiser (a local newspaper) and Die Suid Kaap Burger (a provincial newspaper)

BACKGROUND INFORMATION DOCUMENT With the initial stakeholder registrations background information documents (BID’s) were made available to stakeholders. All key stakeholders were provided with hard copies of the BID along with the notification letters. BID’s were also made available at the Mossel Bay Municipal Library and the Mossel Bay Municipality Planning Department. The BID’s were also made available on the Cape EAPrac Website. Copies of the background information document are included in Appendix F. REGISTRATION OF KEY STAKEHOLDERS A number of key stakeholders were automatically registered and will be given an opportunity to comment on the Draft and Final Basic Assessment Reports.

NOTIFICATION OF NEIGHBOURING PROPERTY OWNERS. Neighbouring property owner’s details were obtained from the Mossel Bay Municipality. These neighbouring property owners were automatically registered as Interested and Affected Parties and have been notified of the availability of the Draft and Final BAR. PRELIMINARY ISSUES RAISED BY I&AP’s The only issue raised thus far relates to potential additional noise associated with the VSBK’s. Please see section F of this report for the Assessment of Impacts as well as Appendix G containing the specialist Air Quality Impact Assessment. AVAILABILITY OF DRAFT BAR All registered I&AP’s including those who responded to the initial call for registration as well as those who were automatically registered were notified of the Availability of the Draft BAR. The Draft BAR was available for a 40 day comment period from Wednesday 16 October 2013 to Monday 26 November 2013 and was available at the Mossel Bay Municipal library in Marsh Street and the Mossel Bay Municipal Planning Office in Montague Street. A digital copy of the report was also available on the Cape EAPrac website at url: www.cape-eaprac.co.za. In order to facilitate effective comment, full hard copies of the report were also provided to Eden District Municipality: Air Quality Management and the Department of Environmental Affairs: Air Quality Management. Digital copies of the report on CD were also provided to all other Key Stakeholders. Proof of the availability of the Draft BAR is attached in Appendix F. COMMENTS ON DRAFT BAR. Comments on the draft BAR were received from the following organisations and individuals:

Mr Clyde Lamberts – Cape Nature Mr Bles de Wet – Surrounding property owner Kainos Hove – DEA&DP Pollution Control Johan Schoeman – Eden District Municipality Air Quality Anton Dellejmin – Chairperson Midbrak Ratepayers Association

http://www.cape-eaprac.co.za/


Cape EAPrac xvi Final Basic Assessment Report

Cape Nature and Midbrak Ratepayers indicated that they had no objection to the proposed replacement of the Clamp Kilns with vertical shaft brick kilns. Eden district municipality and DEA&DP pollution control raised a number of queries relating to the specialist Air Quality Impact – These queries were responded to with input from the specialist. Mr de Wet raised concerns regarding the existing clamp kiln operations and the smoke that they generate. Since the VSBK’s will generate significantly lower volumes of smoke, authorisation of the VSBK’s will address his concern and improve the situation. All comments received as well as Cape EAPrac’s and the Specialist responses are included in Appendix F of this report. AVAILABILITY OF FINAL BAR All registered I&AP’s including those who responded to the initial call for registration, those who were automatically registered as well as those who provided comment on the Draft BAR were notified of the Availability of this Final BAR. The Final BAR was available for a 21 day comment period from Tuesday 28 November 2013 to Monday 6 January 2014 on the Cape EAPrac website at url: www.cape-eaprac.co.za. Proof of the availability of the Final BAR is attached in Appendix F. COMMENTS ON FINAL BAR No additional comments were received on the Final BAR.

7. NEED, DESIRABILITY AND FEASIBILITY

The concept of need and desirability relates to the type of development being proposed in any specific area. According to the DEA&DP guidelines on the consideration of need and desirability, the concept of need and desirability can be explained in terms of the general meaning of its two components in which need refers to time and desirability to place. In other words, one must ask “is this the right time and is it the right place for locating the type of land-use/activity being proposed?” Need and desirability can be equated to wise use of land to ensure that the activity proposed is the most sustainable use of land.

The need and desirability of this activity is considered in Section D of this report below. The following summary and additional feasibility information is provided in this regard.

7.1 NEED AND DESIRABILITY QUESTIONS.

In terms of the Need and Desirability guidelines, need and desirability should be considered through consideration of the following questions.

7.1.1 Need (Timing)

Question 1: Is the land use (associated with the activity being applied for) considered within the timeframe intended by the existing approved Spatial Development Framework (SDF) agreed to by the relevant environmental authority?

The current land use where the activity is proposed is industrial, and more specifically for the manufacture of clay bricks. The improvement of technology within the brick making industry is consistent with the land use.



Cape EAPrac xvii Final Basic Assessment Report

Question 2: Should development, or if applicable, expansion of the town/area concerned in terms of this land use (associated with the activity being applied for), occur here at this point in time?

The site is used for brick making purposes and has been in excess of 40 years.

There will thus be no change in land use by the changing in technology within this industry. The continued use of the area for industrial purposes is thus deemed to be the most suitable land use at this point in time.

Question 3: Does the community/area need the activity and the associated land use concerned (is it a societal priority)?

The directly adjacent / immediate communities / area will have very little direct need for the facility. Its significance is more established on a regional and national scale in terms of provision of building material as an economic driver in South Africa.

Question 4: Are the necessary services with adequate capacity currently available (at the time of application), or must additional capacity be created to cater for the development?

The services (roads, water and electrical) will be used and it is not necessary to upgrade any of these services. The replacement of the clamp kilns with VSBK’s will also not result in an increased demand on any services.

Question 5: Is this development provided for in the infrastructure planning of the municipality, and if not, what will the implication be on the infrastructure planning of the municipality (priority and placement of services and opportunity costs)?

This project will not result in additional opportunity costs and pressure on existing municipal infrastructure. The facility will not result in additional demand on existing infrastructure. The Mossel Bay Municipality: Technical Services Department has been given an opportunity to provide comment in this regard. All comments in this regard have been provided with this Final Basic Assessment Report.

Question 6: Is this project part of a national programme to address an issue of national concern or importance?

The project is not intended to address an issue of national concern or importance.

7.1.2 Desirability (‘place’):

Question 7: Is the development the best practicable environmental option for this land/site?

The proposed facility is entirely consistent with the existing land use. The nature of the proposed site favours a brick manufacturing industry and any other land use (agriculture, residential, conservation) cannot be considered in this context.

Question 8: Would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF as agreed to by the relevant authorities.

This application is for a technological improvement of an existing facility and will not have any effect of the integrity of the IDP or SDF.

Question 9: Would the approval of this application compromise the integrity of the existing environmental management priorities for the area (e.g. as defined in EMF’s), and if so, can it be justified in terms of sustainability considerations?


Cape EAPrac xviii Final Basic Assessment Report

There are no Environmental Management Frameworks approved / in place for this area. Considering the nature of the site and its context within an existing developed industrial area, it is highly unlikely that any future EMF’s will identify the site of strategic environmental importance.

Question 10: Do location factors favour this land use (associated with the activity applied for) at this place? (this relates to the contextualisation of the proposed land use on this site within its broader context).

Yes. As previously mentioned, this activity is merely an improvement to a facility that has been in operation for more than 40 years.

Question 11: How will the activity, or the land use associated with the activity applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

The facility will be consistent with the existing built environment landscape and will not likely affect it in any way. Because of its consistency with surrounding land use (where natural and cultural landscapes are already highly transformed), it can be stated with a high level of confidence that this facility will not have a significant negative impact on the natural or cultural landscapes.

Question 12: How will the development impact on people’s health and wellbeing (e.g. in terms of noise, odours, visual character and sense of place, etc)?

Mr Chris Albertyn of Lethabo Air Quality Services was appointed to develop a dispersion model of the facility and to undertake an Air Quality Impact Assessment.

The results of this assessment show that the technological improvements will not impact on ambient air quality standards and will in fact result in an overall improvement in ambient air quality.

Question 13: Will the proposed activity or the land use associated with the activity applied for, result in unacceptable opportunity costs?

The construction of this facility at the preferred location will not cause the loss of potential gain from another alternative industry / land use on this piece of land. The production capacity of Rheebok Bricks will not be increased by this technological improvement.

Question 14: Will the proposed land use result in unacceptable cumulative impacts?

The activity will not result in significant cumulative impacts. In terms of cumulative impact, the changing of technology will result in an improvement to air quality in the region. An assessment of the cumulative impact of this facility is included in Section F of this report.

8. SUMMARY OF IMPACTS The potential impacts of this facility are summarised in the Tables below. Please refer to Section F of this report as well as Appendix G for further details regarding the assessment of impacts. 8.1 IMPACTS THAT MAY RESULT FROM THE PLANNING, DESIGN AND CONSTRUCTION PHASE

Potential impacts Fugitive Dust Low-None The dust impact during in the construction phase is likely to be extremely limited, as the construction of the VSBK’s will take place beneath an existing structure. Earthworks during


Cape EAPrac xix Final Basic Assessment Report

construction are thus limited to the casting of foundation structures. Potential impact on ecological functioning of the area. Low - None

Due to the irreversibly transformed nature of site and the low impact construction, the construction phase impact on the ecological functioning of the area is deemed to be negligible. Potential impact on Hydrological Resources. Low-Very Low

The construction activities are not in proximity to any water resources and the nature of the construction activities is highly unlikely to have any effect on hydrological resources. Potential impacts Employment opportunities during construction Medium (Positive)

The activity will result in a number of employment opportunities during the construction phase. Potential impacts on cultural-historical aspects: None

Due to the nature of the facility in the landscape (i.e that the construction activities will take place amidst other continual industrial activities) it is highly unlikely that the construction phase of this project will have any impact on any heritage aspects of the area. Potential noise impacts: Medium - Low Noise during construction is not likely to be higher than the ambient noises already present in this existing industrial area. Potential visual impacts: None It is highly unlikely that the activity will result in any visual impacts during construction. The type of activates associated with construction are the same activities that are already taking place daily in this industrial area. 8.2 IMPACTS THAT MAY RESULT FROM THE OPERATIONAL PHASE

Potential impacts of Fugitive Dust Medium-Low Fugitive dust will likely be less than with the current clamp kiln firing process Potential impacts on Traffic (additional trip generation) Low - Neutral

The impacts on traffic are deemed to be insignificant as no additional trips will be required. Potential impact Ecological Functioning of the Area Low

The site is already irreversibly transformed and contains no remnants of vegetation, nor any ecological pattern or process. The impact on the ecological functioning of this facility on the area is thus deemed to be negligible. Potential impact on the Hydrological Functioning of the Area: Low

The proposed positioning of the facility is not in proximity to any surface or groundwater resources and as such is unlikely to have any impact on these resources. Potential impacts on Employment opportunities High Positive

This project will generate a number of long term employment opportunities. Should Rheebok Bricks implement a skills transfer programme, the direct positive impact on the local communities and economy could be high. Potential impacts on the socio- Low Neutral


Cape EAPrac xx Final Basic Assessment Report

economic aspects of the surrounding community The activity is unlikely to result in significant socio economic impacts on the surrounding communities as the nature of the existing industry will not be changed by these technological changes. Potential impacts on the cultural-historical aspects of the area Low

The position of the activity within the landscape is of such a nature that it is surrounded on all sides by other activities that have already significantly transformed the landscape. This activity will not result in additional activities within the landscape, it is merely improving the technology of the existing industry. Potential noise impacts: Low The Operational impact in terms of noise is deemed to be zero, as ambient noise impacts are already significantly higher than what this facility will contribute. The noise associated with VSBK’s is limited to the extraction fans. Potential visual impacts: Low Positive The facility will include a single stack with controlled as opposed to multiple clamp kilns each one with its own emissions and associated visual impacts. The visual quality of the landscape is thus likely to be improved by this facility. Potential Air Quality Impacts: Low Please see section 2 of this report for further details as well as Appendix G for a copy of the full air quality impact assessment that was undertaken. The replacement of the existing clamp kilns with VSBK’s is likely to result in an improvement in air quality. 8.3 IMPACTS THAT MAY RESULT FROM THE DECOMMISSIONING AND CLOSURE PHASE

Potential impacts of Fugitive Dust Low-None The technological improvements will not likely result in any fugitive dust during the decommissioning stage. Potential impacts on the Ecological Functioning of the Area Low

The decommissioning of this facility will unlikely result in any impacts on the ecological functioning of the area. Potential noise impacts: Noise The decommissioning of this facility will unlikely to result in noise impacts over and above those already associated with an industrial facility. 9. CONCLUSION Cape EAPrac is of the opinion that the information contained in this Final Assessment Report and the documentation attached hereto is sufficient to allow the decision making authority to apply their minds to the potential negative and positive impacts associated with the development, in respect of the activities applied for and make informed decision on the proposal. The proposed technological improvements at Rheebok Bricks have been found to have an overall positive impact to Air Quality, Resource Sustainability and Economic Feasibility of the existing industry without compromising the biophysical and social environment. Sufficient mitigation measures have been recommended to reduce potential negative impacts to low levels and enhance positive impacts.


Cape EAPrac xxi Final Basic Assessment Report

All comment received on both the draft and final BAR’s are included in this report.


Cape EAPrac xxii Final Basic Assessment Report

GLOSSARY BGIS Biodiversity Geographic Information System BID Background Information Document CBA Critical Biodiversity Area CBD Central Business District DEA Department of Environmental Affairs DEA&DP Department of Environmental Affairs and Development Planning EA Environmental Authorisation EAP Environmental Impact Practitioner ECO Environmental Control Officer EHS Environmental, Health & Safety EIA Environmental Impact Assessment EMP Environmental Management Programme GPS Global Positioning System HDD Horizontal Directional Drilling HWC Heritage Western Cape I&APs Interested and Affected Parties IDP Integrated Development Plan N / A Not Applicable NEMA National Environmental Management Act NEMBA National Environmental Management: Biodiversity Act NFA National Forest Act NFEPA National Freshwater Ecosystem Priority Area NHRA National Heritage Resources Act NSBA National Spatial Biodiversity Assessment NWA National Water Act SAHRA South African National Heritage Resources Agency SANBI South Africa National Biodiversity Institute SANS South Africa National Standards SDF Spatial Development Framework


Cape EAPrac xxiii Final Basic Assessment Report

ABBREVIATIONS AIA Archaeological Impact Assessment BGIS Biodiversity Geographic Information System BID Background Information Document CBD Central Business District ACMP Archaeological Conservation Management Plan CDSM Chief Directorate Surveys and Mapping CEMP Construction Environmental Management Plan dBA Decibel (measurement of sound) DBAR Draft Basic Assessment Report DEA Department of Environmental Affairs DEA&DP Department of Environmental Affairs and Development Planning EAP Environmental Impact Practitioner EHS Environmental, Health & Safety EIA Environmental Impact Assessment EIR Environmental Impact Report EMP Environmental Management Programme FBAR Final Basic Assessment Report GPS Global Positioning System HIA Heritage Impact Assessment HWC Heritage Western Cape I&APs Interested and Affected Parties IDP Integrated Development Plan KOP Key Observation Point kV Kilo Volt LAeq,T Time interval to which an equivalent continuous A-weighted sound level LUDS Land Use Decision Support LUPO Land Use Planning Ordinance NEMA National Environmental Management Act NEMAA National Environmental Management Amendment Act NEMBA National Environmental Management: Biodiversity Act NHRA National Heritage Resources Act NID Notice of Intent to Develop NSBA National Spatial Biodiversity Assessment NWA National Water Act PIA Paleontological Impact Assessment PM Post Meridiem; “Afternoon” SAHRA South African National Heritage Resources Agency SANBI South Africa National Biodiversity Institute SANS South Africa National Standards SDF Spatial Development Framework SMME Small, Medium and Micro Enterprise SAPD South Africa Police Department TIA Traffic Impact Assessment VIA Visual Impact Assessment

Rheebok Bricks – VSBK’s BASIC ASSESSMENT REPORT MOS243a/12


SECTION 1: BASIC ASSESSMENT

REPORT


Cape EAPrac 1 Final Basic Assessment Report

BASIC ASSESSMENT REPORT

(AUGUST 2010)

BASIC ASSESSMENT FORM

(AUGUST 2011) Basic Assessment Report in terms of the NEMA Environmental Impact Assessment

Regulations, 2010 AUGUST 2010

Kindly note that:

1. This Basic Assessment Report is the standard report required by DEA&DP in terms of the EIA Regulations, 2010 and must be completed for all Basic Assessment applications.

2. This report must be used in all instances for Basic Assessment applications for an environmental authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), as amended, and the Environmental Impact Assessment Regulations, 2010, and/or a waste management licence in terms of the National Environmental Management: Waste Act, 2008 (Act 59 of 2008) (NEM: WA), and/or an atmospheric emission licence in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (NEM: AQA).

3. This report is current as of 2 August 2010. It is the responsibility of the Applicant / EAP to ascertain whether subsequent versions of the report have been published or produced by the competent authority.

4. The required information must be typed within the spaces provided in the report. The sizes of the spaces provided are not necessarily indicative of the amount of information to be provided. It is in the form of a table that will expand as each space is filled with typing.

5. Incomplete reports will be rejected. A rejected report may be amended and resubmitted.

6. The use of “not applicable” in the report must be done with circumspection. Where it is used in respect of material information that is required by the Department for assessing the application, this may result in the rejection of the report as provided for in the regulations.

7. While the different sections of the report only provide space for provision of information related to one alternative, if more than one feasible and reasonable alternative is considered, the relevant section must be copied and completed for each alternative.

8. Unless protected by law all information contained in, and attached to this report, will become public information on receipt by the competent authority. If information is not submitted with this report due to such information being protected by law, the applicant and/or EAP must declare such non-disclosure and provide the reasons for the belief that the information is protected.

9. This report must be submitted to the Department at the postal address given below or by delivery thereof to the Registry Office of the Department. No faxed or e-mailed reports will be accepted. Please note that for waste management licence applications, this report must be submitted for the attention of the Department’s Waste Management Directorate (tel: 021-483-2756 and fax: 021-483-4425) at the same postal address as the Cape Town Office Region A.

Unless indicated otherwise, two electronic copies (CD/DVD) and three hard copies of this report must be submitted to the Department.



DEPARTMENTAL DETAILS CAPE TOWN OFFICE REGION A (Cape Winelands, City of Cape Town: Tygerberg and Oostenberg Administrations)

CAPE TOWN OFFICE REGION B (West Coast, Overberg, City of Cape Town: Helderberg, South Peninsula, Cape Town and Blaauwberg Administrations

GEORGE OFFICE (Eden and Central Karoo)

Department of Environmental Affairs and Development Planning Attention: Directorate: Integrated Environmental Management (Region A2) Private Bag X 9086 Cape Town, 8000 Registry Office 1st Floor Utilitas Building 1 Dorp Street, Cape Town Queries should be directed to the Directorate: Integrated Environmental Management (Region A2) at: Tel: (021) 483-4793 Fax: (021) 483-3633

Department of Environmental Affairs and Development Planning Attention: Directorate: Integrated Environmental Management (Region B) Private Bag X 9086 Cape Town, 8000 Registry Office 1st Floor Utilitas Building 1 Dorp Street, Cape Town Queries should be directed to the Directorate: Integrated Environmental Management (Region B) at: Tel: (021) 483-4094 Fax: (021) 483-4372

Department of Environmental Affairs and Development Planning Attention: Directorate: Integrated Environmental Management (Region A1) Private Bag X 6509 George, 6530 Registry Office 4th Floor, York Park Building 93 York Street George Queries should be directed to the Directorate: Integrated Environmental Management (Region A1) at: Tel: (044) 805 8600 Fax: (044) 874-2423

View the Department’s website at http://www.capegateway.gov.za/eadp for the latest version of this document.

DEPARTMENTAL REFERENCE NUMBER(S)

File reference number (EIA): 16/3/1/1/D6/31/0045/13 File reference number (Waste): None File reference number (Other): EDE019 – Eden District Municipality (Air Quality) PROJECT TITLE Rheebok Bricks – Vertical Shaft Brick Kilns

http://www.capegateway.gov.za/eadp



DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) Environmental Assessment Practitioner (EAP):

Cape Environmental Assessment Practitioners (Pty) Ltd

Contact person: Dale Holder Postal address: P O Box 2070 George Postal code: 6530 Telephone: (044) 874 0365 Cell: 0824489225

E-mail: [email protected] Fax: (044) 874 0432

EAP Qualifications EAP, Dale Holder - NDip NatCon Director, Louise Mari van Zyl – MA Environmental Management

EAP Registrations/Associations

IAIAsa EAPSA

DETAILS OF THE EAP’S EXPERTISE TO CARRY OUT BASIC ASSESSMENT PROCEDURES The EAP has more than 11 years’ experience in carrying out Environmental Impact Assessment Procedures in the Western, Eastern and Northern Cape Provinces of South Africa. The EAP has experience related to a number of other Brick Manufacturing Facilities in the Western Cape. A highly experienced air quality specialist has also been appointed to undertake relevant specialist studies. EXECUTIVE SUMMARY OF THE CONTENT OF THE BASIC ASSESSMENT REPORT: A detailed executive summary in the form of a Basic Assessment Overview is included in pages i to xxi of this report and is not repeated here.



SECTION A: ACTIVITY INFORMATION 1 PROJECT DESCRIPTION

(aIs the project a new development? YES NO (b) Provide a detailed description of the development project and associated infrastructure. Rheebok Brick Holdings (Pty) Ltd have submitted an application for a Basic Assessment, as well as an application for an Atmospheric Emissions Licence to replace their existing Clamp Kilns with Vertical Shaft Brick Kilns (VSBK’s).

It is proposed that the existing clamp kilns currently in operation at Rheebok Bricks be systematically phased out and replaced with VSBK’s over a 5 year period. The manufacturing capacity of Rheebok Bricks will not increase as a result of this technological improvement. In order to meet the current manufacturing capacity, a total of 24 VSBK’s will be constructed.

VSBK are a continuous type clay brick firing method which operate according to the counter-current firing principle. In other words the air moves upwards through the kiln, while the bricks move downwards, in a continuous cycle.

The unfired or “green bricks” are stacked into the opening at the top of the shaft. A measured amount of coal is placed into the spaces between the bricks during each batch.

The fired bricks (finished product) are unloaded from the bottom of the shaft at pre-determined intervals.

Every time one batch of finished bricks is unloaded at the bottom of the shaft, the new batch of “green” bricks is put into the top of the shaft, making this a continuous process.

(c) List all the activities assessed during the Basic Assessment process: GN No. R. 544 Activity No(s):

Describe the relevant Basic Assessment Activity(ies) in writing as per Listing Notice 1 (GN No. R. 544)

Describe the portion of the development as per the project description that relates to the applicable listed activity.

28 The expansion of or changes to existing facilities for any process or activity where such expansion or changes to will result in the need for a permit or licence in terms of national or provincial legislation governing the release of emissions or pollution, excluding where the facility, process or activity is included in the list of Waste Management Activities published in terms of section 19 of the NEM:WA.

Rheebok Brick Holdings intend changing their existing facility by systematically replacing their existing Clamp Kilns to Vertical Shaft Brick Kilns. Please note: the footprint or throughput of the facility will not be expanded as part of this application.

GN No. R. 546 Activity No(s):

Describe the relevant Basic Assessment Activity(ies) in writing as per Listing Notice 3 (GN No. R. 546)


None None None



If the application is also for activities as per Listing Notice 2 and permission was granted to subject the application to Basic Assessment, also indicate the applicable Listing Notice 2 activities: GN No. R. 545 Activity No(s):

If permission was granted in terms of Regulation 20, describe the relevant Scoping and EIA Activity(ies) in writing as per Listing Notice 2 (GN No. R. 545)


None None None Waste management activities in terms of the NEM: WA (Government Gazette No. 32368): GN No. 718 - Category A Activity No(s):

Describe the relevant Category A waste management activity in writing.

None None Please note: If any waste management activities are applicable, the Listed Waste Management Activities Additional Information Annexure must be completed and attached to this Basic Assessment Report as Appendix I. If the application is also for waste management activities as per Category B and permission was granted to subject the application to Basic Assessment, also indicate the applicable Category B activities:

GN No. 718 – Category B Activity No(s):

Describe the relevant Category B waste management activity in writing.

None None Atmospheric emission activities in terms of the NEM: AQA (Government Gazette No. 33064):

GN No. 248 Activity No(s): Describe the relevant atmospheric emission activity in writing.

5 (7) The production of tiles, bricks, refractory bricks, stoneware or porcelain ware by firing.

(d) Please provide details of all components of the proposed project and attach diagrams (e.g. architectural drawings or perspectives, engineering drawings, process flow charts etc.). Buildings YES NO Provide brief description: The proposed VSBK’s will be constructed within an existing building on site. This existing building is currently being used to store / dry unfired (green) bricks. The existing building will be modified in such a manner so that it is suitable (installing additional support, replacing roof sheeting etc) to install the VSBK’s.



Figure 11: Showing existing building where VSBK’s will be housed.

Figure 12: The building is currently used for air drying bricks before they are packed into the clamp kilns. The VSBK’s will be constructed in this area. Infrastructure (e.g. roads, power and water supply/ storage) YES NO Provide brief description: There is existing sufficient electrical supply to the site. The electrical supply is currently used to supply electricity to large fans that are used to air dry the bricks. The electrical requirements of the VSBK’s is generally limited to and electrical lift (to lift green bricks to the



top of the shaft), hydraulic pump / electrical screw (to lower fired bricks out of the shaft) and an extraction fan to evacuate exhaust fumes. The existing electrical supply is sufficient and will not include any upgrading. It is highly likely that the electrical demand of the VSBK’s will be less than that of the current drying fans.

The VSBK’s will not require any additional water over and above that already used in the shaping / extrusion process. Rheebok Bricks currently receives “brown water” (i.e. untreated water from the municipal supply dam) from the Mossel Bay Municipality - This treated water is used in the extrusion process (i.e. shaping the green bricks). The proposed technological improvement to the firing methodology will not result in any additional water demand.

All access roads are in existence and no additional access roads will be required.

No additional bulk infrastructure is requires for this technological improvement.

Processing activities (e.g. manufacturing, storage, distribution) YES NO Provide brief description: The proposal does not include any processing activities. Storage facilities for raw materials and products (e.g. volume and substances to be stored) Provide brief description YES NO The following raw materials are already stored as part of the existing manufacture process:

- Ball Clay – 9093.28 Tons per month. - Coal Spiral & Small Nuts – 2266.8 Tons per month.

When the Clamp Kilns are replaced with VSBK’s, the clay requirements will remain the same, but the coal requirements in the manufacture process will be significantly reduced (as VSBK’s use significantly less coal than Clamp Kilns).

Storage and treatment facilities for solid waste and effluent generated by the project Yes No

Provide brief description The existing and future proposed manufacturing process does not generate any solid waste whatsoever. Any improperly or partially fired are recycled back into the process as “grog”. The percentage of improperly fired bricks associated with VSBK’s is significantly lower than that of Clamp Kilns. Other activities (e.g. water abstraction activities, crop planting activities) Yes No Provide brief description None 2. PHYSICAL SIZE OF THE ACTIVITY

Size of the property: (a) Indicate the size of the property (cadastral unit) on which the activity is to be undertaken. 26000m2

Size of the facility:



(b) Indicate the size of the facility (development area) on which the activity is to be undertaken. 6000m2

Size of the activity:

(c) Indicate the physical size (footprint) of the activity together with its associated infrastructure: ±2240m2 (28m x 80m)

(d) Indicate the physical size (footprint) of the activity: ±2240m2 (28m x 80m) (e) Indicate the physical size (footprint) of the associated infrastructure: 0m2

The size indicated above relates to the area that will be taken up by the VSBK’s. and, for linear activities:

Length of the activity: (f) Indicate the length of the activity: Not a linear activity

3. SITE ACCESS (a) Is there an existing access road? YES NO (b) If no, what is the distance over which a new access road will be built? 0m

Figure 13: Showing existing access and internal roads that will be used. The replacement of the clamp kilns with VSBK’s will not require any additional Haul Roads. (c) Describe the type of access road planned: Existing access roads and internal roads will be used. These will not need to be upgraded as part of this process.

Please Note: indicate the position of the proposed access road on the site plan.



4. DESCRIPTION OF THE PROPERTY ON WHICH THE ACTIVITY IS TO BE UNDERTAKEN AND THE LOCATION OF THE ACTIVITY ON THE PROPERTY

(a) Provide a description of the property on which the activity is to be undertaken and the location of the activity on the property.

The property is situated North of the N2 approximately 1.5km north of Tergniet. Please see Appendix A attached to this report showing the location of Rheebok Bricks.

(b) Please provide a location map (see below) as appendix a to this report which shows the

location of the property and the location of the activity on the property; as well as a site map (see below) as appendix b to this report; and if applicable all alternative properties and locations.

Locality map:

The scale of the locality map must be at least 1:50 000. For linear activities of more than 25 kilometres, a smaller scale e.g. 1:250 000 can be used. The scale must be indicated on the map. The map must indicate the following: an accurate indication of the project site position as well as the positions of the

alternative sites, if any; road names or numbers of all the major roads as well as the roads that provide

access to the site(s) a north arrow; a legend; the prevailing wind direction (during November to April and during May to October);

and GPS co-ordinates (Indicate the position of the activity using the latitude and

longitude of the centre point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes. The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection).

Site Plan:

Detailed site plan(s) must be prepared for each alternative site or alternative activity. The site plan must contain or conform to the following: The detailed site plan must be at a scale preferably at a scale of 1:500 or at an

appropriate scale. The scale must be indicated on the plan. The property boundaries and numbers of all the properties within 50m of the site must

be indicated on the site plan. The current land use (not zoning) as well as the land use zoning of each of the

adjoining properties must be indicated on the site plan. The position of each element of the application as well as any other structures on the

site must be indicated on the site plan. Services, including electricity supply cables (indicate above or underground), water

supply pipelines, boreholes, sewage pipelines, storm water infrastructure and access roads that will form part of the development must be indicated on the site plan.

Servitudes indicating the purpose of the servitude must be indicated on the site plan. Sensitive environmental elements within 100m of the site must be included on the site

plan, including (but not limited to): o Rivers. o Flood lines (i.e. 1:10, 1:50, year and 32 meter set back line from the banks of a

river/stream). o Ridges. o Cultural and historical features. o Areas with indigenous vegetation (even if it is degraded or infested with alien



species). Whenever the slope of the site exceeds 1:10, then a contour map of the site must be

submitted. The location plan is attached in Appendix A. The Site Plan is attached in Appendix B of this report. (c) For a linear activity, please also provide a description of the route. The proposal does not include any linear activities. The activity will be limited to the ±2240m2 (28m x 80m) footprint as indicated in Appendix B of the report.

Indicate the position of the activity using the latitude and longitude of the centre point of the site. The co-ordinates must be in degrees, minutes and seconds. The minutes should be given to at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection.

Latitude (S): Longitude (E):

34o 3‘ 0.34“ 22o 11‘ 25.98“

(d) or: For linear activities: Latitude (S): Longitude (E): Starting point of the activity o ‘ “ o ‘ “ Middle point of the activity o ‘ “ o ‘ “ End point of the activity o ‘ “ o ‘ “ Please Note: For linear activities that are longer than 500m, please provide and addendum with co-ordinates taken every 100 meters along the route.



5. SITE PHOTOGRAPHS Colour photographs of the site and its surroundings (taken of the site and from the site) with a description of each photograph. The vantage points from which the photographs were taken must be indicated on the site plan, or locality plan as applicable. If available, please also provide a recent aerial photograph. Photographs must be attached as Appendix C to this report. It should be supplemented with additional photographs of relevant features on the site. Date of photographs must be included. Please note that the above requirements must be duplicated for all alternative sites. Site photographs of the site, alternative sites and surrounding land use are included in Appendix C of this Report.



SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT 1 SITE/AREA DESCRIPTION For linear activities (pipelines, etc.) as well as activities that cover very large sites, it may be necessary to complete copies of this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section B and indicate the area which is covered by each copy No. on the Site Plan.

The proposed site for the VSBK’s will be contained within the existing footprint of Rheebok Bricks (The proposed footprint is within a covered area used to air dry “green bricks”). The site is entirely disturbed with no remnant ecological functioning. The proposed VSBK’s will be constructed under an existing roof that is currently used for the air drying of bricks. Structural improvements to this building are required; the footprint however will not be expanded. 2. GRADIENT OF THE SITE Indicate the general gradient of the sites (highlight the appropriate box).

Flat Flatter than 1:10 1:10 – 1:4 Steeper than 1:4 3. LOCATION IN LANDSCAPE (a) Indicate the landform(s) that best describes the site (highlight the appropriate box(es).

Ridgeline Plateau Side slope of hill/mountain

Closed valley

Open valley Plain

Undulating plain/low

hills Dune Sea-

front

(b) Please provide a description of the location in the landscape. The site is situated on high ground within a slightly undulating landscape north of Tergniet.

Figure 14: Showing the context of Rheebok Bricks within the landscape (this image has a 2x vertical exaggeration to highlight context)



4. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (a) Is the site(s) located on or near any of the following (highlight the appropriate boxes)?

Shallow water table (less than 1.5m deep) YES NO UNSURE Seasonally wet soils (often close to water bodies) YES NO UNSURE

Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE

Dispersive soils (soils that dissolve in water) YES NO UNSURE Soils with high clay content YES NO UNSURE Any other unstable soil or geological feature YES NO UNSURE An area sensitive to erosion YES NO UNSURE An area adjacent to or above an aquifer. YES NO UNSURE An area within 100m of the source of surface water YES NO UNSURE

(b) If any of the answers to the above are “YES” or “unsure”, specialist input may be requested by the Department.

(Information in respect of the above will often be available at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

(c) Please indicate the type of geological formation underlying the site.

Granite Shale Sandstone Quartzite Dolomite Dolorite Other (describe)

Please provide a description. According Agricultural Geographic Information Systems from the National Department of Agriculture, the underlying geological formation is alluvial valley deposits.

5. SURFACE WATER (a) Indicate the surface water present on and or adjacent to the site and alternative sites

(highlight the appropriate boxes)? Perennial River YES NO UNSURE Non-Perennial River YES NO UNSURE Permanent Wetland YES NO UNSURE Seasonal Wetland YES NO UNSURE Artificial Wetland YES NO UNSURE Estuarine / Lagoonal wetland YES NO UNSURE

(b) Please provide a description. The closest natural surface water body is a head of a watercourse situated approximately 350 west of the proposed site. An earth dam is situated approximately 550m north of the proposed site. (Please see the detailed description of the aquatic ecosystems and photographs in section 6 of this report)



Figure 15: Showing proximity of the closest surface water bodies to the proposed VSBK’s.




Figure 16: Showing the location of the VSBK's in relation to Freshwater Ecosystem Priority Areas.

6. BIODIVERSITY Please note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the site and potential impact(s) of the proposed activity/ies. To assist with the identification of the biodiversity occurring on site and the ecosystem status consult http://bgis.sanbi.org or [email protected]. Information is also available on compact disc (cd) from the Biodiversity-GIS Unit, Ph (021) 799 8698. This information may be updated from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is used. A map of the relevant biodiversity information (including an indication of the habitat conditions as per (b) below) and must be provided as an overlay map to the property/site plan as Appendix D to this report. (a) Highlight the applicable biodiversity planning categories of all areas on site and indicate the

reason(s) provided in the biodiversity plan for the selection of the specific area as part of the specific category).

Systematic Biodiversity Planning Category If CBA or ESA, indicate the reason(s) for its selection in biodiversity plan

Critical Biodiversity Area (CBA)

Ecological Support

Area (ESA)

Other Natural Area

(ONA)

No Natural Area

Remaining (NNR)

According to SANBI the site is not designated as an Aquatic or Terrestrial Critical Biodiversity Area (CBA). It is also not situated in an Ecological Support Area nor a CBA buffer area. According to the Mossel Bay CBA Maps, the site is depicted as “no natural areas remaining”.

http://bgis.sanbi.org/

mailto:[email protected]



Maps showing the site in relation to the CBA’s are attached in Appendix D.

Figure 17: Showing the proposed VSBK’s in relation to Critical Biodiversity Areas (Green) and Ecological Support Areas / CBA Buffers (Blue).

(b) Highlight and describe the habitat condition on site.

Habitat Condition

Percentage of habitat condition

class (adding up to 100%)

Description and additional Comments and Observations

(including additional insight into condition, e.g. poor land management practises, presence of

quarries, grazing/harvesting regimes etc.).

Natural 0% There are no remnants of Natural vegetation left on

site. Near Natural

(includes areas with low to moderate

level of alien invasive plants)

0% There are no remnants of Near Natural vegetation left on site.

Degraded (includes areas

heavily invaded by alien plants)

0% There are no remnants of Degraded vegetation left on site.

Transformed 100% The site is completely and irreversibly transformed



(includes cultivation, dams, urban,

plantation, roads, etc.)

through current industrial activities.

(c) Complete the table to indicate:

(i) the type of vegetation, including its ecosystem status, present on the site; and (ii) whether an aquatic ecosystem is present on site.

(d) Please provide a description of the vegetation type and/or aquatic ecosystem present on

site, including any important biodiversity features/information identified on site (e.g. threatened species and special habitats)



A site inspection by a biodiversity specialist has confirmed that the closest natural vegetation

Terrestrial Ecosystems Aquatic Ecosystems

Ecosystem threat status as per the National Environmental

Management: Biodiversity Act (Act No. 10 of 2004)

Critical Wetland (including rivers, depressions,

channelled and unchanneled

wetlands, flats, seeps pans, and artificial

wetlands)

Estuary Coastline

Endangered Vulnerable

Least Threatened

Yes NO Unsure Yes NO Yes NO

Figure 18: Showing the transformed nature of the site. The site where the VSBK’s are proposed consists of a covered building used for brick drying and is irreversibly transformed with no remnants of natural vegetation.



is a few small thicket patches surrounding the existing dam approximately 550m north of the proposed VSBK location.

7. LAND USE OF THE SITE Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed activity/ies. Untransformed

area Low density residential

Medium density residential

High density residential

Informal residential

Retail Commercial & warehousing Light industrial Medium

industrial Heavy industrial

Power station Office/consulting room

Military or police base/station/co

mpound

Casino/entertainment complex

Tourism & Hospitality

facility

Open cast mine Underground mine

Spoil heap or slimes dam

Quarry, sand or borrow pit Dam or reservoir

Hospital/medical center School Tertiary

education facility Church Old age home

Sewage treatment plant

Train station or shunting yard Railway line Major road (4

lanes or more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste treatment site Plantation Agriculture River, stream or

wetland

Nature conservation

area Mountain,

koppie or ridge Museum Historical building Graveyard Archeological

site

Other land uses (describe):

(a) Please provide a description. The site proposed for the construction of the VSBK’s is completely transformed through past and present industrial activities. The site is currently under roof and is used for drying of bricks as part of the brick manufacturing process that currently takes place at Rheebok Bricks. 8. LAND USE CHARACTER OF SURROUNDING AREA (a) Highlight the current land uses and/or prominent features that occur within +/- 500m radius

of the site and neighbouring properties if these are located beyond 500m of the site. Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed activity/ies. Untransformed

area Low density residential

Medium density residential

High density residential

Informal residential

Retail Commercial & warehousing Light industrial Medium industrial Heavy

industrial

Power station Office/consulting room

Military or police base/station/compoun

Casino/entertainment complex

Tourism & Hospitality



d facility

Open cast mine

Underground mine

Spoil heap or slimes dam

Quarry, sand or borrow pit

Dam or reservoir

Hospital/medical center

School / Crèche

Tertiary education facility Church Old age

home Sewage

treatment plant Train station or shunting yard Railway line Major road (4 lanes

or more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste

treatment site Plantation Agriculture River, stream or

wetland

Nature conservation

area Mountain,

koppie or ridge Museum Historical building Graveyard Archeological site

Other land uses

(describe):

(b) Please provide a description, including the distance and direction to the nearest residential

area and industrial area. The image below shows the typical land use surrounding land use as described in the table above.

Figure 19: Showing the proposed facility in relation to the surrounding land use. 9. SOCIO-ECONOMIC ASPECTS Describe the existing social and economic characteristics of the community in order to provide baseline information.



Socio-Economic Context of the Mossel Bay Municipal Area.

According to the Mossel Bay IDP (2012), Mossel Bay has the 2nd largest population in the Eden District with a population size of 117 840 in 2007 compared to 71 499 in 2001. The population grew on average by 8.7 per cent between 2001 and 2007 as compared to the district wide growth of 2 %.

The IDP concludes that a population growth of this proportion is likely to place strain on existing backlogs and the municipality’s ability to effectively service the community.

Mossel Bay’s population composition is as follows:

- children at 25.6%; - economically active population at 67.3%; and - persons aged 65 and older at 7.2%

The current gender ration is 111.6 males per 100 females. Overall there has been a shift in the gender distribution in Mossel Bay. In 2001, there were 49.7% males to 50.3%females. In 2007, this shifted to 52.8% males to 47.2 %females creating a shift in the female dominance in 2001 to a male dominance from 2007.

Mossel Bay’s population distribution by race is as follows:

- African racial group 41.6% - Coloured racial group 37.9% - White racial group 19.2% - Representation by the Indian/Asian population in Mossel Bay is relatively small

compared to the other population groups

The biggest employment contributors in the Mossel Bay Municipal are:

- construction (9%) - wholesale & retail trade (8%) - community; social & personal services (7%) - manufacturing (6%)

The three largest economic sectors are:

- manufacturing (28.7%); - finance and business services (27.5%); - trade (13.4%).

The unemployment rate for males was 15.6% with a 44.5 percentage share of the unemployed. The unemployment rate for females was significantly higher at 28.9% but the percentage share of the unemployed lower at 55.5 %.

Rheebok Bricks is deemed to form part manufacturing sector, the largest economic sector in the Mossel Bay District.

Please note that this section deals with the socio economic context of the municipal area, the specific socio economic context of the proposed facility is considered and detailed in section D of this report.

10. HISTORICAL AND CULTURAL ASPECTS (a) Please be advised that if section 38 of the National Heritage Resources Act, 1999 (Act No.

25 of 1999), is applicable to your proposed development, then you are requested to furnish this Department with written comment from Heritage Western Cape as part of your public



participation process. Section 38 of the Act states as follows: “38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorised as-

(a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length;

(b) the construction of a bridge or similar structure exceeding 50m in length; I any development or other activity which will change the character of a site- (i) exceeding 5 000 m2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; (d) the re-zoning of a site exceeding 10 000 m2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a

provincial heritage resources authority, must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.”

(b) The impact on any national estate referred to in section 3(2), excluding the national estate contemplated in section 3(2)(i)(vi) and (vii), of the National Heritage Resources Act, 1999 (Act No. 25 of 1999), must also be investigated, assessed and evaluated. Section 3(2) states as follows: “3(2) Without limiting the generality of subsection (1), the national estate may include—

(a) places, buildings, structures and equipment of cultural significance; (b) places to which oral traditions are attached or which are associated with living heritage; (c) historical settlements and townscapes; (d) landscapes and natural features of cultural significance; (e) geological sites of scientific or cultural importance; (f) archaeological and palaeontological sites; (g) graves and burial grounds, including— (i) ancestral graves; (ii) royal graves and graves of traditional leaders; (iii) graves of victims of conflict; (iv) graves of individuals designated by the Minister by notice in the Gazette; (v) historical graves and cemeteries; and (vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act No. 65 of 1983); (h) sites of significance relating to the history of slavery in South Africa; (i) movable objects, including— (i) objects recovered from the soil or waters of South Africa, including archaeological and palaeontological objects and material, meteorites and rare geological specimens; (ii) objects to which oral traditions are attached or which are associated with living heritage; (iii) ethnographic art and objects; (iv) military objects; (v) objects of decorative or fine art; (vi) objects of scientific or technological interest; and (vii) books, records, documents, photographic positives and negatives, graphic, film or video material or sound recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South Africa Act, 1996 (Act No. 43 of 1996).”



Is section 38 of the National Heritage Resources Act, 1999, applicable to the development?

YES NO UNCERTAIN

If YES, explain:

The proposed VSBK will not transform more that 5000m2 (they will be build within an existing structure)nor does it require the rezoning of more than 10000m2 and as such does not require authorisation in terms of the National Heritage Resources Act.

Will the development impact on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999?

YES NO UNCERTAIN

If YES, explain:

Will any building or structure older than 60 years be affected in any way? YES NO UNCERTAIN

If YES, explain: No buildings will be affected by this proposal.

The facility will be consistent with the existing built environment landscape, i.e. a manufacturing industry situated in an area dominated by other manufacturing industries. Because of its consistency with surrounding land use (where natural and cultural landscapes are already highly transformed), it can be stated with a high level of confidence that this facility will not have a significant negative impact on the natural or cultural landscapes. Notwithstanding the above finding of no significant impact, Heritage Western Cape has been automatically registered as a key stakeholder and have been given an opportunity to provide input and comment on this report. Please Note: If uncertain, the Department may request that specialist input be provided.

11. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES (a) Please list all legislation, policies and/or guidelines that have been considered in the

preparation of this Basic Assessment Report.

LEGISLATION ADMINISTERING AUTHORITY

TYPE Permit/ license/

authorisation/comment / relevant consideration (e.g.

rezoning or consent use, building plan approval)

DATE (if already obtained):

National Environmental Management: Air Quality Act

Eden District Municipality

Atmospheric Emissions Licence

In progress

National Environmental Management Act: EIA regulations

Western Cape Department of Environmental Affairs and Development Planning

Environmental Authorisation In Progress

POLICY/ GUIDELINES ADMINISTERING AUTHORITY

National Building Regulations Building Inspectors from the local Authority



(Mossel Bay Municipality)

SANS 10400 (National Building Standards) Building Inspectors from the local Authority (Mossel Bay Municipality)

Western Cape Provincial Spatial Development Framework (PSDF) DEA&DP

Mossel Bay Structure Plan Mossel Bay Municipality Mossel Bay Spatial Development Framework Mossel Bay Municipality

Mossel Bay Integrated Development Plan (IDP) Mossel Bay Municipality

DEA&DP EIA Guideline Information Document on Generic Terms of Reference for EAP's and Project Schedules (Aug. 2010 & Oct.2011)

DEA&DP

DEA&DP EIA Guideline on Need & Desirability (Aug. 2010 & Oct. 2011) DEA&DP

DEA&DP EIA Guideline on Alternatives (Aug. 2010 & Oct. 2011) DEA&DP

DEA&DP Guidelines on Environmental Management Plans (August 2010) DEA&DP

DEA&DP Guideline for Determining the Scope of Specialist Involvement (June 2005) DEA&DP

DEA&DP Guideline for Involving Biodiversity Specialists in EIA processes (June 2005) DEA&DP

South African VSBK – Operational Training Manual

Swiss Agency for Development and Cooperation.

Waste minimisation guideline document for environmental impact assessment reviews (may 2003)

DEA&DP

(b) Please describe how the legislation, policies and/or guidelines were taken into account in

the preparation of this Basic Assessment Report.

LEGISLATION / POLICY / GUIDELINE

DESCRIBE HOW THE LEGISLATION / POLICY / GUIDELINE WERE TAKEN INTO ACCOUNT

(E.g. describe the extent to which it was adhered to, or deviated from, etc.).

National Building Regulations

The Mossel Municipality considers the Application in terms of these National Standards prior to approval of the building plans (should building plans be required for the improvements that are required to the existing building).

SANS 10400 (National Building Standards)

The National Building Standards are considered during the assessment and approval of building plans (if required) and implementation of standards are enforced throughout the construction period by means of Municipal building inspectors visiting the construction site.

Western Cape Provincial Spatial Development Framework (PSDF)

The Provincial Spatial Development Framework was consulted to determine whether the development proposal is in line with the framework’s recommendations for land



use.

Mossel Bay Spatial Development Framework

The Spatial Development Framework is used to consider the consistency of the proposed land use with regards to future planning for the municipal area.

DEA&DP EIA Guideline Information Document on Generic Terms of Reference for EAP’s and Project Schedules (August 2010)

The EIA Guideline Information Document ToR for EAP’s and Project Schedules were consulted to ensure that the EAP’s conduction of the process and the Project Schedule of this application correspond to these requirements.

DEA&DP EIA Guideline on Need & Desirability (August 2010)

The EIA Guideline on Need & Desirability was consulted as part of the project motivation and section of this report describing the proposal’s need & desirability.

DEA&DP Guidelines on Environmental Management Plans (August 2010)

The Environmental Management Plans Guidelines were consulted as part of the compiling of the Environmental Management Programme (EMP) for this application to ensure that the EMP prescribed complies with the Guidelines.

DEA&DP Guideline for Determining the Scope of Specialist Involvement (June 2005)

This Guideline was consulted and considered at project inception. Due to the complete irreversible transformation of the site, a botanical specialist study was not deemed necessary. The potential impact of the facility on ambient air quality was deemed to be one of the most potentially significant issues in this application and as such, a specialist air quality specialist was appointed to undertake a comprehensive air quality impact assessment.

DEA&DP Guideline for Involving Biodiversity Specialists in EIA processes (June 2005)

This Guideline was consulted and considered during the initial project inception. The EAP assessed the site conditions and confirmed that the proposed site is irreversibly transformed and contains no ecological functioning in terms of species, pattern, process or ecosystem services. The site is furthermore not designated as a Critical Biodiversity Area, Buffer Area or Ecological support area. The appointment of a biodiversity specialist for this development was thus not deemed necessary.

DEA&DP Guideline for Involving Heritage Specialists (June 2005)

This Guideline was consulted and considered at project inception. The National Heritage Resources Act was also consulted and it was confirmed that the facility does not require authorisation in terms of the National Heritage Resources Act. The facility will be consistent with the existing built environment, i.e. a manufacturing industry situated in an area dominated by other manufacturing industries. Because of its consistency with surrounding and existing land use (where natural and cultural landscapes are already highly transformed), it can be stated with a high level of confidence that this facility will not have a significant negative impact on the natural or



cultural landscapes and such, a heritage specialist was not appointed. Notwithstanding this, Heritage Western Cape were automatically registered as a key stakeholder and given an opportunity to provide input and comment on this process.

South African VSBK – Operational Training Manual

This document was primarily used to gain understanding of the operational aspects associated with VSBK’s in order to assess any potential impacts.

Waste minimisation guideline document for environmental impact assessment reviews (may 2003)

This Guideline raises awareness to waste minimisation issues and highlights waste and wastage minimization practices. Part B of this document is of particular importance, as it addresses issues of general waste and wastage minimization during construction activities.

Please note: Copies of any permit(s) or licences received from any other organ of state must be attached this report as Appendix E.



SECTION C: PUBLIC PARTICIPATION The public participation process must fulfil the requirements outlined in NEMA, the EIA Regulations, and if applicable the NEM: WA and/or the NEM: AQA. This Department’s Guideline on Public Participation (August 2010) and Guideline on Exemption Applications (August 2010), both of which are available on the Department’s website (http://www.capegateway.gov.za/eadp), must also be taken into account. Please highlight the appropriate box to indicate whether the specific requirement was undertaken or whether there was a deviation that was agreed to by the Department. 1. Were all potential interested and affected parties notified of the application by – (a) fixing a notice board at a place conspicuous to the public at the boundary or on the fence of -

(i) the site where the activity to which the application relates is to be undertaken; and YES Deviated

(ii) any alternative site mentioned in the application; YES Deviated (b) giving written notice to –

(i) the owner or person in control of that land if the applicant is not the owner or person in control of the land; YES N/A

(ii) the occupiers of the site where the activity is to be undertaken and to any alternative site where the activity is to be undertaken; YES Deviated

(iii) owners and occupiers of land adjacent to the site where the activity is to be undertaken and to any alternative site where the activity is to be undertaken;

YES Deviated

(iv) the municipal councillor of the ward in which the site and alternative site is situated and any organisation of ratepayers that represent the community in the area;

YES Deviated

(v) the municipality which has jurisdiction in the area; YES Deviated (vi) any organ of state having jurisdiction in respect of any aspect of the

activity; and YES Deviated

(vii) any other party as required by the competent authority; YES Deviated I placing an advertisement in -

(i) one* local newspaper; and YES Deviated (ii) any official Gazette that is published specifically for the purpose of

providing public notice of applications or other submissions made in terms of these Regulations;

YES Deviated N/A

(d) placing an advertisement in at least one* provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken.

YES Deviated N/A

* Please note: In terms of the NEM: WA and NEM: AQA a notice must be placed in at least

two newspapers circulating in the area in which the activity applied for is to be carried out. 2. Provide a list of all the state departments that were consulted:

- Mossel Bay Municipality: Technical Services; - Mossel Bay Municipality: Town Planning; - Mossel Bay Municipality: Environmental Management; - Mossel Bay Municipality: Health; - Western Cape Provincial Department of Health; - Department of Environmental Affairs and Development Planning: Pollution Control;




3. Please provide an overall summary of the Public Participation Process that was followed. (The detailed outcomes of this process must be included in a comments and response report to be attached to the final Basic Assessment Report (see note below) as Appendix F). As part of the public participation process the following steps were taken to ensure compliance with the legislation and to allow ample opportunity for members of the public and key stakeholders to be involved and participate in the environmental process. Please see Appendix F for evidence and further details of this Public Participation process. The Public Participation Process has been undertaken according to the requirements of the new NEMA EIA regulations. The following requirements i.t.o the Draft and Final Basic Assessment Reports have been undertaken and complied with in terms of Regulation 56: CHRONOLOGY OF EVENTS Please see table 4 below for a summary of the public participation to date. Table 4: Summary of Public Participation Process to date.

DATE ACTION 18 July 2013

Notification was sent to the Landowner notifying him of the development proposal and the environmental process to be followed.

18 July 2013

Notifications were sent to neighbouring landowners informing them of the development proposal and the environmental process. They were automatically registered as Interested and Affected Parties

18 July 2013

The Mossel Bay Local Municipality (which have jurisdiction over the area) were notified and automatically registered as key stakeholders.

18 July 2013

Organs of state (including Mossel Bay Municipality: Technical Services, Mossel Bay Municipality: Town Planning, Mossel Bay Municipality: Environmental Management, Mossel Bay Municipality: Health, Western Cape Provincial Department of Health, Department of Environmental Affairs and Development Planning: Pollution Control, Department of Environmental Affairs and Development Planning: Air Quality Management, Eden District Municipality: Environmental, Eden District Municipality: Health, Eden District Municipality: Air Quality, Cape Nature and Heritage Western Cape) were notified and registered as key stakeholders

19 July 2013

Advert was placed in a regional newspaper, Die Suid Kaap Burger calling for the registration of Interested and affected parties.

19 July 2013

Advert was placed in a local newspaper, The Mossel Bay Advertiser calling for the registration of Interested and affected parties.

19 July 2013

Background information documents were placed at the Mossel Bay Municipal Library and the Mossel Bay Municipal Planning Departments.

19 July 2013

2 site notices were placed on the boundary of the property as well as on the proposed site of the development.

July 2013

A Stakeholder Register was opened and the details of all registered stakeholders entered for future correspondence.

17 October 2013

A Draft Basic Assessment Report was made available for a 40 Day comment period extending until 26 November 2013.

28 November 2013

A Final Basic Assessment Report was made available for a 21 Day comment period extending until Monday 06 January 2014.

NOTE Public participation information with regards to the availability of the Draft Basic and Final Basic Assessment Reports are included in this report.

- Department of Environmental Affairs and Development Planning: Air Quality Management; - Eden District Municipality: Environmental; - Eden District Municipality: Pollution and Waste - Eden District Municipality: Air Quality; - Cape Nature; and - Heritage Western Cape.



NEWSPAPER ADVERTS Two newspaper adverts calling for registration of interested and affected parties were placed in the Mossel Bay Advertiser (a local newspaper) and Die Suid Kaap Burger (a provincial newspaper)

Figure 19: Showing newspaper adverts calling for the registration of Interested and Affected Parties.

BACKGROUND INFORMATION DOCUMENT With the initial stakeholder registrations background information documents (BID’s) were made available to stakeholders. All key stakeholders were provided with hard copies of the BID along with the notification letters. BID’s were also made available at the Mossel Bay Municipal Library and the Mossel Bay Municipality Planning Department. The BID’s were also made available on the Cape EAPrac Website. Copies of the background information document are included in Appendix F.



Figure 20: Showing availability of Background Information Document on the Cape EAPrac website. The website also included an online registration form, whereby potential stakeholders could register.

REGISTRATION OF KEY STAKEHOLDERS A number of key stakeholders were automatically registered and were given an opportunity to comment on the Draft and Final Basic Assessment Report.

NOTIFICATION OF NEIGHBOURING PROPERTY OWNERS. Neighbouring property owners details were obtained from the Mossel Bay Municipality. These neighbouring property owners were automatically registered as Interested and Affected Parties and were notified of the availability of the Draft and Final BAR. PRELIMINARY ISSUES RAISED BY I&AP’s The only preliminary relates to potential additional noise associated with the VSBK’s. Please see section F of this report for the Assessment of Impacts as well as Appendix G containing the specialist Air Quality Impact Assessment. AVAILABILITY OF DRAFT BAR All registered I&AP’s including those who responded to the initial call for registration as well as those who were automatically registered were notified of the Availability of the Draft BAR. The Draft BAR was available for a 40 day comment period from Wednesday 16 October 2013 to Monday 26 November 2013 and was available at the Mossel Bay Municipal library in Marsh Street and the Mossel Bay Municipal Planning Office in Montague Street. A digital copy of the report was also available on the Cape EAPrac website at url: www.cape-eaprac.co.za. In order to facilitate effective comment, full hard copies of the report were also provided to Eden District Municipality: Air Quality Management and the Department of Environmental Affairs: Air Quality Management. Digital copies of the report on CD were also provided to all other Key Stakeholders. Proof of the availability of the Draft BAR is attached in Appendix F.




COMMENTS ON DRAFT BAR. Comments on the draft BAR were received from the following organisations and individuals:

Mr Clyde Lamberts – Cape Nature Mr Bles de Wet – Surrounding property owner Kainos Hove – DEA&DP Pollution Control Johan Schoeman – Eden District Municipality Air Quality Anton Dellejmin – Chairperson Midbrak Ratepayers Association

Cape Nature and Midbrak Ratepayers indicated that they had no objection to the proposed replacement of the Clamp Kilns with vertical shaft brick kilns. Eden district municipality and DEA&DP pollution control raised a number of queries relating to the specialist Air Quality Impact – These queries were responded to with input from the specialist. Mr de Wet raised concerns regarding the existing clamp kiln operations and the smoke that they generate. Since the VSBK’s will generate significantly lower volumes of smoke, authorisation of the VSBK’s will address his concern and improve the situation. All comments received as well as Cape EAPrac’s and the Specialist responses are included in Appendix F of this report. AVAILABILITY OF FINAL BAR All registered I&AP’s including those who responded to the initial call for registration, those who were automatically registered as well as those who provided comment on the Draft BAR were notified of the Availability of this Final BAR. The Final BAR was available for a 21 day comment period from Tuesday 28 November 2013 to Monday 6 January 2014 on the Cape EAPrac website at url: www.cape-eaprac.co.za. Proof of the availability of the Final BAR is attached in Appendix F. COMMENTS ON FINAL BAR No additional comments were received on the Final BAR.

Please note: Should any of the responses be “No” and no deviation or exemption from that requirement was requested and agreed to /granted by the Department, the Basic Assessment Report will be rejected.

A list of all the potential interested and affected parties, including the organs of State, notified and a list of all the register of interested and affected parties, must be submitted with the final Basic Assessment Report. The list of registered interested and affected parties must be opened, maintained and made available to any person requesting access to the register in writing.

The draft Basic Assessment Report must be submitted to the Department before it is made available to interested and affected parties, including the relevant organs of State and State departments which have jurisdiction with regard to any aspect of the activity, for a 40-day commenting period. With regard to State departments, the 40-day period commences the day after the date on which the Department as the competent/licensing authority requests such State department in writing to submit comment. The applicant/EAP is therefore required to inform this Department in writing when the draft Basic Assessment Report will be made




available to the relevant State departments for comment. Upon receipt of the Draft Basic Assessment Report and this confirmation, this Department will in accordance with Section 24O(2) and (3) of the NEMA request the relevant State departments to comment on the draft report within 40 days.

All comments of interested and affected parties on the draft Basic Assessment Report must be recorded, responded to and included in the Comments and Responses Report included as Appendix F to the final Basic Assessment Report. If necessary, any amendments in response to comments received must be effected in the Basic Assessment Report itself. The Comments and Responses Report must also include a description of the public participation process followed.

The final Basic Assessment Report must be made available to registered interested and affected parties for comment before submitting it to the Department for consideration. Unless otherwise indicated by the Department, a final Basic Assessment Report must be made available to the registered interested and affected parties for comment for a minimum of 21-days. Comments on the final Basic Assessment Report does not have to be responded to, but the comments must be attached to the final Basic Assessment Report.

The minutes of any meetings held by the EAP with interested and affected parties and other role players which record the views of the participants must also be submitted as part of the public participation information to be attached to the final Basic Assessment Report as Appendix F.

Proof of all the notices given as indicated, as well as of notice to the interested and affected parties of the availability of the draft Basic Assessment Report and final Basic Assessment Report must be submitted as part of the public participation information to be attached to the final Basic Assessment Report as Appendix F.



SECTION D: NEED AND DESIRABILITY Please Note: Before completing this section, first consult this Department’s Guideline on Need and Desirability (August 2010) available on the Department’s website (http://www.capegateway.gov.za/eadp).

1. Is the activity permitted in terms of the property’s existing land use rights? YES NO Please

explain The property is zoned for industrial use. The VSBK’s are consistent with this zoning and the current land use. A copy of the zoning certificate is attached in Appendix E, Annexure E1. 2. Will the activity be in line with the following?

(a) Provincial Spatial Development Framework (PSDF) YES NO Please explain

This area is identified as a potential industrial development node in the PSDF (Industrial Development Node 3)

(b) Urban edge / Edge of Built environment for the area YES NO Please explain

The proposed in an industrial area completely surrounded by other industrial activities. The land-use will not be changed by the activity. (c) Integrated Development Plan and Spatial Development

Framework of the Local Municipality (e.g. would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF?).

YES NO Please explain

The SDF plan 8 – Dated 20 October 2006 indicates the site as Category E – Industrial Area

(d) Approved Structure Plan of the Municipality YES NO Please explain

This proposal is consistent with the structure plan. This proposal will not require any amendment to the existing Mossel Bay Structure Plan. (e) An Environmental Management Framework (EMF) adopted by the Department (e.g. Would the approval of this application compromise the integrity of the existing environmental management priorities for the area and if so, can it be justified in terms of sustainability considerations?)


There is no Environmental Management Framework that has been adopted for this area.

(f) Any other Plans (e.g. Guide Plan) YES NO Please explain

3. Is the land use (associated with the activity being applied for) considered within the timeframe intended by the existing approved Spatial Development Framework (SDF) agreed to by the relevant environmental authority (i.e. is the proposed development in line with the projects and programmes identified as priorities within the credible IDP)?


This is not a specific project identified by the IDP. The IDP does however indicate that the Manufacturing Industry is one of the key economic drivers in the region. 4. Should development, or if applicable, expansion of the

town/area concerned in terms of this land use (associated with the activity being applied for) occur here at this point in time?





The site proposed for the construction of the VSBK’s is already used for industrial activities. The area has no remaining ecological functioning and is completely surrounded by other industrial activities. The continued use of the area for industrial purposes is thus deemed to be the most suitable land use at this point in time. 5. Does the community/area need the activity and the associated

land use concerned (is it a societal priority)? (This refers to the strategic as well as local level (e.g. development is a national priority, but within a specific local context it could be inappropriate.)


The directly adjacent communities and area will have very little direct need for the facility. Its significance is more established on a national scale in terms of provision of building materials in the form of clay bricks. The throughput of the facility will however not be increased (i.e. the amount of bricks produced remain unchanged to what is currently produced.) 6. Are the necessary services with adequate capacity currently

available (at the time of application), or must additional capacity be created to cater for the development? (Confirmation by the relevant Municipality in this regard must be attached to the final Basic Assessment Report as Appendix E.)


Municipal Services, i.e. water and electricity are existing and available on the site. VSBK’s will not use any additional water to that which is already used for the production of bricks in clamp kilns. The proposal will not generate any additional liquid effluent – existing ablution facilities at Rheebok bricks will be used. This project will not require any upgrades to bulk municipal infrastructure. 7. Is this development provided for in the infrastructure planning

of the municipality, and if not what will the implication be on the infrastructure planning of the municipality (priority and placement of services and opportunity costs)? (Comment by the relevant Municipality in this regard must be attached to the final Basic Assessment Report as Appendix E.)


This project will not result in additional opportunity costs and pressure on existing municipal infrastructure. The facility will not result in additional demand on existing infrastructure. The Mossel Bay municipality technical services department were given an opportunity to provide comment in this regard 8. Is this project part of a national programme to address an

issue of national concern or importance? YES NO Please explain

The project is not intended to address an issue of national concern or importance. 9. Do location factors favour this land use (associated with the

activity applied for) at this place? (This relates to the contextualisation of the proposed land use on this site within its broader context.)


The proposed position of the facility is consistent with its surrounding context. The surrounding context consists of a series of other industrial activities. The majority of these activities are related to the manufacture industries. The nature of the proposed site favours manufacturing industry and any other land use (agriculture, residential, conservation) cannot be considered in this context. 10. How will the activity or the land use associated with the YES NO Please



activity applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

explain

The facility will be consistent with the existing built environment, i.e. a manufacturing industry situated in an area dominated by other manufacturing industries. Because of its consistency with surrounding land use (where natural and cultural landscapes are already highly transformed), it can be stated with a high level of confidence that this facility will not have a significant negative impact on the natural or cultural landscapes. 11. How will the development impact on people’s health and

wellbeing (e.g. in terms of noise, odours, visual character and sense of place, etc.)?


Mr Chris Albertyn of Lethabo Air Quality Services (LAQS) was appointed to develop a dispersion model of the facility and to undertake an Air Quality Impact Assessment.

The results of the dispersion modelling study show that the estimated maximum ground-level concentrations under the planned conditions would be below the official ambient air quality standards.

It is also important to note that the VSBK installation will result in substantially lower emissions than is currently taking place with the clamp kilns. The installation of the VSBK’s will thus lead to improved air quality with subsequent improvement in people's health and wellbeing.

12. Will the proposed activity or the land use associated with the activity applied for, result in unacceptable opportunity costs?


The construction of this facility at the preferred location will not cause the loss of potential gain from another alternative industry. The manufacturing capacity of Rheebok Bricks will not be increased – this proposal merely improves the technology used in the manufacture process. 13. What will the cumulative impacts (positive and negative) of

the proposed land use associated with the activity applied for, be?


This facility will not likely result in any significant cumulative impacts on the directly surrounding area or the region as a whole. Please refer to section G of this report for further details in this regard. 14. Is the development the best practicable environmental option

for this land/site? YES NO Please explain

This proposal is consistent with the existing and surrounding land use and as such is deemed to be the best practicable environmental option for the site. Any other use (other than manufacturing industry) would not compliment the surrounding land use and would not be consistent with the surroundings.

15. What will the benefits be to society in general and to the local communities? Please explain

This proposal will result in a number of short term employment opportunities during the construction phase as well as long term employment opportunities during the operation phase.

16. Any other need and desirability considerations related to the proposed activity? Please explain

Several million tons of CO2 and other pollutants are emitted by the South African brick industry every year, this causes South Africa’s emission to be in the top ten in the worldwide pollution ranking.

Replacing the highly inefficient clamp brick kilns with energy efficient brick kilns such as VSBK’s carries a huge potential for reducing the brick making industries ecological footprint, without any economic or social disadvantages.



(17) Please describe how the general objectives of Integrated Environmental Management as set out in section 23 of NEMA have been taken into account:

The purpose of Section 23 of NEMA is to promote the application of appropriate environmental management tools in order to ensure the integrated environmental management of activities.

The aim of these principles is to identify, predict and evaluate the actual and potential impact on the environment (including socio-economic and cultural environments), to assess alternatives and propose mitigation options which will contribute to minimizing detrimental impact.

For this application, actual and potential impacts on the various environments have been considered and assessed. The nature of the application results in minimal impacts, with potential health risks associated with impacts on air quality (air quality will actually be improved). However, a number of precautionary, mitigation and monitoring measures have been proposed to avoid potential environmental impacts. These mitigation and monitoring measures are described in this BAR, and associated specialist report, as well as the attached EMP.

Technology Alternatives have been considered to determine the most suitable technology for the activity.

The mitigation measures proposed and described in both this report and the attached Environmental Management Programme (EMP) will ensure that the activities proposed will be done in a controlled manner which reduces the chances of significant environmental impact.

Finally, in accordance with the Integrated Environmental Management principles, ample opportunity is being allowed for public participation. Two adverts (calling for the registration of I&AP’s) were placed in the local newspaper, informing members of public of the proposal and available information, and included details on how members of public can register as stakeholders and through doing so, form part of the environmental process. Other key stakeholders (e.g. the local Councillor, direct neighbours and Other Key Stakeholders) have been identified and notified of the process. Two Notice Boards were placed at the development site. The notices sent to identified stakeholders, included details of the proposal and how comment can be submitted on the application.

All relevant State Departments were provided with a digital copy (CD) of the Draft BAR together with the details of the comment period. All registered Interested and affected parties were furthermore given an opportunity to comment on the Final Basic Assessment Report.

(18) Please describe how the principles of environmental management as set out in section 2 of NEMA have been taken into account: The main and applicable principles of environmental management as set out in Section 2 of NEMA emphasizes the following: Environmental management placing people and their needs at forefront of its concern,

and serve their physical, physiological, developmental, cultural and social interests equitably – the proposed development will not extend beyond the building restriction area and will not exceed the limitations of the industrial zoning. Potential pollution aspects will be improved by the replacement of clamp kilns with vertical shaft brick kilns.

Socially, environmentally and economically sustainable development – the potential



need and desirability of the proposed facility has been given specific attention to determine whether there is a need and/or demand for the facility. The proposed VSBK’s are consistent and have the potential to compliment the surrounding land use. The demand / market has been proved through the existing facility (which has been successfully operational for more than 40 years and an overall positive economic impact on both the local and regional economies are proven.

Consideration for ecosystem disturbance and loss of biodiversity – no conservation worthy species will be lost or damaged as the indigenous vegetation on the site is non-existent.

Pollution and environmental degradation – potential for pollution impacts, particularly contamination of soil and groundwater during construction and operation (possible fuel/oil spills) have been considered and mitigation measure proposed in this BAR, the attached EMP. It is anticipated that with the diligent implementation of all these measures, pollution will be avoided to a great extent, and the significance rating of potential contamination will be low.

Landscape disturbance – The landscape is characterised will not be changed by the VSBK’s, as they will be constructed in an existing building. The development site is adjacent to major roads. The development of the site is considered in line with the current landscape character.

Waste avoidance, minimisation and recycling – A waste minimization, cradle-to-grave approach is to be implemented, with waste separation at source. The EMP attached to this report promotes the adoption of an integrated waste minimisation approach, which is recommended for both construction and operation phases of the development. The attached EMP describes the waste disposal methods to be adopted, and is in line with the principles of waste avoidance, minimisation and recycling.

Responsible and equitable use of non-renewable resources – The replacement of clamp kilns with VSBK’s will significantly decrease the need for coal (a fossil fuel) used in the manufacture process.

Avoidance, minimisation and remedying of environmental impacts; - Various precautionary and mitigation measures have been incorporated to ensure environmental, as well as health & safety, impacts are avoided or kept to a minimum. The selection of the preferred site took this risk adverse approach into consideration.

Interests, needs and values of interested and affected parties – This process provides potential interested & affected parties and other key stakeholders with ample opportunity for review, comment and input on available documentation. Details of the public participation process undertaken are included in Appendix F of this report and have been reported on in this FBAR.

Access of information – Members of public, interested & affected parties, key stakeholders and relevant state departments are all provided with all the available documentation contained in the Draft and Final BAR.



SECTION E: ALTERNATIVES Please Note: Before completing this section, first consult this Department’s Guideline on Alternatives (August 2010) available on the Department’s website (http://www.capegateway.gov.za/eadp). “Alternatives”, in relation to a proposed activity, means different means of meeting the general purposes and requirements of the activity, which may include alternatives to –

(a) the property on which, or location where, it is proposed to undertake the activity; (b) the type of activity to be undertaken; I the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity.

The NEMA prescribes that the procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment must, inter alia, with respect to every application for environmental authorisation – ensure that the general objectives of integrated environmental management laid down in

NEMA and the National Environmental Management Principles set out in NEMA are taken into account; and

include an investigation of the potential consequences or impacts of the alternatives to the activity on the environment and assessment of the significance of those potential consequences or impacts, including the option of not implementing the activity.

The general objective of integrated environmental management is, inter alia, to “identify, predict and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage, the risks and consequences and alternatives and options for mitigation of activities, with a view to minimising negative impacts, maximising benefits, and promoting compliance with the principles of environmental management” set out in NEMA. 1. In the sections below, please provide a description of any identified and considered

alternatives and alternatives that were found to be feasible and reasonable. Please note: Detailed written proof the investigation of alternatives must be provided and motivation if no reasonable or feasible alternatives exist.

(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable

negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

Location and site alternatives were not considered, nor are deemed necessary to consider for the following reasons:

The building / enclosure for the VSBK’s is existing, thus limiting the number of new structures that need to be constructed,

The location is close to the existing crusher / extruder, thus limiting transport distance of the “green bricks”.

The no go alternative in this case means the continuation of the brick manufacturing process using clamp kilns. The environmental benefits in terms of improved air quality and improved resource efficiency will not be realised should this alternative be considered further.




(b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: Rheebok Bricks is an existing industry that specialises in the manufacture of clay bricks. It is thus unreasonable for such an industry to consider other activities. (c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative

impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

Technological alternatives were considered, namely the replacement of the clamp kilns with tunnel kilns as opposed to VSBK’s. This alternative was eliminated for the following reasons:

- Tunnel kilns take up significantly more space than VSBK’s, - Tunnel kilns are less efficient in terms of heat transfer than VSBK’s and as such

require more resources (coal) to operate, - Tunnel kilns require significant amounts of electricity to operate large three phase

fans (VSBK’s do not), and - Tunnel kilns have a much larger capital outlay than VSBK’s.



SECTION F: IMPACT ASSESSMENT, MANAGEMENT, MITIGATION AND MONITORING MEASURES

Please note: The information in this section must be duplicated for all the feasible and reasonable alternatives (where relevant). 1 DESCRIBE THE MANNER IN WHICH THE DEVELOPMENT WILL IMPACT ON THE

FOLLOWING ASPECTS: (a) Geographical and physical aspects: The facility is proposed on an existing level platform that is already physically transformed by existing industrial activities. The proposed location is within an existing building that is hard surfaced.

Geographically, the proposed location of the facility is situated on the crest of hill. The entire facility is however set back from the slopes of the hill.

The impact on the geographical and physical aspects of the site is thus deemed to be Low – No impact before mitigation and management.

No mitigation measures are necessary in this regard

(b) Biological aspects: Will the development have an impact on critical biodiversity areas (CBAs) or ecological support areas (CSAs)? YES NO

If yes, please describe: The development is not situated in a CBA, ESA or CBA buffer area. Will the development have on terrestrial vegetation, or aquatic ecosystems (wetlands, estuaries or the coastline)? YES NO

If yes, please describe: There is NO vegetation whatsoever on the site and as such, the development will not impact on terrestrial vegetation. The Development is significantly setback (at least 350m) from all aquatic ecosystems and as such is unlikely to have an impact on these. Will the development have an impact on any populations of threatened plant or animal species, and/or on any habitat that may contain a unique signature of plant or animal species?

YES NO

If yes, please describe: The site is irreversibly transformed and does not contain any remnants of indigenous or other vegetation. It is thus not possible that the facility will impact on threatened plant or animals species or habitat. Please describe the manner in which any other biological aspects will be impacted:






(c) Socio-Economic aspects: What is the expected capital value of the activity on completion? Confidential What is the expected yearly income or contribution to the economy that will be generated by or as a result of the activity?

Confidential

Will the activity contribute to service infrastructure? YES NO How many new employment opportunities will be created in the construction phase of the activity?

30 -50

What is the expected value of the employment opportunities during the construction phase?

R 3 000 000.00

What percentage of this will accrue to previously disadvantaged individuals? 40% How will this be ensured and monitored (please explain): The EMP makes provision for monitoring compliance with this condition. This will be reported to the Department of Environmental Affairs and Development Planning as part as part of the recommended monthly ECO Reports. How many permanent new employment opportunities will be created during the operational phase of the activity?

22

What is the expected current value of the employment opportunities during the first 10 years?

R15 000 000

What percentage of this will accrue to previously disadvantaged individuals? 30% How will this be ensured and monitored (please explain): The EAP has recommended that an environmental audit be undertaken within 1 year of commencement of operations. This Audit will assess the compliance with these commitments. The results of this Audit will be submitted to DEA&DP, who can take any corrective action that may be required. Any other information related to the manner in which the socio-economic aspects will be impacted:



The employment opportunities and capital contribution are deemed to have a medium positive impact. The facility is consistent with the surrounding land use and the air quality specialist has confirmed that emissions will not exceed the ambient air quality standards but will in fact improve air quality. As such, the negative social impact is deemed to be zero. The facility will thus more likely result in a medium positive social impact. (d) Cultural and historic aspects: Because of its consistency with surrounding and existing land use (where natural and cultural landscapes are already highly transformed), it can be stated with a high level of confidence that this facility will not have a significant negative impact on the natural or cultural landscapes. Notwithstanding the above finding of no significant impact, Heritage Western Cape has been automatically registered as a key stakeholder and have been given an opportunity to provide input and comment on this report. 2. WASTE AND EMISSIONS (a) Waste (including effluent) management Will the activity produce waste (including rubble) during the construction phase? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type? ±10M3

The waste generated during the construction phase is likely to be extremely limited. The waste generated will be limited to non-hazardous building rubble. This will be stored on site during skips and removed on a regular basis during the construction period. Rubble will be dumped at the existing licenced building rubble dump site near Mossel Bay. The EMP includes additional management requirements relating to construction phase waste. Will the activity produce waste during its operational phase? YES NO If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type? ±1M3

Where and how will the waste be treated / disposed of (describe)? If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type per phase of the development? The waste generated during the operational phase of this facility will be limited to normal non-hazardous domestic waste generated in the administration component. Because of the technology and the controlled firing process, the VSBK will produce far less incorrectly fired / damaged bricks than with clamp kilns. Notwithstanding, these incorrectly fired / damaged bricks are not deemed to constitute waste, as they are recycled back into the manufacture process. Has the municipality or relevant authority confirmed that sufficient capacity exist for treating / disposing of the waste to be generated by this activity(ies)? If yes, provide written confirmation from Municipality or relevant authority. The Mossel Bay Municipality was automatically registered as an I&AP for this environmental process. They have been given an opportunity to comment on the Basic Assessment Report. This activity will however not generate any waste and as such confirmation of capacity is not deemed necessary.

YES NO



Will the activity produce waste that will be treated and/or disposed of at another facility other than into a municipal waste stream?

YES NO

If yes, has this facility confirmed that sufficient capacity exist for treating / disposing of the waste to be generated by this activity(ies)? Provide written confirmation from the facility and provide the following particulars of the facility:

YES NO

Does the facility have an operating license? (If yes, please attach a copy of the license.) YES NO

Facility name: No additional waste outside of the normal municipal waste stream will be generated. Contact person: NA Postal address: NA Postal code: NA Telephone: NA Cell: NA E-mail: NA Fax: NA Describe the measures that will be taken to reduce, reuse or recycle waste: The DEA&DP waste minimisation guideline document for environmental impact assessment reviews (may 2003) is the key guideline document regarding management of waste during the construction period. This Guideline raises awareness to waste minimisation issues and highlights waste and wastage minimization practices. Part B of this document is of particular importance, as it addresses issues of general waste and wastage minimization during construction activities. The recommendations and principles of this document have been used to inform the Environmental Management Programme (attached in Appendix H).

Effective management of domestic waste contributes to a more sustainable implementation of landfill sites and their management. Sorting of recyclable materials at the source, i.e. in the offices and laboratory can lessen backlog at the landfill site. The domestic waste generated by this facility will be minimal and as such management interventions are limited. The following is however recommended in this regard (included in the EMP in Appendix H)

It is recommended that recycling bins are placed at a central point at the manufacture facility and the offices, allowing easy access for all staff to encourage recycling of most of the domestic waste that is produced. Bins need to be adequately marked for ease of reference. Rheebok Bricks should ascertain whether or not the municipality will collect recyclable materials, alternatively, they should enter into an agreement with a local recycling organisation for collection of these materials.

(b) Emissions into the atmosphere Will the activity produce emissions that will be disposed of into the atmosphere? YES NO

If yes, does it require approval in terms of relevant legislation? YES NO Describe the emissions in terms of type and concentration and how it will be treated/mitigated: Mr Chris Albertyn of Lethabo Air Quality Services (LAQS) undertook a detailed Air Quality Impact Assessment of the proposed facility. A full copy of this study is attached in Appendix G of this report. The following is summarised from this study:

Emissions from the VSBK were modelled to determine the impact that emissions will have on



the surrounding air quality.

The approach to the project was to determine both the annual average ground-level concentrations and 99-percentile concentrations (the level below which concentrations are expected to occur for 99% of the time) of the pollutants in the immediate vicinity of the plant, i.e. where the concentrations are expected to be the highest. In addition, the corresponding values at the two nearest residential properties (referred to as eastern and western properties) and at the Tergniet residential area were estimated.

The 99-percentile approach was selected as it is the nearest approximation to the allowed frequency of exceedence of the ambient air quality standards, i.e. 88 hours per year for hourly concentrations and 4 days per year for annual average concentrations.

All simulations were carried out for a receptor height of 2 metres above ground level and a plume dispersion period of 120 minutes. This simulation period ensured that very low winds, e.g. below 1 m/s, would carry pollutants some distance from the plant.

The dispersion results of Total particulate Matter (TPM), Sulphur Dioxide (SO2), Oxides of Nitrogen (NOx) and Hydrofluoric Acid (HF) from Rheebok Bricks's operations are shown graphically in Figures 2 to 9 (pages 15 – 20) of the Air Quality impact Assessment attached in Appendix G of this Report.

The following results were derived from the dispersion modelling estimations:

Total particulate matter:

- Maximum annual average concentration 1.6 μg/m3 - Maximum 99-percentile concentration 24.6 μg/m3 - Annual avg. concentration at western property 0.3 μg/m3 - 99-percentile concentration at western property 7.7 μg/m3 - Annual avg. concentration at eastern property 0.5 μg/m3 - 99-percentile concentration at eastern property 9.8 μg/m3 - Annual avg. concentration at Tergniet 0.3 μg/m3 - 99-percentile concentration at Tergniet 13.4 μg/m3

Sulphur dioxide:


Nitrogen oxides:

- Maximum annual average concentration 2.1 μg/m3 - Maximum 99-percentile concentration 41.1 μg/m3 - Annual avg. concentration at western property 0.4 μg/m3 - 99-percentile concentration at western property 10.5 μg/m3 - Annual avg. concentration at eastern property 0.6 μg/m3 - 99-percentile concentration at eastern property 13.4 μg/m3 - Annual avg. concentration at Tergniet 0.4 μg/m3



- 99-percentile concentration at Tergniet 15.3 μg/m3

Hydrofluoric acid:


The prevailing winds in this area are predominantly from the west / south and from an easterly direction. Northerly winds will carry pollutants in the direction of Tergniet, but these winds are infrequent, i.e. less than 1% of the time.

Air quality standards for some pollutants were published by the Department of Environmental Affairs (DEA) in Government Notice No. 263 on 13 March 2009 (GN 263). Of the pollutants included in the Air Quality Impact Assessment, ambient air quality standards only exist for SO2 and NOx only and these are shown in the following two tables:

Table 5: Ambient Air Quality Standards for SO2 and NOx

SO2 NOx

Annual average: 50 μg/m3 40 μg/m3

Maximum hourly concentration: 350 μg/m3 200 μg/m3

South Africa currently does not have ambient air quality standards for total particulate matter (TPM), but only for PM10 particulates, a sub-set of TPM, and the values are:

Table 6: Ambient Air Quality Standards for PM10

PM10

Annual average: 40 μg/m3

Maximum daily concentration: 75 μg/m3

At the time of publication of the Air Quality Act draft AQ limits (these are currently not yet legislated, but are in a public review process) for TPM were considered by the specialist and these were:

- Annual average of 100 μg/m3 - 24-hour average of 300 μg/m3

The following estimated emissions from the VSBK’s were determined by the air quality specialist.

Sulphur Dioxide

The highest annual average concentration of SO2 was shown to be less than 0.1 μg/m3



which is well below the allowable annual average standard of 50 μg/m3 published in GN 263.

The maximum 99-percential concentration was shown to be 1.99 μg/m3 which is also

below the ambient air quality standard published in GN 263.

Nitrogen Oxides

The highest annual average concentration of NOx was shown to be 2.1μg/m3 which is below the allowable annual average standard of 40 μg/m3 published in GN 263.

The maximum 99-percential concentration was shown to be 41.1 μg/m3 which is also lower than the ambient air quality standard published in GN 263.

Total Particulate Matter

The highest annual average concentration of TPM was shown in to be 1.6 μg/m3 and the maximum 99-percential concentration was shown to be 21.4 μg/m3, both of which are lower that the PM10 standards.

The estimated ground-level concentrations are based on emissions from the VSBK operation only. However, particulate matter is also emitted during milling of the clay on site (this is an existing activity and will remain unchanged by the installation of the VSBK’s). Emission factors for such operations can be derived from the Australian Government's National Pollution Inventory (NPI) Emission Estimation Technique Manual for Mining. This publication lists a PM10 emission factor of 0.004 kg PM10 particulates per ton of high-moisture ore milled. High-moisture ores are defined as having water content in excess of 4% by mass.

Rheebok Bricks mill approximately 12 880 tons clay per month, or approximately 154 560 tons per annum, and the water content of the clay is 11 - 14 % by mass.

Applying the emission factor to Rheebok Bricks' operation yields an annual estimated PM10 emission of 3.1 tons. If this mass is added to the estimated emissions from the VSBK operation, and assuming that all emissions from the VSBK consist of PM10 particulates, it implies a total annual emission of 16 tons per annum, i.e. an increase of 24%. The total particulate matter at the various points including the mining operation is as follows:


All of these concentrations are well below the ambient air quality standards for PM10 particulates even with the existing mining operation considered cumulatively.

Hydrofluoric Acid

No ambient air quality standard for HF exists in South Africa, but the European Union



suggests the following guideline concentration for European countries: "The 1-hour reference exposure level to protect against any respiratory irritation is about 0.6 mg/m3, and the level to protect against severe irritation from a once-in-a-lifetime release is about 1.6 mg/m3."

The maximum hourly concentration of HF estimated by the dispersion model is 1.7 μg/m3, i.e. substantially lower than the EU guideline of 0.6 mg/m3 (600 μg/m3).

Conclusion of the Air Quality Impact Assessment

The results of the dispersion modelling study show that the estimated maximum ground-level concentrations under the planned conditions would be far below the official ambient air quality standards, even if the higher TPM and SO2 emission scenarios are taken into account.

The Air Quality Specialist also concludes that a VSBK installation will result in substantially lower emissions than is the case of clamp kilns (as are existing in the case of Rheebok Bricks).

Using typical emission factors published by the USEPA, and Rheebok Bricks's annual production capacity, the existing emissions from clamp kilns at Rheebok Bricks can be expected to be the following:

- TPM 103.5 tpa - SO2 68.1 tpa - NOx 28.9 tpa - HF 9.6 tpa

As can be seen these emissions are substantially higher than the emissions expected after the replacement of the clamp kilns with VSBK’s.

Recommendations of Air Quality Specialist

- Until the new plant has been installed the uncertainty in emissions will remain. The specialist recommends, therefore, that the emissions from the VSBK stack are verified by means of manual emission measurements once the plant has been constructed, commissioned and optimised.

- The specialist recommends that no continuous emission monitoring (CEM) equipment will be required once the plant is in operation, but that emissions should be verified annually by a duly competent laboratory as per the requirements of GN 248.

- Because of the low emissions and low estimated impact on air quality the specialist is of the opinion that a dedicated air quality management plan for Rheebok Bricks's operation is not required.

3. WATER USE Please indicate the source(s) of water for the activity by ticking the appropriate box(es)

Municipal Water board Groundwater River, Stream,

Dam or Lake Other The activity will not use water

The VSBK’s will not use any additional water to that already used by the existing brick making process. If water is to be extracted from a groundwater source, river, stream, dam, lake or any other



natural feature, please indicate the volume that will be extracted per month: 0 m3 Please provide proof of assurance of water supply (eg. Letter of confirmation from municipality / water user associations, yield of borehole) Does the activity require a water use permit / license from DWAF? YES NO If yes, please submit the necessary application to Department of Water Affairs and attach proof thereof to this application. Describe the measures that will be taken to reduce water demand, and measures to reuse or recycle water: Measures to reduce water demand are limited for this process. Recommendations with regard to the retrofitting of the existing ablutions to make provision for dual flush toilets and low flow shower heads are included in the environmental management programme. 4. POWER SUPPLY Please indicate the source of power supply eg. Municipality / Eskom / Renewable energy source The electrical supply will be directly from an existing municipal supply within the building. This supply will not require any upgrade and is sufficient for the VSBK operations (The VSBK’s will likely use less electricity than the fans currently used for drying the bricks). If power supply is not available, where will power be sourced from? The facility will connect directly to the existing electrical supply. 3. ENERGY EFFICIENCY Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient: The VSBK’s by nature are designed specifically to be energy efficient and utilise significantly less resources than traditional clamp kilns. Additional recommendations in terms of energy saving lighting are made in the EMP attached in Appendix H of this document. Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any: Considering the current challenges as regards to global weather changes, the introduction and application of cleaner brick production technologies and resultant reduction in CO₂ and other emissions production will lead to a general improvement in environmental conditions. 5. DESCRIPTION AND ASSESSMENT OF THE SIGNIFICANCE OF IMPACTS PRIOR TO

AND AFTER MITIGATION Please note: While sections are provided for impacts on certain aspects of the environment and certain impacts, the sections should also be copied and completed for all other impacts.

It must be kept in mind that different impact may be:

- Associated with normal operation of the plant. These may be continuous (e.g. from the drum) or intermittent (e.g. from loading the trucks);

- Associated with upsets conditions resulting from unplanned incidents. These are difficult to quantify since they are by definition unexpected, and may result from various circumstances (for this reason, it is recommended that the applicant develop an emergency response plan prior to commencing with operation at the facility);

− Associated with changes in operating conditions , e.g. changes in mix temperature, or



- Associated with start-up and shut-down which result from planned filling, purging or draining operations performed when bringing a unit or the plant into or out of service.

These variations in will result in different impacts in the operational and decommissioning and closure phases of the project and are considered and assessed as such below. (a) Impacts that may result from the planning, design and construction phase (briefly describe

and compare the potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the planning, design and construction phase.

Potential impacts on geographical and physical aspects: Fugitive Dust

Nature of impact: Negative - Fugitive Dust from construction activities

Extent and duration of impact: Short Term Probability of occurrence: Likely Degree to which the impact can be reversed: High

Degree to which the impact may cause irreplaceable loss of resources: Low

Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

Low

Degree to which the impact can be mitigated: High

Proposed mitigation: Implementation of construction phase dust management measures as defined in the EMP

Cumulative impact post mitigation: Medium - Low Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low - None

The dust impact during in the construction phase is likely to be extremely limited, as the construction of the VSBK’s will take place beneath an existing structure. Earthworks during construction are thus limited to the casting of foundation structures.

Potential impact on biological aspects: Construction phase impacts on the ecological functioning of the area.

Nature of impact: Neutral Extent and duration of impact: Short Term Probability of occurrence: Low Degree to which the impact can be reversed: Completely


Cumulative impact prior to mitigation: Low - None Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

Low - None



Degree to which the impact can be mitigated: None

Proposed mitigation: No mitigation is recommended in this regard. Cumulative impact post mitigation: Low - None Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low - None

Due to the irreversibly transformed nature of site and the low impact construction (i.e. within an existing building), the construction phase impact on the ecological functioning of the area is deemed to be negligible.

Potential impact on biological aspects: Construction phase Impact on Hydrological Resources.

Nature of impact: Negative Extent and duration of impact: Local / Short Term Probability of occurrence: low Degree to which the impact can be reversed: High


Cumulative impact prior to mitigation: Low Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

Low


Proposed mitigation: - Implementation of EMP conditions relating to stormwater management

Cumulative impact post mitigation: Low – Very Low Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low – Very Low

Potential impacts on socio-economic aspects:

Employment opportunities during construction

Nature of impact: Positive Extent and duration of impact: Local / Short Term Probability of occurrence: High Degree to which the impact can be reversed: Low

Degree to which the impact may cause irreplaceable loss of resources: None


Low

Degree to which the impact can be mitigated: Medium

Proposed mitigation: Sourcing of construction staff from local



communities as far as possible (the EMP makes provision for monitoring of compliance with this recommendation).

Cumulative impact post mitigation: Low Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Medium

Potential impacts on cultural-historical aspects:

Impacts of the construction phase on Heritage aspects of the area.

Nature of impact: Neutral Extent and duration of impact: Local / Short Term Probability of occurrence: Unlikely Degree to which the impact can be reversed: None


Cumulative impact prior to mitigation: None Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

None


Proposed mitigation: None Recommended Cumulative impact post mitigation: None Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

None

Due to the nature of the facility in the landscape (i.e that the construction activities will take place amidst other continual industrial activities) it is highly unlikely that the construction phase of this project will have any impact on any heritage aspects of the area. Potential noise impacts: Noise Nature of impact: Negative - Noise during construction activities Extent and duration of impact: Local / Short Term Probability of occurrence: High Degree to which the impact can be reversed: Low



Medium


Proposed mitigation: Limiting construction hours Ensuring noise abatement technologies on construction machinery



Cumulative impact post mitigation: Medium Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Medium - Low

Noise during construction is not likely to be higher than the ambient noises already present in this existing industrial area. Potential visual impacts: Visual Impacts During Construction Nature of impact: Neutral Extent and duration of impact: Local / Short Term Probability of occurrence: Low Degree to which the impact can be reversed: High



None


Proposed mitigation: None recommended Cumulative impact post mitigation: None Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

None

It is highly unlikely that the activity will result in any visual impacts during construction. The type of activates associated with construction are the same activities that are already taking place daily in this industrial area. (b) Impacts that may result from the operational phase (briefly describe and compare the

potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the operational phase.

Potential impacts on the geographical and physical aspects: Fugitive Dust

Nature of impact: Negative - Fugitive Dust from stockpiles and haul roads

Extent and duration of impact: Local / Long Term during operating hours and windy conditions.

Probability of occurrence: Likely Degree to which the impact can be reversed: High


Cumulative impact prior to mitigation: Medium - the facility will not significantly increase the dust impact that is already present

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, Medium



High, or Very-High) Degree to which the impact can be mitigated: Moderate - Low

Proposed mitigation: None Cumulative impact post mitigation: Medium Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Medium-Low

Potential impacts on the geographical and physical aspects: Traffic Impact (additional trip generation)

Nature of impact: Neutral Extent and duration of impact: Local / long term Probability of occurrence: unlikely Degree to which the impact can be reversed: Low



Low

Degree to which the impact can be mitigated: Low

Proposed mitigation: None Cumulative impact post mitigation: Low Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low

The impacts on traffic are deemed to be insignificant as no additional trips will be required.

Potential impact biological aspects: Impact on the Ecological Functioning of the Area

Nature of impact: Negative Extent and duration of impact: Local / Long Term Probability of occurrence: Low Degree to which the impact can be reversed: High



Low


Proposed mitigation: None Cumulative impact post mitigation: Low



Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low

The site is already irreversibly transformed and contains no remnants of vegetation, nor any ecological pattern or process. The impact on the ecological functioning of this facility on the area is thus deemed to be negligible.

Potential impact biological aspects: Impact on the Hydrological Functioning of the Area




Low


Proposed mitigation: Cumulative impact post mitigation: Low Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low

The proposed positioning of the facility is not in proximity to any surface or groundwater resources and as such is unlikely to have any impact on these resources. Potential impacts on the socio-economic aspects: Employment opportunities

Nature of impact: Positive

Extent and duration of impact: Local / Long Term (for the duration of the lifespan of the facility)

Probability of occurrence: High Degree to which the impact can be reversed: Low



Medium


Proposed mitigation: - Sourcing of employees from local

community as far as possible. - Implementing a skills transfer



programme. Cumulative impact post mitigation: High Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

High

This project will generate a number of long term employment opportunities. Should Rheebok Bricks implement a skills transfer programme, the direct positive impact on the local communities and economy could be high. Potential impacts on the socio-economic aspects:

Socio-economic impact on surrounding community

Nature of impact: Neutral Extent and duration of impact: Local / Long term Probability of occurrence: Low Degree to which the impact can be reversed: Low



Low



Low

The activity is unlikely to result in significant socio economic impacts on the surrounding communities as the nature of the existing industry will not be changed by these technological changes. Potential impacts on the cultural-historical aspects:

Operational Impacts on the Heritage of the area.

Nature of impact: Negative Extent and duration of impact: Local / Long Term Probability of occurrence: Low Degree to which the impact can be reversed: Completely



Low


Proposed mitigation: None




Low

The position of the activity within the landscape is of such a nature that it is surrounded on all sides by other activities that have already significantly transformed the landscape. This activity will not result in additional activities within the landscape, it is merely improving the technology of the existing industry. Potential noise impacts: Noise Nature of impact: Neutral Extent and duration of impact: Local / long term (during operating hours only) Probability of occurrence: Unlikely Degree to which the impact can be reversed: Low



Low


Proposed mitigation: None Cumulative impact post mitigation: None Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low

The Operational impact in terms of noise is deemed to be zero, as ambient noise impacts are already significantly higher than what this facility will contribute. The noise associated with VSBK’s is limited to the extraction fans. Potential visual impacts: Visual Impacts of the Facility Nature of impact: Positive Extent and duration of impact: Permanent Probability of occurrence: Likely Degree to which the impact can be reversed: High



Low

Degree to which the impact can be mitigated: No mitigation deemed necessary

Proposed mitigation: None Cumulative impact post mitigation: Low Significance rating of impact after Low



mitigation (Low, Medium, Medium-High, High, or Very-High) The facility will include a single stack with controlled as opposed to multiple clamp kilns each one with its own emissions and associated visual impacts. The visual quality of the landscape is thus likely to be improved by this facility. Potential Air Quality Impacts: Impacts on Air Quality Nature of impact: Positive Extent and duration of impact: Local / Long Term (during operating hours) Probability of occurrence: Likely Degree to which the impact can be reversed: Low


Cumulative impact prior to mitigation: None – The emissions will be lower than the ambient air quality thresholds

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

Low


Proposed mitigation:

- Carry out emission measurements once the plant has been constructed, commissioned and optimised.

- Emissions of all controlled pollutants should be verified annually.

Cumulative impact post mitigation: None Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Low

Please see section 2 of this report for further details as well as Appendix G for a copy of the full air quality impact assessment that was undertaken. The replacement of the existing clamp kilns with VSBK’s is likely to result in an improvement in air quality. (c) Impacts that may result from the decommissioning and closure phase (briefly describe and

compare the potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the decommissioning and closure phase.

Potential impacts on the geographical and physical aspects: Fugitive dust

Nature of impact: Negative - Fugitive dust from decommissioning of plant

Extent and duration of impact: Local / Temporary Probability of occurrence: Likely Degree to which the impact can be reversed: Completely


Cumulative impact prior to mitigation: Low



Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

Low


Proposed mitigation: Implementing the decommissioning dust control mechanisms detailed in the EMP


Low - None

Potential impacts on the geographical and physical aspects:

Impact on the Ecological Functioning of the Area




Low



Low

Potential noise impacts: Noise

Nature of impact: Negative - Noise during decommissioning activities

Extent and duration of impact: Local / Short Term Probability of occurrence: High Degree to which the impact can be reversed: Low



Medium


Proposed mitigation: - Limiting decommissioning hours



- Ensuring noise abatement technologies on construction machinery

Cumulative impact post mitigation: Medium Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

Medium - Low

6. SPECIALIST INPUTS/STUDIES AND RECOMMENDATIONS

Please note: Specialist inputs/studies must be attached to this report as Appendix G. Also take into account the Department’s Guidelines on the Involvement of Specialists in EIA Processes available on the Department’s website (http://www.capegateway.gov.za/eadp).

Specialist inputs/studies and recommendations: A Specialist Air Quality Impact Assessment was undertaken by Mr Chris Albertyn of LAQS and is attached Appendix G of this report. The Air Quality specialist made the following recommendations in this regard:

- Rheebok Bricks should commission a suitably qualified and experienced contractor to carry out emission measurements once the plant has been constructed, commissioned and optimised; and

- Emissions of all controlled pollutants should be verified annually by an independent contractor and reported to EDM accordingly to meet regulatory requirements.

7. IMPACT SUMMARY Please provide a summary of all the above impacts. As can be seen from the findings in this report, the negative environmental and social impacts associated with this technological improvement are virtually non-existent. The potential positive environmental and social benefits in terms of improved air quality (through reduced emissions) as well as reduced resource requirements are a significant positive benefit. 8. OTHER MANAGEMENT, MITIGATION AND MONITORING MEASURES (a) Over and above the mitigation measures described in Section 6 above, please indicate any

additional management, mitigation and monitoring measures. - The EMP developed for Rheebok Bricks must be adopted and implemented. - The requirements and recommendations with regards to health safety and the

environment in the Operations Manual for VSBK’s must be adopted and implemented - An ECO should be appointed to oversee construction activities. - An Environmental Audit should be undertaken within 6 months after completion of

construction to ensure that conditions of the Environmental Authorisation and the EMP were adhered to.

(b) Describe the ability of the applicant to implement the management, mitigation and monitoring measures. Rheebok Bricks is the largest clay brick manufacturer between Cape Town and Port Elizabeth and has been operational for over 40 years. Mr. Nicky van Wyk, General Manager of Rheebok Bricks has more than 10 years experience in the manufacturing of bricks and is deemed competent to implement such a project.




Please note: A draft ENVIRONMENTAL MANAGEMENT PROGRAMME must be attached this report as Appendix H.



SECTION G: ASSESSMENT METHODOLOGIES AND CRITERIA, GAPS IN KNOWLEDGE, UNDERLAYING ASSUMPTIONS AND UNCERTAINTIES

(a) Please describe adequacy of the assessment methods used. The assessment methods used comply with all necessary guidelines to undertake such assessments. Assessment Methods used included the following: Site assessments by the EAP to determine the nature and sensitivity of the site and to

gain an understanding of the surrounding environment; Site assessments by the EAP and Air Quality Specialist of an existing operational VSBK

facility in the Eastern Cape; Consultation with the Applicant and industry specialists to gain an understanding of the

need for the proposed activity as well as the nature of the proposed activity; Consultation with stakeholders (see the complete stakeholder list as part of Appendix F); Obtaining of specialist input ; Consultation with Department of the Health and other key stakeholders relating to the

potential health risk and impact on ambient air quality; Consultation with the Department of Environmental Affairs & Development Planning

regarding the process and requirements; Consultation with the Mossel Bay Municipality regarding planning context and availability of services.

Consideration of the applicable Legislation, Guidelines & Policies (complete list indicated in Section 10).

The assessment methods used are anticipated to be adequate for the nature of the application and site. (b) Please describe the assessment criteria used. The assessment criteria used includes the following: Nature of the impact: Impacts have been described in terms of whether it will have a

positive or negative impact, as well as a description of what or who will be affected. Extent of the impact: Impacts were considered in terms of whether it will affect the site,

the surrounding area, or on a wider scale (i.e. regional / national). Duration of the impact: Impacts have been assessed in terms of the anticipated duration

of the impact. The lifetime of impacts were determined and classified as: o short term (e.g. during the construction phase); o medium term (e.g. during part or all of the operational phase); o long term (e.g. beyond the operational phase, but not permanently); o permanent (where the impact is for all intents and purposes irreversible; or o Discontinuous or intermittent (where the impact may only occur during specific

climatic conditions or during a particular season of the year). Intensity or magnitude: The size of the impact (if positive) or its severity (if negative)

have been assessed as: o low, where biodiversity is negligibly affected or where the impact is so low that

remedial action is not required; o medium, where biodiversity pattern, process and/or ecosystem services are altered,

but not severely affected, and the impact can be remedied successfully; and o high, where pattern, process and/or ecosystem services would be substantially (i.e. to

a very large degree) affected. If a negative impact, could lead to irreplaceable loss of



biodiversity and/or unacceptable consequences for human wellbeing. Probability: The anticipated impacts have been assessed as having either an

improbable, probable, highly probable or definite probability of occurring. Significance: The significance of impacts can be determined through a synthesis of the

assessment criteria. Significance can be described as: o low, where it would have negligible effect on biodiversity, and on the decision; o medium, where it would have a moderate effect on biodiversity, and should influence

the decision; o high, where it would have, or there would be a high risk of, a large effect on

biodiversity. These impacts should have a major influence on the decision; o very high, where it would have, or there would be a high risk of, an irreversible

negative impact on biodiversity and irreplaceable loss of natural capital or a major positive effect. Impacts of very high significance should be a central factor in decision-making.

Confidence levels were applied to the assessment: o low, where there is little confidence in the prediction, due to inherent uncertainty

about the likely response of the receiving ecosystem, or inadequate information; o medium, where there is a moderate level of confidence in the prediction; or o high, where the impact can be predicted with a high level of confidence.

(Source: Adapted from criteria used by the Department of Environmental Affairs and Tourism, 1998.) (c) Please describe the gaps in knowledge. Actual measured emissions of the facility can only take place once the facility is in operation. (d) Please describe the underlying assumptions.

The assumption is made that the information on which this report is based (project information and specialist input) is correct, factual, and truthful.

It is assumed that all the relevant mitigation measures specified in this report will be implemented in order to ensure minimal negative impact on the site and surrounding social and biophysical environment.

(e) Please describe the uncertainties. None



SECTION H: RECOMMENDATION OF THE EAP In my view (EAP), the information contained in this application form and the documentation attached hereto is sufficient to make a decision in respect of the activity applied for.

YES NO

If “NO”, list the aspects that should be further assessed through additional specialist input/assessment or whether this application must be subjected to a Scoping & EIR process before a decision can be made: If “YES”, please indicate below whether in your opinion the activity should or should not be authorised: Activity should be authorised: YES NO Please provide reasons for your opinion The replacement of clamp kilns with VSBK’s will result in improved air quality of the region as well as improved resource efficiency and economic viability without any significant negative impact on the biophysical, social or economic environments. If you are of the opinion that the activity should be authorised, then please provide any conditions, including mitigation measures that should in your view be considered for inclusion in an authorisation.

- The EMP developed for Rheebok Bricks must be adopted and implemented. - The requirements and recommendations with regards to health safety and the

environment in the Operations Manual for VSBK’s must be adopted and implemented - An ECO should be appointed to oversee construction activities. - An Environmental Audit should be undertaken within 6 months after completion of

construction to ensure that conditions of the Environmental Authorisation and the EMP were adhered to.

- The existing clamp kilns should be phased out entirely over a five year period. - Rheebok Bricks should commission a suitably qualified and experienced contractor to

carry out emission measurements once the plant has been constructed, commissioned and optimised; and

- Emissions of all controlled pollutants should be verified annually by an independent contractor and reported to EDM accordingly to meet regulatory requirements.

Duration and Validity: Environmental authorisations are usually granted for a period of three years from the date of issue. Should a longer period be required, the applicant/EAP is requested to provide a detailed motivation on what the period of validity should be. A three year validity period for the environmental authorisation is deemed to be sufficient for commencement of this activity, however the competent authority must please note that the clamp kilns will be phased out and replaced with VSBK’s over a five year period.



SECTION I: APPENDICES The following appendices must be attached to this report:

Appendix

Tick the box if

Appendix is attached

Appendix A: Locality map

Appendix B: Site plan(s)

Appendix C: Photographs

Appendix D: Biodiversity overlay map

Appendix E: Permit(s) / license(s) from any other organ of state including service letters from the municipality (Zoning Certificate)

Appendix F:

Public participation information: including a copy of the register of interested and affected parties, the comments and responses report, proof of notices, advertisements and any other public participation information as required in Section C above.

Appendix G: Specialist Report(s) – Air Quality Impact Assessment

Appendix H: Environmental Management Programme

Appendix I: Additional information related to listed waste management activities (if applicable)

Appendix J: Any Other (if applicable) (describe) – Landowner Consent, VSBK operational manual.



DECLARATIONS 1. THE APPLICANT I …………………………………., in my personal capacity or duly authorised (please circle the applicable option) by ……………..................................………………… thereto hereby declare that I: regard the information contained in this report to be true and correct, and am fully aware of my responsibilities in terms of the National Environmental Management

Act of 1998 (“NEMA”) (Act No. 107 of 1998), the Environmental Impact Assessment Regulations (“EIA Regulations”) in terms of NEMA (Government Notice No. R. 543 refers), and the relevant specific environmental management Act, and that failure to comply with these requirements may constitute an offence in terms of the environmental legislation;

appointed the environmental assessment practitioner as indicated above, which meet all the requirements in terms of regulation 17 of GN No. R. 543, to act as the independent environmental assessment practitioner for this application;

have provided the environmental assessment practitioner and the competent authority with access to all information at my disposal that is relevant to the application;

will be responsible for the costs incurred in complying with the environmental legislation including but not limited to – o costs incurred in connection with the appointment of the environmental assessment

practitioner or any person contracted by the environmental assessment practitioner; o costs incurred in respect of the undertaking of any process required in terms of the

regulations; o costs in respect of any fee prescribed by the Minister or MEC in respect of the

regulations; o costs in respect of specialist reviews, if the competent authority decides to recover costs;

and o the provision of security to ensure compliance with the applicable management and

mitigation measures; am responsible for complying with the conditions that might be attached to any decision(s)

issued by the competent authority; have the ability to implement the applicable management, mitigation and monitoring

measures; hereby indemnify, the government of the Republic, the competent authority and all its

officers, agents and employees, from any liability arising out of, inter alia, the content of any report, any procedure or any action for which the applicant or environmental assessment practitioner is responsible; and

am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543. Please Note: If acting in a representative capacity, a certified copy of the resolution or power of attorney must be attached.

Signature of the applicant: Name of company: Date:



2. THE INDEPENDENT ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) I ……………………………………, on behalf of Cape EAPrac, as the appointed independent environmental practitioner (“EAP”) hereby declare that I: act/ed as the independent EAP in this application; regard the information contained in this report to be true and correct, and do not have and will not have any financial interest in the undertaking of the activity, other

than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

have and will not have no vested interest in the proposed activity proceeding; have disclosed, to the applicant and competent authority, any material information that have

or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact Assessment Regulations, 2010 (specifically in terms of regulation 17 of GN No. R. 543) and any specific environmental management Act, and that failure to comply with these requirements may constitute and result in disqualification;

have ensured that information containing all relevant facts in respect of the application was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments;

have ensured that the comments of all interested and affected parties were considered, recorded and submitted to the competent authority in respect of the application;

have kept a register of all interested and affected parties that participated in the public participation process;

have provided the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; and

am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543. Note: The terms of reference must be attached. Signature of the environmental assessment practitioner: Signature of the environmental assessment practitioner: Name of company: Date:



3. THE INDEPENDENT PERSON WHO COMPILED A SPECIALIST REPORT OR UNDERTOOK A SPECIALIST PROCESS

I ……………………………………, as the appointed independent specialist hereby declare that I: act/ed as the independent specialist in this application; regard the information contained in this report as it relates to my specialist input/study to be

true and correct, and do not have and will not have any financial interest in the undertaking of the activity, other

than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

have and will not have no vested interest in the proposed activity proceeding; have disclosed, to the applicant, EAP and competent authority, any material information that

have or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact Assessment Regulations, 2010 (specifically in terms of regulation 17 of GN No. R. 543) and any specific environmental management Act, and that failure to comply with these requirements may constitute and result in disqualification;

have ensured that information containing all relevant facts in respect of the specialist input/study was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments on the specialist input/study;

have ensured that the comments of all interested and affected parties on the specialist input/study were considered, recorded and submitted to the competent authority in respect of the application;

have ensured that the names of all interested and affected parties that participated in terms of the specialist input/study were recorded in the register of interested and affected parties who participated in the public participation process;

have provided the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; and

am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543. Note: The terms of reference must be attached. Signature of the specialist: Name of company: Date:



REFERENCES DWA (2001). Generic public participation guideline. Department of Water Affairs and Forestry. DEAT (2002). Integrated Environmental Management Information Series 3: Stakeholder Engagement. Department of Environmental Affairs and Tourism, Pretoria. DEADP (2003). Waste Minimisation Guideline for Environmental Impact Assessment reviews. NEMA EIA Regulations Guideline & Information Series, Department Environmental Affairs & Development Planning. DEAT (2004). Criteria for determining alternatives in EIAs, Integrated Environmental Management, Information Series 11, Department of Environmental Affairs & Tourism, Pretoria. DEAT (2004). Environmental management Plans, Integrated Environmental management, Informatino Series 12, Department Environmental Affairs & Tourism. DEAT (2005). Assessment of Impacts and Alternatives, Integrated Environmental Management Guideline Series, Department of Environmental Affairs & Tourism, Pretoria. DEAT (2005). Guideline 4: Public Participation, in terms of the EIA Regulations 2005, Integrated Environmental Management Guideline Series, Department of Environmental Affairs and Tourism, Pretoria. DEADP (2005). Guideline for the review of specialist input in the EIA process. NEMA EIA Regulations Guideline & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2005). Guideline for involving biodiversity specialists in the EIA process. NEMA EIA Regulations Guideline & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2005). Guideline for environmental management plans. NEMA EIA Regulations Guideline & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2005). Provincial urban edge guideline. Department Environmental Affairs & Development Planning. DEAT (2006). EIA Regulations in terms of the National Environmental Management Act (Act No 107 of 1998) (Government Notice No R 385, R 386 and R 387 in Government Gazette No 28753 of 21 April 2006). DEADP (2006). Guideline on the Interpretation of the Listed Activities. NEMA EIA Regulations Guidelines & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2007). Guide on Alternatives, NEMA EIA Regulations Guidelines & Information Document Series, Department of Environmental Affairs & Development Planning.



DEADP (2007). Guideline on Appeals, NEMA EIA Regulations Guidelines & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2007). Guideline on Exemption Applications. NEMA EIA Regulations Guidelines & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2007). Guideline on Public Participation. NEMA EIA Regulations Guidelines & Information Document Series, Department of Environmental Affairs & Development Planning. DEADP (2009). Guideline on Need & Desirability, NEMA EIA Regulations Guideline and Information Document Series, Department Environmental Affairs & Development Planning. DEADP (2009). Guideline on Alternatives, NEMA EIA Regulations Guideline and Information Document Series, Department Environmental Affairs & Development Planning. DEADP (2009). Guideline on Transitional Arrangements, NEMA EIA Regulations Guideline and Information Document Series, Department Environmental Affairs & Development Planning. DEADP (2009). Guideline on Exemption Applications. NEMA EIA Regulations Guideline and Information Document Series, Department Environmental Affairs & Development Planning. DEADP (2009). Guideline on Appeals. NEMA EIA Regulations Guideline and Information Document Series, Department Environmental Affairs & Development Planning. DEADP (2009). Guideline on Public Participation. NEMA EIA Regulations Guideline and Information Document Series, Department Environmental Affairs & Development Planning. Keatimilwe K & Ashton PJ 2005. Guideline for the review of specialist input in EIA processes. Department Environmental Affairs & Development Planning. Lochner P (2005). Guideline for Environmental Management Plans. Department Environmental Affairs & Development Planning. Münster, F. (2005). Guidelines for Determining the Scope of Specialist Involvement in EIA Processes: Edition 1. CSIR Report No ENV-S-C 2005 053 A. Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs and Development Planning, Cape Town. Oberholzer B (2005). Guideline for involving visual & aesthetic specialists. Department Environmental Affairs & Development Planning. Winter S & Beaumann N (2005). Guideline for involving heritage specialists in EIA processes. Department Environmental Affairs & Development Planning. Hsai-Yang, F (Ed)(2006). Environmental Geotechnology Dictionary (online version). University of North Caroline, Charlotte, USA. Mucina, L. & Rutherford, M.C. (eds) 2006. The Vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria.



Saayman, I. (2005). Guideline for Involving Hydrogeologists in EIA Processes: Edition 1. CSIR Report No ENV-S-C 2005 053 D. Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs and Development Planning, Cape Town. SANBI Biodiversity GIS (2007). South African National Biodiversity Institute, Cape Town, South Africa.

Rheebok Bricks - VSBK MOS243a/12


APPENDIX A LOCATION PLAN



APPENDIX B SITE LAYOUT PLAN



APPENDIX C PHOTOGRAPHIC

PLATES



APPENDIX D BIODIVERSITY

OVERLAY MAPS



APPENDIX E PERMITS /

LICENCES from other Organs of

State



ANNEXURE E1 ZONING

CERTIFICATE



APPENDIX F PUBLIC

PARTICIPATION



APPENDIX G SPECIALIST REPORTS



ANNEXURE G1 AIR QUALITY IMPACT

ASSESSMENT



APPENDIX H CONSTRUCTION PHASE

ENVIRONMENTAL MANAGEMENT PROGRAMME



APPENDIX J ADDITIONAL

INFORMATION



ANNEXURE J1 LANDOWNERS

CONSENT



ANNEXURE J2 VSBK Operational

Manual

Documents

FINAL BASIC ASSESSMENT REPORT - cape-eaprac.co.zacape-eaprac.co.za/projects/MOS243a Rheebok Bricks VSBK/Final Ba… · Rheebok Bricks – VSBK’s MOS43a/12 Cape EAPrac Final Basic