N2 WILD COAST TOLL HIGHWAY ENVIRONMENTAL …€¦ · M.Sc. (Botany), HDE . PROFESSIONAL REGISTRATION: Pr.Sci.Nat., CEAPSA . EXPERIENCE IN YEARS: 16 . EXPERIENCE: Fuad Fredericks has

NRA01N2WC/EMP June 2016

N2 WILD COAST TOLL HIGHWAY

ENVIRONMENTAL MANAGEMENT PROGRAMME

Prepared for: National Department of Environmental Affairs

On behalf of: The South African National Roads Agency SOC Limited

Prepared by: CCA Environmental (Pty) Ltd (part of the SLR Consulting group)

NRA01N2WC/EMP June 2016

N2 WILD COAST TOLL HIGHWAY

ENVIRONMENTAL MANAGEMENT PROGRAMME

Prepared for: National Department of Environmental Affairs

Environment House 473 Steve Biko Road

Arcadia, Pretoria 0083

On behalf of:

The South African National Roads Agency SOC Limited 48 Tambotie Avenue

Val de Grace, Pretoria 0184

Prepared by: CCA Environmental (Pty) Ltd (part of the SLR Consulting group)

Contact person: Fuad Fredericks Unit 39, Roeland Square

30 Drury Lane Cape Town

8001 Tel: 021 461 1118 Fax: 021 461 1120

Email: [email protected]

N2 Wild Coast Toll Highway

CCA Environmental (Pty) Ltd i EMP

PROJECT INFORMATION

TITLE Environmental Management Programme for the N2 Wild Coast Toll Highway

APPLICANT South African National Roads Agency SOC Limited

ENVIRONMENTAL CONSULTANT CCA Environmental (Pty) Ltd (part of the SLR Consulting group)

REPORT REFERENCE NRA01N2WC/EMP

DEA REFERENCE 12/12/20/701

REPORT DATE June 2016

REPORT COMPILED AND REVIEWED BY: Fuad Fredericks ........................................................ Fuad Fredericks Pr.Sci.Nat., CEAPSA Director


CCA Environmental (Pty) Ltd ii EMP

EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER

NAME: Mr Fuad Fredericks RESPONSIBILITY ON PROJECT: Project management and quality control QUALIFICATIONS: M.Sc. (Botany), HDE PROFESSIONAL REGISTRATION: Pr.Sci.Nat., CEAPSA EXPERIENCE IN YEARS: 16

EXPERIENCE:

Fuad Fredericks has been involved in environmental consulting since 1999 and is currently a Director of CCA Environmental (Pty) Ltd. He has experience in a wide range of environmental disciplines, including Environmental Impact Assessments, Environmental Management Programmes, Environmental Monitoring and Auditing, Environmental Education and Public Consultation. He has been responsible for management and quality control of environmental assessments dealing with a number of highly complex and controversial projects, such as the proposed toll roads on the national routes in the Western Cape and the proposed N2 Wild Coast Toll Highway between the Eastern Cape and KwaZulu-Natal. He also has extensive experience in the environmental assessment, monitoring and auditing of projects related to railway facilities, landfill sites, wastewater treatment facilities, and water and sewage pipelines.


CCA Environmental (Pty) Ltd iii EMP

DOCUMENT REVISIONS

NO. REPORT REFERENCE VERSION / REVISION CHANGE DATE

1. NRA01N2WC/EMP Rev. 0 - June 2016

2.

3.

4.

5.

6.

7.

8.

9.


CCA Environmental (Pty) Ltd iv EMP

TABLE OF CONTENTS PROJECT INFORMATION ................................................................................................................... i EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER ............................................. ii DOCUMENT REVISIONS ................................................................................................................... iii TABLE OF CONTENTS ................................................................................................................ iv GLOSSARY OF TERMS ..................................................................................................................... vi ABBREVIATIONS ................................................................................................................................ x 1. INTRODUCTION ........................................................................................................................... 1

1.1 OVERVIEW OF THE PROJECT ........................................................................................ 1 1.2 RECORD OF DECISION ................................................................................................... 1 1.3 OVERALL PURPOSE AND SCOPE OF THE EMP .......................................................... 1 1.4 TERMS OF REFERENCE OF THE EMP ........................................................................... 3 1.5 STRUCTURE OF THE EMP .............................................................................................. 3

2. ENVIRONMENTAL LEGISLATION, POLICIES, PROGRAMMES AND STANDARDS ............. 6 2.1 LEGISLATIVE FRAMEWORK ........................................................................................... 6

2.1.1 Statutory and Other Applicable Legislation and Policies ..................................... 6 2.1.2 Approval/licence/authorisation/permit requirements ........................................... 7

2.2 ENVIRONMENTAL STANDARDS .................................................................................... 8 2.2.1 National environmental management principles ................................................. 8 2.2.2 Duty of care and remediation of environmental damage..................................... 8 2.2.3 Control of emergency incidents .......................................................................... 9 2.2.4 Ambient air quality standards and guidelines ..................................................... 9 2.2.5 National dust control regulations ........................................................................ 9 2.2.6 Noise Control Regulations ................................................................................ 10 2.2.7 Blasting Regulations and Standards ................................................................ 10 2.2.8 Taking of water from a water resource (abstraction of water) ........................... 10 2.2.9 Impeding or diverting the flow of water in a watercourse and altering the bed,

banks, course or characteristics of a watercourse ............................................ 10 2.2.10 Control of alien vegetation ................................................................................ 10 2.2.11 Control of development affecting natural forests .............................................. 11 2.2.12 NHRA Regulations ........................................................................................... 11

3. ADMINISTRATION, MANAGEMENT, MONITORING AND AUDITING OF ENVIRONMENTAL OBLIGATIONS ........................................................................................................................... 12 3.1 MANAGEMENT STRUCTURE ........................................................................................ 12 3.2 ROLES AND RESPONSIBILITIES .................................................................................. 12

3.2.1 Environmental authority (DEA) ......................................................................... 12 3.2.2 Applicant (SANRAL) ......................................................................................... 12 3.2.3 Engineer .......................................................................................................... 13 3.2.4 Contractor ........................................................................................................ 13 3.2.5 Project Environmental Manager (PEM) ............................................................ 14 3.2.6 Environmental Control Officer .......................................................................... 14 3.2.7 Site Environmental Control Officer (SECO) ...................................................... 15 3.2.8 Environmental Auditor ...................................................................................... 16 3.2.9 Authorities Coordination Committee (ACC) ...................................................... 16 3.2.10 Environmental Monitoring Committee (EMC) ................................................... 17 3.2.11 Specialist environmental service provider (s) ................................................... 17

3.3 REPORTING AND RECORD-KEEPING ......................................................................... 17 3.3.1 Administration .................................................................................................. 17 3.3.2 Method Statements .......................................................................................... 18 3.3.3 Document Control ............................................................................................ 18 3.3.4 Notification to relevant environmental authorities ............................................. 18


CCA Environmental (Pty) Ltd v EMP

3.4 ENVIRONMENTAL TRAINING AND AWARENESS ...................................................... 19 3.5 PERFORMANCE INDICATORS AND TARGETS ........................................................... 20 3.6 EMERGENCY PREPAREDNESS ................................................................................... 20 3.7 PUBLIC COMMUNICATION AND LIAISON WITH INTERESTED AND AFFECTED

PARTIES .......................................................................................................................... 21 3.7.1 Information Distribution .................................................................................... 21 3.7.2 Information Boards ........................................................................................... 22 3.7.3 Complaints Register ......................................................................................... 22

4. ENVIRONMENTAL SPECIFICATIONS: DESIGN .................................................................... 23 4.1 INTRODUCTION .............................................................................................................. 23 4.2 ENVIRONMENTAL MANAGEMENT MEASURES - DESIGN ........................................ 23

5. ENVIRONMENTAL SPECIFICATIONS: CONSTRUCTION AND OPERATION ...................... 37 5.1 INTRODUCTION .............................................................................................................. 37 5.2 ENVIRONMENTAL MANAGEMENT MEASURES – CONSTRUCTION AND

OPERATION .................................................................................................................... 37 6. CONCLUSION AND WAY FORWARD ...................................................................................... 57 Figure 1.1 The N2 Wild Coast Toll Highway between the Gonubie Interchange (Eastern Cape) and the

Isipingo Interchange (KwaZulu-Natal) Figure 1.2 Topography and land use between Ndwalane/Port St Johns and the Mthamvuna River,

showing the two greenfields sections Figure 4.1 Ecological sensitivity of habitats between Ndwalane and Ntafufu Figure 4.2 Ecological sensitivity of habitats between Lusikisiki and the Mthamvuna River Appendix A Record of Decision Appendix B Supplementary EMP for Aquatic Ecosystems Appendix C Plant Search and Rescue Plan Appendix D Alien and Invasive Species Management Plan Appendix E List of proposed fines


CCA Environmental (Pty) Ltd vi EMP

GLOSSARY OF TERMS The definitions given below are for explanatory purposes only and are applicable to this Environmental Management Programme (EMP). In the event that any conflict arises between the definitions contained herein and those contained within the final contract, those within the contract shall prevail. Alien vegetation: Alien vegetation is defined as undesirable plant growth which shall include, but not be limited to Category 1 plants (declared weeds), Category 2 plant invaders (commercial value) and Category 3 plant invaders (ornamental value) as set out in the Amended Regulations of the Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (CARA). Other vegetation deemed to be alien invasive shall be those plant species that show the potential to occupy in number, any area within the defined construction area. Alien species also include species that are not indigenous species or any indigenous species that has been translocated or is intended to be translocated to a place outside its natural distribution range in nature, but does not include indigenous species that have extended their natural distribution range by natural means of migration or dispersion without human intervention. Authorities Coordination Committee (ACC): A structure, comprising various authorities, which shall serve as a forum for the discussion and coordination of project-related issues, and for timeous dissemination of information about progress on the project to the key authorities. SANRAL shall convene an ACC quarterly or as agreed upon with the Department of Environmental Affairs during the planning and construction phase of the project. COLTO Specifications: Standard specifications for road and bridge works for state road authorities. Construction activity: Any action taken by the Contractor, his subcontractors, suppliers or personnel during the construction process, as defined in the South African National Roads Agency Limited and National Roads Act, 1998 (Act No. 107 of 1998). Construction area: (compare with “site”) All areas reasonably required by the Contractor to undertake the construction activities. Construction camp: (also called site camp) All storage and stockpile sites, site offices, staff accommodation, container sites, workshops and testing facilities and other areas required to undertake construction activities. Site Environmental Control Officer (SECO): The representative of the Contractor responsible for implementing the environmental provisions of specific construction contracts and appointed by each service provider that carries out construction activities on behalf of SANRAL, as required. The SECO, also known as the Designated Environmental Officer (DEO), is responsible for ensuring that the specific construction contract is undertaken in accordance with the relevant environmental requirements of the Environmental Management Programme (EMP). The SECO shall implement any remedial measures as required from time to time and shall ensure that any authorisations/licences required in terms of the service contract are obtained timeously and complied with on site. EIA Regulations: Environmental Impact Assessment (EIA) Regulations dated 5 September 1997, published by the Minister of Environmental Affairs and Tourism pursuant to sections 21, 22 and 26 of the Environment Conservation Act,


CCA Environmental (Pty) Ltd vii EMP

1989 (Act No. 73 of 1989), as applicable to the Application for Environmental Authorisation. Also refers to Regulations GN R385, R386 and R387 (dated 21 April 2006), Regulations GN R543, R544, R545 and R546 (dated 18 June 2010) and Regulations GN R982, R983, R984 and R985 (dated 4 December 2014) published in terms of Chapter 5 of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended, as may be applicable to any further Environmental Authorisation requirements of the proposed project, as appropriate. Environment: The surroundings in which humans exist and which comprise: a) The land, water and atmosphere of the earth; b) Micro-organisms, plant and animal life; c) Any part or combination of a) and b) and the interrelationships among and between them; and d) The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that can

influence human health and well-being. (After National Environmental Management Act, 1998 (Act No.107 of 1998)). Environmental Control Officer (ECO) A suitably qualified and experienced independent person or entity appointed by SANRAL. The ECO is responsible for overall monitoring of compliance of construction activities with the requirements of the Record of Decision, environmental legislation, specifications of the EMP and other applicable permits/licences. Environmental Impact: Any change to the environment resulting from a construction activity, whether desirable or undesirable. An impact may be the direct, indirect or cumulative consequence of an activity. Environmental Impact Assessment (EIA): A process of examining the environmental effects of development (after DEAT, 1998. Guideline Document: EIA Regulations). The assessment requires detailed/specialist studies of key issues that have been identified during the environmental scoping process. Also, “a systematic process of identifying, assessing and reporting environmental impacts associated with an activity and includes basic assessment and S&EIR” (after GN R982 dated 4 December 2014). Environmental Management Programme (EMP): A detailed programme of action prepared to ensure that recommendations for enhancing positive impacts and preventing or limiting negative environmental impacts are implemented during the life-cycle of a project. Project Environmental Manager (PEM): A person to be appointed by SANRAL for the planning and construction phases of the project. The PEM must be an independent consultant and must be permanently on the site to support and assist the ECOs during the period of construction (after Record of Decision dated 19 April 2010). Environmental Monitoring Committee (EMC): A structure created in consultation with various stakeholder groups whose role will be to (1) monitor and audit the project compliance with specific conditions of the environmental authorisation and the requirements of the approved EMP, (2) make recommendations to the Department of Environmental Affairs (DEA) on issues related to the monitoring and auditing of the project implementation and (3) advise DEA on issues related to non-conformance reports raised against SANRAL by the ECOs. Alien Vegetation Eradication Programme: The organised clearing and rehabilitation of land infested by invasive alien plant species.


CCA Environmental (Pty) Ltd viii EMP

Greenfields Section: This refers to an undisturbed/undeveloped area through which a proposed new section of road will be constructed. Hazard: A source of or exposure to danger. Environmental Auditor (EA): A suitably qualified and experienced independent expert appointed by SANRAL to verify compliance with the Record of Decision, EMP and associated authorisations. Interested and Affected Party (I&AP): Refers to any person or group of persons concerned with or affected by an activity and its consequences. These include the authorities, local communities, investors, work force, customers and consumers, environmental interest groups and the general public (after the EIA Regulations of September 1997 and Guideline Document: EIA Regulations of April 1998). In terms of GN R385 of 21 April 2006, it includes “any person, group of persons or organisation interested in or affected by an activity”; and “any organ of state that may have jurisdiction over any aspect of the activity”. GN R543 of 18 June 2010 and GN R982 of 4 December 2014 describe a “registered” I&AP in relation to an application as an I&AP “whose name is recorded in the register opened for that application”. Method Statement: A written submission by the Contractor in response to a specification or a request by the Engineer, setting out the plant, materials, labour and method proposed to carry out an activity, in such detail that the Engineer and/or ECO is able to assess any associated environmental risks. Mitigate: The implementation of practical measures to avoid or reduce adverse impacts, or enhance beneficial impacts of an activity. No-go area: Area where construction activities are prohibited. Pesticide: Chemicals used by humans to kill organisms that threaten their health and well-being, pets and livestock or cause damage to crops. This includes insecticides, herbicides, fungicides, acaricides, nematicides and rodenticides (after Fuggle et al, 1992). Pollution: Any change in the environment caused by (i) substances; (ii) radioactive or other waves; or (iii) noise, odours, dust or heat emitted from any activity, including the storage or treatment of waste or substances, construction and the provision of services, whether engaged in by any person or an organ of state, where that change has an adverse effect on human health or well-being or on the composition, resilience and productivity of natural or managed ecosystems, or on materials useful to people, or will have such an effect in the future (after National Environmental Management Act, 1998). Record of Decision or Environmental Authorisation: A written statement from the relevant environmental authority that records its approval/rejection of a listed activity (for example, to build or upgrade a section of road). Approval is usually granted with conditions specifying the necessary measures required to prevent or reduce the effects of environmental impacts during the life of a contract.


CCA Environmental (Pty) Ltd ix EMP

Rehabilitation: To re-establish or restore to a healthy, sustainable capacity or state. Riparian zone: A zone located next to a stream or river, affected by stream processes such as flooding and deposition of alluvial soil, and supporting a fauna and flora different from the upland slopes. Road reserve: The area of land reserved for the construction, maintenance and future development of a road, interchanges and associated infrastructure as defined by co-ordinates and/or proclamation. Site: (compare with “construction area”) Refers to those sections of the existing N2, existing R61 and greenfields sections of the N2 Wild Coast Toll Highway which will generally include the road reserve and such other areas that may become part of the Site as provided for in the Contract.


CCA Environmental (Pty) Ltd x EMP

ABBREVIATIONS AEL Atmospheric Emission Licence CARA Conservation of Agricultural Resources Act, 1989 (Act No. 43 of 1989) COLTO Committee of Land Transport Officials DAFF Department of Agriculture, Forestry and Fisheries DEA Department of Environmental Affairs DMR Department of Mineral Resources DWS Department of Water and Sanitation ECA Environment Conservation Act, 1989 (Act No. 73 of 1989) ECO Environmental Control Officer ECPTA Eastern Cape Parks and Tourism Authority EIA Environmental Impact Assessment EIR Environmental Impact Report EMP Environmental Management Programme EMPR Environmental Management Programme Report EMS Environmental Management System I&AP Interested and Affected Party IEA Independent Environmental Auditor KPI Key Performance Indicator NBI National Botanical Institute NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998) NFA National Forests Act, 1998 (Act No. 84 of 1998) NHRA National Heritage Resources Act, 1999 (Act No. 25 of 1999) NWA National Water Act, 1998 (Act No. 36 of 1998) OHSA Occupational Health & Safety Act, 1993 (Act No. 85 of 1993) ROD Record of Decision SAHRA South African Heritage Resources Agency SANRAL The South African National Roads Agency SOC Limited SECO Site Environmental Control Officer TOPS Threatened or Protected Species WfW Working for Water [now incorporated into DEA’s Natural Resource Management

programmes]


CCA Environmental (Pty) Ltd 1 EMP

1. INTRODUCTION

1.1 OVERVIEW OF THE PROJECT The N2 Wild Coast Toll Highway extends over a total distance of about 560 km between the N2 Gonubie Interchange (near East London in the Eastern Cape) and the N2 Isipingo Interchange (south of Durban in KwaZulu-Natal) – see Figure 1.11. The key components of the proposed project include the following: • Upgrading and widening of existing road sections (of the N2 and R61) included within the proposed

project (approximately 470 km); • New road construction within two “greenfields” sections in the Eastern Cape portion of the project

(approximately 90 km) – see Figure 1.2; • Construction of nine new bridges in the “greenfields” sections of the project; • Upgrading and/or construction of new road interchanges and intersections; and • Construction of associated structures (such as toll plazas, pedestrian overpasses and animal

underpasses). A detailed description of the project is provided in Chapter 4, Volume 1 (Main Report) of the Final Environmental Impact Report (EIR) for the N2 Wild Coast Toll Highway (dated December 2009).

1.2 RECORD OF DECISION On 19 April 2010 the Department of Environmental Affairs (DEA) issued a Record of Decision (ROD) for the project in terms of section 22 (3) of the Environment Conservation Act, 1989 (ECA; Act No. 73 of 19189) and Regulations 9 and 10 of the ECA Environmental Impact Assessment (EIA) Regulations – see Appendix A. The ROD authorised the Applicant, the South African National Roads Agency SOC Limited (SANRAL), to undertake the construction of the proposed N2 Wild Coast Toll Highway, subject to various conditions (which form part of the environmental authorisation) and a statutory appeal period of 30 days. Following the lodging of numerous appeals against the issuing of the environmental authorisation, the Minister of Water and Environmental Affairs issued an Appeal Decision on 25 July 2011 which dismissed the appeals and confirmed the ROD (environmental authorisation) issued by DEA on 19 April 2010.

1.3 OVERALL PURPOSE AND SCOPE OF THE EMP SANRAL is responsible for ensuring compliance with the conditions contained in the ROD. This includes any person acting on SANRAL’s behalf, including but not limited to, an agent, contractor, sub-contractor, employee, consultant or person rendering a service to SANRAL (ROD Item 6.1.3). In this regard, Item 6.2.1.2 of the ROD stipulates that all recommendations contained in the Final EIR and supporting documentation, which are not covered explicitly under the conditions contained in the ROD, must be regarded as conditions in terms of the ROD. Amongst others, SANRAL is required to submit a draft Environmental Management Programme (EMP) to DEA for approval.

1 It should be noted that the project has, in the interim, been identified by the South African Government as a Strategic Infrastructure Project (SIP), overseen by the Presidential Infrastructure Coordinating Committee (PICC). The current construction programme excludes the KwaZulu-Natal portion.



The EMP has to be compiled in terms of the requirements contained in the ROD and has to cover, amongst others, the following aspects (ROD Item 6.2.16.1): a) Rehabilitation of areas to be disturbed during the construction of the proposed project and associated

infrastructure; b) Siting and management of construction camps; c) Plant search and rescue before commencement of any construction-related activities; d) Waste avoidance and minimisation during construction; e) Management of traffic during the construction phase where the N2 and R61 crosses roads and other

transportation networks; f) Measures to reduce soil erosion; g) Measures aimed at controlling invasive plant species and weeds; h) An organogram illustrating the management structure for implementation of the EMP; and i) Roles and responsibilities of persons responsible for the implementation of the EMP. The ROD (Items 6.2.1.4 and 6.2.16.3 to 6.2.16.14) also stipulates the following: • The conditions of the ROD, the mitigation measures and recommendations contained in the Final EIR

and the final approved construction and operational EMPs and/or any other subsequent submitted approved documentation/Method Statements/plans, shall be legally binding components of any contract and must therefore be legally enforceable;

• SANRAL must use the draft EMP to develop final comprehensive site specific construction and operation EMPs;

• The final EMPs must at least have, but need not be limited to, the following headings: project phase; activity; environmental specification; and responsible person/s so that they are capable of being audited;

• The final construction and operational EMPs, and/or other required plans may be altered, where independent monitoring and auditing of the project show this to be beneficial. Any alterations to the final EMPs and other required plans shall be subject to approval by the relevant authorities;

• The Applicant must comply with the draft approved EMPs and any other subsequent approved documentation;

• The final EMPs and other required plans must be made available to I&APs upon request; • The final EMPs and other required plans must form part of all contractors’ and sub-contractors’

conditions of contract; • The final construction EMP must accommodate traditional issues and be sensitive to the fragmentation

of families and clans; • Before operation commences, an operational EMP, which includes a Maintenance Plan and an

Emergency Plan, must be developed and submitted to DEA for approval. The applicable conditions of the ROD, the mitigation measures and recommendations contained in the Final EIR and supporting documentation dated December 2009, the draft EMP and final construction EMP, and any other relevant subsequent submitted and approved documentation/Method Statements/plans must be incorporated within the operational EMP;

• The operational EMP must be updated and resubmitted to DEA annually or within an agreed specified period between the relevant parties;

• The operational EMP will be subject to audits during its development as well as during its implementation; and

• The Applicant must apply measures to ensure construction and maintenance crews take ownership of the environmental management relevant to their work as per recommendations in the EMP.

In compliance with the relevant conditions of the ROD, and in order to ensure a holistic approach to the management of environmental impacts, this EMP sets out applicable environmental specifications during the design, construction and operational phases of the N2 Wild Coast Toll Highway. The EMP thus outlines the environmental specifications which are required to be implemented and adhered to by the technical design, construction and operational teams. The EMP has as its basis relevant mitigation measures recommended



in the Final EIR (and associated specialist reports) and relevant conditions of the ROD. Where necessary, certain measures have been expanded upon or additional issues have been addressed in order to ensure that all environmental aspects are appropriately considered and monitored. It should be noted, however, that issues associated with aspects such as toll funding, health and safety, management of ribbon development and tourism management, amongst others, have been excluded from the EMP since they will be addressed in accordance with relevant legislation and/or are outside SANRAL’s jurisdiction and mandate. The EMP includes measures specified by the relevant heritage resources authorities in response to a supplementary archaeological survey (undertaken during 2011) and a revised Palaeontological Impact Assessment of the project (undertaken during 2012). The EMP is supplemented with relevant management measures arising from an updated Aquatic Impact Assessment (which included wetland delineation), undertaken during 2014, as specified in a Supplementary EMP for Aquatic Ecosystems (see Appendix B). The document also includes a Plant Search and Rescue Plan (see Appendix C) and an Alien and Invasive Species Management Plan (Appendix D). Furthermore, the EMP incorporates specific environmental management measures relating to the design, construction and operational phases of the new road sections, river crossings/bridges with associated haul and approach roads, and toll plazas. As such, this EMP is considered to also serve the purpose of the “site specific construction and operation EMPs” as envisaged in the ROD and is thus applicable to all separate contracts into which SANRAL may divide the project, as appropriate. Any further environmental conditions of permits or licences to be issued for the project should be viewed as being part of the EMP.

1.4 TERMS OF REFERENCE OF THE EMP The EMP has the following objectives: • To comply with the relevant conditions of the ROD issued on 19 April 2010, as well as applicable

legislative and regulatory requirements; • To identify the standards and relevant guidelines which are applicable in terms of environmental

legislation; • To specify the mitigation measures which are required to be implemented for all phases of the project in

order to prevent or minimise the extent of negative environmental impacts; • To specify enhancement measures which should be implemented in order to improve potential project

benefits and, where possible, to improve the condition of the environment; • To define corrective actions which must be taken in the event of non-compliance with the specifications

of this EMP; • Provide measures for ensuring that environmental monitoring and audits are undertaken to ensure

compliance with the EMP and the ROD; and • Provide criteria for notifying DEA of any non-compliance with the ROD/EMP.

1.5 STRUCTURE OF THE EMP This EMP includes the following: • Background information regarding the N2 Wild Coast Toll Highway and the EMP (Chapter 1); • The relevant environmental guidelines, legislation and standards (Chapter 2); • The requirements for the appropriate administration, management, monitoring and auditing of

environmental obligations (Chapter 3); • Environmental specifications applicable to the design phase of the project (Chapter 4); • Environmental specifications applicable to the construction and operational phases of the project

(Chapter 5); and • Conclusion and way forward (Chapter 6).



Figure 1.1: The N2 Wild Coast Toll Highway route between the Gonubie Interchange (Eastern Cape) and the Isipingo Interchange (KwaZulu-Natal)



Figure 1.2: Topography and land use between Ndwalane/Port St Johns and the Mthamvuna River, showing the two greenfields road sections



2. ENVIRONMENTAL LEGISLATION, POLICIES, PROGRAMMES AND STANDARDS

2.1 LEGISLATIVE FRAMEWORK It should be noted that obligations imposed by the ROD and EMP are legally binding in terms of environmental statutory legislation (i.e. NEMA). In this regard, ROD Item 6.1.16 stipulates that national government, provincial government, local authorities or committees appointed in terms of the conditions of the authorisation, or any other public authority or organisation, shall not be held responsible for any damages or losses suffered by SANRAL in any instance where construction or operation subsequent to construction is temporarily or permanently stopped for reasons of non-compliance with the conditions of approval as set out in the ROD or any other subsequent document emanating from the conditions of approval. 2.1.1 Statutory and Other Applicable Legislation and Policies ROD Item 6.1.1 indicates that authorisation was granted only in terms of Section 22 of the ECA and does not exempt SANRAL from compliance with any other legislation (albeit that the authorisation was also regarded as being an environmental authorisation issued in terms of NEMA and its regulations). ROD Items 6.1.4 and 6.2.2.1 state that the authorisation refers only to the activity as specified and described in the Final EIR dated December 2009. In this regard it should be noted, for example, that the development of borrow pits and quarries have not been approved as part of the ROD. Furthermore, the ROD indicates that the development is also subject to the approval by the relevant local authorities in terms of any applicable legislation administered by those authorities (Item 6.1.5). Also, DEA may add to, change and/or amend any of the conditions of the ROD in such lawful and fair manner if, in the opinion of DEA, the addition, change or amendment is environmentally justified (ROD Item 6.1.11). In the event that the predicted impacts exceed the significance as predicted in the Final EIR and supporting documentation, the authorisation may be withdrawn after the appropriate procedures have been followed (ROD Item 6.1.12). In the event of any dispute concerning the significance of a particular impact, the opinion of DEA in respect of its significance will prevail (ROD Item 6.1.13). SANRAL shall identify and comply with all South African national and provincial environmental legislation, including associated regulations and all local by-laws relevant to the project. Key national and provincial environmental legislation that is currently applicable to the design, construction and operational phases of the project must be compiled with. The list of applicable legislation and policies below is intended to serve as a guideline only and is not exhaustive: • Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983; CARA); • Constitution of South Africa Act, 1996 (Act No. 108 of 1996); • Environment Conservation Act, 1989 (Act No. 73 of 1989; ECA) (as amended); • Hazardous Substances Act, 1973 (Act No. 15 of 1973); • Health Act, 1977 (Act No. 63 of 1977); • Marine Living Resources Act, 1998 (Act No. 18 of 1998); • Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002; MPRDA) (as amended)

and its applicable Regulations (as amended); • National Environmental Management Act, 1998 (Act No. 107 of 1998; NEMA) (as amended); • National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004; NEM:AQA); • National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004; NEM:BA); • National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24 of 2008); • National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008; NEM:WA); • National Forests Act, 1998 (Act No. 84 of 1998; NFA);



• National Heritage Resources Act, 1999 (Act No. 25 of 1999; NHRA) and its Regulations (Government Notice No. R. 548 of 2 June 2000);

• National Water Act, 1998 (Act No. 36 of 1998; NWA) and its applicable Regulations; • Nature and Environmental Conservation Ordinance, 1974 (as amended); • Noise Control Regulations: ECA; • National Dust Control Regulations, 2013: NEM:AQA; • Alien and Invasive Species Regulations, 2014: NEM:BA; • Occupational Health and Safety Act, 1993 (Act No. 85 of 1993; OHSA); and • Policy Principles and Guidelines for Control of Development Affecting Natural Forests. 2.1.2 Approval/licence/authorisation/permit requirements In addition to the environmental authorisation issued on 19 April 2010 (refer to Section 1.3), the following additional approval/licence/authorisation/permit requirements would, amongst others, be relevant to the project: • Authorisation for any other listed activities (i.e. other than the activities authorised in the ROD - see

Appendix A) under NEMA and its EIA Regulations. In this regard, the ROD (Item 6.2.6.4) indicates that no site camps will be allowed outside the footprint of the development area as the establishment of such structures may trigger a listed activity as defined in the NEMA EIA Regulations;

• General Authorisation/Water Use Licences, as appropriate, from the Department of Water and Sanitation (DWS) for “water use” activities in terms of Section 21 of the NWA, specifically relating to the project activities associated with river/stream crossings, water abstraction exceeding levels prescribed by General Authorisations and encroachment on wetlands or riparian zones.

• Licences from DAFF to cut, destroy, prune, etc. a forest tree in terms of Section 7 of the NFA and also to cut, destroy, etc. any of the 47 protected tree species that may occur inside or outside forests in terms of Section 15 of the NFA. Application could be made for a blanket licence to cut forest and protected trees within the entire road reserve, or for sections of the proposed route;

• Approvals/permits from the South African Heritage Resources Agency (SAHRA) (and its relevant “units”) and the relevant provincial heritage authorities relating to heritage resources (such as burial grounds and graves, archaeological sites etc.);

• In terms of mining activities, the Minister responsible for mineral resources implements the provisions of the environmental legislation in this regard, including issuing of environmental authorisations for mining activities (e.g. borrow pits) in terms of NEMA. Authorisation from the relevant regional office of the Department of Mineral Resources (DMR) must thus be obtained for extraction of any construction materials;

• Atmospheric Emission Licences (AELs) from the relevant authorities for the operation of on-site asphalt plants in terms of the NEM:AQA;

• Permits from the Department of Agriculture, Forestry and Fisheries (DAFF) for the removal, relocation or pruning of any protected plants. The principles of search and rescue of species must be explored prior to removal;

• Permits from the relevant provincial conservation authorities to destroy or remove any protected indigenous plants listed in relevant Nature Conservation Ordinances/Decrees. The principles of search and rescue of species must be explored prior to destruction or removal;

• Health permits for hostels and sanitation (provincial health authorities); and • Blasting permits (obtained from DMR for borrow pits and quarries and from the Chief Inspector of

Explosives Unit (SAPS) for earthworks in road reserve). ROD item 6.2.1.3 stipulates that copies of all permits or licences issued that have relevance to the environment must be provided to DEA for record purposes.



2.2 ENVIRONMENTAL STANDARDS All applicable environmental standards contained within the environmental legislation shall be adhered to. These include, but are not necessarily limited to, the following: 2.2.1 National environmental management principles Section 2 of NEMA (as amended) sets out principles which apply to the actions of all organs of state that may significantly affect the environment. The following principles are, amongst others, of particular relevance to the proposed project: • Environmental management must place people and their needs at the forefront of its concern, and serve

their physical, psychological, developmental, cultural and social interests equitably; • Development must be socially, environmentally and economically sustainable; • Sustainable development requires the consideration of all relevant factors, including the following:

that the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied;

that pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied;

that the disturbance of landscapes and sites that constitute the nation’s cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied;

that waste is avoided, or where it cannot be altogether avoided, minimised and reused or recycled where possible and otherwise disposed of in a responsible manner;

that a risk-averse and cautions approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions; and

that negative impacts on the environment and on people’s environmental rights be anticipated and prevented, and where they cannot be altogether prevented, are minimised and remedied;

• The right of workers to refuse work that is harmful to human health or the environment and to be informed of dangers must be respected and protected;

• The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment;

• The vital role of women and youth in environmental management and development must be recognised and their full participation therein must be promoted; and

• Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

2.2.2 Duty of care and remediation of environmental damage Section 28 of NEMA (as amended) sets out provisions relating to the duty of care and remediation of environmental damage. Key provisions relevant to the project include, but are not limited to, the following: • Every person who causes, has caused or may cause significant pollution or degradation of the

environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing, or, in so far as such harm to the environment is authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of the environment;

• The measures required in terms of the above provision may include measures to: investigate, assess and evaluate the impact on the environment;



inform and educate employees about the environmental risks of their work and the manner in which their tasks must be performed in order to avoid causing significant pollution or degradation of the environment;

cease, modify or control any act, activity or process causing the pollution or degradation; contain or prevent the movement of pollutants or causant of degradation; eliminate any source of the pollution or degradation; or remedy the effects of the pollution or degradation;

2.2.3 Control of emergency incidents Key provisions relating to the control of emergency incidents include, but are not limited to, the following (refer to Section 30 of NEMA (as amended)): • The responsible person or, where the incident occurred in the course of that person’s employment, his or

her employer, must, as soon as reasonably practicable after knowledge of the incident: take all reasonable measures to contain and minimise the effects of the incident, including its effects

on the environment and any risks posed by the incident to the health, safety and property of persons; undertake clean-up procedures; remedy the effects of the incident; and assess the immediate and long-term effects of the incident on the environment and public health.

• The responsible person or, where the incident occurred in the course of that person’s employment, his or her employer, must, within 14 days of the incident, report to the Director-General, provincial head of department and municipality such information as is available to enable an initial evaluation of the incident.

2.2.4 Ambient air quality standards and guidelines As stated in ROD Item 6.2.6.1, asphalt plants are considered scheduled processes listed in the second schedule to the NEM:AQA. Asphalt (macadam) production is a listed activity (Subcategory 5.8) in terms of Government Notice No. 893 of 22 November 2013 (NEM:AQA - List of activities which result in atmospheric emissions which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage). New and existing plants are subject to different limits. The activities and resultant emissions from asphalt plants should not result in exceedances of the National Ambient Air Quality Standards (DEA, 2009: NEM:AQA – National Ambient Air Quality Standards, Government Notice No. 1210 of 24 December 2009). 2.2.5 National dust control regulations These regulations prescribe general measures for the control of dust in all areas. Any person who conducts any activity in such a way as to give rise to dust in quantities and concentrations that may exceed the above dustfall standard must, upon receipt of a notice from an air quality officer, implement a dustfall monitoring programme (and compile a dustfall monitoring report) as per the requirements of the regulations. Any person who has, based on the monitoring programme (and report), exceeded the above dustfall standard must, within three months after submission of the monitoring report, develop and submit a dust management plan to the air quality officer for approval. The contents of such a dust management plan are stipulated in Regulation 6(2) of the regulations and include, amongst others, the following – identification of all possible sources of dust within the affected site; detailing of the best practicable measures to be undertaken to mitigate dust emissions; and identifying the line management responsible for implementation.



2.2.6 Noise Control Regulations In terms of Schedule 3(d) of the national Noise Control Regulations: “No person shall build a road or change an existing road, or alter the speed limit on a road, if it shall in the opinion of the local authority concerned cause an increase in noise in or near residential areas, or office, church, hospital or educational buildings, unless noise control measures have been taken in consultation with the local authority concerned to ensure that the land in the vicinity of such road shall not be designated as a controlled area”. Therefore, if the predicted noise due to the proposed development is likely to cause the noise level on surrounding land to exceed 65 dBA, noise mitigation measures would need to be implemented to ensure that noise levels on affected land are reduced so as not to exceed 65 dBA. 2.2.7 Blasting Regulations and Standards Adherence to all relevant statutes and regulations that control the use of explosives should be ensured wherever blasting activity is required on the site (including quarries and/or borrow pits). According to Section 67 of the MPRDA Regulations of 23 April 2004, as amended, a holder of a right or permit in terms of the MPRDA must comply with the provisions of the Mine Health and Safety Act, 1996 (Act No. 29 of 1996), as amended, as well as other applicable law regarding blasting, vibration and shock management and control. 2.2.8 Taking of water from a water resource (abstraction of water) Notwithstanding the licence/permit requirements in terms of the NWA (refer to Section 2.1.2 above), Section 39 of the NWA establishes a procedure to permit the use of water by publishing General Authorisations in the Gazette. Government Notice No. 1191 of 8 October 1999 (as revised and amended by Government Notice No. 399 of 26 March 2004) replaced the need for a water user to apply for a licence in terms of the NWA for, amongst others, the taking of water from a water resource (Schedule 1) provided that the taking of water is within the limits and conditions set out in the authorisation (note, however, that certain areas are excluded from General Authorisation for the taking of surface water). According to Section 1.8 of Schedule 1 (of GN No. 399 of 26 March 2004), a person who uses water in terms of the authorisation must submit to the responsible authority a registration form or any other information requested in writing by the responsible authority for the registration of the water use before commencement of taking more than 50 cubic metres from surface water or 10 cubic metres from groundwater on any given day. Adherence to the stipulated conditions should be ensured. 2.2.9 Impeding or diverting the flow of water in a watercourse and altering the bed, banks,

course or characteristics of a watercourse Government Notice No. 1199 of 18 December 2009 replaced Government Notice No. 398 of 26 March 2004 in terms of authorising all or any category of persons to use water in respect of Sections 21(c) and (i) of the NWA, subject to the conditions set out in the Schedule thereto (note, however, that certain areas are excluded from General Authorisation for these water use activities). Adherence to the conditions stipulated in the Schedule should be ensured. 2.2.10 Control of alien vegetation Government Notice R1048 of 25 May 1984 (as amended by Government Notices R2687 of 6 December 1985 and R280 of 30 March 2001) deals with Regulations promulgated in terms of CARA. In addition to CARA, the Alien and Invasive Species Regulations, 2014 (A&IS) were published under Government Notice



R598 of 1 August 2014 (effective as from 1 October 2014) under NEMBA. Further to the Regulations, a list of alien and invasive species, the Alien and Invasive Species List, 2014, under Government Notice R590 of 1 August 2014 was published. The Regulations must thus be read together with the A&IS list. The main difference between NEMBA and CARA is that the latter is aimed at the preservation of natural agricultural resources with a view to ensure the maintenance of the production potential of land, which may be affected by weeds and invader plants. CARA only applies in respect of flora (invader plants and weeds), not fauna. NEMBA, on the other hand, is an environmental statute that has a wider scope of the preservation of natural ecological systems (both flora and fauna) of South Africa (within the principles and obligations of environmental and natural resources protection espoused by NEMA. Where there is conflict between CARA and NEMBA, the latter prevails. 2.2.11 Control of development affecting natural forests The DAFF has developed a set of Policy Principles and Guidelines for Control of Development Affecting Natural Forests (2008) to serve as the basis for decisions and comments made by forestry staff in all regions when dealing with development proposals, land use planning and EIAs affecting natural forests. The policy and guidelines aid the proper implementation of existing legislation, especially the NFA (as amended), which provides the strongest and most comprehensive legislation and mandate for the protection of all natural forests in South Africa. Developments affecting natural forests are also subject to a licence application. 2.2.12 NHRA Regulations Government Notice No. R548 of 2 June 2000 (promulgated in terms of section 25 of the NHRA) contain, amongst others, the following minimum qualifications and standards of practice with regard to permit applications for burial grounds and graves (Chapter IX): A permit will be issued only for exhumation or removal that is to be done: • Under the supervision of a qualified archaeologist or person approved by the relevant heritage

resources authority; • With due respect for any human remains and the customs and beliefs of any person or community

concerned with such grave or burial ground and, when requested, in the presence of such person or community representative; and

• After arrangements have been made for the re-interment of any human remains and the re-interment or curation of any other contents of such grave or burial ground, to the satisfaction of SAHRA or the relevant heritage resources authority, in accordance with Guidelines.



3. ADMINISTRATION, MANAGEMENT, MONITORING AND AUDITING OF ENVIRONMENTAL OBLIGATIONS

3.1 MANAGEMENT STRUCTURE The management structure for the implementation, monitoring and auditing of the environmental obligations of the EMP is presented in the organogram below. All official communication and reporting lines including instructions, directives and information shall be channelled according to the management structure.

3.2 ROLES AND RESPONSIBILITIES 3.2.1 Environmental authority (DEA) DEA is the designated authority responsible for approving this EMP and has overall responsibility for ensuring that the Applicant complies with the EMP and any conditions listed in the ROD. DEA shall also be responsible for approving any substantive amendments that may be required to the EMP and may also perform random site inspections to check compliance with the EMP. 3.2.2 Applicant (SANRAL) The Applicant, SANRAL, is ultimately responsible for the implementation of the EMP and the associated financial costs in this regard. SANRAL must ensure that any person acting on its behalf complies with the conditions/specifications contained in the EMP, as appropriate. SANRAL is also ultimately responsible for the appointment of all the required environmental management personnel. SANRAL shall address any site problems pertaining to the environment at the request of DEA, the Engineer, Project Environmental Manager (PEM) and/or Environmental Control Officer (ECO). The ECO shall be appointed at least one month prior to the commencement of any specific construction contract. The name

Applicant SANRAL

Engineer Contractor

Site Environmental Control Officer

Environmental Control Officer (s)

Authority DEA

Project Environmental Manager

Authorities Coordination Committee

Environmental Monitoring Committee

Environmental Auditor

ROD and EMP



and contact details of the ECO must be announced and forwarded to DEA before construction commences (ROD Item 6.2.3.7). The ECO shall remain employed until all rehabilitation measures, as required for implementation due to construction damage, are completed. 3.2.3 Engineer The Engineer shall oversee the planning, design and construction phases of the project. The Engineer shall assign a Resident Engineer (RE) to act as on-site implementing agent. The RE shall ensure that the Engineer’s responsibilities are executed in compliance with the EMP. Any on-site decisions regarding environmental management are ultimately the responsibility of the RE. The RE shall assist the PEM and/or ECO where necessary and shall have the following responsibilities in terms of the implementation of this EMP: • Reviewing and approving the Contractor’s Method Statements with input from the PEM and/or ECO

where necessary; • Taking action if specifications are not followed; • Keeping a photographic record of construction activities on site; • Assisting the Contractor in finding environmentally responsible solutions to problems with input from the

PEM and/or ECO where necessary; • Ordering the removal of person(s) and/or equipment not complying with the EMP specifications; • Issuing spot fines, where deemed appropriate, for transgressions of site rules of the EMP; • Delaying any construction activity if he/she believes the environment has been or is likely to be seriously

harmed/impacted; • Providing input into the PEM’s and ECO's ongoing internal review of the EMP; and • Communicating environmental issues to the Contractor. The Engineer shall address any site problems pertaining to the environment at the request of the PEM and/or ECO. The Engineer shall also be responsible for ensuring that any contraventions of the EMP are addressed in the most appropriate manner. 3.2.4 Contractor The Contractor shall have the following responsibilities in terms of the EMP: • Implement all applicable provisions of the EMP. If the Contractor encounters difficulties with

specifications, he/she must discuss alternative approaches with the RE, PEM and/or ECO prior to proceeding;

• Ensure that all staff and sub-contractors are familiar with the provisions of the EMP; • Make personnel aware of environmental issues and to ensure they show adequate consideration of the

environmental aspects of the project; • Prepare and/or update the required Method Statements; • Report any incidents of non-compliance with the EMP to the RE, PEM and/or ECO; and • Rehabilitate any sensitive environments damaged due to the Contractor’s negligence. This shall be

done in accordance with the RE’s, PEM’s and ECO’s specifications. Failure to comply with the EMP may result in fines and reported non-compliance may result in the suspension of work or termination of the contract by the Engineer. Compliance with the relevant provisions contained herein or any relevant conditions imposed by the ROD and any additional environmental approvals/licences/permits for the project shall become the responsibility of the Contractor through a suitably qualified and experienced Site Environmental Control Officer (SECO). The



appointment of the SECO shall be subject to the approval of SANRAL. Furthermore, ROD Item 6.2.5 also requires that a representative of the Contractor should serve on the Environmental Monitoring Committee (EMC). 3.2.5 Project Environmental Manager (PEM) ROD Item 6.2.3.8 stipulates that the Applicant must appoint a PEM for the planning and construction phases of the project. The PEM must be an independent consultant and must be permanently on the site to support and assist the ECOs during the period of construction. The qualifications and terms of reference of the PEM shall include the following: • Have a tertiary qualification in the natural sciences and a proven track record in environmental contract

management on large projects. Assist the ECOs to formulate the most effective and structured monitoring and reporting strategy, tailored to the conditions of the contract;

• With the ECOs, review the Method Statements prepared, in terms of compliance with the final construction EMP, and ensure that these are sufficient to meet the outcomes that are required;

• Assist the ECOs to prepare the monthly monitoring reports; • Report to and discuss with the relevant authorities any significant non-compliance and the steps to be

taken to rectify this; • Interact with and provide all necessary assistance to the environmental auditor to complete the tasks

required for the quarterly independent audits; and • Serve as secretariat of the ACC. The PEM shall thus oversee the overall implementation of the EMP in accordance with the requirements of the ROD and shall: • Be responsible for the further development and finalisation of this EMP in consultation with SANRAL; • Be responsible for the overall implementation of the EMP in accordance with the requirements of DEA; • Ensure that adequate and competent environmental staff is on site at any construction activity during

construction works; • Ensure that all third parties who carry out all or part of SANRAL’s obligations comply with the

requirements of the EMP; • Ensure that any further environmental approvals/licences/permits required for the design, construction

and operation of the proposed N2 Wild Coast Toll Highway are obtained, as appropriate; • Be responsible for submitting the required written notices to DEA and the relevant provincial

environmental departments, as per the relevant conditions of the ROD, and • Submit a compliance report to DEA (per completed section of the highway) six months after the final

Taking Over Certificate and a final compliance report 18 months after the Final Completion Certificate has been issued. The compliance must indicate the date on which the construction was completed and detail compliance with the conditions of the ROD and status of the rehabilitation programme.

3.2.6 Environmental Control Officer SANRAL shall appoint a suitably qualified ECO for the construction phase of any specific construction contract and, where required, for relevant operational/expansion works thereafter. The terms of reference of the ECO must comply with the requirements of the EMP and any subsequent amendments approved by DEA (ROD Item 6.2.3.7). The roles and duties of the ECO shall include, inter alia, the following: • Helping individual employees to meet their immediate responsibility for environmental management

within his or her area of work, albeit that managers and supervisors of line functions are ultimately responsible for environmental management, not the ECO who is an adviser, coordinator, facilitator and guide (ROD Item 6.2.3.5);



• Oversee and monitor adherence to and implementation of the final construction EMP, Method Statements and other required plans as well as compliance with the relevant conditions contained in the ROD and the mitigation measures, recommendations and conditions stipulated in the Final EIR and its supporting documentation dated December 2009 (ROD Item 6.2.3.5);

• Report to the PEM, the Environmental Monitoring Committee (EMC) and the ACC on a regular basis as decided by these parties in the form of an Environmental Management Compliance Report (EMCP) (ROD Item 6.2.3.5);

• Advising the Contractor and/or the RE on environmental issues within defined construction areas; • Undertaking regular site visits to ensure compliance with the EMP and verifying that environmental

impacts are avoided or kept to a minimum throughout the contract; • Completing environmental checklists during site visits; • Keeping a photographic record of progress on site from an environmental perspective; • Assisting the Contractor and/or the RE in finding environmentally acceptable solutions to construction

problems; • Recommending additional environmental protection measures should this be necessary; • Giving a report back on any environmental issues at site meetings; • Reporting any incidents that may or have caused damage to the environment or breaches of the EMP;

and • Prepare an environmental audit report at the conclusion of the construction phase. The ECO shall communicate directly with the RE and PEM. Should problems arise on site that cannot be resolved between the ECO, RE and PEM, the ECO shall take the matter up with SANRAL. If SANRAL does not respond the ECO shall take the matter up with DEA. 3.2.7 Site Environmental Control Officer (SECO) Each Contractor that carries out any construction activities for SANRAL shall be required to dedicate a suitably qualified environmental officer (SECO), who shall be the responsible person for the implementation of the environmental provisions of the specific construction contract. The SECO’s duties shall include, inter alia, the following: • Monitoring and verifying that the EMP and Method Statements are adhered to at all times and taking

action if specifications are not followed; • Conducting environmental awareness training and helping individual employees to meet their immediate

responsibility for environmental management within his or her area of work, albeit that managers and supervisors of line functions are ultimately responsible for environmental management;

• Monitoring and verifying that environmental impacts are avoided or kept to a minimum; • Assisting the Contractor, RE, PEM and ECO in finding environmentally responsible solutions to

problems; • Inspecting the site on a daily basis with regard to compliance with the EMP; • Keeping accurate and detailed records of these inspections; • Ensuring that the following are maintained on site:

A daily site diary; A non-conformance register; A public complaints register; and A register of audits

• Reporting any non-compliances with the EMP to the RE, PEM and ECO; • Keeping a register of complaints on site and recording community comments and issues, and the

actions taken in response to these complaints; and • Record and communicate environmental incidents (as they occur) to the RE, PEM and ECO and

maintain records thereof.



3.2.8 Environmental Auditor SANRAL shall appoint a suitably qualified, independent Environmental Auditor to audit the construction activities in terms of the relevant EMP provisions. The auditor must be an independent consultant registered with a recognised agency. The auditor’s duties shall include, inter alia, the following: • Audit compliance to the EMP and other specifications as follows:

At the end of the design phase to verify compliance with the EMP (including ROD) requirements, as appropriate; On a quarterly basis during the construction phase. The quarterly audit reports must be distributed to DEA, the relevant provincial environmental departments, the ACC and the EMC. The audit reports must be available to I&APs on request (ROD item 6.2.3.9); At the completion of the construction phase (post construction). The audit report must be submitted to DEA, the relevant authorities and the ACC within 30 days after completion of the said audit. The audit must, as a minimum, evaluate adherence to the relevant conditions contained in the ROD and other provisions. The audit must indicate any evidence of accelerated erosion or infestation by alien invasive plant species caused by construction, the severity of these problems and how they should be managed (ROD Item 6.2.3.11); and On an annual basis after completion of the construction phase. If the audits show no significant problems, they may be discontinued at the discretion of DEA, or may be limited to the specific areas and/or timeframes where problems require ongoing monitoring and action by SANRAL (ROD item 6.2.3.12).

3.2.9 Authorities Coordination Committee (ACC) ROD Item 6.2.4.1 stipulates that SANRAL shall convene an ACC quarterly or as agreed upon with DEA during the planning and construction phase of the project and shall in addition to representation from the ECOs, invite representation from the following authorities: • DEA; • KwaZulu-Natal Department of Agriculture and Environmental Affairs (DAEA); • Eastern Cape Department of Economic Development and Environmental Affairs (DEDEA); • DWS; • DAFF; • DMR; • Ezemvelo KZN Wildlife; • Eastern Cape Parks and Tourism Authority (ECPTA); • South African National Parks (SANParks); • Relevant local authorities; and • SAHRA. This committee (with the PEM fulfilling the role of secretariat) shall serve as a forum for the discussion and coordination of project-related issues and for timeous dissemination of information about progress on the project to the key authorities. The composition of the committee may be changed if circumstances justify it. Regarding the latter, and in light of the current project programme excluding the KwaZulu-Natal portion, it is anticipated that no representation from KwaZulu-Natal authorities listed above (as stipulated in the ROD) would be required on the ACC. Independent specialist consultants must be called upon when, in the opinion of the PEM, auditor, ACC or DEA, there is a need for expert opinion during the monitoring of the construction and operation phases (ROD Item 6.2.3.10).



3.2.10 Environmental Monitoring Committee (EMC) SANRAL shall establish an EMC for the duration of the construction phase. The ROD (Item 6.2.5) specifies the following in terms of the functioning of the EMC: • The EMC must meet on a quarterly basis or as decided by the members of the EMC; • The EMC must be chaired by an independent chairperson appointed by the EMC and must consist of

representatives of the key authorities (i.e. DEA, relevant provincial environmental authorities, DWS and relevant local municipalities etc.), the ECO(s), a representative of the Tribal Authorities and the main contractor;

• SANRAL must supply the secretariat services for the EMC; • The EMC must report to the Director: Environmental Impact Management at DEA from the start of the

project until completion of the construction phase; and • All costs associated with the functioning of the EMC and secretariat services shall be borne by SANRAL. The purpose of the EMC would be to execute the following: • To monitor and audit the project compliance with specific conditions of the environmental authorisation

and the requirements of the approved EMP; • To make recommendations to the Director at DEA on issues related to the monitoring and auditing of the

project implementation; and • To advise DEA on issues related to non-conformance reports raised against SANRAL by the ECO(s). 3.2.11 Specialist environmental service provider (s) Specialist input may be required from time to time during the construction and operational phases of the project.

3.3 REPORTING AND RECORD-KEEPING 3.3.1 Administration A list of environmental reports and/or documents related to the EMP which have been, and are likely to be, generated during the planning and implementation of the project is set out below for reference purposes: • The Final EIR for the N2 Wild Coast Toll Highway and associated ROD (as well as Minister’s Decision

on Appeals); • Supplementary Archaeological Survey Report, Palaeontological Impact Assessment Report; • Updated Aquatic Impact Assessment Report; • Final EMP; • All communications detailing changes of design/scope that may have environmental implications; • Weekly and monthly site monitoring reports; • Complaints register; • Training records, including attendance registers; • Incident and accident reports; • Emergency preparedness and response plans; • Permits and legal documents; • Monthly site meeting minutes during construction; • Method Statements for river crossings; • The ROD and all subsequent environmental authorisations, as appropriate; and • Audit reports.



3.3.2 Method Statements The ROD stipulates the following regarding Method Statements: • The Applicant must prepare and submit detailed Method Statements, which are required to be

implemented in order to meet the required environmental specifications (Item 6.2.17.1) – see Appendix B for relevant Method Statements in relation to aquatic ecosystems;

• The Applicant shall ensure that all the Method Statements are reviewed by the PEM and the ECO prior to submission for approval (Item 6.2.17.2);

• The Applicant must submit all Method Statements to DEA and/or other relevant authorities for approval prior to the activity taking place (Item 6.2.17.3); and

• The development and implementation of Method Statements must be contractually binding (Item 6.2.17.4).

Relevant Method Statements are included in Appendices B. Any additional Method Statements which may be required will be approved by the Engineer, with input from the PEM and ECO. 3.3.3 Document Control SANRAL shall also ensure that documents related to the EMP are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the EMP are performed. All documents shall be made available to the external auditor or authorities within seven days of request. The ROD stipulates the following in this regard: • A copy of the authorisation, the Final EIR dated December 2009 and the approved Final EMP must be

available at the project site offices during construction and all staff, contractors and sub-contractors must be familiar with or be made aware of the contents of the authorisation (Item 6.1.11); and

• Compliance/non-compliance records must be kept and must be made available on request from the authorities (Item 6.1.12).

3.3.4 Notification to relevant environmental authorities Written notices should be submitted to DEA and the relevant provincial environmental departments in the following instances, as per the stipulations of the ROD: • Two weeks’ written notice must be given before the commencement of construction activities. The

notice shall make clear reference to the site location details and DEA reference number. The notice must also contain proof of compliance with the conditions of the ROD as appropriate (Item 6.1.6);

• Two weeks’ written notice must be given before the commencement of the operation of the road. The notice shall make clear reference to the site location details and DEA reference number. The notice must also contain proof of compliance with the conditions of the ROD as appropriate (Item 6.1.7);

• Within 24 hours thereof, if any condition of the authorisation is not complied with (Item 6.1.10); • Within 30 days thereof, of any change of ownership and/or project developer. Conditions imposed in the

ROD must be made known to the new owner and/or developer and are binding on the new owner and/or developer (Item 6.1.14);

• Of any change of address of SANRAL (Item 6.1.15);



• Copies of all permits or licences issued to SANRAL that have relevance to the environment must be provided to DEA for record purposes. The relevant environmental conditions of these permits or licences must be incorporated into the final EMP (Item 6.2.1.3); and

• The names and contact details of the ECOs must be announced and forwarded to DEA before construction commences (Item 6.2.3.7).

3.4 ENVIRONMENTAL TRAINING AND AWARENESS Construction personnel shall be adequately trained with regard to the implementation of the EMP, as well as regarding environmental legal requirements and obligations. All construction personnel shall attend an induction course presentation on environmental awareness. Where possible, presentations need to be conducted in the language of the employees. The environmental training should, as a minimum, include the following: • The importance of conformance with all environmental requirements; • The significant environmental impacts, actual or potential, as a result of work activities; • The environmental benefits of improved personal performance; • Roles and responsibilities in achieving conformance with the environmental policy and procedures,

including emergency preparedness and response requirements; • The potential consequences of departure from specified operating procedures; • The mitigation measures required to be implemented when carrying out their work activities; • The importance of not littering; • The need to use water sparingly; • Details of, and encouragement to, prevention or minimisation of the production of waste and re-use,

recover and recycle waste where possible; • Details regarding archaeological and/or historical sites which may be unearthed during construction, and

the procedures to be followed should these be encountered; • The procedures which should be followed should a grave be encountered or unearthed during the

construction phase; • Details regarding “no-go” and sensitive areas, flora and fauna of special concern (including

protected/endangered plant/tree and animal species), and the procedures to be followed should these be encountered during the construction phase. A qualified botanist should compile a simple plant identification manual that illustrates the differences between indigenous and invasive plant species; and

• Details of responsible persons and responses to be undertaken for emergencies and/or incidents. Environmental awareness training programmes should be targeted at three distinct levels of employment, i.e. the executive, middle management and labour. Environmental awareness training programmes should contain the following information: • The names, positions and responsibilities of personnel to be trained; • The framework for appropriate training plans; • The summarised content of each training course; and • A schedule for the presentation of the training courses. The Contractor shall ensure that records of all training interventions are kept as set out in this EMP. The training records shall verify each of the targeted personnel’s training experience.



3.5 PERFORMANCE INDICATORS AND TARGETS ROD Item 6.1.8 stipulates that the applicable conditions of the ROD must form part of all contractors’ and sub-contractors’ conditions of contract. A performance-based requirement with regard to environmental impact management must be included in all contracts related to any aspect of the environmental authorisation. SANRAL must carry out regular environmental audits to establish compliance with the conditions of the authorisation and contracts. In the event of non-conformance, SANRAL must institute an appropriate penalty based on a “penalty system” developed by SANRAL and included as an annexure in the contract (ROD Item 6.1.8). The Contractor is deemed not to have conformed to the provisions of the EMP if: • There is evidence of contravention of the EMP specifications within the boundaries of the construction

site, site extensions and haul/access roads; • There is contravention of the EMP specifications which relate to activities outside the boundaries of the

construction sites; • Environmental damage occurs due to negligence; • Construction activities take place outside the defined boundaries of the site; • The Contractor fails to comply with corrective or other instructions issued by the RE within a specific time

period; and/or • There is a complaint from the local environmental authority with respect to non-conformance that has not

been adequately addressed after a valid instruction from the RE to rectify the complaint. The Contractor shall timeously notify SANRAL, the Engineer, PEM and/or ECO of the details of any non-conformance and the measures taken to rectify the situation. The Engineer shall, prior to the effective date, submit to SANRAL, PEM and/or ECO a penalty system in order to effectively manage non-conformance with the EMP. The penalty system should include withholding of payment to the Contractor should repeated environmental damage be caused by non-adherence to the EMP. It should also provide for the Engineer to have the power to remove from site any person who is in contravention of the EMP. SANRAL may impose fines for any of the transgressions – proposed fines are presented in Appendix E. These transgressions, along with the appropriate guidelines to determine the fines, shall be agreed to by SANRAL with input from the Engineer, PEM and/or ECO. Such fines will be issued in addition to any remedial costs incurred as a result of non-conformance as confirmed by the Engineer, PEM or environmental auditor. It should be noted, however, ROD Item 7.9 recommends that SANRAL must not simply consider fines and penalties as means of enforcing environmental compliance, but think creatively in terms of incentives and rewards for good housekeeping and continual improvement in environmental management. Thus, consideration should be given to the development and implementation of a suitable system of “awards” to serve as recognition of meritorious environmental practice by the Contractor.

3.6 EMERGENCY PREPAREDNESS SANRAL shall ensure compliance with the emergency preparedness and incident and accident-reporting requirements, as required by the Occupational Health and Safety Act, 1993 (Act No. 85 of 1993), NEMA, the National Water Act, 1998 (Act No. 36 of 1998) and the National Veld and Forest Fire Act, 1998 (Act No. 101 of 1998), as amended, and/or any other relevant legislation.



If a reportable incident occurs as a result of construction activities, the local emergency services must be immediately notified of the incident. The PEM and ECO shall define a “reportable incident”, on the basis of the quantity (more than 50 l) and hazard rating of the material, and the sensitivity of the spill site. The following information must be provided: • The location; • The nature and quantity of the load; and • The status at the site of the accident itself (i.e. whether further leakage is still taking place, whether the

vehicle or the load is on fire). Written records must be kept on the corrective and remedial measures decided upon and the progress achieved therewith over time. Such progress reporting is important for monitoring and auditing purposes. The written reports may be used for training purposes in an effort to prevent similar future occurrences.

3.7 PUBLIC COMMUNICATION AND LIAISON WITH INTERESTED AND AFFECTED PARTIES

SANRAL shall establish a process to engage in an ongoing manner with relevant stakeholders. The process shall provide an opportunity for I&APs to submit comments, identify issues and express concerns regarding the implementation of the project. The ROD stipulates the following with regard to cooperation, communication and information: • The Applicant must submit a detailed Communication Strategy/Plan, after input was obtained from the ACC

and the EMC, to DEA for approval prior to completion of final design. Such a plan must clearly indicate, amongst others, the mechanisms that will be used to involve local government, community forums, affected parties and interested parties and the mechanisms that will be used to facilitate two-way communication between the Applicant and the above parties regarding project progress, environmental performance, adherence to conditions of the ROD and risk communication and management where applicable (Item 6.2.18.1); and

• I&APs must be given further opportunities to comment on any additional environmental issues identified during the lifetime of the project. Public consultation must be undertaken on an ongoing basis in order to inform final design – especially concerning details of accesses, under- and overpasses, service roads, fences and barriers and other safety measures, to ensure that complaints and concerns can be addressed during construction and operation of the road (Item 6.2.18.2).

3.7.1 Information Distribution Copies of the EMP shall be made available to all members of the EMC, the Contractor and on the SANRAL website. Other copies shall be distributed to all senior contract personnel. All senior personnel on the construction site will be required to familiarise themselves with the contents of the document. The final EMPs and other required plans must be made available to I&APs upon request. Also, SANRAL must apply measures to ensure construction and maintenance crews take ownership of the environmental management relevant to their work as per recommendations in the EMP. SANRAL shall ensure that information is provided to, and received from, I&APs in an ongoing manner, as per the requirements of its Communication Plan.



3.7.2 Construction Information Boards The Contractor shall be responsible for erecting information boards on site. The information board will essentially be to advise the public of the construction activity and the prohibition of entering certain areas. The information boards shall also provide the name and contact number of the Contractor’s responsible person, to ensure that the public has ready access to the Contractor to ask for information and/or to lodge any complaints. 3.7.3 Complaints Register ROD Item 6.2.18.3 stipulates that a protocol for the management of complaints must be developed and included in the EMP. Any complaint from the public during the construction phase must be attended to as soon as possible. SANRAL shall ensure that a complaints register is established and maintained during the construction and operation of the project, together with any necessary actions taken to address issues raised. The register shall contain the contact details of the person who made the complaint and information regarding the complaint itself, including the date of submission. The register shall be produced upon request.



4. ENVIRONMENTAL SPECIFICATIONS: DESIGN

4.1 INTRODUCTION This chapter of the EMP sets out environmental specifications which are required to be implemented during the design phase of the project. Key mitigation measures relevant to the design of the relevant project components, as per the findings and recommendations of the Final EIR for the project and the ROD, are incorporated as appropriate.

4.2 ENVIRONMENTAL MANAGEMENT MEASURES - DESIGN The environmental management measures applicable to the design of the project are presented in Table 4.1 overleaf. In order to facilitate monitoring and auditing, the table has been structured to indicate the aspect (or impact) to be addressed, the environmental management measure to be implemented and the parties responsible for implementation. The following aspects are addressed: • Biodiversity Offset Agreement • Earthworks and layerworks • Ecological impact management • Drainage • Heritage impact management • Erosion control • Social impact management • Cut and fill slopes • Noise impact management • Pollution prevention and control • Air Quality impact management • Access requirements • Visual impact and lighting management • Safety and security • Planning/development impact management • Tourism management • Site camps and site layout plans • Road layout plans and design • Access/haul roads The list of requirements may include measures which already form part of SANRAL’s standard road design guidelines.



Table 4.1: Environmental specifications applicable to the design phase of the project, with identification of responsible party (-ies), as appropriate

ACTIVITY MANAGEMENT MEASURE RESPONSIBLE

PARTY (-IES) PROJECT

PHASE

1. BIODIVERSITY OFFSET AGREEMENT General • In compliance with ROD Items 6.2.7.1 and 6.2.7.2, a compliant Biodiversity

Offset Agreement has been duly completed by SANRAL during March 2016. SANRAL should ensure that the requirements of the Biodiversity Offset Agreement are implemented effectively and adequately monitored

SANRAL Design

Plant Search and Rescue in greenfields sections

• In compliance with ROD Item 6.2.7.2, SANRAL has duly appointed a botanist to compile a Search & Rescue Plan which is appended to this EMP as Appendix C. Compliance with the requirements of the Search & Rescue Plan should be ensured and adequately monitored

SANRAL

2. ECOLOGICAL IMPACT MANAGEMENT Areas of specific importance

• The ecological sensitivity of habitats along the road alignment is shown in Figures 4.1 and 4.2. Highly sensitive areas include the approaches to the Msikaba, Mthentu, Mnyameni, Mpahlane and Mzamba rivers

SANRAL; Engineer

Design; Construction

• Identified no-go areas include the following: Rocky outcrops – in particular those on the south and north sides of the

Msikaba and Mthentu river gorges, as well as the Mnyameni and Mzamba rivers, which have high conservation status and contain a large number of Species of Special Concern

Forests (gorges and margins) – these tend to occur on the south and north sides of the Msikaba, Mthentu, Mnyameni, Mpahlane and Mzamba river gorges

Wetlands – special care should be taken to avoid damage to palustrine seepage wetlands occurring along the route, where possible

Protea savanna – an emerging protea savannah/scrub vegetation type occurs at both the south and north sites of the Mthentu River bridge. Damage to this vegetation must be limited to the pier sites, while no-go areas should be designated between them. In particular, work areas for piers 8 and 9 of the Mthentu River bridge should not exceed the designated footprint. The boundaries of the footprint shall be fenced and no access to areas beyond this boundary should be permitted

• The following restrictions shall apply in all areas identified as being of high ecological sensitive: Restrict construction activities within the designated road reserve (width

of construction corridor to be finalised during final detailed design, but to be as narrow as possible)

Site-specific ecological appraisals should be undertaken prior to any work commencing in areas of high ecological sensitivity, as required, in order to demarcate no-go areas

No spoil areas shall be located in identified no-go areas No construction camps shall be established in the identified no-go areas Limited construction activities (including new haul roads) shall only be

permitted outside the road reserve after approval by the Engineer, and only if deemed of critical importance

No sensitive vegetation shall be removed unless in accordance with the Plant Search & Rescue Plan – Appendix C)

No damage to forest patches shall take place as far as possible Ecological impact management

• In compliance with ROD Item 6.2.7.2, an Alien Invasive Control Programme has been compiled – see Appendix D. Compliance with the requirements of the Programme should be ensured and adequately monitored

SANRAL




ACTIVITY MANAGEMENT MEASURE RESPONSIBLE PARTY (-IES)

PROJECT PHASE

• Sensitive ecological areas adjacent to the approved road alignment should be regarded as “no-go” areas unless approved by the Engineer

• Stockpiles, site offices and other required infrastructure should be located appropriately in order to limit damage to sensitive areas

• Search and rescue of any valuable taxa (protected, threatened, endemic, medicinal etc.) should be undertaken within the construction footprint, where appropriate. The relocation of plant species must be fully addressed in the final construction EMP in respect of responsibility (ROD Item 6.2.12.2) Note: The Plant Search & Rescue Plan (Appendix C) provides the required details in this regard

• ROD Item 6.2.12.3 stipulates that “all rare, endangered and endemic species and species of conservation value in the road reserve must be translocated, in close co-operation with the National Botanical Institute (NBI), to a suitable nursery with the aim to be re-established in a national botanical garden that is to be created in the Pondoland Centre of Endemism or a suitable existing conservation area”. Note: This condition has been taken into account in the compilation of the Plant Search & Rescue Plan (see Appendix C)

• Obtain all necessary permits prior to construction (e.g. for removal of protected species)

• Ensure that vegetation clearing is minimised and restricted to the area required for road construction purposes only

• Ensure that indigenous species are retained, where possible, along the alignment

• Ensure cleared indigenous vegetation is chopped and mulched for use in revegetation

• Ensure that Contractors are made aware of the environmental issues and associated risks prior to commencement of construction

• Design and implement erosion and sedimentation control measures in order to protect habitats. For example, consider drainage of road runoff through grassy channels as an erosion and sedimentation control measure

Fauna • Avoid disturbances to the breeding colonies of the Cape Griffon Vulture (refer to Figure 1.2) - air and road traffic should observe the maximum possible exclusion zone around the Msikaba colony. Collaborate with the Vulture Study Group regarding any additional mitigation, monitoring and management requirements which may be required

SANRAL; Engineer; PEM; ECO


• Rest stops and associated structures should not be placed adjacent to forests due to the increased fire risks and should be kept free from broken bottles, cigarettes etc.

• Underpasses should be large enough to allow maintenance of water flow and soil dynamics, and to serve as migratory paths for small animals

• Road kills, which can attract vultures, must be prevented by proper fencing. Measures must be developed and implemented to ensure that road kills do not occur and if they occur, that proper management measures are in place to address the potential negative impacts (ROD Item 6.2.13.1)

• Steps must be taken in conjunction with conservation authorities to protect or translocate any animal populations encountered during project implementation




PROJECT PHASE

Aquatic ecosystems

• In compliance with ROD Item 6.2.7.2, all wetlands in the greenfields sections have been delineated (as part of the updated Aquatic Impact Assessment - refer to Section 1.3) by a suitably qualified wetland specialist, and specific mitigation measures for each wetland class have been compiled. Relevant mitigation measures (specifications) are included in the Supplementary EMP for Aquatic Ecosystems (Appendix B) and should be implemented, as appropriate to the construction phase of the project

SANRAL; Engineer; Contractor; PEM; ECO


• Clearing of vegetation should be scheduled for the drier winter months and limited to areas immediately needed for construction

• Where wetlands cannot be avoided, any loss of wetland structure and functioning must be compensated. Note: The above-mentioned Biodiversity Offset Agreement includes any offset requirements associated with potential impacts on aquatic ecosystems

• Ensure that no flows are altered, i.e. flows are not diverted or impounded by the physical structure of the road

• Bridges should, if at all possible, span the entire width of the channel and floodplain so as to avoid disturbance to the riparian zones of rivers. Pillars, columns or bridge buttresses should not be placed in instream or riparian zones, if at all possible. The number and width of pillars, vertical columns and buttresses placed within the river channel and floodplain should be minimised

• Adequate drainage must be included in the road design so as to ensure effective drainage of wetland areas

• Sensitive areas, where the possibility of impact is high, should be monitored before and after construction so as to detect changes in the present state of aquatic biota, as appropriate (see Appendix B for further requirements in this regard)

• The design and construction of a surface stormwater drainage system must be done in a manner that would protect the quality and quantity of the downstream system. The use of swales, which could then be grassed for the operational phase, is recommended as the swales would attenuate runoff water (ensure that water released off-site is off a better quality)

• Toll plazas must be designed with oil traps to prevent any contamination of downstream areas

• All necessary measures in line with DWS procedures and requirements must be implemented where deeply incised gorges and any watercourses (i.e. streams, rivers etc.) will be crossed (ROD Item 6.2.11.5)

3. HERITAGE IMPACT MANAGEMENT Supplementary archaeological inspection

• In compliance with ROD Item 6.2.14.1, SANRAL appointed a heritage practitioner to undertake a supplementary inspection of limited sections of the approved alignment, in different terrain types, with the objective of determining areas identified as sensitive in terms of the discovery of any heritage resources”. The resultant report (dated December 2012) was subsequently submitted to SAHRA and the Eastern Cape Provincial Heritage Resources Authority (ECPHRA) for consideration. Relevant heritage impact management requirements stipulated by the ECPHRA and SAHRA have been incorporated into this EMP, as appropriate

SANRAL; Engineer





PROJECT PHASE

Heritage impact management

• The farmhouse (Retreat) recorded along the route alignment between the Ndwalane Interchange and the proposed Mzimvubu River Bridge may be older than 60 years, at least in its original core, along with a few other homesteads. If they are older than 60 years, SANRAL will need to apply for a permit under Section 34 of the NHRA before any alterations are undertaken. The age of other industrial buildings in close proximity to Retreat must also be ascertained before demolition may occur

SANRAL; Engineer; Contractor


• It is advised that all graves older than 60 years identified within the road reserve or in close proximity (10 m) of the road reserve are avoided and re-routing be considered as an option. If this option proves unworkable, grave relocation may be considered as a last resort. Before relocation of burials may occur, a permit issued under Section 36 of the NHRA must be received from the ECPHRA. The compulsory 60-day public participation process will also need to be followed

• Since dense vegetation occurs between the Ndwalane and Ntafufu interchanges, these could not be inspected by the archaeologist – thus, an ECO, trained by an archaeologist, must be present on site during all vegetation clearing activities in this section

Palaeontology / SAHRA requirements (as per “Decision” dated 19 July 2012)

• As per SAHRA requirements, a palaeontologist was appointed to update the original palaeontological study and to investigate whether monitoring etc. may be needed during construction for any road cuttings that were either highlighted as sensitive in the original specialist report or not assessed in that report – relevant requirements in this regard have been included in this EMP. According to the palaeontologist, it was deemed inappropriate to undertake a survey of the greenfields sections before commencement of construction due to their extreme inaccessibility as well as minimum current outcrop – rather, it was deemed that it would be far more productive to survey these areas during the late construction phase as the road works were likely to produce much more outcrop

SANRAL; Engineer


• A Phase 2 palaeontological impact assessment must be undertaken for the shale layers in the Ecca Group in the proximity of the Mngazi River

• A Phase 2 palaeontological impact assessment must be undertaken on the significant palaeontological material (mostly fossilised bone) identified between East London and Mooiplaas in the Adelaide Subgroup

• A Phase 2 palaeontological impact assessment must be undertaken on the already identified fossils along the section close to the Mbashe River in the Katberg Formation, Tarkastad Subgroup, Beaufort Group

• For all Phase 2 palaeontological impact assessments, before any collections or excavations of fossil material may occur, the palaeontologist will require a mitigation permit in terms of Section 35 of the NHRA. SAHRA will make further recommendations regarding the sites upon receipt of a satisfactory Phase 2 mitigation report. The specialist may also apply for a destruction permit on behalf of SANRAL after the submission to SAHRA of the final Phase 2 report

• A palaeontologist must train the ECOs in the identification of fossil material, as appropriate

Training and Awareness

• A suitably experienced archaeologist and palaeontologist should undertake induction and training of the ECOs and relevant site management personnel in the identification and monitoring/recovery protocols for heritage resources (including marked and unmarked burial grounds and graves), as appropriate






PROJECT PHASE

• Ensure that environmental induction/awareness courses for construction personnel include relevant heritage-related aspects to enable personnel to participate effectively in heritage resource management

DEA notification

• DEA must be kept abreast of all issues related to and discussed with SAHRA (ROD Item 6.2.14..2)

SANRAL

4. SOCIAL IMPACT MANAGEMENT Social impact management

• SANRAL must ensure that key policies and plans (including appropriate monitoring regimes) on the employment, empowerment and skills development of local people are developed to effectively manage the key social issues associated with the project (ROD Item 6.2.1.8)



• ROD Item 6.2.1.5 stipulates that the land acquisition process must be conducted in terms of section 25 of the Constitution. The land acquisition process where relocation of settlements, communities and assets will take place (including compensation) must be finalised before construction on these specific sections of the road commences. A detailed Relocation Action Plan must be developed in consultation with the directly affected parties, including traditional leaders as well as the relevant authorities prior to the resettlement of communities or assets. The latter must be submitted to this department for record keeping purposes

• Carefully select and position over- and underpasses in consultation with local affected communities and parties. Ensure that central service nodes (schools, clinics, water points, etc.) remain easily and safely accessible

5. NOISE IMPACT MANAGEMENT General Key potential noise impacts are associated with the following:

• Construction and operation of the greenfields section between Ndwalane

and the Ntafufu River; • Ndwalane mainline and ramp toll plazas; • Traffic on the proposed four-lane undivided road through the outskirts of

Lusikisiki; • Construction and operation of the greenfields section between Lusikisiki

(Magwa Intersection) and the Mthamvuna River

SANRAL; Engineer


Noise impact management (as per ROD)

• SANRAL must ensure that noise mitigation measures are implemented where the road passes through or close to residential areas. The latter could include, but is not limited to, the construction of earth berms and noise barriers, and specific types of surface material to mitigate noise generation (ROD Item 6.2.6.9)

• The proposed new road will be located between 10 m and 250 m from numerous dwellings in the section from Ndwalane to the Ntafufu River. In terms of the Noise Control Regulations, noise mitigation would be required in order to ensure that the noise rating level does not exceed 65 dBA at any of the affected residential dwellings (ROD Item 6.2.15.2)

6. AIR QUALITY IMPACT MANAGEMENT General • Should the use of an asphalt plant be required on site, an application must

first be made to the relevant authority for an AEL SANRAL; Engineer

Design

Air quality impact management

• Sites where favourable meteorological dispersion prevails should be considered in finalising the location of toll plazas. The factors to consider are relatively elevated flat areas, avoiding valley sites and areas where the general wind flow is impeded by topography




PROJECT PHASE

• Optimise traffic flow through the toll plazas and ensure that vehicle idling times are limited to a minimum, particularly at peak times or during periods of high pollution potential

• Appropriate dust control management practices and procedures must be implemented, such as wetting of active construction areas and unpaved roads, and the vegetation of permanent stockpiles, in order to ensure the effective suppression of dust during all construction activities

Toll booths • Toll booths should be designed so as to ensure that toll booth workers do not suffer from any detrimental health effects associated with vehicle emissions or particulate matter such as dust. Cold/heat stress should also be controlled in toll booths

7. VISUAL IMPACT AND LIGHTING MANAGEMENT Visual impact and lighting management

• SANRAL should ensure that visual and light mitigation measures are implemented where the road passes through or close to residential areas

SANRAL; Engineer

Design

• Consideration should be given to incorporating a tourist viewing point into the road design where visitors can stop and view from strategic points at the Msikaba and Mthentu river bridges

The following factors should, amongst others, be considered in the siting and design of toll plazas: • The final location of the toll plazas must also be informed by the topography; • The siting of toll plazas must take account of light pollution, and must be

designed to minimise this impact on the surrounding environment; • Where appropriate, use natural construction materials in the design of toll

plazas; and • As far as possible, the design of the plaza buildings should blend with the

local architecture, where applicable 8. PLANNING/DEVELOPMENT IMPACT MANAGEMENT Planning/ development impact management

• Ensure that proposed intersection upgrading accommodate planned land uses at identified nodes

SANRAL; Engineer


• Bypasses, with proper intersection to allow traffic to enter and leave the CBD, should be constructed at Butterworth, Dutywa and Mthatha [these would be subject to separate environmental authorisation processes]

• Interchanges should be considered at the Libode and Ngqeleni intersections

• Consultation with the Regional Land Clams Commissioner’s office and land claimants should be undertaken regarding the resolution of applicable land claims

• ROD Item 6.2.8.8 stipulates that “access to the environmentally sensitive areas alongside the route must be controlled during both construction and operational phases to prevent disturbances, littering and increased accidental fires. Access control and waste management programmes are required in the sensitive greenfields sections”

9. SITE CAMPS AND SITE LAYOUT PLANS General • SANRAL must take note that no site camps will be allowed outside the

footprint of the development area as the establishment of such structures may trigger a listed activity as defined in the NEMA Regulations (ROD Item 6.2.6.4)






PROJECT PHASE

• In determining the location of the construction camps, cognisance must be taken of the identified and mapped sensitive and no-go areas, especially within the new road sections (see Figures 4.1 and 4.2), and the requirement that “no construction camps, dumping or stockpiling of construction material is allowed in or close to the wetlands and other watercourses” (ROD Item 6.2.11.1). Preferred locations for siting of site offices and accommodation units would be areas of little relief. If the route traverses watercourses, streams and rivers, it is recommended that the offices (and in particular the ablution facilities, aggregate stockpiles, spoil areas and hazardous material stockpiles) are located as far away as possible from any watercourse, and downstream of water bodies

• Final overall site layout plans (and route alignment maps with coordinates) must be submitted to DEA for approval prior to construction (ROD Item 6.2.8.1).

Site camps and site layout plans

The final design of the project must include the appropriate siting of all construction camps (i.e. site camps and worker accommodation camps, where required), including the following: • Site access (including entry and exit points); • Access / haul routes; • All material and equipment storage areas (including storage areas for

hazardous substances such as fuel and chemicals). Provision may also need to be made for an on-site nursery;

• Construction offices and other structures (accommodation for staff, where required and considered appropriate);

• Security requirements (including temporary and permanent fencing, and lighting) and accommodation areas for security staff;

• Areas where vegetation will be cleared; • Solid waste collection facilities for litter, kitchen refuse, and for all non-

hazardous solid waste including office and workshop waste; • Waste treatment facilities for sewage, grey water and workshop-derived

effluents, where no formal facilities exist; • Stormwater control measures; and • Provision of potable water and temporary ablution facilities. Sanitation

facilities must be provided at the construction camps and along the road to ensure that workers do not pollute the surrounding environment



• No septic tanks and soak-aways shall be constructed on site. Conservancy tanks to safely and effectively handle sewage shall be required. Alternative methods for handling sewage could be used, but permission to do so shall be obtained from the Engineer. The type of sewage treatment will depend on the duration of the contract and proximity (availability) of providers of chemical toilets. The waste material generated from these facilities shall be serviced on a regular basis. The positioning of the chemical toilets shall be done in consultation with the Engineer

10. ACCESS/HAUL ROADS Access/Haul Roads

• In determining the location, alignment and extent of access/haul roads, cognisance must be taken of the identified and mapped sensitive areas (see Figures 4.1 and 4.2)

SANRAL; Engineer; PEM; ECO





PROJECT PHASE

• As far as possible, use must be made of existing roads in the area, or temporary access/haul roads should be established within the boundaries of the road reserve. Any clearing for access or haul roads by Contractors, both within and where necessary outside the road reserve, shall only be undertaken after written approval from the Engineer, with input from the PEM and/or ECO

11. EARTHWORKS AND LAYERWORKS Stockpiles • Where possible, stockpile areas should be identified and approved during the

design phase and be located within the road reserve boundary where feasible. In determining the location of these stockpile areas, cognisance must be taken of the identified and mapped sensitive and no-go areas, especially within the new road sections. If the stockpile area is located closer than 500 m from a river, erosion protection measures must be designed and implemented



• As far as possible, existing roads should be used to access these stockpile areas. Where new access/haul roads are required to be constructed, these should be designed in accordance with the relevant drainage specifications

Spoil areas • Where possible, candidate spoil sites should be identified and approved during the design phase prior to the commencement of any activities that will generate spoil materials. In determining the appropriate location of these spoil areas, cognisance must be taken of the identified and mapped ecologically sensitive and no-go areas, especially within the new road sections. Spoil areas should not negatively affect surface drainage, nor shall they alter the topography to the extent that they become visually intrusive



Quarries and borrow pits

• If required, sites for quarries and borrow pits must be identified and sampled during the design phase. In determining the appropriate location of these quarries and borrow pits, cognisance must be taken of the identified and mapped sensitive and no-go areas, including wetlands. No borrow pits or associated requirements should be sited in the vulture exclusion zones

SANRAL; Engineer


• Prior to undertaking excavation activities a mining authorisation is required from the relevant authorities. Any borrow pit application must be forwarded to the DMR (and relevant environmental authority where applicable) for approval sufficiently early in order to prevent delays with construction

12. DRAINAGE General • ROD Item 6.2.9.1 stipulates the following - although generic guidelines exist

in the SANRAL EMP for road drainage and rehabilitation, site-specific plans must be prepared in tandem with the final road design and must include specific measures to mitigate erosion as well as realistic and practical rehabilitation plans setting standards for rehabilitation, and indications on how these standards will be met

SANRAL; Engineer


• The detail of effective protection measures around drainage infrastructure must form part of the site development plans (ROD Item 6.2.6.8).

• ROD Item 6.2.11.8 requires the following - construction must include appropriate design measures that allow surface and subsurface movement of water along drainage lines so as not to impede natural surface and subsurface flows. Drainage measures must promote the dissipation of stormwater runoff




PROJECT PHASE

Toll plazas • The separation of contaminated and uncontaminated surface water runoff should be included in the design of the stormwater system. Water flowing from parking areas and areas where traffic slows down would be contaminated with oils, rubbers and chloro-fluoro-carbons. Water flowing from roof surfaces should be controlled to avoid excess erosion. Water flow from the surrounding landscape should be channelled to natural areas

• Oil traps (interceptors) should be incorporated into the drainage system at the toll plazas. Where the receiving environment is considered sensitive (e.g. wetland areas), spillage containment facilities should be considered

13. EROSION CONTROL Erosion control

• According to ROD Item 6.2.9.2, the pass through the Tutor Ndamase mountainous area is an area of geotechnical instability and erosion, and additional safety measures such as slope stability measures and retaining walls at unstable cuttings must be implemented

SANRAL; Engineer


• Steep cut and fill slopes in soft or erodable material will require erosion control measures and appropriate re-vegetation methods. Such areas are to be identified during the design phase and appropriate remedial design implemented

14. CUT AND FILL SLOPES Cut and fill slopes

• As far as possible, steep or unstable slopes should be avoided in selecting the final road alignment, as well as the final location of toll plazas, access/haul roads, construction camps and borrow pits/quarries (if required). Also, the section between Ndwalane and the Ntafufu River will require special design of cuts, fills and erosion protection during the design phase

SANRAL; Engineer


• Extensive cuts into side slopes should be avoided as far as possible in order to minimise the potential for soil erosion. Such cuts are difficult to rehabilitate naturally and can be visible from great distances. Spoil from cut areas should be used in the construction of the road, where appropriate, for the in-filling of erosion gulleys, or in the rehabilitation of borrow pit sites (where applicable)

• Slopes should be cut to gradients that will ensure stability, as indicated by a full slope stability analysis. Areas in which such an analysis will be required must be defined and specified in the detailed design stage. All new cut and fill areas should be rounded on the edges to allow them to blend into the surrounding landscape, and should, as far as possible, reflect the natural form and contours of the landscape to reduce visual intrusiveness. Slopes with a constant gradient from top to bottom and across the face, the so-called “butter-knife” cut, must be avoided

• Cut slopes should be self-sustaining. However, where it is necessary to use retaining structures or gabions, these must be designed to minimise visual intrusiveness. In areas where the road intersects ridges or spurs, the exposed rock face and soil must be stepped back in a manner that mimics natural rock faces as far as possible

• Where possible, weed-free topsoil with an appropriate indigenous seed mix should be placed on the slopes. Soil should be retained in small pockets in the irregular surface of the slope. This will allow for the creation of micro-habitats where plants can become established

15. POLLUTION PREVENTION AND CONTROL Pollution prevention and control

• Hazard substance retention areas for spills must be designed and constructed for all major drainage line crossings to prevent pollution from accidental spills (ROD Item 6.2.8.7)

SANRAL; Engineer





PROJECT PHASE

• Silt traps should be included where there is the risk of high sediment loading. Such areas may include cuttings where soil stability is uncertain, or where the new road intercepts additional catchment runoff and the soils are identified as highly erosive. Silt traps must be situated upstream of any oil trap

16. ACCESS REQUIREMENTS Access requirements

• ROD Item 6.2.18.2 requires that public consultation must be undertaken on an ongoing basis in order to inform final design – especially concerning details of accesses, under- and overpasses, service roads, fences and barriers and other safety measures, to ensure that complaints and concerns can be addressed during construction and operation of the road

SANRAL; Engineer; Community Liaison service provider

Design

• During the final design phase, SANRAL must consult with affected landowners and/or communities regarding safety and access requirements (including the provision of taxi facilities). The consolidation of existing accesses must be identified and detailed. Such communication shall be undertaken in a sensitive manner appropriate to the culture of the affected parties

SANRAL; Engineer; Community Liaison service provider

Design

17. SAFETY AND SECURITY Safety and security

• The pass through the Tutor Ndamase mountainous area is in an area of geotechnical instability and erosion, and additional safety measures such as slope stability measures and retaining walls at unstable cuttings must be implemented (ROD Item 6.2.9.2)

SANRAL; Engineer


• Road design should include safety features such as fencing of the road reserve, appropriate signage, guardrails, etc. along the entire length of the route. In addition, lighting, high standard warnings and traffic calming measures should be considered in areas where road safety has been identified as a concern (e.g. through the towns of Butterworth, Dutywa and Mthatha) and where construction interferes with traffic

• Appropriate security measures must be implemented around each toll plaza control building and within the toll booths on account of cash stored in the building. The design of the toll plazas should not include allowance for truck stops

18. TOURISM MANAGEMENT Tourism management

• Consideration should be given to providing the road user and tourist with the opportunity of optimising the visual attributes of the scenic landscape. This can be achieved through the establishment of view sites and visitor information centres at strategic locations along the route. The number, location and design of these sites should be undertaken in consultation with the local authorities. The environmental impacts associated with the establishment of view sites and visitor information centres should be assessed during design, and the development approved by the regulatory authority (if required) prior to implementation

SANRAL; Engineer


19. ROAD LAYOUT PLANS AND DESIGN General • Any change in the road alignment (including bridges, over- and under

passes, toll plazas, interchanges, etc.) is subject to approval by the relevant authorities after input has been received from the ECOs, PEM, ACC and the environmental auditor. Independent specialist consultants must be called upon when, in the opinion of the PEM, environmental auditor, the ACC or a relevant authority, there is a need for expert opinion (ROD Item 6.2.8.4)

SANRAL; Engineer





PROJECT PHASE

• The road alignment must be sensitive to existing residential patterns and should be finalised taking into account the need to minimise the fragmentation of families and clans. This can be dealt with by consulting the directly affected communities and parties and also traditional leaders and relevant authorities (ROD Item 6.2.8.5)

• ROD Item 6.2.8.6 stipulates that all construction activities must be undertaken within the road reserve with the exception of sections highlighted and considered in the Final EIR dated December 2009

• ROD Item 7.5 recommends that intersections be limited to existing access and planned roads as far as possible



Figure 4.1: Ecological sensitivity of habitats between Ndwalane and Ntafufu



Figure 4.2: Ecological sensitivity of habitats between Lusikisiki and the Mthamvuna River



5. ENVIRONMENTAL SPECIFICATIONS: CONSTRUCTION AND OPERATION

5.1 INTRODUCTION This chapter of the EMP outlines environmental specifications which are required to be implemented during the construction and operational phases along the various sections of the project. Key mitigation/enhancement measures relevant to the construction and operational phases, as per the findings and recommendations of the Final EIR for the project and the ROD, are incorporated as appropriate.

5.2 ENVIRONMENTAL MANAGEMENT MEASURES – CONSTRUCTION AND OPERATION

The environmental management measures applicable to the construction and operational phases of the project are presented in Table 5.1 overleaf. In order to facilitate monitoring and auditing, the table has been structured to indicate the aspect (or impact) to be addressed, the environmental management measure to be implemented and the parties responsible for implementation. The following aspects are addressed: • Establishment of construction camps • Access requirements • Fencing and no-go areas • Accommodation of road and pedestrian traffic • Site and construction camp clearing • Waste management • Stockpiling of topsoil and relevant material • Stormwater and drainage • Construction materials and stockpiling • Batching sites • Fuel and hazardous material handling, use and

storage • Protection of natural features, flora and fauna

• Spillages • Control and management of alien vegetation • Water pollution control • Blasting • Fires • Management of heritage resources • Dust and air quality management • Spoil sites • Working hours • Excavation, hauling and placement • Employment • Erosion and sedimentation control • Noise management • Site clean-up and rehabilitation • Safety and security • Monitoring and auditing programme All applicable requirements included in additional authorisations/approvals/licences/permits to be issued by the relevant authorities should be viewed as being part of the EMP.



Table 5.1: Environmental specifications applicable to the construction and operational phases of the project, with identification of responsible party (-ies), as appropriate

ACTIVITY SPECIFICATION RESPONSIBLE

PARTY (-IES) PROJECT

PHASE

1. ESTABLISHMENT OF CONSTRUCTION CAMPS Location of construction camp and site layout plans

• Before construction activities commence, the Contractor shall submit Method Statements to the Engineer for approval, following input from the PEM and ECO, which shall indicate the location, layout and preparation of the construction camps. Only designated areas may be used for the storage of materials, machinery, equipment, site offices and accommodation facilities. The Contractor shall establish these facilities in accordance with the relevant design criteria set out in Chapter 5 of this EMP, and in a manner that does not adversely affect the environment. Camps, offices, workshops, staff accommodation and laboratory/testing facilities shall be maintained in an orderly and tidy condition


Construction

• Throughout the period of construction, the Contractor shall restrict all activities to within the designated areas on the construction layout plan. Any relaxation or modification of the construction layout plan is to be approved by the Engineer, PEM and ECO

• Construction camps (site offices, workshops, yards, etc.) shall be established in appropriate (preferably previously disturbed) locations prior to the commencement of construction activities. The Contractor, Engineer, PEM and ECO shall agree on mutually acceptable locations for the establishment of camps. The Engineer shall approve the final location of all camps prior to their establishment. Any sites proposed for staff accommodation (if required) shall be selected in consultation with the relevant community and authority stakeholders, as appropriate

• The Contractor shall take detailed colour photographs of the proposed sites before any clearing may commence. These records are to be kept for consultation during rehabilitation of the site

• The Contractor shall advise on all temporary services required on site during construction and shall submit a plan to the Engineer detailing where and how he proposes to lay such services

• Site establishment and vegetation and topsoil removal are to occur only after the required Plant Search and Rescue

Construction camp restrictions and constraints

The following restrictions and constraints are applicable to the construction camps, and construction staff in general, and should be monitored by the Engineer, Contractor, PEM and ECO: • The use of rivers and streams for washing of clothes and kitchen utensils; • The use of welding equipment, oxy-acetylene torches and other bare flames

where veld fires constitute a hazard; • Indiscriminate disposal of rubbish or construction wastes or rubble; • Littering of the site; • Spillage of potential pollutants, such as petroleum products; • Collection of firewood; • Poaching of any description; • Any non-use of designated ablution facilities; and • Burning of wastes and/or cleared vegetation.


Construction



ACTIVITY SPECIFICATION RESPONSIBLE PARTY (-IES)

PROJECT PHASE

Water for human consumption

• Water for human consumption should be available at the site offices and at other convenient locations on site

Contractor Construction

Eating areas • The Contractor shall provide designated eating areas for employees. Personnel shall only be permitted to eat and smoke in these areas and no littering, alcohol abuse or drugs shall be allowed on site

Contractor; Engineer; PEM; ECO

Construction

• The Contractor shall provide the necessary bins at these areas and bins shall be emptied on a regular basis. The collected waste shall be stored in a central waste area that has been approved by the Engineer, PEM and ECO

Cooking fuel • The Contractor shall provide adequate cooking facilities for its staff, preferably gas, so that they are not encouraged to supplement their comforts on site by accessing what can be taken from the natural surroundings. The Contractor shall ensure that energy sources are available at all times for construction activities, and supervision personnel, for heating and cooking purposes


Wastewater and sewage treatment / sanitation

• The Contractor shall provide suitable sanitary arrangements at construction camps and on site. All effluent water from the camp/office sites shall be disposed of in a properly designed and constructed system, situated so as not to adversely affect water sources (streams, rivers etc.). Only domestic type wastewater (i.e. water from any kitchen, showers, sinks etc.) shall be allowed to enter this system

Engineer; Contractor

Construction

• Particular reference in the site establishment plans shall be given to the treatment of sewage generated at the site offices, site laboratory, staff accommodation and on-site (road) facilities for labour. Sanitary arrangements should be to the satisfaction of the Engineer, the relevant authorities and all applicable legal requirements

• Toilets should be easily accessible and should be positioned within walking distance from wherever employees are employed on the works. Performing ablutions outside the toilet facilities are strictly prohibited and the use of the veld for this purpose shall not, under any circumstances, be allowed. Toilets shall not be placed in areas susceptible to standing or flowing water and shall be sited away from any identified ecologically sensitive areas. It should be ensured that the entrances to toilets are adequately screened from public view

• Toilets should be secured in order to prevent them from blowing over. The toilets shall be emptied on a regular basis. The Contractor shall ensure that there is no spillage when the chemical toilets are cleaned or during normal operation and that the contents are properly removed from site

• Runoff from fuel depots/workshops/truck washing areas and concrete swills shall be directed into a conservancy tank and disposed of at a site approved by the Engineer. The Contractor shall be responsible for the construction and operation of the necessary collection facilities in order to prevent such pollution and/or settlement of suspended matter

2. FENCING AND NO-GO AREAS Construction phase

• The Contractor shall make provision for appropriate fencing to be erected along the perimeter of construction areas, where appropriate. No-go areas shall be demarcated by suitable fencing to ensure that personnel, machinery, equipment or material do not impact these areas. The Contractor is required to demarcate the working areas and “no-go” areas in consultation with the Engineer


Construction




PROJECT PHASE

• No activities shall take place beyond the demarcated areas, unless otherwise specified by the Engineer. Fences are to be erected as agreed with the Engineer, taking into consideration the sequence and time programme, and co-ordinated with the arrival of equipment, staff and materials onto site

• The fencing shall not be moved or removed, at any stage of the project, without written consent of the Engineer. The Contractor shall ensure that any fencing damaged during construction activities shall be repaired or replaced immediately and at their expense

The following measures should be implemented in order to address increased safety hazards for pedestrians and traffic: • Fencing should be inspected weekly and maintained properly; and • Ensure that signs, which should be pictorial/graphic and in the local

vernacular, are erected on all boundary fences warning against entering the construction area/road reserve

Operational phase

• Fences required during road maintenance shall be erected and maintained along the perimeter of the demarcated areas as described above and/or through a separate SANRAL contract for Routine Road Maintenance

SANRAL; Contractor

Operational

3. SITE AND CONSTRUCTION CAMP CLEARING Site and construction camp clearing

• Disturbance to vegetation must be restricted to the absolute minimum and areas disturbed as a result of construction activities must be rehabilitated as soon as possible to the satisfaction of DEA, the relevant authorities, the ECO, the PEM and the Environmental Auditor

SANRAL; Engineer; Contractor; DEA; PEM; ECO

Construction

• Prior to any disturbance/stockpiling and clearing of natural vegetation and soil (either within the road reserve or at designated or instructed areas outside the road reserve), the Contractor shall submit a plan of action and Method Statements to the Engineer, PEM and ECO for approval. For rehabilitation to be effective, the topsoil must be stripped and stockpiled prior to construction or ongoing maintenance activities, and then re-used during rehabilitation

• The plan of action shall contain a photographic record and chainage/land reference of the areas to be disturbed. The Contractor shall consult these records during rehabilitation of the site. This plan shall form part of the Contractor’s records, and shall be comprehensive and clear, allowing for easy identification during subsequent inspections

• The use of herbicides shall be in compliance with the terms of the Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (Act No 36 of 1947). In terms of this Act, a registered pest control operator shall apply herbicides, or shall supervise the application of herbicides. The use of herbicides shall be restricted to the removal and control of alien vegetation, and shall not be permitted within identified sensitive areas

• The Contractor shall be held responsible for the re-establishment of vegetation within the road reserve boundaries for all areas disturbed during road construction. This includes, for example, service roads, stockpile and spoil areas, stop/go facilities, windrows and wherever material generated for, or from, road construction has to be stored temporarily or otherwise within the road reserve, or at designated or instructed areas outside the road reserve




PROJECT PHASE

• The Contractor has a responsibility to inform all staff of the need to be vigilant against any practice that will have a harmful effect on vegetation. This information shall form part of the Environmental Awareness Programme to be effected by the Contractor, and is of particular importance during site establishment within the Pondoland Centre of Endemism

Vegetation clearance

• The relevant permits, in terms of the Provincial Nature Conservation Ordinance (1974) and the National Forests Act, 1998 must be obtained from the relevant authorities prior to the disturbance, removal or destruction of any TOPS


Construction

• The Contractor’s responsible person shall be present during vegetation clearing

• The natural vegetation encountered at the site and construction camp is to be conserved and left as intact as far as possible. Only trees, shrubs, grasses and herbs directly affected by the works, and such others as may be indicated by the Engineer in writing, may be felled or cleared, as appropriate

• The Contractor should retain identified mature trees as indicated by the Engineer and botanical specialist before upgrading and construction of interchanges

• Where possible and without compromising road safety, all existing large trees that fall outside of the works, yet inside of the road reserve, must be retained. These will assist in softening the local visual impact and aid in visual screening from distant viewpoints

• All indigenous plant material removed from the cleared areas shall be stockpiled for mulching. Indigenous vegetation from different topsoil types shall be stockpiled separately, each to be returned to its respective parent topsoil type. Stockpile sites shall be identified by the Contractor and approved by the Engineer

• A firebreak shall be cleared and maintained around the perimeter of the site camp/s and office sites

• Vegetation stripping within the development footprint shall occur in parallel with the progress of road construction to minimise erosion and/or runoff

Vegetation removal and trimming in watercourses

• The Contractor shall ensure that the environmental management measures set out in Chapter 4 of the Supplementary EMP for Aquatic Ecosystems (see Appendix B) are adhered to, as appropriate


4. STOCKPILING OF TOPSOIL AND RELEVANT MATERIAL Construction phase

• Good quality topsoil shall be removed from areas to be disturbed during construction and shall be stockpiled and properly managed for revegetation purposes. Topsoil is considered to be the natural soil covering, and should include all organic matter. Depth may vary at each site, and must be determined on a site-specific basis and removed accordingly. The areas to be cleared of topsoil shall include the storage areas and site camps


Construction

• Topsoil should be stockpiled separately from sub-soil. Stockpiled soil should be seeded to maintain biological activity and to keep invasive alien species from establishing on it and seeding it. Care must be taken not to allow heavy traffic over the topsoil




PROJECT PHASE

• All topsoil stockpiles and windrows shall be maintained throughout the contract period in a weed-free condition. Weeds appearing on the stockpiled topsoil shall be removed by hand. The topsoil stockpiles shall be stored, shaped and sited in such a way that they do not interfere with the flow of water such that damming or erosion is caused, or itself be eroded through the action of water. Stockpiles of topsoil shall not exceed a height of 2 m, and if they are to be left for longer than 6 months shall be analysed and, if necessary, nutrient levels replenished before replacement. Temporary topsoil stockpiles must not be placed in sensitive areas where nutrient-poor soils occur

• The Contractor shall ensure that minimal amounts of topsoil are lost due to erosion, either by wind or water. This can be facilitated through the grassing of topsoil stockpiles. Areas to be topsoiled and grassed shall be done systematically to allow for quick cover and reduction in the chance of heavy topsoil losses due to unusual weather patterns. The Contractor’s programme shall clearly show the proposed rate of progress of the application of topsoil and re-vegetation. The Contractor shall be held responsible for the replacement, at his own cost, for any unnecessary loss of topsoil due to his failure to work according to the progress plan approved by the Engineer. The Contractor’s responsibility shall also extend to the clearing of drainage or water systems that may have been affected by such negligence within and beyond the boundaries of the road reserve

Operational phase

• Vegetation and silt collected during maintenance operations (e.g. alien eradication, culvert clearing, verge mowing etc.) shall be stockpiled and used during rehabilitation (topsoil and mulch), such stockpiling, however, must not occur near residential areas. If silt is stockpiled, the Contractor shall ensure that minimal amounts of silt are lost due to erosion, either by wind or water. This can be facilitated through the grassing of stockpiles

SANRAL; Contractor

Operational

5. CONSTRUCTION MATERIALS AND STOCKPILING Construction materials and stockpiling

• As far as possible, the Contractor shall plan its activities so that materials excavated from borrow pits and cuttings during construction and routine maintenance activities can be transported directly to and placed at the point where it is to be used. However, should temporary stockpiling become necessary, the areas for the stockpiling of excavated and imported material shall be indicated and demarcated on the site plan and submitted in writing to the Engineer for approval, together with the Contractor’s proposed measures for prevention, containment and rehabilitation against environmental damage


Construction

The areas chosen for temporary stockpiling shall have no indigenous trees and shrubs present that may be damaged during activities. In determining the location of these temporary stockpile areas, cognisance must be taken of the requirements of the ROD (in particular Item 6.2.11.1) and mapped sensitive and no-go areas, particularly within the greenfields sections. Temporary stockpile areas should be located within the road reserve boundary, where feasible. Care shall be taken to preserve all vegetation in the immediate area of these temporary stockpiles. During the life of these temporary stockpiles, the Contractor shall at all times ensure that they are: • Positioned and sloped to create the least visual impact; • Constructed and maintained so as to avoid erosion of the material and

contamination of the surrounding environment; and • Kept free from all alien/undesirable vegetation.




PROJECT PHASE

• The storage of building materials such as sand and cement shall take place away from any natural vegetation and cultivated lands and shall be limited to clearly identified areas in order to minimise negative visual impact. All stockpiling shall be done in a neat and safe manner. Imported materials shall be free of weeds, litter and contaminants

• Where necessary, stockpiles shall be fenced with solid boarding to ensure material does not spill into rivers or drainage lines. Fine material stockpiles shall be covered with canvas, if necessary, in order to prevent possible pollution of nearby watercourses or other sensitive areas. These sites shall be rehabilitated to their original condition to the satisfaction of the Engineer on completion of construction activities. No foreign material generated/deposited during construction shall remain on site. Areas affected by stockpiling shall be landscaped, topsoiled, grassed and maintained at the Contractor’s cost until clearance from the Engineer is received

• Material milled from the existing road surface that is temporarily stockpiled in areas approved by the Engineer within the road reserve, shall be subject to the same condition as other stockpiled materials. Excess materials from windrows, in situ milling or any detritus of material from road construction or maintenance activities may not be swept off the road and/or left

6. FUEL AND HAZARDOUS MATERIAL HANDLING, USE AND STORAGE Handling and safety

• Hazardous and flammable substances must be stored and used in compliance with the applicable regulations and safety instructions (ROD Item 6.2.10.3).

• The Contractor shall be responsible for the training and education of all employees who will be handling hazardous materials about their proper use, handling and disposal. All the necessary handling and safety equipment required for the safe use of petrochemicals and oils shall be provided by the Contractor to, and used or worn by, the staff whose duty it is to manage and maintain plant, machinery and equipment


Hazardous material transport and storage

• The Contractor shall comply with all relevant legislation with regard to the transport and storage of hazardous substances. The Contractor shall provide proof to the Engineer, PEM and ECO that relevant authorisation to store such substances has been obtained from the relevant authority. The Contractor shall comply with all applicable by-laws with regard to road safety and the transport of materials, especially hazardous materials


• In addition, hazard signs indicating the nature of the stored materials shall be clearly displayed on the storage facility or containment structure. Before containment or storage facilities can be erected, the Contractor shall furnish the Engineer with details of the preventative measures (emergency procedure to deal with accidents and incidents arising from hazardous substances), which are proposed to be installed as mitigation for potential pollution of the surrounding environment from leaks or spillage. The preferred method of such mitigation shall comprise a concrete floor that is bunded. The Contractor shall furnish employees with details of the proposed preventative measures

• The Contractor shall report major incidents (spills in excess of 50 litres) to the Engineer, PEM and ECO immediately and follow the designated emergency response procedure




PROJECT PHASE

Fuel, oil and other substances

• All fuel, oil and other hazardous substance storage shall be confined to the demarcated areas. The Contractor shall ensure that all toxic products (i.e. fuel, poisons, bitumen etc.) are stored and handled in a manner that minimises the potential for spillage and possible pollution to rivers or soil


• Fuel should be stored in a secure area in a steel tank supplied and maintained by the fuel suppliers. Leakage of fuel should be avoided and if it occurs, should be remedied immediately. An adequate bund wall (110% volume) should be provided for fuel and diesel areas to accommodate any spillage or overflow of these substances. The area inside the bund wall should be lined with an impervious lining to prevent infiltration of the fuel into the soil

• Gas welding cylinders and LPG cylinders should be stored in a secure, well-ventilated area, which is clearly marked with hazard signs. Servicing of equipment shall only take place in properly demarcated areas. Refuelling vehicles shall be equipped with drip trays and a spillage kit and no spillages shall be permitted on site

7. SPILLAGES Spillages • Streams, rivers and dams should be protected from direct or indirect spillage

of pollutants such as refuse, garbage, cement, concrete, sewage, chemicals, fuels, oils, aggregate, tailings, wash water, organic materials and bituminous products. In the event of a spillage during construction, the responsibility for spill treatment lies with the Contractor, who will be liable to arrange for competent assistance to clear the affected area. The Contractor shall compile and maintain environmental emergency procedures to ensure that there will be an appropriate rapid response to unexpected or accidental environment-related incidents


Construction

• Hazard substance retention areas for spills must be designed and constructed for all major drainage line crossings to prevent pollution from accidental spills (ROD Item 6.2.8.7)

• The individual responsible for, or who discovers a hazardous waste spill, must report the incident to the Contractor and the Engineer. The Contractor shall assess the situation in consultation with the Engineer, PEM and ECO and act as required. In all cases, the immediate response shall be to contain the spill. The Contractor, in consultation with the Engineer, shall determine the exact treatment of polluted soil/water. Areas cleared of hazardous waste shall be re-vegetated according to the Engineer’s instructions

• Should water downstream of the spill be polluted, and fauna and flora show signs of deterioration or death, specialist hydrological or ecological advice must be sought for appropriate treatment and remedial procedures to be followed. The requirement for such input shall be agreed with the Engineer, PEM and ECO. The costs of containment and rehabilitation shall be for the Contractor’s account, including the costs of specialist input

8. WATER POLLUTION CONTROL Water pollution control

• The Contractor shall prevent pollution of surface or groundwater that could result from construction or operational activities. Such pollution could result from the release, accidental or otherwise of chemicals, oils, fuels, cement, sewage, construction water etc.

Engineer; Contractor

Construction

• Monitoring of aquatic ecosystems shall be undertaken in accordance with the requirements of the Supplementary EMP for Aquatic Ecosystems (see Appendix B), as appropriate




PROJECT PHASE

• The Engineer shall approve the demarcation of the construction area within the confines of rivers and streams. Diverted streams and watercourses shall be reinstated to the satisfaction of the Engineer. The Contractor shall not modify the banks of watercourses unless in accordance with the contract specifications. Stream banks shall be suitably stabilised immediately after construction

• Where possible, damage to wetland areas shall be avoided. No materials shall be stockpiled in any wetland areas

9. FIRES Fires • Open fires will only be permitted at the construction camps in facilities or

equipment specially constructed for this purpose SANRAL; Engineer; Contractor

Construction

• The Contractor shall take all reasonable steps to avoid any fires. Prior to the commencement of construction activities the Contractor is to ascertain the fire requirements of the local council, as appropriate, and must submit a contingency plan in case of fire to the Engineer. The Contractor shall ensure that there is basic fire-fighting equipment on site (including toll plazas) at all times. This equipment shall include, as a minimum, fire extinguishers and beaters

• The Contractor shall pay the costs incurred by organisations called to put out fires started by himself or any Sub-contractor. The Contractor shall also pay the costs incurred to reinstate burnt areas as deemed necessary by the Engineer

• The Contractor shall also take all reasonable steps to extinguish any fires where other road users may have started a fire, either intentionally or unintentionally

10. DUST AND AIR QUALITY MANAGEMENT Construction phase

• The Contractor shall take appropriate measures to minimise dust generation on site during construction activities, in particular where activities are undertaken in close proximity to agricultural crops and residential areas. The Contractor shall ensure that loose building materials and excavated material stockpiles are adequately protected against the wind by using suitable covering, such as canvas. In the short term, stockpiles, active construction areas and unpaved roads may also be dampened to minimise dust generation


Construction; Operational

• SANRAL must ensure that dust abatement measures are implemented, such as wetting of active construction areas and unpaved roads and the vegetation of permanent stockpiles (ROD Item 6.2.6.3)

• The Contractor must adhere to all the relevant provisions of the NEM:AQA and other applicable legislation in this regard

Specific dust abatement measures include the following: • Remove only limited vegetation to accommodate construction activities; • Speed restrictions must be imposed on the construction sites and access

roads to limit the effects of dust entrainment; and • Verges, cuttings, lay down areas and construction camps must be re-

vegetated as soon as construction is complete. • The speed limit in work zones, during construction and maintenance

activities, shall be 40 km/h. No vehicles are to leave or reverse off designated access roads unless at areas previously agreed to with the Engineer




PROJECT PHASE

Operational phase

• SANRAL shall develop and implement a monitoring programme at toll plazas to determine the risk of exposure of workers to elevated concentrations of Volatile Organic Compounds and diesel particulates. The monitoring should take into account diurnal and seasonal traffic volumes. At weigh-bridges the Contractor should test the degree of compliance of heavy-duty vehicles in terms of diesel emissions

SANRAL; Engineer

Operational phase

11. WORKING HOURS Working hours

• The Contractor must ensure that construction activities are limited to daylight hours (06h00 to 18h00), Mondays to Saturdays, where the alignment passes through or close to residential areas; no construction work may be undertaken close to residential areas on Sundays (ROD Item 6.2.6.6). The Contractor shall be familiar with all relevant local by-laws and regulations concerning noise, hours of operation etc. and shall adhere to these by-laws and regulations. Only emergency work shall be allowed on Sundays and at night


Construction

• The Contractor shall negotiate for any permits requiring deviation from local by-laws and/or regulations. The Contractor shall be held responsible for any complaints received from the authority and/or public with respect to any contravention of the agreed conditions. Other work outside of normal hours shall be subject to consultation with residents in close proximity of the construction site that will be affected by the noise

12. EMPLOYMENT Employment • Without compromising construction and operation activities and schedules,

local labour should be employed as far as possible. Those successful in obtaining employment should be provided with the appropriate skills development and training. Communication channels between the Contractor, local community structures and the South African Police Services (SAPS) should be developed and maintained in order to facilitate effective management of the local workforce


Construction

• The Contractor is to submit the names of all personnel on site (those permanently living on site and those travelling to and from the site each day). Personnel will only be permitted to eat and smoke in cordoned-off areas and no littering, alcohol or drugs will be allowed on site

• Workers from outside the local area should be provided with adequate on-site temporary accommodation and amenities

13. NOISE MANAGEMENT Construction phase

• The Contractor shall endeavour to keep noise-generating activities associated with construction and maintenance activities to a minimum. Noises that could cause a major disturbance (e.g. blasting) should only be carried out in areas located in close proximity to communities and/or residences during normal working hours. Should noise-generating activities have to occur at night (e.g. drilling of blast holes), communities and/or landowners in the vicinity of the drilling should be warned about the noise well in advance and the activities should be kept to a minimum. Compliance with the appropriate legislation with respect to noise will be mandatory. The Contractor shall familiarise himself with and adhere to, any local by-laws and regulations regarding the generation of noise


Construction

• For construction of the proposed new roads in rural areas it is recommended that machinery with the lowest noise emission be used and that a well-planned and co-ordinated “fast track” procedure be implemented to complete the total construction process in any area in the shortest possible time




PROJECT PHASE

Operational phase

• SANRAL shall ensure that the road infrastructure is maintained such that noise levels in identified noise sensitive areas associated with road traffic do not exceed the legally acceptable level for affected communities or households

SANRAL Operational

14. SAFETY AND SECURITY Safety and security

• The Contractor shall comply with all relevant national, provincial or local regulations with regard to safety on site to ensure the safety of his staff. All accidents and incidents resulting in injury or death during construction are to be reported

Contractor; Community Liaison service provider

Construction

• The Contractor shall ensure that all construction vehicles using public roads are in a roadworthy condition, that they adhere to the speed limits and that their loads are secured. Vehicles transporting materials such as topsoil and spoil shall be covered to prevent their contents falling/blowing off and causing a traffic hazard

• The Contractor must place cordons, barriers and warning signs around excavations in the suburban and village sites and wherever there is a hazard to workers, the public and animals. Traffic calming and speed control measures for access to construction sites should be implemented in consultation with the local authorities

• ROD Item 6.2.6.2 requires that the Contractor must provide high standard warnings and traffic calming measures where construction activities interfere with traffic

• Liaison structures with local police should be established in order to monitor changes in crime patterns during the construction phase. Where necessary, additional security should be provided. Establishment of Community Policing Forums, where they do not exist in the affected areas, should be considered where appropriate

15. ACCESS REQUIREMENTS Construction phase

• The Contractor shall take all appropriate measures to ensure that adequate, safe access to road-side facilities is maintained and that there is clear signage to guide passing motorists


Construction

• No access/haul roads other than those required for construction purposes shall be developed. As far as possible, existing roads shall be used for access/haulage purposes. The Engineer shall approve all new temporary access/haul roads. Prior to the construction of new access/haul roads, topsoil shall be stripped and stockpiled as required. All temporary roads no longer required shall be decommissioned and the land rehabilitated appropriately

Construction and operational phases

• ROD Item 6.2.8.8 stipulates that access to the environmentally sensitive areas alongside the route must be controlled during both construction and operational phases to prevent disturbances, littering and increased accidental fires. Access control and waste management programmes are required in the sensitive greenfields sections



Operational phase

• Haul roads required during maintenance periods shall be developed and managed as described above

SANRAL; Engineer; Contractor; Community Liaison service provider

Operational

• In order to ensure the safety of road users, SANRAL shall develop an on-going monitoring programme of accesses in which illegal accesses are identified and closed

• Consideration should be given to providing local communities with education regarding road safety, including the need for restricted access onto the road through limited access points and the fencing of the road reserve




PROJECT PHASE

16. ACCOMMODATION OF ROAD AND PEDESTRIAN TRAFFIC Accommodation of road and pedestrian traffic

• In general, it should be ensured that regular road users are not unreasonably delayed due to construction and maintenance activities by keeping as many (currently available lanes) open as possible at any time. The Contractor shall also make adequate provision to accommodate pedestrian traffic where appropriate

SANRAL; Contractor


• Construction activities should be scheduled appropriately in order to minimise delays. A suitable public communication strategy should be developed to keep road users informed, as appropriate

17. WASTE MANAGEMENT Waste management

• ROD Item 6.2.10.1 stipulates that an integrated waste management approach must be used that is based on best practices and should incorporate reduction, recycling, re-use and disposal, where appropriate. All waste generated on site during construction and/or operation of the development must be stored, handled and disposed of in an environmentally acceptable way, and as directed by DEA or any other relevant authority


Construction; Operation

• According to ROD Item 6.2.10.2, construction waste (such as sand, gravel, concrete and waste material) that cannot be used in the filling and rehabilitation of gravel pits, and other litter and waste generated during the construction and operational phases must be removed from site and disposed of safely and responsibly at an authorised landfill site [or at a site approved by DEA in the event that an operating permitted landfill site is not within reasonable distance]

• ROD Item 6.2.10.3 requires that hazardous and flammable substances must be stored and used in compliance with the applicable regulations and safety instructions

• The Contractor’s intended methods for waste management must be implemented at the outset of the contract, and approved by the Engineer. All personnel shall be instructed to dispose of all waste in the proper manner

• No waste material shall be burned at the site offices, or anywhere else on the site, including the approved solid waste disposal site. The Contractor shall ensure that no waste is disposed of within quarries or borrow pits

• All waste bins must have lids and be suitably wind-proof, being made of a durable, appropriate material. Bins are to be located at all areas of the site, with waste to be removed from the waste bins daily or when near full. All waste shall be stored in a demarcated area, which meets the satisfaction of the Engineer

• Wherever possible, materials used or generated by construction shall be sorted for recycling. Containers for glass, paper, metals and plastics shall be provided. Office and camp areas are particularly suited for this purpose. These materials could be sold to appropriate recycling merchants or taken to an appropriate recycling plant

Solid waste: operational phase

• Solid waste at toll plazas, visitor information centres, view sites or any other areas where road users may be allowed to stop shall be collected on a regular basis and stored in a designated area in covered, tip proof metal drums for collection and disposal. All drums shall have lids and be suitably wind-proof. Bins shall be emptied on a regular basis


Operational




PROJECT PHASE

• Vegetation and silt collected during maintenance operations (e.g. alien eradication, culvert clearing, verge mowing etc.) could be stockpiled in areas indicated by the Engineer and used during environmental rehabilitation (topsoil and mulch). Vegetation and silt must not be stockpiled near residential areas. The vegetation would need to be chipped

• A refuse control system shall be established for the collection and removal of refuse to the satisfaction of the Engineer. As far as possible, general waste (including paper, glass, plastics, aluminium etc.) shall be sorted for recycling. These materials could be sold to appropriate recycling merchants or taken to an appropriate recycling plant

• Disposal of solid waste shall be at a DEA-permitted landfill site, or at a site approved by DEA in the event that an operating permitted landfill site is not within reasonable distance. No waste shall be burned at toll plazas or along road verges, nor anywhere else, including the approved solid waste disposal site

Litter: construction phase

• No littering by construction workers must be allowed. During the construction period, the facilities shall be maintained in a neat and tidy condition, and the site is to be kept free of litter. Fines shall be implemented for persons found littering


Construction

• Measures shall be taken to reduce the potential for litter and negligent behaviour with regard to the disposal of all refuse. At all places of work, the Contractor shall provide litter collection facilities for later safe disposal at approved waste disposal sites

Litter: operational phase

• The road reserve and toll plazas shall be cleared of litter on a regular basis during the operational phase. Once collected, this litter shall be stored in a designated area in covered, tip-proof metal drums for collection and disposal at an authorised landfill. As far as possible, general waste (including paper, glass, plastics, aluminium etc.) shall be sorted for recycling, and the remainder shall be disposed of at a DEA approved waste disposal site


Operational

Hazardous waste: construction phase

• Hazardous waste such as bitumen, tar, oils etc. shall be disposed of in a DEA-approved hazardous landfill site. Special care should be taken to avoid spillage of tar products such as pre-coating fluid to avoid water-soluble phenols from entering the ground or contaminating water


Construction

• Under no circumstances shall the spoiling of bituminous products on the site, over embankments, in borrow pits or any burying be allowed. Unused or rejected bituminous products shall be removed from site and taken to the supplier’s production plant. No spillage of bituminous products shall be allowed on site. In the event of the above occurring, the affected areas shall be promptly reinstated to the satisfaction of the Engineer

• Used oil, lubricants and cleaning materials from the maintenance of vehicles and machinery should be collected in a holding tank and returned to the supplier. Water and oil should be separated in an oil trap. Oils collected in this manner should be retained in a safe holding tank and removed from site by a specialist oil recycling company for disposal at approved waste disposal sites for toxic/hazardous materials. Oil collected by a mobile servicing unit should be stored in the service unit’s sludge tank and discharged into the safe holding tank for collection by the specialist oil recycling company. The Contractor shall ensure that an emergency preparedness plan is in place for implementation in the case of a spill of substances which can be harmful to an individual or the receiving environment




PROJECT PHASE

• All used filter materials should be stored in a secure bin for disposal off site. Hazardous waste shall not be stored or stockpiled in any area other than that designated on the construction site layout. Hazardous and flammable substances must be stored and used in compliance with the applicable regulations and safety instructions (ROD Item 6.2.10.3). Soils contaminated by oils and lubricants should be collected and disposed of at a facility designated by the local authority to accept contaminated materials

Hazardous waste: operational phase

• Hazardous materials (e.g. used oil, lubricants and cleaning materials) may also be generated during general operation and these shall be collected in a holding tank and disposed of in a DEA approved hazardous waste landfill site or returned to the supplier. Hazardous waste shall not be stored in any area other than that designated on the layout plan. The preferred method of storage shall be a concrete floor that is bunded


Operational

• SANRAL shall ensure that an emergency preparedness plan is in place for implementation in the case of a spill of substances at the toll plaza or along any stretch of the toll road, which can be harmful to an individual or the receiving environment

• Soils contaminated by oils and lubricants shall be collected and disposed of at a facility designated by the local authority to accept contaminated materials. Should weigh-bridges be constructed on the route, oil traps shall be constructed at the weigh-bridges in order to provide for oil spills at the facilities

18. STORMWATER AND DRAINAGE Scheduling of construction activities

• ROD Item 6.2.1.7 stipulates that construction activities must, as far as possible, be scheduled to take place during the lowest rainfall season when flows are the lowest and inundation is limited


Construction

Construction phase

• ROD Item 6.2.11.3 requires that no trenches may be dug in wetland areas for the disposal of storm water. Construction must include appropriate design measures that allow surface and subsurface movement of water along drainage lines so as not to impede natural surface and subsurface flows. Drainage measures must promote the dissipation of stormwater runoff (ROD Item 6.2.11.8)


Construction

Operational phase

• SANRAL shall ensure that effective stormwater management and drainage control measures are implemented. Stormwater from toll plazas shall be treated before it is discharged into drainage systems, wetlands or rivers

SANRAL; Operational

19. BATCHING SITES Batching sites • Asphalt production shall be undertaken in accordance with all relevant

legislative and regulatory requirements, as appropriate. SANRAL; Engineer;

Construction




PROJECT PHASE

• Crushing plants and asphalt or concrete batching plants shall be located in an area of low environmental sensitivity away from residential areas. The Contractor shall provide measures to prevent, contain and rehabilitate any environmental damage from toxic/hazardous substances.

All sites shall adhere to the following requirements: • No batching activities shall occur on unprotected substratum of any kind (i.e.

directly on the ground); • All wastewater and runoff from batching areas shall be strictly controlled,

and cement-contaminated water shall be collected, stored and disposed of at a site approved by the Engineer. Mixing trays shall be used at all mixing and supply points;

• Contaminated water shall be disposed at a waste disposal site approved by the Engineer;

• Effluent from concrete batch plants and crusher plants should be treated in a suitable designated sedimentation dam to the legally required standards to prevent surface and groundwater pollution. The designs of such a facility should be submitted to the Engineer for approval;

• Contaminated water storage facilities shall not be allowed to overflow and appropriate protection from rain and flooding shall be implemented;

• Unused cement bags are to be properly stored so as not to be affected by rain or runoff events. The Contractor shall dispose of used bags in an appropriate manner;

• Care shall be taken to collect contaminated wash-water resulting from cleaning activities of equipment and flushing of mixers, and dispose of it in a manner approved by the Engineer;

• Suitable screening and containment shall be in place to prevent wind-blown contamination associated with bulk cement silos, loading and batching; and

• All visible remains of excess concrete shall be physically removed on completion of the plaster or concrete pour section and disposed of. All excess aggregate shall also be removed.

Contractor

Batching or crushing sites – operating measures

The following measures shall apply to the operation of the crushing or batching plants: • Installation of a dust extraction unit on the crusher plant to ensure the

collection of dust for subsequent and appropriate disposal; and • Installation of an emissions control device on the asphalt plant exhaust.


Construction

• Ultimate approval for operating measures shall be obtained from the relevant authorities, as appropriate. The Contractor shall comply with all relevant inspection requirements of the regulatory authorities

20. PROTECTION OF NATURAL FEATURES, FLORA AND FAUNA Construction phase

• The Contractor shall comply with of any Ordinances, Acts, by-laws and regulations pertaining to the protection of natural features, flora and fauna on site


Construction

• No activities shall take place outside the demarcated construction areas. The removal, damage or disturbance of flora, fauna or avifauna is forbidden in all demarcated “no-go” areas or specified environmentally sensitive areas. The clearing and pruning of vegetation within the construction areas shall take place under the direction of the Engineer




PROJECT PHASE

• The trapping of any animal or picking of any flora is strictly prohibited. Any animal killed as a result of trapping or hunting or any flora that is found in the possession of an employee of the Contractor will result in that employee being removed from site for the duration of the contract. No domestic pets or livestock shall be permitted on site during construction or pavement maintenance periods

• The construction servitude through any wetland areas must be kept to a minimum. No construction camps, dumping or stockpiling of construction material shall be allowed in or close to wetlands and other watercourses (ROD Item 6.2.11.1). The Contractor must ensure that all disturbed areas of wetlands are re-vegetated using either specified indigenous seed mix where appropriate and/or vegetation removed from other stable sites within the wetland (ROD Item 6.2.11.2)

• Ongoing monitoring should take place during the construction phase in order to assess the success of the mitigation/management measures. This may be done at different levels of detail, e.g. visual assessments, sampling, monitoring of alien plants etc.

Operational phase

• Management of the road reserve during the operational phase shall focus on maintaining vegetation and managing alien invasion (in accordance with the Alien and Invasive Species Management Plan – Appendix D). Also, it should be ensured that vegetation in the road reserve is kept short by way of regular maintenance in order to function as effective firebreaks


Operational

21. CONTROL AND MANAGEMENT OF ALIEN VEGETATION Construction phase

• Alien vegetation shall be controlled and managed in accordance with the stipulations of the Alien and Invasive Species Management Plan (Appendix D and/or as approved). Minimisation of the risk of alien plant invasion can be achieved by rehabilitating disturbed areas, managing the vegetation of the road reserve and eradicating alien plants from the road reserve


Construction

• The Contractor shall be held responsible for the removal of alien vegetation, which has become established within the road reserve due to construction activities. This includes, for example, service roads, stockpile areas, stop/go facilities, windrows and wherever material generated for or from road construction has been stored temporarily or otherwise within the road reserve. Alien plants must be removed as soon as they are detected

• A registered pest control operator registered for the industrial application of herbicides shall apply herbicides, or shall supervise the application of herbicides in compliance with the terms of the Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (Act No. 36 of 1947). The use of herbicides shall not be permitted within identified sensitive areas. Removal of alien vegetation within these areas must be undertaken by hand

Operational phase

• SANRAL shall be held responsible for the removal of alien vegetation within the road reserve during the operational phase and in accordance with the Alien and Invasive Species Management Plan (Appendix D and/or as approved). All invasive alien plants along the road reserve and other rehabilitated areas shall be controlled on a regular, ongoing basis, preferably six-monthly


Operational

• Herbicides or other poisonous substances may only be used on site with the prior knowledge and written consent of the Engineer. In particular, the use of herbicides in the road reserve and at toll plazas shall be restricted and controlled




PROJECT PHASE

22. BLASTING Blasting • The Contractor shall obtain a current and valid authorisation for blasting from

the relevant authorities prior to any blasting activity. A Method Statement shall be required for any blasting-related activities. The Method Statement should include a locality plan of the blast site on which shall be shown the zones of influence of the ground and air shock-waves and expected limits of fly-rock. The plan shall also show each dwelling, structure, service and water sources within the zones of influence


Construction

• The Contractor shall take all necessary precautions to prevent damage to special features and the general environment, which includes the removal of fly-rock. Environmental damage caused by blasting/drilling shall be repaired at the Contractor’s expense. At least one week prior to blasting, the Contractor shall notify the relevant occupants/owners of surrounding land and address any concerns. Buildings within the potential damaging zone of the blast shall be surveyed, preferably with the owner present, and any cracks or latent defects pointed out and recorded either using photographs or video

• Any blasting that might be required along the greenfields section between the Msikaba and Mthentu rivers should avoid the Cape Griffon Vulture (Msikaba colony) egg-laying season (March-July)

• Where loss of livestock production due to blasting has been adequately demonstrated, compensation should be considered

23. MANAGEMENT OF HERITAGE RESOURCES Management of heritage resources

• The Contractor must ensure compliance with the relevant requirements of the NHRA, the Human Tissues Act, 1983 (Act No. 65 of 1983) and the Exhumations Ordinance (No. 12 of 1980) during construction. Regular monitoring of potential impacts on heritage resources must be undertaken as construction activities proceed


Construction

Archaeological and historical sites and materials

• If archaeological material is found all work in the immediate vicinity must be stopped and the Contractor shall notify the Engineer and PEM immediately and divert plant away from the archaeological site until an inspection has been completed. An accredited professional archaeologist shall undertake such an inspection. SAHRA shall immediately be informed in the event of such a find

SANRAL; Engineer; Contractor; PEM; archaeologist

Construction

• Historical buildings, structures or features shall not be destroyed, damaged, excavated, altered or removed from its original position without a permit issued by SAHRA. Offenders may be prosecuted. Archaeological and cultural sites must be identified and fenced off in accordance with the requirements of the relevant heritage authority before construction commences

Burial grounds and graves

• If a grave is uncovered on site during construction work, or discovered before the commencement of work, all work in the immediate vicinity of the gravesite and the Contractor shall inform the Engineer of the discovery. Arrangements should be made for an undertaker to carry out exhumation and reburial in accordance with all applicable legislative and regulatory procedures. The undertaker will, together with SAHRA, be responsible for attempts to contact family of the deceased and for the site where the exhumed remains can be re-interred. The exhumation and re-interment shall be carried out with all due ceremony and ritual.

SANRAL; Engineer; Contractor; archaeologist





PROJECT PHASE

Palaeontology management measures

• Any road widening in the Mbashe River valley (Katberg Formation) must be monitored by a qualified palaeontologist

• ECOs, trained by a palaeontologist, should monitor the following identified sensitive features: Freshly exposed outcrops of the Ecca and Beaufort Group Any road

widening in the Mbashe River valley Shales in the Msikaba Formation; and Possible outcrop of the Mzamba Formation

• A palaeontologist should inspect any new road cuttings before rehabilitation occurs in order to identify possible exposure of palaeontological material

SANRAL; Engineer; Contractor; palaeontologist

Construction

24. SPOIL SITES Spoil sites • The Contractor shall be responsible for the safe siting, operation,

maintenance and closure of any spoil site used during the contract period. This shall include existing spoil sites that are being re-entered. Before spoil sites may be used, proposals for their locality, intended method of operation, maintenance and rehabilitation shall be given to the Engineer for approval. The affected landowner must be consulted and must provide consent for the location of these spoil sites on his property prior to the submission of proposals for use. No spoil site shall be located within 50 m of any watercourse, nor in areas of high ecological sensitivity. A photographic record shall be kept of all spoil sites for monitoring purposes, and must include photographs of before the site is used, as well as after re-vegetation



• The use of approved spoil sites for the disposal of hazardous or toxic wastes shall be prohibited unless special measures are taken to prevent leaching of the toxins into the surrounding environment. Such special measures shall require the approval of the relevant provincial or national authority. The Contractor shall be required to obtain the necessary authority approval

• Spoil sites shall be shaped to fit the natural topography. Slopes shall not exceed a vertical: horizontal ratio of 1:2. Only under exceptional circumstances shall approval be given to exceed this ratio. These sites shall receive a minimum of 75 mm topsoil and be grassed with a suitable seed mixture. Appropriate revegetation measures to minimise soil erosion shall be undertaken by the Contractor. The Engineer may only approve a completed spoil site at the end of the construction period upon receipt from the Contractor of a landowner’s clearance notice and a certificate certifying slope stability. The Contractor’s costs incurred in obtaining the necessary certification for opening and closing of spoil sites shall be deemed to be included in the tendered rates for spoiling

25. EXCAVATION, HAULING AND PLACEMENT Excavation, hauling and placement

• The Contractor shall provide the Engineer with detailed plans of his intended construction and maintenance processes prior to starting any cut or fill or layer. The plans shall detail the number of personnel and plant to be used and the measures by which the impacts of pollution (noise, dust, litter, fuel, oil, sewage etc.), erosion, vegetation loss and deformation of landscape will be prevented, contained and rehabilitated. Particular attention shall also be given to the impact that such activities will have on the adjacent built environment, as appropriate.



• The Contractor shall demonstrate his “good housekeeping”, particularly with respect to closure at the end of every day so that the site is left in a safe condition from rainfall overnight or over periods when there is no construction activity




PROJECT PHASE

26. EROSION AND SEDIMENTATION CONTROL Erosion and sedimentation control

• The Contractor shall protect areas susceptible to erosion by installing necessary temporary and permanent drainage works as soon as possible and by taking other measures necessary to prevent the surface water from being concentrated in streams and from scouring slopes, banks or other areas. A Method Statement shall be developed and submitted to the Engineer to deal with erosion issues prior to bulk earthwork operations commencing



• Runnels or erosion channels, which developed during the construction or maintenance periods, shall be backfilled and compacted, and the areas restored to a proper condition. Stabilisation of cleared areas to prevent and control erosion shall be actively managed. The method of stabilisation shall be determined in consultation with the Engineer. Consideration and provision shall be made for the suitable methods (or combination of methods).

• Traffic and movement over stabilised areas shall be restricted and controlled, and damage to stabilised areas shall be repaired and maintained to the satisfaction of the Engineer

27. SITE CLEAN-UP AND REHABILITATION Site clean-up and rehabilitation

• On completion of the construction works the Contractor shall ensure that all structures, equipment, materials (including concrete slabs and braai areas), waste, rubble, notice boards, fences and other temporary features are removed with minimum damage to the surrounding area. The Contractor shall clear and clean the site to the satisfaction of the Engineer. Cleared areas will require ripping and the re-spreading of topsoil to facilitate vegetative growth



• In the case of accidental spills of oil or chemicals during construction, the affected soil shall be dug out and replaced with fresh topsoil

• Rehabilitation of aquatic ecosystems shall be undertaken as per the requirements of the Supplementary EMP for Aquatic Ecosystems (Method Statement 3 of Appendix B)

• Planting and establishment of vegetation on areas disturbed during the construction phase of the project shall be undertaken as set out in the Plant Search & Rescue Plan (see Appendix C) and the Rehabilitation Plan

• Harvesting of suitable plant material should also be undertaken for rehabilitation, non-horticultural purposes (where appropriate) and mulching

• The re-integration of the new road into the landscape would also require the harvesting of rocks during construction for placement in suitable locations at completion of the works

• Provision should also be made for seed collection (from adjacent areas) of suitable species, as well as propagation of suitable plant material, for subsequent use in rehabilitation

• Adequate preparation and stabilisation of ground surfaces and slopes/embankments should be ensured in order to facilitate the rehabilitation process

• Maintenance of rehabilitated areas should be undertaken and should involve, amongst others, control of invasive alien plants, watering (when required), and replanting and repair of damaged areas

• Upon completion of all work, all rehabilitated areas shall be surveyed to ensure that sufficient plant cover and diversity is obtained. If deemed necessary, ongoing monitoring should be undertaken to ensure the long-term viability of rehabilitated areas




PROJECT PHASE

28. MONITORING AND AUDITING PROGRAMME Monitoring and auditing

• ROD Item 6.2.3.1 requires that a monitoring and auditing programme must be developed and implemented to assess compliance with the conditions stipulated in the ROD, the EMP and any other required plans prior to construction taking place. This monitoring and auditing programme must be included in the EMP. ROD Item 6.2.3.3 stipulates that the monitoring and auditing of the construction and operation of the activity shall be in accordance with the monitoring and auditing programme or any amendment thereof as approved by the relevant environmental authorities

SANRAL; Engineer; Contractor (SECO); PEM; ECO; Environmental auditor; EMC


• Based on the proposed management structure and roles and responsibilities for the administration, management, monitoring and auditing of environmental obligations set out in Sections 3.1 and 3.2 above, it is envisaged that the SECO, ECO, PEM, EMC and environmental auditor would be key role players in implementation of the required monitoring and auditing programme during construction. It is envisaged that relevant EMP requirements will be monitored and audited on the following basis:

Daily - SECO with support from ECO and PEM; Weekly/two-weekly/monthly - ECO with support from PEM; and Quarterly - EMC and environmental auditor

• DEA reserves the right to monitor and audit the development throughout its full lifecycle to ensure that it complies with the conditions of the ROD and other relevant provisions. Records of monitoring and/or auditing must be available for inspection to any relevant authority inspecting the development. Should monitoring and auditing results indicate that there are significant detrimental environmental impacts or non-compliance with the EMP and/or any other required plans/Method Statements, and/or with the conditions of the ROD, DEA reserves the right to take appropriate action (ROD Item 6.2.3.2)

• Any additional “water use” and other applicable authorisation/licence requirements with regard to monitoring and auditing, as may be specified by DWS and other relevant authorities, must be adhered to, as appropriate



6. CONCLUSION AND WAY FORWARD This EMP incorporates relevant requirements of the ROD issued on 19 April 2010 and specific environmental management measures relating to the design, construction and operational phases of the new road sections, river crossings/bridges with associated haul and approach roads, and toll plazas associated with the N2 Wild Coast Toll Highway project. As such, this EMP is considered to also serve the purpose of “site specific construction and operation EMPs”, as specified in the ROD, and is thus applicable to all separate contracts into which SANRAL may divide the project, as appropriate. Any further environmental conditions of other permits or licences to be issued for the project should be viewed as being part of the EMP. This EMP will be submitted to DEA for approval. SANRAL will be responsible for any further updating of this EMP, as appropriate. Compliance with the EMP forms part of the contract documents of all contractors working on the project, including (but not limited to) an agent, employee or any person rendering a service to SANRAL in respect of the works.

APPENDIX A

RECORD OF DECISION

APPENDIX B

SUPPLEMENTARY EMP FOR AQUATIC ECOSYSTEMS

APPENDIX C

PLANT SEARCH AND RESCUE PLAN

APPENDIX D

ALIEN AND INVASIVE SPECIES MANAGEMENT PLAN

APPENDIX E

LIST OF PROPOSED FINES

Documents

N2 WILD COAST TOLL HIGHWAY ENVIRONMENTAL …€¦ · M.Sc. (Botany), HDE . PROFESSIONAL REGISTRATION: Pr.Sci.Nat., CEAPSA . EXPERIENCE IN YEARS: 16 . EXPERIENCE: Fuad Fredericks has