Divisional Director
Eskom Transmission Division
PO Box 1091
Johannesburg
2000
Our Ref, : 99041/C/R
19th September 2003
Attention: Mr J Geeringh
Dear Sir,
Gamma-Omega 765 kV Transmission Line EIA:
Response to the Eskom Transmission Line Action Committee letter of 17 July 2003
We make reference to the abovementioned letter and your instruction to address the contents therein. It is our understanding that the Eskom Transmission Line Action Committee (ETLAC) is a recently formed committee, but that a copy of the Environmental Impact Report (EIR) has been handed to them prior to the date of their letter. It is not apparent that the writer of the above letter has read the EIR, and you have therefore requested us to prepare a response to the issues listed in the letter and to assist the writer in gaining a thorough understanding of the findings of the Environmental Impact Assessment (EIA) with particular focus on the Tulbagh valley area. However, as the Tulbagh valley cannot be considered in isolation in a study of this nature, it will be necessary to present the broader elements of the study in addition to the more site specific issues.
Introduction
It is necessary that EIRs provide a thorough and comprehensive account of the work undertaken in an EIA, and present a clear description of the findings of the study. The content of the document needs to be sufficient for the authorities to make a decision on the environmental acceptability of the development, but it should also be accessible to stakeholders for information and comment. For developments of the nature of a 520km Transmission line, the contents of the report become extensive and it is for this reason that careful planning was put into the structure of the document. It is the responsibility of stakeholders, interested and affected parties (I&APs), etc., to invest effort in reading the EIR, and the writer of the ETLAC letter of the 17th July is encouraged to do so, as this response will not be able to address the full extent of the study undertaken.
To assist in this, the Table of Contents of the EIR are presented as a `document map' at the front of the EIR and enables readers with different levels of interest to access the document as follows:
Overview level:
For the reader seeking a broad overview of the study area, main issues and findings.
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Chapter 1 - Summary of Project Findings
Appendix 5 - Maps of the study area
Chapter 6 - Conclusions and Recommendations
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Assessment level:
For the reader seeking an understanding of the study and assessment process, as well as the integration of all the environmental issues.
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Chapter 1 - as above
Appendix 5 - as above
Chapter 2 - Environmental Impact Assessment, giving information on route selection, description of the terrain and a listing of the environmental issues.
Appendix 1 - Impact Tables, giving concise summaries on each environmental issue.
Chapter 6 - Conclusions and Recommendations.
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Detailed Assessment:
Certain readers will have specific interests and may require further detail in these areas. Therefore in addition to the `Assessment level' chapters/appendices, the reader may choose to look into any of the following:
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Chapter 3 - Overview of the Cape Strengthening Programme, giving the background to the Transmission line proposals, details of the type of line, strategic planning issues, etc.
Chapter 4 - Approach and Methodology, giving assumptions and limitations to the study, the focus of the specialist investigations, impact assessment criteria, etc.
Chapter 5 - Public Involvement Process. This chapter gives details of the consultation programme, identification of stakeholders, advertising of the study, meetings, and a list of registered stakeholders.
Chapters 7 to 12 - Specialist study reports.
Chapter 7 - Bird studies
Chapter 8 - Ecology
Chapter 9 - Heritage
Chapter 10 - Social Impact Assessment
Chapter 11 - Soils
Chapter 12 - Visual Impact Assessment
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Due to the cost of producing and distributing copies of the EIR (approximately R1000/copy), many electronic versions were distributed. However, hard copies were made available at municipalities and libraries throughout the study area, including the following locations relevant to the ETLAC. These were not reclaimed after the closing of the comment periods and should still be available for inspection:
Witzenberg Municipal Offices (Ceres) & Main Library
Tulbagh Municipal Offices & library
Wolseley Municipal offices & library
Study Programme and Public Consultation Process
The study programme and public consultation process is based on sound Integrated Environmental Management Principles (IEM). The principles listed by Department of Environmental Affairs and Tourism (DEA&T) that are relevant to the public involvement were adopted, and these included inter alia:
Meaningful and timeous participation of I&APs.
Focus on important issues.
Due consideration of alternatives.
Accountability for information used for decision-making.
Application of “due process” particularly with regard to public participation in environmental governance as provided for in the Constitution and the National Environmental Management Act (NEMA)
(It is important to note that while the Constitution and NEMA places a great deal of emphasis on the rights of the public to participate and be heard, it is the Constitution which is specific in stating that these rights are not absolute, that there are corresponding obligations. Relating specifically to EIA studies, I&APs have a strong obligation to participate through the appropriate channels and at the appropriate times throughout the process and this participation should be conducted in good faith; as opposed to frustrating the process. This would include attending meetings and reading documentation and reports.)
Inclusivity: the needs, interests and values of I&APs must be considered in the decision-making process.
For the benefit of the ETLAC the timeline of the study is outlined here. The various channels that are referred to in the section above are listed in the second column.
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Activity / Event
(see Chapter 1 of the EIR - Section 4).
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Specific involvement of I&AP's from the ETLAC area (see Chapter 5)
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1
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The EIA study was initiated in September 1999
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Background Information Document (BID) prepared and distributed via municipal offices, Co-ops, regional and provincial govt. departments.
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2
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As part of the early stages of the Scoping Study a `Strategic Workshop' was held with key stakeholders on 28th January 2000, at Koeberg Power Station.
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Wolseley Municipality
Ceres Municipality
SAFCOL
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3
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A round of Public Open Days were held along the route in the second half of February 2000.
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Belmont Hotel, Ceres, 26th Feb.
Wolseley Community Hall, 28th Feb.
Tulbagh Town Hall, 1st March
Attendance of the Tulbagh Farmers Assoc. meeting 26th Feb
Meeting with Mr Patrys Theron (Farmers Assoc Chairperson) 28th Feb.
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4
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In March 2000 the study was put on hold for strategic planning reasons.
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5
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A bridging document was sent to all registered I&APs in November 2000.
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Interim information BID distributed as per first BID, but also posted to all registered I&APs.
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6
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The study continued in June 2001. Letters sent to all registered I&APs.
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Information document distributed as above, giving notice of date and location of availability of Draft Scoping Report (DSR).
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7
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Distribution of the Draft Scoping Report (DSR) in July 2001.
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Advertisements:
National - Sunday Times, Rapport, City Press, Engineering News.
Regional - Cape Argus, Cape Times, the Standard.
Local - Swartland Monitor, Witsenberg Herald
DSR locations
Ceres - Witsenburg Mun. Offices, Library, PLK
Tulbagh - Mun. Offices, Library, WPK
Wolseley - Mun. Offices, Library, Romansrivier Co-op.
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8
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Discussions with Farmers Associations along the route - July and August 2001.
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Ceres Library Hall - 1st August 2001
Ceres District Agric. Union
Koue Bokkeveld Agric. Union
Warm Bokkeveld Agric. Union
Wolseley Agric. Union
Tulbagh - 2nd August 2001
Tulbagh Farmers Assoc.
Tulbagh Agric. Union
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9
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Environmental Forum Workshops 13th to 17th August 2001. Date of written notification 16 July 2001
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Ceres - Belmont Hotel, 16 August 2001
Presentation and discussion of DSR, including route selection process. See list of invited delegates in Annexure 1.
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10
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Submission of Final Scoping Report to the authorities on 30th September 2001.
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11
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Specialist studies - September 2001 to February 2002.
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12
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Distribution of Draft EIR on 20th March 2002.
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Registered I&APs notified by letter dated 20th March 2002.
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13
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Closure of public comment period on 19th April 2002.
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14
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Submission of Final EIR (Addendum Report) to the Authorities on 30th April 2002.
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15
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Issue of Letter of Approval by DEAT
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Registered I&APs notified by letter dated 2nd April 2002.
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The project I&AP database is developed at the beginning of the study and is updated throughout the duration of the study. Much of the information disseminated at the various stages listed above would have been sent directly to the I&APs on this database, with the exception of the main reports (DSR and EIR). Annexure 1 lists the registered I&APs relevant to the Ceres, Agter Witsenberg, Tulbagh and Wolseley areas. There are over 180 for the area made up of; 32 from the agricultural organisations, 12 from local government offices, 105 landowners and 4 from tourism. The latter is perhaps most important as it is understood that one of the main areas of focus is tourism. It is then worth noting here that the following tourism representatives were kept informed of the progress and findings of the study:
Ceres Tourism Bureau,
Tulbagh Valley Publicity Association,
Wolseley Toerisme,
Wolseley Tourist Information.
The study covered a period of some two and a half years, involved a number of meetings and workshops in the local area and included an extensive information dissemination effort. It is therefore of concern that the ETLAC has become involved at this late stage. If it is indeed the overwhelming consensus of the general community, business and political leaders that any line through the valley is unacceptable, then (with the exception of Witzenberg Municipality and Witzenberg Agricultural Union) it must be questioned why these individuals and offices did not make use of the opportunities to do the same during the study process.
Route Selection
Before addressing the issues raised in the ETLAC letter, it is important to place the selection of the route in context.
The strategic issues surrounding the need for the new line are discussed in detail in the EIR. Assuming those arguments are accepted here, it must then be accepted that an additional line from the Mpumalanga power generation area is required to fulfil both current electricity supply reliability and future growth requirements in the Western Cape.
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See Chapter 3,
Section 2
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Following the existing 400kV Transmission lines initially appeared to be the best option, though the mountain region near Ceres was a concern. Routes to the north (via Clanwilliam) and south (via Worcester) were considered, but these were either likely to be much longer and/or more technically complex. As such the associated environmental impacts would also prove to be greater than for the route following the existing lines.
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See Chapter 1,
Section 5.3.3
Chapter 2,
Section 3.1,
Map 1b
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However, the Ceres mountain region (including the Witsenberge, Skurweberge, Watervalsberge and Elandskloofberge) still remained a concern from an environmental perspective, and other routes were considered.
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See Chapter 2,
Section 3.2,
Map 1a
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By the end of the Scoping Study, after consultation at both a regional and local level, the route alternatives were narrowed to three main options and one localised deviation (refer to the copy of Map 2a of the EIR, attached).
The `Southern Route' followed the existing 400kV lines past Ceres and Wolseley.
The `Central Route' (eventually became the `Preferred Route') follows the base of the Waboomberge, passes through the Agter Witzenberg and Tulbagh valleys and crosses the Obiekwaberge near Gouda. This is the route that passes just to the south of the town of Tulbagh. The basis for this route was to cross low points in the mountain ranges, this being seen to have both technical and environmental benefits.
(Note there was also the `Central Alternative' that offered a localised deviation through the Agter Witsenberg valley, but the route through the Tulbagh valley is the same as the `Central Route'. For the purposes of this letter, the `Central Alternative' is not considered in any detail here.)
The `Northern Route' leaves the existing 400kV lines just before entering the mountain region near Karoopoort. It deviates through the valley behind the Waboomberge before joining the `Central Route' just before the Agter Witzenberg valley. The basis for this route was to avoid the Ceres valley entirely. Similar effort was given for the Tulbagh valley, but the terrain to the north proved to be too high, rugged and inaccessible. Hence the `Northern Route' joins the `Central Route' near the Gydo Pass.
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See Chapter 2,
Section 3.3,
Map 2a
Section 5.2
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It is also important to note that the impact of a linear development such as a Transmission line is seldom of direct benefit to locations along the route; ie the environmental impact at any point is usually negative. Instead such developments are for the regional and national good. Choosing the best alternative is then a case of looking for the option with the least environmental impact. This can be somewhat subjective and therefore debatable, especially with stakeholders. To minimise the effects of this the following are relevant:
The environmental consultant has no vested interest in any of the locations along any of the routes.
The consultant also has nothing to gain from the development (or not) of the line.
The overall assessment in the EIR is the integrated assessment of a team of specialists, and not just from one person.
The study team was informed by I&APs who participated in the process (see Annexure 1).
The details of the assessments are provided such that the authorities may change the preferred route should they consider this to be appropriate.
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See Chapter 4
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The public consultation process is fully described in the EIR. There was particular activity in the Ceres-Tulbagh-Wolseley area for the duration of the study. Key members of the community were active in participating in the various meetings and were sent the various document packages. The involvement of the stakeholders listed in Annexure 1 was instrumental in the identification and assessment of routes through the Ceres valley, the Agter Witzenberg, and the Tulbagh valley.
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See Chapter 5
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Summary of Assessment
It is important to understand that the location of a line is determined not only by conditions at a point but by the conditions some way ahead and behind as well. This was considered in both selecting and assessing the route alternatives.
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There are two main routes through the Tulbagh valley: the Southern Route and the Central Route (the latter becoming the Preferred Route). A summary of the key issues relating to the two routes are given below. This is a very brief summary. It is necessary for the ETLAC to read the relevant sections of the EIR to see the greater detail of the assessment:
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See Chapter 2, Table 5
Section 5.2.3
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In terms of Avifauna (birds) the route of preference would be to follow the existing 400kV lines past Ceres and Wolseley (the Southern Route). Under these circumstances the risk of increased bird mortality due to collision would be low. However, with the recommended mitigation measures (bird flappers on the new line at key locations) the impact of the Central Route is still anticipated to be low.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables p30-31,
Chapter 7
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In terms of indigenous flora, the Central Route is considered to be the best option as the natural vegetation is more disturbed, mainly due to agriculture and urban development. Following the existing 400kV lines the Southern Route would impact on important Central Mountain Renosterveld in the Elandskloof Nature Reserve and on the lower slopes of the Witsenberge in the Wolseley area.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables p32-35,
Chapter 8
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Erosion is also a particular concern affecting the natural environment, and this is seen to be a greater problem on the Southern Route where the mountain crossings are much higher, less accessible and more sensitive to erosion. While the potential for erosion is also significant along the Central Route, there is better access and greater potential for monitoring and rehabilitation.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables -p29,
Chapter 11
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For indigenous fauna, the main concern is the Geometric Tortoise that exists in pockets of Renosterveld throughout the area, but is more prevalent on the Southern Route. Hence again the Central Route is preferred in this regard, though the farm Skilpadrug, just south of Tulbagh, is known to be a location of the tortoise. Careful management during construction will be required if the lines passes through this site, or the line should be moved approximately 500m northwards.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables -p28,
Chapter 8
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From a Cultural heritage perspective the Southern Route offers the least impact, as the new line would run next to the existing 400kV lines. There are a number of historically significant sites along the Central Route, mainly in the Agter Witsenberg; a possible VOC cannon site, the possible remains of a British fort, and the old wagon trail to Wuppertal. The `sense of place' of the historic slave settlement of Steinthal near Tulbagh will be negatively affected, as will possible war grave sites in the Ceres mountains. The old wagon trail between Tulbagh and Gouda is also close to the Central Route. With the exception of the `sense of place' at Steinthal, all of these sites can be avoided by careful placement of the towers, and careful management of the construction process will be required. However, the Southern Route would be the preferred route from a heritage perspective.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables p37-39,
Chapter 9
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The social impact assessment (SIA) identified the resettlement, disruption and safety of communities along both the Southern and Central Routes to be potentially significant. Communities in Prince Alfred Hamlet, Chris Hani Settlement (both Central Route) and Ceres may be affected, though the proximity of the Bella Vista community to the Southern Route is of particular concern as the relocation of properties may be required. On either route some resettlement may be required, but the impacts on the social fabric of communities along the Southern Route were rated greater.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables p3,8,11-23,
Chapter 10
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The height of the 765kV Transmission line and the size of the towers will make the development highly visible whichever option is adopted, though following the existing 400kV lines (Southern Route) is considered to offer the least visual impact.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables p4-6,
Chapter 12
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Initial route identification for alternatives to following the existing lines placed particular emphasis on the visual impact. With particular reference to the Central Route the following refer:
Avoid crossing high points on ridges to avoid the silhouette of the pylons.
In lower areas set the line against complex backdrops (towers more difficult to see) - this is achieved in particular along the Waboomberg, but also on the Skurweberge and Witsenberge.
Follow `low' points in the valleys such that the visual impact from the main viewing points (eg main roads) is minimised. This is seen to be achieved in part in the Tulbagh valley and in the Agter Witsenberg.
Cross over main roads (critical viewpoints) at right angle as this exposes the line to viewers for the shortest period.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables p4-6,
Chapter 12
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The route through the Tulbagh valley (the Central Route) was identified after input was received from the local community, and in particular from Steinthal School and the Farmers Union. By siting the line to the south of the town, there would be much less impact on landuse (agricultural activities) and the visual impact would be less. The main viewpoint would be the R46 and the line would be visible to road users travelling from Tulbagh to Gouda. For road users travelling into Tulbagh (north of the R46), the impact is considered to be somewhat less as the line is visible for a brief period as one passes under the line. The line will still be noticeable, but the impact will be reduced by following the route through the valley as recommended in the EIR.
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Chapter 2,
Section 5.2.3,
Chapter 12
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Tourism impacts tend to follow the same trend as the visual impact. The Tulbagh valley and the Gydo Pass are seen to receive the greater number of visitors to the area and the Central Route will offer the greatest impact of all the route options (the Southern Route would be the preferred route in this case). However, given the mitigation measures set out in the EIR and outlined in brief above, the anticipated impacts on tourism to the areas is reduced to moderate (from potentially high).
(It is important to note that the growth of the tourism industry in the area was still speculative in many respects, and therefore difficult to quantify in terms of impacts. Tourism bodies were consulted and given the opportunity to participate in the study, and their input was used to make the final assessment. Where these bodies chose not to participate, it was assumed the potential impacts were not perceived to be significant. In this case, the planning of this new line should then inform urban and tourism planners in the review and updating respective development plans.)
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables -p7,
Chapter 10
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Fire fighting and safety. This was not a significant issue along much of the study length of the line, but was raised by the local community as a particular concern in the Tulbagh and Wolseley areas due to serious fires in recent past. The existing 400kV lines past Wolseley have proved to be an obstacle to effective and safe fire fighting. Fire fighters cannot work under the live lines during fires and water bombing from the air is also done at high risk. That the existing 400kV lines are immediately adjacent adds to the problem. The areas around Wolseley and north of Tulbagh are the most problematic for forest fires. In this instance, the Central Route is the preferred option.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables -p10
Chapter 10
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The above issue leads to the consideration of one of the main technical issues. Due to load capacity and stability requirements it proves to be very difficult to switch off one of the 400kV lines. During forest fires it may be required to switch off both as they are next to each other. For this reason it is necessary to seek a separate route for the new line. On the basis of the environmental considerations outlined above, the Central Route is the preferred option.
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Chapter 2,
Section 5.2.3,
App 1 - Impact Tables -p2
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It is the nature of environmental impact assessments that once the impacts in the individual specialist fields of focus have been analysed, they then need to be integrated to form an overall assessment of the development on the environment. This means comparing, for example, the sensitivity and significance of the social issues to the ecological issues. As indicated previously, this requires careful consideration of the information gained during the study and debate within the study team. The outcome of this process was that the most sensitive issues were considered to be:
The potential impacts on the social fabric of the Ceres, Wolseley areas (Southern Route) are higher in comparison to that of the Tulbagh valley (Central Route),
The safety issues regarding fire fighting under three parallel Transmission lines near Wolseley (Southern Route),
The stability of the network and therefore the reliability of supply of the Southern Route when compared to the Central Route, and
The sensitive Renosterveld flora in the Elandskloof Conservation area (Southern Route). The conservation value of this habitat is seen to be significant in the regional context and, unlike other fauna and flora concerns, will experience damage during construction and the rehabilitation process will be more difficult to manage.
Within each of these the Central Route offers the least impact. The majority of the other issues can be mitigated or are manageable within the Central Route environment. The impacts on birds can be minimised by strategic placement of diverters and bird guards where appropriate. Other ecological impacts are of such a nature that they can be avoided by careful selection of the pylon footprints and good management during construction. Erosion is less of a concern (but still needs management) on the Central Route. The impacts on tourism are not seen to be as significant when considered in parallel with other socio-economic aspects such as resettlement, disruption and safety. The historic sites along the Central Route can be avoided by careful placement of the pylons and good construction management.
With careful design and planning, construction management, and long-term maintenance the anticipated levels of impact of the preferred route are considered to be as follows:
Aspect
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Level of significance after mitigation on the Central Route
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Avifauna
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Low
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Ecology - fauna & flora
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Low
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Cultural heritage
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Moderate to low
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Social & socio-economic (incl. tourism)
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Moderate to low
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Soils
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Moderate
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Visual
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Moderate
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Technical (incl. Fire fighting)
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Low
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Please note: The table above is a very narrow summary of the impact assessment. The Impact Tables of the EIR (Appendix 1) offer a more comprehensive summary, and the individual specialist assessments provide the detail of the assessments. The above table is intended to assist the ETLAC in following the overall assessment process undertaken by the study team. Should this be insufficient and further detail be required the EIR must be inspected in more detail.
The integration of the different issues for the different routes is not a simple task, and it will include a level of subjective judgement. The recommendation of the Central Route as that offering the least environmental impact was made by the study team as a whole, thus bringing together the different environmental aspects.
Specific Responses to the ETLAC Letter of 17 July
The following are responses to item 2 in the abovementioned letter:
“Impact on the tourism industry”
See above. The line will be noticeable, but it has been located such that the main attractions for visitors to the area are minimally affected.
“Impact on business opportunities in general”
Separate to the matter above, it is not expected that there should be any direct change to business opportunities in general. The new Transmission line is intended to support the economic growth of the region as a whole, thereby indirectly benefiting towns like Tulbagh.
The main business sector that will be directly affected will be the agricultural sector. However, the route has been chosen such that current landuse can be continued after the construction of the line.
“Impact on the growth of the economy”
The growth of the regional economy is expected to be a key driver of the local economies of towns in this area. It is understood that present electricity supplies to the Western Cape is in a critical state in terms of both reliability and capacity (there have been a number of notable blackouts in recent years!). The principal reason for the development of the proposed line is to address these issues as there are yet to be any viable alternatives that will meet the short-term needs. (The future of any gas fired power station or any additional nuclear facility remains uncertain, and the wind turbine pilot project is still too small.) Hence it is understood there is a greater risk to the regional economy, and therefore local economies, if a new line is not provided to stabilise and add capacity to the existing network.
“Impact on job creation”
The construction and operation of the new line is unlikely to provide anything significant in terms of job creation within the local environment. Both require specialised technical skills.
“Impact on previously disadvantaged empowerment projects”
No such projects were raised in the Tulbagh area during our study. There were a number of RDP housing projects identified of which the Chris Hani scheme south of Tulbagh is relevant. The new line should not impact on the development of that settlement. It is unlikely that any such project should be affected by the new line unless it falls within the proposed servitude. To date we are not aware of any such project.
We are, however, aware of the initiatives at the Steinthal School, and we have had considerable and very useful input from the head of the school in this regard. Ds Dreyer was instrumental in selecting the route near the school.
It is important that community representatives and municipalities were invited to participate in the study. Any input provided by them has been captured and used in our evaluations. It is similarly expected that the proposed new line would have a presence in any new planning initiatives in the area as the municipal and community representatives should now be aware of the proposed development.
“Possible health ramifications”
The primary health concern is that of Electric and Magnetic Fields (EMFs) on human and animal health. As set out in the Impact Tables (Appendix 1, p 8) of the EIR, the 80m servitude width is set in part to deal with the uncertainties that exist in this regard. Beyond the 80m servitude the EMFs drop to background levels. Eskom Transmission follows the precautionary approach, preventing anyone living or working (in a workplace) within the 80m servitude, and recommending that feedlots, chicken farms, etc. are also kept out of the servitude. However, the servitude can still be used for grazing and planting, as these present limited exposure.
There are also health issues associated with the construction process, and are minimised by careful location of the construction camps, and management of the construction teams. This is addressed in the Impact Tables in some detail.
“Sterilisation of future development”
The servitude will be established giving Eskom the right to limit any future development. Clearly buildings and urban development in the servitude will be very limited, as will certain commercial farming activities such as forestry and sugar cane (mainly from the fire control perspective). The future landuses are negotiated with the landowner at the time of servitude establishment, and compensation is paid accordingly.
However, most agricultural practices are able to continue within the servitude, including grazing and most cropping activities. There are also few concerns in placing other services across the servitude (roads, pipelines, etc.), though permission from Eskom will still be required. In the urban environment, such servitudes have also been utilised as public open space and have been landscaped accordingly.
“Harmful effects to agriculture”
Stock pens, feed lots, chicken houses/battery farms and similar intensive livestock farming practices should not be established within the 80m servitude. As described above, this is a precautionary measure, as research into the effects of EMFs remain inconclusive. There are few, if any, of these along the route in question, and these would be relocated in negotiation with Eskom. There is no known harmful effect on crops.
Other threats to agricultural practices are the maintenance of access roads (particularly with regard to erosion) and the maintenance and closure of farm gates (allowing animals to escape, cross-breed, etc.). These are standard issues requiring open liaison with the landowner and the regional Eskom manager.
“Ecological impacts on the breeding of the various species of indigenous cranes and other fauna and flora”
The main impact on fauna and flora occurs during construction. This line has been routed away from as many of the sensitive areas as possible, and much of the Central Route crosses land disturbed by agriculture. However, as at any location, the servitude needs to be rehabilitated to conditions similar to that before construction.
The sensitive flora environments exist mainly on the Southern Route on the Elandskloofberge and in the Voëlvlei Conservation area. There are a number of sensitive fauna sites, these being the geometric tortoise that occurs on a number of farms, but mainly along the Southern Route. There is a farm, Skilpadrug, just south of Tulbagh that needs to be avoided, and this is expected to be easily achieved by running the line to the north of the farm.
The main threat to the cranes is collision with the lines. There is a risk of this occurring, but it is the opinion of the avifauna specialist that this risk can be minimised by the placement of bird diverters at key locations on the line. These would include the sections just north of the Voëlvlei dam.
No concerns have been raised relating to the breeding of any of the species along any of the routes.
“The severe negative visual impact that the Transmission line would have on the valley.”
The Transmission line will be noticeable in any location. As stated above, this route is not the preferred route from a visual perspective. The impacts have been reduced by careful alignment within the topography. Nevertheless, the fact remains that nobody wants a line of this nature in their vicinity and the arguments have been equally vehement on other routes. It is important therefore that it is understood that other environmental issues have been considered in the selection of this route as the preferred line.
We trust the issues have been answered in sufficient detail to allow the ETLAC a reasonable understanding of the assessment to date. Further enquiries in this regard should be preceded by a closer inspection of the EIR.
It would also be very useful to understand the makeup of the ETLAC, as it is clear that those included in the list to receive a copy of the letter of the ETLAC letter of the 17th July were part of our database and were encouraged to participate in our study.
Finally, it is noted that queries relating to Danie Boshoff's involvement in the valley have been raised. It is perhaps worth noting that the servitude negotiation process is not subject to environmental authorisation (as is the construction of the line). Technically, Eskom Transmission has the right to proceed with servitude establishment at any stage. However, we support the withholding of further negotiations until this matter has been addressed.
Kindly address all queries to Stuart Dunsmore.
Yours faithfully,
JK Haumann Pr.Eng.
Director
PD Naidoo & Associates