Annex C

Public Participation

C1

PUBLIC PARTICIPATION

C1.1

PRELIMINARY DATABASE

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

C1

PUBLIC PARTICIPATION

C1.1

PRELIMINARY DATABASE This is an initial database and the database will be updated as the EIA process progresses.

Table 1.1

Stakeholder Database Name Mr J Creighton (John) Mr C Darrington (Craig) Mr G Harper (Garth) Ms P Mashinini (Precious) Ms C Masimula (Christina) Mr S Naidoo (Steven) Mr D Phaleng (Dipitseng) Mr M Reuter (Marcus) Mr S Thomas (Stanley) Ms J Bodenstein (Janet) Mr I Gildenhuys (Ian) Mr G Oelofse (Gregg) Mr O Oswald (Ossie) Ms K Spalding (Katy) Mr M Theron (Morne) Mrs P Titmuss (Pat) Mr G Visser (Gavin) Mr K Wiseman (Keith) Ms F Albertus (Feroza)

Position

Organization

Manager

Harbour Bridge & Suits

Technical Manager

CTICC

Environmental Specialist

Chevron

Envirionmental Co-Ordinator

BP

Facilities Manager

V&A Waterfront (Pty) Ltd

Environmental Advisor

Shell South Africa (Pty) Limited

General Manager

Royal Cape Yacht Club

Elgin Brown & Hammer

FFS Refiners CCT Dept Env. Planning City of Cape Town Environmental Resource Management - City of CT City of Cape Town Environmental Professional

Senior Environmental Professional City of Cape Town City of Cape Town Environmentalist Fire Chief

Mr G Arendse (Gottlieb)

Environmental Officer Director: Pollution & Waste Mangement

S Arendse ()

Waste Management Licensing

Mr D Colly (Dave) Mr D Daniels (Derril) Ms R de Kock (Rene)

Statutory Control

Mr L Dyabooi () Ms R Gelderbloem (Ruby) Mr E Hanekom (Eddie)

Dep Director: State Property Holdings & Asset Man Director: Waste Disposal Management

Mr P Harmse (Peter) Ms M Hughes (Megan) Ms D James (Debbie)

Asst. to Regional Man & Office Admin

Mr G Louw (Gustav)

Principal Officer

Ms N Magubane (Nelisiwe)

Director General

Mr G Mahlalela (George)

Director General Deputy Director: Integrated Coastal Management Directorate: Administration Support

Dr D Malan (Niel) Mr C Mangcu (Chumani)

City of Cape Town

ENVIRONMENTAL RESOURCES MANAGEMENT

CMC Administration Department of Environmental Affairs WCape Provincial Gvt: Env Affairs & Dev Planning Department of Environmental Affairs and Developmen South African Maritime Safety Authority (SAMSA) Department of Water Affairs (DWA) South African National Roads Agency Ltd Department of Environmental Affairs and Developmen Department of Public Works Department of Environmental Affairs and Developmen Department of Environmental Affairs and Developmen National Ports Authority South African Maritime Safety Authority (SAMSA) South African Maritime Safety Authority (SAMSA) National Government: Dept of Energy National Government: Dept of Transport Marine and Coastal Management : Oceans and Coasts Marine and Coastal Management : Oceans and Coasts

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Name

Position

Dr M Mayekiso (Monde)

Deputy Director General

Mr S Mokoena (Smunda)

The Chief Executive Officer

Mr M Mpaka (Masivuye)

Unknown

Mr M Mukota (Moses)

Environmental Officer: Oil Spills

Ms N Ngcaba (Nosipho) Ms N Ngele (Nobubele)

Director General Director General (Acting)

Ms A Njobeni (Asanda)

Unknown

Adv S Nogxina (Sandile)

The Director General Chief Directorate: Integrated Coastal Mgmt

Dr R Omar (Razeena) S Sauka (Siyasanga) G Croxford L Makrexeni (Lunga) The Tenant The Tenant The Tenant The Tenant Mrs P Titmuss (Pat)

Dr J Augustyn (Johan) Mr A Barnes (Anthony) Ms/Mr R Britten (Robyn)

Cape Town City Council Chevron Refinery Chevron South Africa (Pty) Limited Telkom Friends of Rietvlei Acting Director: Offshore Resource Management Executive Director: Environmental Mgmt

Ms A Duffell-Canham (Alana) Mr R Ellis (Rudi)

Head of Department

Mr P Herselman (Paul)

Acting Land Use Manager

Mr MAR Khan () Mr B Layman (no LPG Saldanha mailing) (Brandon)

Chief Director

Mr H Linde (Hans) Mr T Manyathi (Thami)

FFS Refiners (Pty) Ltd

Tenant

Pollution & Waste Mangement Land Use Advice, Scientific Services

Dr J Leaner (Joy)

Organization Marine and Coastal Management : Oceans and Coasts National Energy Regulator of South Africa (NERSA) Department of Environmental Affairs Department of Environmental Affairs National Government: Dept of Environmental Affairs National Gov Dept of Water Affairs National Development Agency (NDA) National Government: Dept of Mineral Resources Marine and Coastal Management : Oceans and Coasts Department of Environmental Affairs JBS

Land Use Admin Directorate Pollution Management Air Quality Sec Deputy Directo Atmospheric Polution

Ms S Martin (Stacy)

Head of Department Planner: Strategic & Integrated Planning

Mr A Mohamed (Ayub)

Director: Spatial Planning

Mr S Mpakane (Sivuyile)

The Regional Manager

Mr J Peters (John)

Head of Department Environmental Officer: Air Quality Management

Mr A Schoeman (Ambrose) Mr C Wijk (Calvin) Mr N Wiltshire (Nick) Mr EG Booysen (Elrico Godfrey) Mr D Georgeades (Dimitri) Ms A Haycock (Alison) Ms M Naicker (Mona) Mr S Norton (Simon) Ms S Ralston (Samantha)

Western Cape Provincial Government WCape Provincial Gvt: Env Affairs & Dev Planning WCape Dept Environ Affairs & Development Planning Provincial Government WC: Cape Nature Western Cape Provincial Government Western Cape Provincial Government Department of Water Affairs Western Cape Region Western Cape Provincial Government WCape Dept Environ Affairs & Development Planning WCape Dept Environ Affairs & Development Planning Western Cape Provincial Government WC Provincial Government: Transport & Public Works WCape Provincial Gvt: Env Affairs & Dev Planning Western Cape Department of Mineral Resources WCape Prov Gvt: Dept Economic Development&Tourism Provincial Administration Western Cape Heritage Western Cape Heritage Western Cape

Environmental & Heritage: Regional Manager Environmental Manager

City of Cape Town FFS Refiners (Pty) Ltd

Company Secretary

FFS Refiners (Pty) Ltd

Environmentalist

Wildlife & Environment Society of SA (WESSA)

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Name

Position

Organization

N Salie (Nathmi)

Environmental Specialist Refining & Supply

Chevron Refinery

Stanley Thomas Mr G Sieraha (George)

Heritage & Env Portfolio

Mr G Sieraha (George)

Chairman Corporate Environmental Advisor (DASA)

Dipitseng Phaleng Alvin L Cope

ENVIRONMENTAL RESOURCES MANAGEMENT

FFS Refiners (Pty) Ltd Greater Cape Town Civic Alliance (GCTCA) Cape Heritage and Development Forum Shell SA Marketing PGWC

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

C1.2

ADVERT

C1.2.1

Initial Notification

Figure 1.1

Copy of the English Advert

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.2

Copy of the Afrikaans Advert

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.3

Proof of advert placed in the Cape Times

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.4

Proof of advert placed in the CapeTowner

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.5

Proof of advert placed in Die Burger

C1.2.2

Draft Scoping Notification An advert will be placed in the Cape Times, the Cape Towner, and Dir Burger on Thursday December 15 2011. Proof of placement will be provided in the Final Scoping Report.

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.6

Copy of the English Draft Scoping Ad

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.7

Copy of the Afrikaans Draft Scoping Ad

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

C1.3

BACKGROUND INFORMATION DOCUMENT

Figure 1.8

Copy of Background Information Document, Pg1

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.9

Copy of Background Information Document, Pg 2

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.10

Copy of Background Information Document, Pg 3

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.11

Copy of BID Distribution, Pg 4

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

C1.3.1

Proof of BID Distribution via e-mail

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Normal template

Page 1 of 2

Linda Slabber From:

Linda Slabber

Sent:

04 October 2011 15:11

To:

Linda Slabber

Subject:

Proposed fuel storage facility at the Port of Cape Town - Burgon Oil BID

Attachments: Burgon Oil_BID_Initial NotificationV1.0.pdf Bcc:

'[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'

Dear Stakeholder Transnet National Ports Authority (a division of Transnet Limited) has proposed the establishment of a coastal fuel storage facility, distribution facility, and associated infrastructure on a portion of land measuring 30,452m² on the Eastern Mole, Port of Cape Town. Burgan Cape Terminals (Proprietary) Limited has been awarded the tender to develop the facility and Environmental Resources Management (ERM) has been appointed as the independent Environmental Assessment Practitioners (EAP) to undertake the Environmental Impact Assessment (EIA). Please find the Background Information Document attached which provides stakeholders with information about the proposed development, how to register as an I & AP, as well as information about the Scoping and EIA process. Should you have any queries please do not hesitate to direct your comments to Linda Slabber of ERM at: Tel: 021 702 9100 Fax: 086 632 5816 Email: [email protected] Postal address: Postnet Suite 90, Private Bag X12, Tokai, 7966 Please clearly state the DEA&DP and ERM reference numbers on all correspondence as indicated below DEA&DP Ref: E12/2/4/2-A2/75-3030/11 ERM Ref: 0142769

Linda Slabber ERM Southern Africa

04/10/2011

Normal template

Silverwood House,Block A Silverwood Close, Steenberg Office Park Steenberg, 7945 Cape Town, South Africa Tel: +27 21 702 9100 Fax: 086 662 2228 Mobile: +27 84 409 9641 [email protected] www.erm.com

04/10/2011

Page 2 of 2

C1.3.2

Proof of BID Distribution via post

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

C1.4

SITE NOTICE

Figure 1.12

Copy of the site notice placed on site

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.13

Proof of site notice placement on the site boundary, zoomed in

Figure 1.14

Proof of site notice placement on the site boundary, zoomed out

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.15

Zoomed in site notice placed at the harbour

Figure 1.16

Zoomed out site notice placed at the site

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Figure 1.17

Zoomed in site notice at the Royal Yacht Club

Figure 1.18

Zoomed out site notice at the Royal Yacht Club

C1.5

ALL COMMENTS RECEIVED TO DATE

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

C1.6

COMMENTS AND RESPONSE REPORT

ENVIRONMENTAL RESOURCES MANAGEMENT

BURGAN CAPE TERMINALS (PROPRIETY) LIMITED

Table D1

In favour or against the project Favour

Construction, mitigation

Will the site be managed through an environmental management system to facilitate responsible environmental practices and compliance with legal requirements? Emergency procedures need to be done in conjunction with FFS. Cumulative risk and impact in harbour

Chevron South Africa E-mail: Initial (Pty) Ltd-Nathmi Salie Notification

Since Chevron's Cape Town Refinery is dependent on product transfers to and from the Tanker Basins directly adjacent to the proposed developments, the initial concern would be the continued and uninterrupted service delivery to the refinery, keeping in mind the sharing of the narrow access road between the tanker basins and the proposed development area. FFS refineries tank farm is adjacent to the proposed site and is classified as an MHI. What would the cumulative risk/s be with the addition of the proposed tank farmfor FFS and Transet? Will ambient air sampling be undertaken?

E-mail: Initial Notification

E-mail: Initial Notification E-mail: Initial Notification E-mail: Initial Notification

FFS Refineries (Pty) Ltd- Alison Haycock City of Cape Town- D Georgeades

FFS Refineries (Pty) Ltd- Alison Haycock

Yes. Samples will be taken during the Air Quality Impact Assessment done by a Air Quality Specialist Yes, this is the intention.

E-mail: Initial Notification E-mail: Initial Notification

FFS Refineries (Pty) Ltd- Alison Haycock FFS Refineries (Pty) Ltd- Alison Haycock

Noted.

These risks will be explored in the impact assessment as well as during the MHI. Mitigation options during the construction phase will be discussed during the final scoping phase.

This is noted and agreed.

These risks will be explored and taken into account in the MHI risk assessment for the development.

This will be taken into account in the MHI process that will be undertaken for the proposed development. Issues can be discussed during the public participation process. Should a focus group meeting be required in this regard, it can be arranged. This will be taken into account in the MHI process that will be undertaken for the proposed development. A traffic impact study will be undertaken which will investigate access and traffic issues.

Response from Project Team

FFS Refineries (Pty) Ltd- Alison Haycock

E-mail: Initial Notification

FFS Refineries (Pty) Ltd- Mona Naicker

MHI risk changes

E-mail: Initial Notification

E-mail: Initial Notification

FFS Refineries (Pty) Ltd- Mona Naicker FFS Refineries (Pty) Ltd- Mona Naicker

Source

Commentator(s)

Common interest issues

Issues/Comments Raised Primary concerns The proximity of the facility to FFS Refineries site within the Eastern Mole

Comments and Responses Report

Issues/Comments Raised Traffic The involvement of this Branch will only be in terms of the traffic impact during construction as well as during its operation thereafter Vehicular access will be via Table Bay Boulevard (PMR9) and /or Marine Drive (PMR 77) and any significant traffic impact on these 2 Proclaimed Main Roads caused by this proposal will need to be comment on, approved by both the City of Cape Town and this Branch. It is not clear if any application to the LUPO is required, but if so, this Branch will be asked to comment by the Local Authority. As far as your NEMA application is concerned, this Branch offers no objection Minimizing Negative Impacts on Biodiversity As part of the commenting process, CapeNature’s involvement relates specifically to the impact of the proposed development activities on the biodiversity and ecological aspects of the receiving environment. CapeNature expects that a precautionary and riskaverse approach be adopted towards those projects which may result in substantial detrimental impacts on biodiversity and ecosystems, especially the irreversible loss of habitat and ecological functioning in sensitive and threatened ecosystems (as identified by the National Biodiversity Assessment2) or Critical Biodiversity Areas (as identified by systematic conservation plans, Biodiversity Sector Plans or Bioregional Plans).

Source E-mail: Initial Notification E-mail: Initial Notification

E-mail: Initial Notification E-mail: Initial Notification E-mail: Initial Notification

Commentator(s) PGWC- Alvin L Cope

PGWC- Alvin L Cope

PGWC- Alvin L Cope

PGWC- Alvin L Cope

CapeNature

The draft scoping report will identify any issues. Should further investigation and assessment be required, this will be done during the EIR phase. CapeNature will be informed of any findings.

Noted.

Noted.

Noted.

Noted.

Response from Project Team

Issues/Comments Raised All reports must firmly demonstrate how the proponent intends complying with the principles contained in section 2 of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended3 (NEMA), which, amongst other things, indicates that environmental management should: · Sequentially aim to avoid, minimise or remedy disturbance of ecosystems and loss of biodiversity; x Avoid degradation of the environment; x Avoid jeopardising ecosystem integrity; x Pursue the best practicable environmental option by means of integrated environmental management x ·Protect the environment as the people’s common heritage; x Control and minimise environmental damage; and x Pay specific attention to management and planning procedures pertaining to sensitive, vulnerable, highly dynamic or stressed ecosystems. These principles serve as guidelines for all decisionmaking concerning matters which may affect the environment. As such, it is incumbent upon the proponent to show how proposed activities would comply with these principles and thereby contribute towards the achievement of sustainable development as defined by the NEMA, as amended Guidelines and Biodiversity Plans

Commentator(s) CapeNature

Source E-mail: Initial Notification

Response from Project Team Findings to date are that the site is largely devoid of vegetation with only a sparse cover of grass. Any impacts associated with the marine environment will be taken into further consideration.

a. Brownlie S (2005) Guideline for involving biodiversity specialists in EIA processes: Edition 1. CSIR Report No ENV-S-C 2005 053 C. Republic of South Africa, Provincial Government Western Cape, Department of Environmental Affairs and Development Planning, Cape Town2. b. De Villiers C, Driver A, Clark B, Euston-Brown D, Day L, Job N, Helme N, Holmes P, Brownlie S and Rebelo T (2005) Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape, Fynbos Forum and Botanical Society of South Africa, Kirstenbosch, Cape Town5

With a view to adequately assessing impacts on biodiversity, we request that your environmental impact assessment is informed by the following documents. The implementation of relevant recommendations and / or actions as stipulated in these documents should be critically considered, regardless of whether a Basic Assessment, Scoping & EIA, Planning approval or any other authorisation process is to be undertaken.

Issues/Comments Raised The Western Cape Department of Environmental Affairs and Development Planning (DEA&DP) has produced a series of guideline documents that provide clear guidance on the EIA process4. Specifically, they aim to improve the capacity of environmental assessment practitioners (EAP’s) to draft appropriate terms of reference that meet the information requirements for informed environmental decisions. In addition the Fynbos Forum Ecosystems Guidelines for Environmental Assessment in the Western Cape provides appropriate terms of reference for Botanical Assessments. By meeting the requirement for accurate and relevant information on time, EAP’s can support efficient and accountable decisionmaking.

Commentator(s) CapeNature

Source E-mail: Initial Notification

Response from Project Team

Issues/Comments Raised Commentator(s) c. The National Spatial Biodiversity Assessment CapeNature (2004) – NBA 2011 d. The most recent conservation plans and their associated reports and guidelines are available at the SANBI Biodiversity GIS Unit website6. The Land Use Decision Support (LUDS) tool is particularly useful, but please note that while this tool can help identify potential issues, it does not constitute a biodiversity assessment. e. Biodiversity Sector Plans for municipalities, where available. f. The Western Cape Provincial Spatial Development Framework: Statutory Report (2009) (Department of Environmental Affairs and Development Planning Biodiversity ‘red flags’ in the Western Cape The following factors must be taken into account CapeNature during project planning and assessment: a. CapeNature does not support activities that may negatively impact on the following habitats and their ecological functioning: i. Rivers, wetlands, groundwater-dependent communities or ecosystems, flood plains and estuaries, tidal flats or salt marshes. ii. Viable and / or connected habitat in Critically Endangered and Endangered ecosystems. iii. Any area that has been identified as a Critical Biodiversity Area or Ecological Support Area as identified by the latest systematic conservation planning initiative. iv. Any other special habitats that may contain a unique signature of species e.g. dolomite outcrops, quartz or ferricrete patches. v. Any habitat that may contain rare, threatened or range-restricted floral or faunal species. vi. Natural habitat in an ecological corridor or along a vegetation boundary (including frontal dune systems). vii. Formally declared Mountain Catchment Areas.

Response from Project Team These are not applicable to the proposed site as vegeta6ion is not present on site.

Noted. Impact on the marine environmental will be taken into account.

Source E-mail: Initial Notification

E-mail: Initial Notification

Issues/Comments Raised Commentator(s) Appropriate buffers must be determined by a CapeNature suitably qualified specialist to avoid impacting on these habitats and particular attention should be paid to avoiding the loss of intact habitat, maximising connectivity at a landscape scale, maximising habitat heterogeneity and reducing fragmentation at a local and regional scale. Please also note that an infestation by alien plants does not necessarily mean that an area is not important for biodiversity conservation. b.The Cape Floristic Region is largely a fireCapeNature dependent system and natural fire regimes must be maintained and managed in the landscape. The exclusion of fire from certain habitats will be considered unacceptable as this may ultimately cause the loss of species. Where appropriate, the location of fire breaks should be indicated and these fire-breaks may be considered part of the development footprint. A fire-risk assessment can help inform an appropriate layout for developments adjacent to fireprone vegetation

Response from Project Team Noted.

This is not applicable to the proposed site.

Source E-mail: Initial Notification

E-mail: Initial Notification

Issues/Comments Raised Commentator(s) c. Water is a limited resource in the Western Cape. CapeNature Water requirements for proposed activities and the potential impact on broader surface and underground water resources must be rigorously assessed and considered by an aquatic specialist, including the cumulative impact if other developments are also taking place in an area. Cumulative impacts on infrastructure such as Waste Water Treatment Works must also be considered. Groundwater use for bulk supply purposes and irrigation must be assessed rigorously with specific reference to the possible groundwater-surface water interfaces. Groundwater use assessments must include the identification of possible groundwater dependent ecosystems and / or possible interfaces with surface resources. Aquifers need to be described in terms of: aquifer type, aquifer characteristics, aquifer condition, as well as aquifer recharge and yield. Specialist assessment(s) should be undertaken if any of the above-mentioned circumstances prevail or if there is any doubt about the biodiversity value of the potentially impacted areas. The opportunities and constraints of the receiving environment should be used to inform the desirability and layout of any development proposal so as to ensure that developments do not compromise the biodiversity value of the area. Commission of biodiversity specialists

Source E-mail: Initial Notification

Specialists will be appointed where necessary.

Response from Project Team This will be further investigated in the Draft EIR phase.

Issues/Comments Raised Commentator(s) A suitably qualified and experienced specialist is CapeNature often critical to ensuring that the necessary information is provided for informed decisionmaking. Please take note of the following recommendations from the Guideline for involving biodiversity specialists in EIA processes (DEA&DP 2005). Biodiversity specialists should: a. Be competent at interpreting and evaluating information and able to explain the direct and indirect consequences of an activity to biodiversity; b. Have appropriate formal training in his/her field of expertise; c. Have sufficient practical experience working in the specific ecosystems of the affected region; d. Be able to trace impact pathways and identify indirect and cumulative impacts, and consider ecosystem goods and services; e. Have good knowledge relating to assessment techniques and to relevant legislation, policies and guidelines; f. Be independent; and g. Be registered with South African Council for Natural Scientific Professions (SACNASP). CapeNature also recommends that specialists be asked to review the information to be submitted for decision-making to confirm that their opinion has been adequately reflected. Format of Reports

Source E-mail: Initial Notification

Response from Project Team Noted and agreed.

Issues/Comments Raised Please help us provide you with a response on time by supplying all information in a readily accessible format: a. All reports larger than 50 pages must be submitted in hard copy, and be accompanied by a digital version on disc. b. Reports may be submitted via electronic correspondence (subject to above) or on disc (no ftp or website links). c. In the interests of resource conservation measures we encourage you to supply only the relevant information (i.e. main report, location maps and full biodiversity specialist reports) in hard copy, the remaining information can be supplied electronically. d. We also encourage you to reduce the amount of paper used by printing both sides of a page. e. Please supply all labelled maps and alternative layout plans in size A3 and in colour. To facilitate assessment of potential impacts, we request that maps of proposed development layouts be overlaid with identified environmental features of a site. If provided separately, maps should be produced at the same scale. g. GIS Shape-files of the proposed development footprint, particularly for linear developments, would be greatly appreciated. General FFS is currently undertaking an EIA to expand the existing site- need to consider the risks to development of the Transnet Tank farm. An air emissions modelling exercise is likely to be requested by DEA&DP from our experience, or at least a screening.

Source E-mail: Initial Notification

E-mail: Initial Notification E-mail: Initial Notification

Commentator(s) CapeNature

FFS Refineries (Pty) Ltd- Alison Haycock FFS Refineries (Pty) Ltd- Alison Haycock

An Air Quality Impact Assessment study will be undertaken during the Specialist Study Phase.

This will be considered throughout the EIA and will be taken into account during the MHI.

Response from Project Team Noted.