NOTIC
CE OF APP
PLICATIO
ONS FOR VARIOUS
V
S ENVIRONMENTAL
L
AUTHORISATIONS FOR
R THE CON
NSTRUCTI
ION OF A 600 MW
W
INDEPEN
I
DENT POWER PLA
ANT AND ASSOCIA
A
TED
INFRA
ASTRUCTU
URE FOR KIPOWER
R (PTY) LTD
L
NEAR
R DELMAS
S
IN MPUMAL
LANGA
(DEA Ref
R No.: 12/12/20
0/2333; NEAS Reff No.: DEA/EIA/00
000364/2011)
Notice is hereby
h
given of
KiPower Pty (Ltd)’s intent to
carry out the above project th
hat
requires autho
orisation in terms of
the following Acts:
A
 National
Environmenttal
Managemen
nt Act (Act No 10
07
of 1998) an
nd and the new EIA
Regulations
s
(Government
Notice R.54
43 – 546) publishe
ed
in June 201
10.
 Waste Management License in
terms
off
the
Nation
nal
Environmen
ntal Managemen
nt:
Waste Act (Act
(
59 of 2008) an
nd
relevant
regulations
an
nd
notices.
 Water Use License in terms of
the Nationa
al Water Act (Act 3
36
of
1998))
and
relevant
regulations
s and notices.
 Emissions License in terms of
the Nation
nal Environmenttal
Managemen
nt: Air Quality A
Act
(Act No. 39 of 2004) an
nd
relevant
regulations
an
nd
notices.
 Provincial
and
municip
pal
authorisatio
ons for rezoning of
land, build
ding permits an
nd
occupation
nal
health
an
nd
safety reg
gulations and b
bylaws.
Jones & Wa
agener has bee
en
appointed as
s the independent
Environmenta
al
Assessment
Practitioner responsible for th
he
EIA and oth
her environmenttal
processes.
hat all future notice
es
Please note th
regarding
t
the
authorisatio
on
processes will
w
be made to
Interested
an
registered
nd
Affected Partie
es directly.
PUBLIC COMMENT ENCOURAGE
E
D
Interestted and Affected Parties (I&APs) are
a invited to parrticipate by provid
ding comments and
a
raising any
issue
es of concern the
ey may have
To register as an
n I&AP, and to receivve a copy of the Backkground Information Document,
D
please con
ntact:
André Joubert
J
of Zitholele
e Consulting, P O Box 6002, Halfwa
ay House, 1685
Tel: (01
11) 207 2077 Fax:: 086-676-9950
Em
mail: andrej@zitho
olele.co.za
Jones & Wagener
Consulting Civil Engineers
5 9 Bevan Road PO Box 1 434 Rivonia 2 128 S outh Africa
Tel: 00 27 (0)11 519 0200 Fax: 00 27 (0)11 519 0201 email: [email protected]
22 August, 2013
Our Ref:
Your Ref:
C182_004_Let_RA_Kuyasa
Attention:
Mr Ayanda Bam
Kuyasa Mining (Pty) Ltd
2 Neven Street
Private Bag X7250
eMalahleni
1035
Mpumalanga
Republic of South Africa
Dear Mr Bam
POTENTIALLY DIRECTLY AFFECTED PROPERTIES – PROPOSED CONSTRUCTION OF
THE KIPOWER INDEPENDENT POWER PRODUCER (IPP) AND ASSOCIATED
INFRASTRUCTURE
KiPower (Pty) Ltd, a subsidiary of Kuyasa Mining (Pty) Ltd, which also owns the Delmas Coal
(Pty) Ltd and Ikhwezi Colliery (Pty) Ltd, has applied for environmental authorisation and the
required licences to establish a 600 MW independent power plant in close proximity to Delmas
Coal, utilising coal from this mine as the fuel for the power plant. The power plant will consist of
four 150 MW units.
Jones & Wagener has been appointed as the independent Environmental Assessment
Practitioner responsible for the EIA and the other licence applications by Kuyasa Mining (Pty)
Ltd
Associated with the power plant, would be the following infrastructure that will also have to be
authorised before construction:
•
An ash disposal facility;
•
Access road from the R50 road;
•
Coal, sorbent and ash haul routes (road and conveyor);
•
Coasl and limestone lay-down areas;
•
Construction laydown areas;
•
Wetland off-set areas, and
•
Bulk water supply pipeline and associated infrastructure.
The proposed development will be constructed on several properties and may potentially
directly affect the following properties belonging to either Delmas Coal (Pty) Ltd or Ikhwezi
JONES & WAGENER (PTY) LTD
REG NO. 1993/02655/07 VAT No. 4410136685
DIRECTORS: PW Day (Chairman) PrEng MSc(Eng) HonFSAICE D Brink (CEO) PrEng BEng(Hons) FSAICE PG Gage PrEng CEng BSc(Eng) GDE MSAICE AIStructE JP van der Berg PrEng PhD MEng FSAICE
TT Goba PrEng MEng FSAICE GR Wardle (Alternate) PrEng MSc(Eng) FSAICE
TECHNICAL DIRECTORS: JR Shamrock PrEng MSc(Eng) MSAICE MIWMSA JE Glendinning PrSciNat MSc(Env Geochem) NJ Vermeulen PrEng PhD MEng MSAICE A Oosthuizen PrEng BEng(Hons) MSAICE
HR Aschenborn PrEng BEng(Hons) MSAICE M van Zyl PrSciNat BSc(Hons) MIWMSA MW Palmer PrEng MSc(Eng) AMSAICE TG le Roux PrEng MEng MSAICE
ASSOCIATES: BR Antrobus PrSciNat BSc(Hons) MSAIEG AJ Bain BEng AMSAICE PJJ Smit BEng(Hons) AMSAICE R Puchner PrSciNat MSc(Geol) IMSAIEG MAEG M van Biljon MSc(Hydrogeology)
JS Msiza PrEng BEng(Hons) MSAICE MIWMSA RA Nortjé PrEng MScEng MSAICE MIWMSA GB Simpson PrEng MEng MSAIAE
CONSULTANT: JA Kempe PrEng BSc(Eng) GDE MSAICE AIStructE
FINANCIAL MANAGER: HC Neveling BCom MBL
2
Colliery (Pty) Ltd:







Haverklip 265 IR Portion 3:
Haverklip 265 IR Portion 4:
Haverklip 265 IR Portion 5:
Haverklip 265 IR Portion 25:
Haverklip 265 IR Portion 29:
Enkeldebosch 301 IR Portion 8:
Enkeldebosch 301 IR Remaining Extent:
Ikhwezi Colliery
Ikhwezi Colliery
Ikhwezi Colliery
Delmas Coal
Delmas Coal
Delmas Coal
Delmas Coal
An Environmental Impact Assessment (EIA) is being undertaken as part of the application for
environmental authorisation for the proposed development of the KiPower IPP Power Plant and
its associated infrastructure. The EIA is required in terms of the National Environmental
Management Act (No 107 of 1998) and the NEMA EIA regulations (Government Notice R. 543
to 546, published in June 2010). As part of the integrated application, KiPower is also applying
for the following licences:
 A Waste Management Licence in terms of the National Environmental Management:
Waste Act (No. 59 of 2008);
 An Air Emissions Licence in terms of the National Environmental Management Air
Quality Act, Act 39 of 2004; and
 A Water Use Licence in terms of the National Water Act, Act 36 of 1998.
This notice is made in terms of Regulation 15 of Government Notice R. 543, which requires that
landowners and people in control of land are notified of KiPower’s application for environmental
authorisation to the National Department of Environmental Affairs, and therefore serves to
inform Delmas Coal (Pty) Ltd and Ikhwezi Colliery (Pty) Ltd of the above planned development.
Yours sincerely,
Anelle Lötter
for Jones & Wagener
Cc: Ms Fiona Grimmett: Department of Environmental Affairs
[email protected]
Document source: C182_004_Let_RA_Kuyasa
C182_004_Let_RA_Kuyasa_AL_MvZ_22082013
Zitholele Consulting (Pty) Ltd
Reg. No. 2000/000392/07
PO Box 6002, Halfway House, 1685
South Africa
ThandananiPark, Matuka Close
Halfway Gardens, Midrand
Tel 011-207-2060
Fax 086-676-9950
Email: [email protected]
20 July 2011
Dear Stakeholder
Construction of a 600 MW independent power plant and associated
infrastructure for KiPower (Pty) Ltd near Delmas in Mpumalanga
(DEA Ref No.: 12/12/20/2333; NEAS Ref No.: DEA/EIA/0000364/2011)
An Integrated Environmental Impact Assessment (EIA) and other environmental processes (see the Background
Information Document for more details) are being undertaken for the proposed construction of an independent power
plant and associated infrastructure for KiPower (Pty) Ltd near Delmas in Mpumalanga.
KiPower is a subsidiary of Kuyasa Mining, which also owns the Delmas and Ikhwezi Coal Mines, about 10km southeast of Delmas in Mpumalanga. KiPower wishes to establish a 600MW power plant in close proximity to Delmas
Coal, utilising coal from this mine as the fuel for the power plant. Associated with the power plant, would be an ash
disposal facility that must also be located near the plant.
Various environmental authorisations are required for the project, in terms of the following Acts:
 National Environmental Management Act (Act No 107 of 1998) and the new EIA Regulations (GNR 543 - 546 –
Government Gazette No. 33306) published on 18 June 2010.
 Waste Management License in terms of the National Environmental Management: Waste Act (Act 59 of 2008)
and relevant regulations and notices.
 Water Use License in terms of the National Water Act (Act 36 of 1998) and relevant regulations and notices.
 Emissions License in terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004) and
relevant regulations and notices.
 Provincial and municipal authorisations for rezoning of land, building permits and occupational health and safety
regulations and by-laws.
Jones & Wagener has been appointed as the independent Environmental Assessment Practitioner responsible for
the EIA and other environmental processes.
You are invited to register as an Interested and/or Affected Party (I&AP) and to participate in these environmental
processes by using the registration and comment sheet in the enclosed Background Information Document. Please
return the comment sheet at the latest by 12 August 2011 for this initial public notification process, although
submissions and public participation will continue throughout the EIA process. Please note that all future notices
regarding the authorisation processes will be made to registered I&APs directly. Submit any comments, questions or
issues that you may have about the proposed project, in writing, to Zitholele Consulting on fax number
086 676 9950, email [email protected] or postal address PO Box 6002, Halfway House, 1685. You are also
welcome to contact Zitholele telephonically on 011 207 2077 / 2076.
Yours sincerely
André Joubert
Public Participation Office
Zitholele Consulting (Edms) Bpk
Reg. No. 2000/000392/07
Posbus 6002, Halfway House, 1685
Suid-Afrika
Thandanani Park, Matuka Close
Halfway Gardens, Midrand
Tel: 011 207 2060
Faks: 086 676 9950
E-pos: [email protected]
20 Julie 2011
Geagte Belanghebbende
Konstruksie van 'n 600 MW onafhanklike kragstasie en gepaardgaande
infrastruktuur vir KiPower (Edms) Bpk naby Delmas in Mpumalanga
(DOS Verwys No.: 12/12/20/2333; NEAS Verwys No.: DEA/EIA/0000364/2011)
'n Geïntegreerde Omgewingsimpakbepaling (OIB) en ander omgewingsprosesse (kyk na die Agtergrondinligtingsdokument vir meer besonderhede) word gedoen vir die voorgestelde konstruksie van 'n onafhanklike kragstasie en
gepaardgaande infrastruktuur vir KiPower (Edms) Bpk naby Delmas in Mpumalanga.
KiPower is 'n filiaal van Kuyasa Mining, wat ook die Delmas- en die Ikhwez-steenkoolmyn besit, ongeveer 10 km
suidoos van Delmas in Mpumalanga. KiPower wil 'n 600 MW-kragstasie naby Delmas Coal oprig en wil steenkool uit
hierdie myn as brandstof vir die kragstasie gebruik. Saam met die kragstasie sal daar 'n aswegdoenfasiliteit wees
wat ook naby geleë moet wees.
Verskeie omgewingsmagtigings vir die projek word ingevolge die volgende wette vereis:
 Wet op Nasionale Omgewingsbestuur (Wet No 107 van 1998) en die nuwe OIB-regulasies (GK's R. 543 – 546,
Staatskoerant No. 33306) wat op 18 Junie 2010 gepubliseer is.
 Afvalbestuurslisensie ingevolge die National Environmental Management: Waste Act (Wet 59 van 2008) en
toepaslike regulasies en kennisgewings.
 Watergebruikslisensie ingevolge die Nasionale Waterwet (Wet 36 van 1998) en toepaslike regulasies en
kennisgewings.
 Emissielisensie ingevolge die National Environmental Management: Air Quality Act (Wet No. 39 van 2004) en
toepaslike regulasies en kennisgewings.
 Provinsiale en munisipale magtigings vir die hersonering van grond, boupermitte en regulasies en verordeninge
rakende beroepsgesondheid en veiligheid.
Jones & Wagener is aangestel as die onafhanklike Omgewingsbepalingspraktisyn verantwoordelik vir die OIB en
ander omgewingsprosesse.
U word genooi om as 'n Belanghebbende en/of Geaffekteerde Party (B&GP) te registreer en om aan hierdie
omgewingsprosesse deel te neem deur die registrasie- en kommentaarblad in die bygaande
Agtergrondinligtingsdokument te gebruik. Stuur die kommentaarblad asb voor of op 12 Augustus 2011 terug vir
hierdie aanvanklike proses van openbare kennisgewing, hoewel voorleggings en openbare deelname dwarsdeur die
OIB-proses sal voortgaan.
Let asb daarop dat alle toekomstige kennisgewings rakende die magtigingsprosesse regstreeks aan B&GP's
gestuur sal word. Enige kommentaar, vrae of kwessies wat u moontlik oor die voorgestelde projek het, moet skriftelik
aan Zitholele Consulting voorgelê word by faksnommer 086 676 9950, e-pos [email protected] of posadres
Posbus 6002, Halfway House, 1685. U kan Zitholele ook telefonies skakel by 011 207 2077 / 2076.
Met vriendelike groete
André Joubert
Kantoor vir Openbare Deelname
Construction of a 600 MW independent power plant and associated infrastructure
for KiPower (Pty) Ltd near Delmas in Mpumalanga
(DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011)
BACKGROUND INFORMATION DOCUMENT
July 2011
This Background Information
Document provides Interested and
Affected Parties (I&APs) with
information on the environmental
authorisations required for the
proposed construction of an
Independent Power Station and
associated
infrastructure
for
KiPower (Pty) Ltd near Delmas in
Mpumalanga.
This BID also provides I&APs with
the opportunity to:
 Register as stakeholders in the
public participation process; and
 Comment on the proposed
project.
You will be included on the
stakeholder database and receive
further documents for review and
comment. To raise your concerns,
complete the enclosed registration
sheet, write a letter, call or email
the public participation office.
Your comments are important
The purpose of an Environmental
Impact Assessment is to provide
the decision-making authority with
sufficient information on which to
base their decision to grant or
refuse
an
Environmental
Authorisation and if granted, to
define
conditions
for
the
development. The contributions
made by stakeholders from all
sectors of society will ensure
informed decision-making.
You are invited to participate
freely and to submit any
comments or information you feel
may be useful to the EIA process.
Registered interested and affected
parties are entitled to comment, in
writing, on all written submissions
to the competent authority
(Department of Environmental
Affairs) and to bring to the
attention of the competent
authority, any issues which the
party believes may be of
significant to the consideration of
the application.
B ACKGROUND TO I NDEPENDENT P OWER P LANTS
In 2003 Government decided that future
power generation capacity would be divided
between Eskom (70%) and independent
power producers (IPPs) (30%).
In line with that decision, on 5 September
2007 Cabinet designated Eskom as the
single buyer of power from IPPs in South
Africa. Eskom currently supplies over 95% of
the country's electricity and about 60% of
the total electricity consumed in Africa.
Eskom then launched the Multi Site
Baseload IPP programme, inviting interested
parties
to
submit
Statements
of
Qualification for the provision of electricity,
excluding nuclear power.
Each IPP will benefit from a power purchase
agreement with Eskom for a minimum of
200 megawatt (MW) with an envisaged
term of 25 years from the date of project
commercial operations.
access to fuel, transmission infrastructure
and water sources. Connection to the
Eskom transmission grid shall be made in
compliance with the terms of the SA Grid
Code.
The National Energy Regulator of South
Africa (NERSA) is the regulatory authority
responsible for the electricity supply
industry in South Africa. In Its National
Integrated Resource Plan published in 2009,
NERSA has determined that, while various
alternative and renewable electricity
generation options should be continually
investigated, coal should still provide the
main fuel source in South Africa.
KiPower qualified as an IPP that can provide
commercial electricity generation. In order
to install and operate the proposed power
plant, KiPower must obtain various
environmental authorisations, for which this
EIA process is required.
Interested parties were required to select
sites inside South Africa as determined by
P ROJECT B ACKGROUND
KiPower (Pty) Ltd is a subsidiary of Kuyasa
Mining, which also owns the Delmas and
IkhweziCoal Mines 10km south-east of
Delmas in Mpumalanga.
KiPower wishes to establish a 600 MW
power plant in close proximity to Delmas
Coal, utilising coal from this mine as the fuel
for the power plant. The power plant will
consist of four 150 MW units.
Associated with the power plant, would be
an ash disposal facility that must also be
located near the plant. Sufficient coal is
available from Delmas Coal to supply the
plant.
The
power
plant
and
associated
infrastructure will be designed for a life of
30 years. The associated infrastructure
includes:
 Access road from the R50 road;
 Coal and ash haul route (road or
conveyor);
 Laydown area; and
 Bulk water supply (separate EIA).
The ash from the power plant would need
to be disposed of on an ash disposal facility.
For a 600 MW plant approximately 136 000
tonnes per month of ash will be generated.
This translates to almost 50 million tonnes
of ash over an operating life of 30 years.
Thus, the location of the power plant and
the ash facility are key decision points in the
project development. KiPower may also
wish to expand the power plant capacity in
future up to 2000 MW, depending on
economic factors over time.
Coal
Coal can be supplied from either the North
Shaft or South Shaft of the Delmas Coal
Mine. North Shaft has a crusher plant and
will be able to supply crushed coal to the
power plant. A new crusher plant would be
required at South Shaft if coal is supplied
directly from this shaft. The power plant will
require 2.8 million tonnes of coal per
annum. It will run on low grade, high
sulphur, high ash content coal, whicch has
a very low market value.
Water supply
Delmas Coal plans to bring in addittional
potable water either by tapping into a
Rand Water line that runs between
Springs and Devon or by tapping intto the
proposed bulk water line to Delmas..
Other potential sources of water are
e also
being investigated by the mine.
ooling
The power plant, although a dry co
system, will have a significant water
w
requirement, of approximately 100
0 000
cubic meters per month.
It is proposed that water for the mine
and power plant come from the same
source and therefore a separate prroject
is running in parallel to this one, to
o find
potential sources of water and then
develop the supply pipeline to the mine
and the power plant.
A Water Use License Application willl also
be submitted to the Departmen
nt of
Water Affairs for the plant and
d ash
facility.
Access
The provincial R50 road runs to the north
of Delmas Coal and North shaaft is
accessed directly off this road. It is likely
that both the power plant and the ash
disposal facility would req
quire access
onto this road for construction and
operations.
There is a rail link that runs to the west
of the mine, and some raw
w materials,
such as the dolomite or limee stone to be
used for air emissions contrrol (sorbent),
can be brought in via this ro
oute as well.
This rail link is used to expo
ort coal from
Delmas Coal.
Landownership
Whilst Delmas and Ikwezi mines are
M
the
owned by Kuyasa Mining,
surrounding land is mainlyy owned by
various farming enterprisees and BHP
Billiton.
KiPower will need to purchaase land and
ensure it is correctly re-zoned before any
industrial development may take
t
place.
Labour
Between 2 500 and 3 000 skilled and
uired for the
unskilled labour will be requ
project during construction and around
mployment is
200 during operations. Unem
high in Delmas and the surrounding
small towns and thus this project will
offer some relief in the form of
employment opportunities.
Nevertheless, labourr is likely to be
imported during con
nstruction to meet
the high numbers of
o people required
during this period and to meet the skills
level required.
Plant area required
nt requires some 40
A 600 MW power plan
hectares for just the plant, whilst a 2000
MW plant requires ab
bout 160 hectares.
Ash disposal area req
quired
The ash disposal faacility will require
somewhere betweeen 150 and 250
hectares to accommo
odate 600 MW ash
generation over 30 years.
y
If the power
plant is expanded ovver time, this area
requirement will grow
w as well. Thus land
that allows for expansion of the ash
facility would be favou
urable.
Construction lay-dow
wn
A lay-down is the area used during
store
materials,
construction
to
a to house offices
equipment, vehicles and
and ablutions for consstruction personnel.
Power plants take 3 to 4 years to
construct, and are higghly labour intensive
in the construction ph
hase. As a result, up
to 100 hectares may be required for the
lay-down area.
H OW DO
OES A COAL - FIRED PO
OWER PLANT WORK ?
Electricity generation from a coal-ffired power station requires
that coal be burned to heat water which
w
is then converted into
superheated steam. This steam turn
ns a large turbine connected
to a rotating magnet that converts this mechanical energy into
electrical energy (electricity), which is then further increased via
transformers into high voltage electric power.
A 200 MW Circulating Fluidized Beed boiler in China
Source:www.english.iet.cas.cn/ressearch/
LaboratoryofCirculatingFluidizedBed//
High voltage transmission lines traansport the electricity from
the power station into a transmissio
on network. Electricity must
then be
b transformed in substations to volttages more suitable
for ind
dustrial and residential uses.
The teechnology proposed for this power plant is a Circulating
Fluidissed Bed (CFB) which is proven technology that has
becom
me a very efficient method of generatting electricity with
low em
missions and environmental impacts. In a CFB combustion
processs, crushed coal is mixed with a sorben
nt such as limestone
or dolomite and fired in a process resemb
bling a boiling fluid.
The sorbent
s
removes the sulphur and converts
c
it into an
enviro
onmentally-benign powder that is remo
oved with the ash.
Fluidissed beds suspend solid fuels on upward
d-blowing jets of air
duringg the combustion process. The result iss a turbulent mixing
of gass and solids. The tumbling action, mu
uch like a bubbling
fluid, provides more effective chemical reactions
r
and heat
transfer. Fluidised bed combustion evolved from efforts to find
a com
mbustion process able to control pollutant
p
emissions
without external emission controls (such as scrubbers). The
ology burns fuel at temperatures of around
a
900 degrees
techno
Celsius, which is well below the threshold temperature
t
where
therm
mal Nitrogen Oxides can form (at approximately
a
1300
degreees Celsius, nitrogen and oxygen atomss in the combustion
air com
mbine to form nitrogen oxide pollutantts).
The mixing
m
action of the fluidised bed bringss the flue gases into
contacct with a sulphur-absorbing chemical, such
s
as limestone or
dolom
mite. Approximately 90% of the sulphu
ur pollutants in coal
can be captured inside the boiler by the sorbent.
S ITE S ELECTION C RITERIA
2x135 MW CFB Shendong Baode Power Plant in Shanxi, China
(Source:www.industcards.com/st-coal-china-shanxi.htm)
Selecting the best site for a proposed development is important
to prevent or minimise long term operational and
environmental management issues, and is dependent on many
factors. Nine sites were initially identified in a site selection
process, and unsuitable sites as well as less suitable sites were
eliminated. Four of the most suitable sites will be investigated
during the Environmental Impact Assessment (EIA) process.
Land owner notification has been carried out for these
preferred sites. The site selection process done prior to the EIA
will be carried into the Scoping Phase of the EIA as a supporting
report.
Site selection legal requirements
The National Environmental Management Act, No 107 of 1998
(NEMA) as amended does not indicate specific requirements for
site selection or consideration of alternatives. Nevertheless, it
does require that alternatives be considered and assessed in
order to identify the best practicable environmental option.
The National Environmental Management: Waste Act, No 59 of
2008 (NEMWA) also requires that consideration of alternatives
in terms of site and technology be considered.
The latest Department of Water Affairs Minimum Requirements
is used as a best practice guideline in assessing new
applications. These outline a step-wise approach for the
selection of sites, starting with a broad-area based assessment
of potential sites and eliminating sites as more detail is
gathered on sites that show potential for the intended use. The
process outlined in this report follows this best practice
guideline approach.
Methodology
A step-wise site selection process has been followed to ensure
the best available location is found for the power plant and the
ash disposal facility.
Site identification criteria
Both the ash disposal facility and the power plant require the
following key criteria with respect to their location:






The area must preferably not be undermined due to long
term ground stability risks associated with undermined
areas.
The area must not hold viable reserves of coal, which
would be sterilised if the plant or ash were placed on it.
The area should preferably have a low agricultural
potential.
Surface water resources must be protected due to the
highly stressed nature of the local water sources.
Known biodiversity sensitivities must be avoided, especially
wetlands.
The power plant and ash disposal facility must be within
close proximity of the coal source and preferably each
other.
Identification of potential sites
Based on the information listed under site identification
criteria, potential areas were identified for location of the
power plant and/or ash disposal facility.
Screening of potential sites
The nine sites were screened in terms of two sets of criteria:
Technical screening for a power plant, which looked at distance
to coal supply; topography; site constructability; transmission
connection; water supply; distance to ash facility; expansion
potential; underground workings; coal reserves; land ownership
and accessibility. Technical screening of ash disposal sites also
looked at capacity of sites; storage efficiency; topography;
drainage direction; slope; expansion potential; conveyor/truck
access; land ownership.; potential to fit plant and ash on site
and geotechnical.
Environmental screening investigated disciplines such as ground
water; surface water; economic; ecology and aesthetics.
The technical and environmental criteria were considered and
the four best possible sites for the proposed development will
be investigated further during scoping.
LEGAL REQUIREMENTS
The proposed power plant requires a number of environmental processes and approvals. The processes will be conducted
simultaneously as integrated processes complemented by a combined public participation process.
These processes are discussed below.
NATIONAL ENVIRONMENTAL MANAGEMENT ACT
The proposed project and associated infrastructure requires an
Environmental Impact Assessment (EIA) in terms of the National
Environmental Management Act (NEMA), No 107 of 1998 and
the new EIA regulations (Government Notice Regulation R.543
to 546, published in June 2010).
As per Government Notice R.543 of June 2010, Chapter 2 the
competent authority must consult with every government
organ that administers a law relating to a matter affecting the
environment relevant to that application for an environmental
authorisation when considering an application.



infrastructure for the plant. These may exceed 50000 m3
depending on the site specific drainage conditions.
Activity 13: Dangerous goods may be stored on site such as
diesel and chemical reagents. It is unlikely that the storage
capacity would exceed 500 m3.
Activity 18: Conveyors may cross watercourses resulting in
the disturbance of embankments.
Activity 20: The power plant will fall within the mining
rights area of Kuyasa Mine and an amendment of the
mining rights will required for the project.
Activity 22: An access road to the power plant will be
required. This will tie into the existing provincial road that
runs to the north of the mine.
Activity 47: Widening of existing access roads may be
required.
Therefore, the Department of Water Affairs, the Mpumalanga
Department of Economic Development Environment and
Transport, other Directorates of the Department of
Environmental Affairs, Nkangala District Municipality and Victor
Khanye Local Municipality (Delmas) are commenting authorities
in this process.

This process includes Scoping and Environmental Impact Report
(S&EIR) Phases, which are applicable to all projects likely to
have significant environmental impacts due to their nature or
extent, activities associated with potentially high levels of
environmental degradation, or activities for which the impacts
cannot be easily predicted.
In terms of Government Notice R.545 of 2010, the following
listed activities require that a S&EIR be undertaken and are
applicable to this proposed project:
 Activity 1: A proposed power plant of 600MW.
 Activity5: Air Emissions Licence and Water Use Licence will
be required for the power plant.
 Activity 6: Conveyors for ash and coal transport will be
required.
 Activity15: The power plant will require in excess of 20
hectares, and possibly up to 40 hectares.
In terms of Government Notice R.544 of 2010, the following
listed activities require that a Basic Assessment be undertaken
for the proposed project (these activities having a lesser impact
than those of the activities requiring an S&EIR and will result in
one EIA being undertaken for the proposed project):
 Activity 2: Coal will be conveyed to the power plant from
the Delmas Mine. A holding facility for coal will be required
at the plant as buffer storage.
 Activity 11: Bridge crossings may be required for the
transfer of coal, ash, waste and or water depending on the
final site selection scenario.
 Activity 12: Water and storm water storage facilities on site
will be required as part of the water management

In terms of Government Notice R.546 of 2010, the following
listed activity requires that a S&EIR be undertaken and are
applicable to this proposed project:
Activity 14: Clearing of area bigger than 5 hectares outside
urban area.
Therefore, for the proposed power plant, a Scoping and
Environmental Impact Report (S&EIR) has to be undertaken.
NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT
With the proclamation of the National Environmental
Management Waste Act (NEM:WA), No 59 of 2008, all waste
related activities previously listed under the National
Environmental Management Act (NEMA), No 107 of 1998 have
been repealed and are now listed under the NEM:WA.
Government Notice R.718 of the NEM:WA highlights the waste
management activities that require environmental licensing. In
terms of this notice the following activities require
authorisation:
 Category A 3(1): It is expected that more than 100 m3 of
general waste will be stored on site, especially during the
construction phase of the power station.

3
Category A 3(2): It is expected that more than 35 m of
hazardous waste will be stored on site, especially during
the construction phase.

Category A 3(5): At the waste recycling plant/salvage yard
more than 1 ton of general waste will be sorted for
recycling purposes per day.

Category A 3(9): Should a garden waste composting plant
be constructed it will have the capacity to treat more than
10m3 of garden waste per day.

3
Category A 3(11): More than 2000m , but less than
3
15000m of sewage water will be treated at the onsite
sewage works per annum.

Category A 3(12): During the construction and
operational phase, it is likely that diesel and oil spills will
be treated in situ.

Category A 3(18): The construction of facilities for any of
the above listed activities (Category A 3(1, 11 & 12)).

Category B 4(9): This activity is triggered by the disposal
of the boiler ash onto a waste disposal facility.

Category B 4(10): This activity is triggered by the disposal
of the boiler ash onto a waste disposal facility, if the ash
classifies as being hazardous.
As described in the Regulations “a person who wishes to
commence, undertake or conduct an activity listed under this
Category, must conduct an Environmental Impact Assessment
(EIA) process, as stipulated in the EIA regulations made under
Section 24(5) of the NEMA as part of a Waste Management
License Application”.
Therefore the proposed development requires the submission
of a Waste Management License Application as well as a
Scoping and Environmental Impact Report (S&EIR) to the
Department of Environmental Affairs.
NATIONAL WATER ACT
An Integrated Water and Waste Management Plan(IWWMP) will be required as well as an Integrated Water Use License in terms
of Section 21 of the National Water Act (No 36 of 1998). Various other water uses during construction and operation will require
licensing.
A full list of water uses to be licensed will be identified during the early stages of this EIA process.
NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT
All power stations require an Emissions Licence in terms of the National Environmental Management: Air Quality Act (No 39 of
2004) (NEM: AQA). A comprehensive legislative review on all air quality requirements applicable to power plants and coal mines
will be undertaken before this study will commence. Reference will be made to the NEM:WA as well as the National Ambient Air
Quality Standards and the Minimum Emission Limits for Listed Activities.
VICTOR KHANYE LOCAL MUNICIPALITY
All properties to be used for this proposed project must also be properly rezoned according to the requirements of the Victor
Khanye Local Municipality or the Development Facilitation Act.
E NVIRONMENTAL I MPACT A SSESSMENT
An Environmental Impact Assessment (EIA) is a planning and decision-making tool undertaken in terms of the National
Environmental Management Act (NEMA), No 107 of 1998. For this project, all the other environmental processes will feed into the
EIA.
TECHNICAL AND PUBLIC PARTICIPATION PROCESSES
An EIA has two parallel and integrated processes namely, a
technical and a public participation process.
The technical process investigates "hard" information: facts
based on scientific and technical studies, statistics or technical
data. It identifies the potential negative and positive
consequences of a proposed project or development at an early
stage and recommends ways to enhance positive impacts and
to avoid, reduce or mitigate negative impacts.
The EIA regulations require that an Environmental Management
Programme (EMProg) be developed. The EMProg provides
recommendations on how to operate and implement the
project. The provisions of the EMProg are legally binding on the
developer and its contractors
Public participation ensures that the EIA process is fair, open
and transparent. It also provides stakeholders with sufficient
information and gives them opportunity to contribute by
reviewing
and
commenting
on
the
information
Arrangement with regards to negotiations with landowners, if
necessary, for land and servitudes and compensation will be
shared with the stakeholders during the public participation
process of the EIA.
However these negotiations will take place in a separate
process. The findings of the EIA will assist landowners and
KiPower to determine the extent of local impacts in support of
any negotiations that might be necessary.
The public participation process is designed to provide
sufficient and accessible information to Interested and
Affected Parties (I&APs) in an objective manner to assist them
to:
 Raise issues of concern and make suggestions for
alternatives and enhanced benefits.
 Contribute local knowledge.
 Verify that their issues have been captured and considered
by the technical investigations.
 Comment on the findings of the EIA.
PHASES IN AN EIA
SCOPING PHASE
The first phase of an EIA is the Scoping Phase, which is
conducted to gain an understanding of the potential
environmental issues that are relevant to the project and to
determine where further information is required, in the form of
specialist studies/investigations.
The Scoping Report and Plan of Study for the EIA are submitted
to the competent authority for review and to approve the
proposed approach to the detailed investigation required in the
next phase.
Activities involved in the Scoping Phase include:
 Meetings with authorities to agree on process and study
requirements;
n
which includes
 Initial public and landowner notification,
placing of site notices, the distribution
d
of letters, this
Background Information Docum
ment and an invitation to
contribute to the EIA process to
o I&APs in the project area
and beyond;
 Advertisements in local and regional newspapers to
announce opportunities to particcipate;
 Pro
ogress feedback letter to be issued and announcements
to be made of the availability of the Drraft Scoping Report
(DSSR) and Issues and Responses Report (IIRR);
 Disstribution of a DSR, including IRR, for co
omment;
 Co
onvening a stakeholder meeting in the project area to
ob
btain comment on the DSR;
 Submission of a Final Scoping Report (FSR), capturing all
issues raised for the impact assessment, to
t the DEA;
 Submit the Plan of Study for the EIA to th
he DEA;
 Disstribution of the FSR for comments; and
 Disstribution of a progress feedback letterr to stakeholders.
ENVIRONMENTAL IMPACT REPORT PHASE
The second phase is the Environm
mental Impact Report (EIR)
Phase, which entails undertaking vaarious specialist studies and
compiling a Draft EIR.
As part of the assessment, an Environmental Management
O
Plan will also be
Programme (EMProg) as well as an Operational
submitted to the Department of Environmental
E
Affairs for its
approval. By following the EMProg, KiPower and its contractors
will ensure compliance to environm
mental regulations during the
planning, construction, operation and decommissioning (if
applicable) phases.
dies required for this EIR (to
The list of identified specialist stud
date) is listed below (all seasonal dependent studies will be
undertaken in the wet season):
 Traffic;
 Air quality;
 Soils;
 Socio-economic;
 Heritage;
 Groundwater;
 Biodiversity;
 Surface water;
 Cost assessment for haulage altternatives;
 Geotechnical;
 Noise; and
 GIS for mapping purposes.
The names of the specialists who will undeertake these studies
are avvailable from the public participation offfice.
Speciffic activities in this phase will include:
 Specialist studies focused on outcomes of
o the Scoping Phase
and issues raised by stakeholders;
 Pro
ogress feedback to stakeholders;
 Co
ompilation of a Draft EIR and EMP
Prog indicating the
po
otential positive and negative impactss and measures to
enhance positive impacts and to reducee or avoid negative
impacts;
 Environmental Impact Statement, highligghting the preferred
altternative and reasons thereof;
 Ad
dvertise the availability of the Draft EIR and EMProg in
loccal and regional newspapers;
 Disstribution of the Draft EIR and EMPro
og, including Issues
and Responses Report, for comment;
 A stakeholder meeting in the project area
a
to present the
ndings of the EIR for stakeholder comment; and
fin
 Disstribution of the Final EIR and EMProg for
f comment.
The EIIR and EMProg will then be finalised an
nd submitted to the
Deparrtment of Environmental Affairs for autthorisation.
Technical reports from all the envirronmental studies
underrtaken during this project will be available
a
for public
review
w during this phase.
DECISION-MAKING PHASE
The third phase involves notifying the registered I&APs about the decission from the Competent Authority, the Department of
Environmental Affairs in this case. The Department of Environmental Afffairs must accept or reject this reportt within 105 days.
Stakeholders will be advised of the
e Department’s decision if Environmental Authorisation has been granted or not and of the
appeal procedure should they wish to
t appeal the decision.
Contact Us
Public Participation
n Office:
Andre Joubeert
Zitholele Consu
ulting
P O Box 6002
2,
Halfway House, 1685
Tel: 011 207 2077
9
Fax: 086 676 9950
E-mail: andrej@zitho
olele.co.za
Konstruksie van 'n 600 MW onafhanklike kragstasie en gepaardgaande
infrastruktuur vir KiPower (Edms) Bpk naby Delmas in Mpumalanga
(DOS Verwys No: 12/12/20/2333; NEAS Verwys No: DEA/EIA/0000364/2011)
AGTERGRONDINLIGTINGSDOKUMENT
Julie 2011
Hierdie
Agtergrondinligtingsdokument bied aan Belanghebbende
en
Geaffekteerde
Partye (B&GP's) inligting oor die
omgewingsmagtigings wat vereis
word
vir
die
voorgestelde
konstruksie van 'n Onafhanklike
Kragstasie en gepaardgaande
infrastruktuur vir KiPower (Edms)
Bpk naby Delmas in Mpumalanga.
Hierdie dokument bied ook aan
B&GP's 'n geleentheid om:
 Te registreer as belanghebbendes in die proses van
openbare deelname; en
 Kommentaar te lewer op die
voorgestelde projek.
U sal in die databasis van
belanghebbendes opgeneem word
en verdere dokumente ontvang vir
insae en kommentaar. Om u
kwellings te opper, vul bygaande
registrasieblad in, skryf 'n brief,
skakel of stuur 'n e-pos aan die
Kantoor vir Openbare Deelname
A GTERGROND
OOR
O NAFHANKLIKE K RAGSTASIES
Die regering het in 2003 besluit dat
toekomstige
kragopwekkingskapasiteit
verdeel sal word tussen Eskom (70%) en
onafhanklike kragprodusente (OKP's) (30%).
In ooreenstemming met daardie besluit het
die Kabinet Eskom op 5 September 2007
aangewys as die enigste aankoper van OKP's
se elektrisiteit in Suid-Afrika. Eskom verskaf
tans meer as 95% van die land se
elektrisiteit en nagenoeg 60% van al die
elektrisiteit wat in Afrika verbruik word.
Eskom het toe die MultiterreinbasisladingOKP-program begin en belanghebbende
partye genooi om Verklarings van
Kwalifikasie voor te lê vir die verskaffing van
elektrisiteit, kernkrag uitgesonder.
Elke OKP sal baat vind by 'n
kragkoopooreenkoms met Eskom vir 'n
minimum van 200 megawatt (MW) met 'n
beoogde termyn van 25 jaar vanaf die
aanvangsdatum van die projek se
kommersiële bedrywighede.
U kommentaar is belangrik
Die doel van 'n Omgewingsimpakbepaling is om die besluitneemowerheid te voorsien van
genoeg inligting vir sy besluit om
Omgewingsmagtiging te verleen of
te weier, en as dit verleen word,
om
voorwaardes
vir
die
ontwikkeling te stel. Bydraes van
belanghebbendes uit alle sektore
van die samelewing sal ingeligte
besluitneming verseker.
U word genooi om vryelik deel te
neem en enige kommentaar of
inligting voor te lê wat na u
mening vir die OIB-proses nuttig
kan wees. Geregistreerde belanghebbende en geaffekteerde partye
is daarop geregtig om skriftelik
kommentaar te lewer op alle
skriftelike voorleggings aan die
bevoegde owerheid (Departement
van Omgewingsake) en om enige
kwessies wat die party reken van
belang kan wees by die oorweging
van die aansoek, onder die
bevoegde owerheid se aandag te
bring.
Van belanghebbende partye is vereis om
terreine in Suid-Afrika te kies met
inagneming van toegang tot brandstof,
transmissie-infrastruktuur en waterhulpbronne. Aansluiting by Eskom se
transmissienet sal ooreenkomstig die
bepalings van die SA Netkode geskied.
Die Nasionale Energiereguleerder van SuidAfrika (NERSA) is die reguleringsowerheid
verantwoordelik vir die elektrisiteitvoorsieningsbedryf in Suid-Afrika. In sy
Nasionale Geïntegreerde Hulpbronplan wat
in 2009 gepubliseer is, het NERSA bepaal
dat, hoewel verskeie opsies vir alternatiewe
en
hernubare
elektrisiteitopwekking
deurlopend
ondersoek
moet
word,
steenkool
steeds
die
vernaamste
brandstofbron in Suid-Afrika moet wees.
KiPower het gekwalifiseer as 'n OKP wat
kommersiële elektrisiteitopwekking kan
verskaf. Om die voorgestelde kraginstallasie
te installeer en te bedryf, moet KiPower
verskeie omgewingsmagtigings verkry,
waarvoor hierdie OIB-proses nodig is.
P ROJEKAGTERGROND
KiPower (Edms) Bpk is 'n filiaal van Kuyasa
Mining, wat ook die Delmas- en die Ikhwezisteenkoolmyn 10 km suidoos van Delmas in
Mpumalanga besit.
KiPower wil 'n 600 MW-kragstasie naby
Delmas Coal oprig en steenkool van hierdie
myn as brandstof vir die kragstasie gebruik.
Die kragstasie sal uit vier 150 MW-eenhede
bestaan.
Saam met die kragstasie sal daar 'n
aswegdoenfasiliteit wees wat ook naby die
stasie moet wees. Genoeg steenkool van
Delmas Coal is beskikbaar om die installasie
van brandstof te voorsien.
Die
kragstasie
en
gepaardgaande
infrastruktuur sal vir 'n lewensduur van 30
jaar ontwerp word. Die gepaardgaande
infrastruktuur sluit in:
 Toegangspad vanaf die R50-pad;
 Steenkool- en asvervoerroete (pad of
vervoerband);
 Bergingsgebied; en
 Grootmaatwatervoorsiening
(afsonderlike OIB).
Die as van die kragstasie sal weggedoen
moet word op 'n aswegdoenfasiliteit. Vir 'n
600 MW-installasie sal ongeveer 136 000
ton as per maand geproduseer word. Dit
kom neer op byna 50 miljoen ton as oor n
bedryfslewe van 30 jaar.
Die ligging van die kragstasie en die
asfasiliteit is dus sleutelbesluitpunte in die
projekontwikkeling. KiPower sal dalk ook die
kragstasie se kapasiteit in die toekoms tot
2 000 MW wil uitbrei, afhangende van
ekonomiese faktore oor tyd.
Steenkool
Steenkool kan van óf die Noordskag óf die
Suidskag van die Delmas-steenkoolmyn
gelewer word. Die Noordskag het 'n
vergruisaanleg en sal gemaalde steenkool
aan die kragstasie kan lewer. 'n Nuwe
vergruisaanleg sal by Suidskag gebou moet
word as steenkool regstreeks
vanuit hierdie skag verskaf word.
Die kragstasie sal 2.8 milljoen ton
steenkool per jaar nodig hê.
Laegraadse steenkool met hoe
swael-en asinhoud, wat ‘n baie lae
markwaarde het, sal gebruik word.
Watervoorsiening
Delmas
Coal
beoog
om
bykomende drinkbare water in te
bring deur aan te sluit by óf 'n
Rand Water-leiding tussen Springs
en Devon óf die voorgestelde
grootmaatwaterleiding na Delmas.
Ander potensiële bronne van
water word ook deur die myn
ondersoek.
Die
kragstasie,
hoewel
'n
droëkoelingstelsel,
sal
'n
beduidende hoeveelheid water
benodig, ongeveer 100 000 kubieke meter per maand.
Daar word beoog dat water vir die
myn en kragstasie uit dieselfde
bron verkry sal word, en daarom is
daar 'n afsonderlike projek parallel
met dié een om potensiële bronne
van water te kry en dan die
leweringspypleiding na die myn en
die kragstasie te ontwikkel.
'n Aansoek vir 'n watergebruiklisensie vir die kragstasie
en asfasiliteit sal ook aan die Departement
van Waterwese voorgelê word.
dus verligting bring in
i die vorm van
werkgeleenthede.
Toegang
oord van
Die provinsiale R50-pad loop no
Delmas Coal verby, en die Noord
dskag het
regstreekse toegang tot hierdie paad. Sowel
die kragstasie as die aswegdoenfassiliteit sal
waarskynlik toegang tot hierdie pad
p moet
hê vir konstruksie en bedryf.
Desondanks
sal
arbeid
waarskynlik
ngevoer moet word
gedurende konstruksie in
om te voorsien in die vraaag na groot getalle
mense wat gedurende hiierdie tydperk nodig
sal wees en om die nod
dige vaardighede te
verskaf.
Daar is 'n spoorlyn wes van die myyn, en van
die grondstowwe, soos die dolo
omiet of
kalksteen
wat
vir
lugemisssiebeheer
(sorbens) gebruik sal word, kan ook oor
hierdie roete ingebring word. Hierdie
spoorlyn word gebruik om steen
nkool van
Delmas Coal uit te voer.
Grondeienaarskap
ord deur
Die Delmas- en Ikwezi-myne wo
Kuyasa Mining besit, maar die om
mliggende
grond is hoofsaaklik die eiend
dom van
verskeie boerdery-ondernemings en BHP
Billiton.
KiPower sal grond moet koop en seeker maak
dat dit korrek hersoneer word voorrdat enige
nywerheidsontwikkeling kan plaasvvind.
Arbeid
oolde en
Tussen 2 500 en 3 000 gesko
ongeskoolde werkers sal geedurende
konstruksie vir die projek nodig wees,
w
en
ongeveer
200
gedurende
bedryf.
Werkloosheid is hoog in Delmass en die
omliggende dorpies, en hierdie projek
p
sal
Gebied benodig vir die in
nstallasie
'n 600 MW-kragstasie vereis sowat 40
hektaar, en 'n 2 000 MW-kragstasie sal
odig hê.
ongeveer 160 hektaar no
Aswegdoengebied benod
dig
Die aswegdoenfasiliteit sal tussen 150 en
250 hektaar nodig hê vir die 600 MW-as wat
oor 30 jaar geproduseer sal
s word.
As die kragstasie oor tyd
d uitgebrei word, sal
meer grond benodig wo
ord. Grond wat vir
die uitbreiding van die asfasiliteit
voorsiening maak, sal duss gunstig wees.
Konstruksiebergplek
'n Bergingsgebied is die gebied wat tydens
konstruksie gebruik worrd vir die berging
van materiaal, toerustingg en voertuie en vir
kantore en ablusiefasiliteeite vir konstruksiepersoneel.
Die konstruksie van kraggstasies duur 3 tot 4
jaar en is baie arbeidsintensief. Gevolglik
kan tot 100 hektaar nodig
n
wees vir die
bergingsgebied.
H OE
E WERK ' N STEENKOO L - KRAGSTASIE ?
Elektrisiteitopwekking deur 'n stee
enkool-kragstasie vereis dat
steenkool verbrand word om waater te verhit, wat dan in
superverhitte stoom omgeskakel word.
w
Hierdie stoom draai 'n
groot turbine wat aan 'n draaiend
de magneet verbind is wat
hierdie meganiese energie omskakel in elektriese energie
(elektrisiteit), wat dan deur transsformators verder verhoog
word tot hoëspanning elektriese kraag.
Hoësp
panningtransmissielyne vervoer die elektrisiteit
e
van die
kragsttasie na 'n transmissienetwerk. Elektrrisiteit moet dan in
substaasies getransformeer word na spannin
ngs wat meer geskik
is vir residensiële
r
en nywerheidsgebruike.
Die teegnologie wat vir hierdie kragstasie beoog word, is 'n
Sirkuleeerfluïedbed (SFB), wat bewese tegno
ologie is wat 'n baie
doeltrreffende metode geword het om elekktrisiteit op te wek
met lae emissies en omgewingsimpaakte. In 'n SFBool gemeng met 'n
verbraandingsproses word gemaalde steenko
sorben
ns soos kalksteen of dolomiet en verrbrand in 'n proses
soortggelyk aan 'n kokende vloeistof. Die sorbens verwyder die
swael en skakel dit om in 'n omgewingsvrieendelike poeier wat
saam met die as verwyder word.
wwe op opwaartse
Fluïedbeddens suspendeer vaste brandstow
lugstraale tydens die verbrandingsproses. Die resultaat is 'n
turbullente vermenging van gas en vaaste stowwe. Die
tuimelaksie, baie soos 'n borrelende vloeistof, verskaf
doeltrreffender chemiese reaksies en warmte-oordrag.
Fluïedbedverbranding het ontwikkel uitt pogings om 'n
verbraandingsproses te kry wat diee uitlating van
besoedelstowwe kan beheer sonder eksterne emissiebeheermaatrreëls (soos gaswassers).
‘n 200 MW Sirkuleerfluïedbe-kragsstasie in China
Bron:www.english.iet.cas.cn/research/
LaboratoryofCirculatingFluidizedBed//
Die tegnologie verbrand brandstof teen temperature van
ongevveer 900 grade C, wat heelwat laer is as die
dremp
peltemperatuur waar termiese sttikstofoksiede kan
ontstaan (teen nagenoeg 1 300 grade C kombineer stikstof- en
suurstofatome in die verbrandingslug om stikstofoksiedbesoedelstowwe te vorm).
Die mengaksie van die fluïedbed bring die rookgasse in
aanraking met 'n swaelabsorberende chemikalie soos kalksteen
of dolomiet. Ongeveer 90% van die swaelbesoedelstowwe in
steenkool kan binne die ketel deur die sorbens opgevang word.
2x135 MW Sirkuleerfluïedbed kragstasie in in Shanxi, China
(Bron:www.industcards.com/st-coal-china-shanxi.htm)
T ERREINKEURINGSPROSES
Die keuse van die beste terrein vir 'n voorgestelde ontwikkeling
is belangrik ten einde bedryfs- en omgewingsbestuurskwessies
op lang termyn te voorkom of te beperk, en dit hang van baie
faktore af. Nege terreine is aanvanklik in 'n
terreinkeuringsproses geïdentifiseer, en ongeskikte terreine
asook mindergeskikte terreine is uitgeskakel. Vier van die
geskikste terreine sal tydens die Omgewingsimpakbepaling
(OIB)-proses ondersoek word. Grondeienaars betrokke by
hierdie voorkeurterreine is in kennis gestel. Die
terreinkeuringsproses wat voor die OIB gedoen is, sal as 'n
stawende verslag na die Omvangbepalingsfase van die OIB
oorgedra word.
Wetlike vereistes vir terreinkeuring
Die Wet op Nasionale Omgewingsbestuur, No 107 van 1998
(NEMA) bepaal nie spesifieke vereistes vir terreinkeuring of die
oorweging van alternatiewe nie. Die wet vereis egter wel dat
alternatiewe oorweeg en geëvalueer word om die beste
praktiese omgewingsopsie te identifiseer.
Die National Environmental Management: Waste Act, No 59
van 2008 (NEMWA), vereis ook dat alternatiewe betreffende
terrein en tegnologie oorweeg moet word.
Die Departement van Waterwese se jongste minimum vereistes
word gebruik as 'n bestepraktykriglyn om nuwe aansoeke te
evalueer. Dit skets 'n stapsgewyse benadering vir die keuring
van terreine, beginnende met 'n grootgebiedevaluering van
potensiële terreine en die uitskakeling van terreine namate
meer besonderhede verkry word oor terreine wat potensiaal vir
die beoogde gebruik toon. Die proses wat in hierdie verslag
geskets word, volg hierdie benadering van bestepraktykriglyne.
Metodologie
'n Stapsgewyse terreinkeuringsproses word gevolg om te
verseker dat die beste beskikbare ligging vir die kragstasie en
die aswegdoenfasiliteit gekry word.
Kriteria vir identifisering van terrein
Sowel die aswegdoenfasiliteit as die kragstasie vereis die
volgende sleutelkriteria ten opsigte van ligging:
 Die gebied moet verkieslik nie ondermyn wees nie, as
gevolg van langtermynrisiko's van grondstabiliteit.
 Die gebied moet nie bruikbare steenkoolreserwes bevat
nie, wat deur die installasie of as gesteriliseer sal word.
 Die gebied moet verkieslik 'n lae landboupotensiaal hê.
 Oppervlakwaterbronne moet beskerm word as gevolg van
die hoë stres op plaaslike waterbronne.
 Biodiversiteitsensitiwiteite moet vermy word.
 Die kragstasie en die aswegdoenfasiliteit moet naby die
steenkoolbron en verkieslik mekaar wees.
Identifisering van potensiële terreine
Gebaseer op die inligting wat onder Kriteria vir Identifisering
van Terrein genoem is, is potensiële gebiede vir die plasing van
die kragstasie en/of die aswegdoenfasiliteit geïdentifiseer.
Sifting van potensiële terreine
Die nege terreine is gesif aan die hand van twee stelle kriteria:
Tegniese sifting vir 'n kragstasie, waar gekyk is na afstand na
steenkoolbron; topografie; transmissieaansluiting; watervoorsiening; afstand na asfasiliteit; uitbreidingspotensiaal;
ondergrondse werkplekke; steenkoolreserwes; grondeienaarskap en toeganklikheid. Tegniese sifting van aswegdoenterreine
het gekyk na kapasiteit van terreine; bergingsdoeltreffendheid;
topografie; dreineerrigting; uitbreid-ingspotensiaal; toegang vir
vervoerband of vragmotors; grondeienaarskap; potensiaal om
stasie en as op terrein in te pas, en geotegnies.
Omgewingsifting het gekyk na dissiplines soos grondwater;
oppervlakwater; ekonomie; ekologie en estetika.
Die tegniese en omgewingskriteria is oorweeg en die vier beste
moontlike terreine vir die voorgestelde ontwikkeling sal tydens
omvangbepaling verder ondersoek word.
WETLIKE VEREISTES
Die voorgestelde kragstasie vereis 'n aantal omgewingsprosesse en -goedkeurings. Die prosesse sal gelyktydig gedoen word as
geïntegreerde prosesse, aangevul deur 'n gekombineerde proses van openbare deelname.
Hierdie prosesse word hieronder bespreek.
WET OP NASIONALE OMGEWINGSBESTUUR
'n Omgewingsimpakbepaling (OIB) word vir die voorgestelde
projek en gepaardgaande infrastruktuur vereis ingevolge die
Wet op Nasionale Omgewingsbestuur (NEMA), No 107 van
1998, en die nuwe OIB-regulasies (Goewermentskennisgewings
R.543 tot 546, gepubliseer in Junie 2010).
Ingevolge Goewermentskennisgewing R.543 van Junie 2010,
Hoofstuk 2, moet die bevoegde owerheid oorleg pleeg met elke
staatsorgaan wat 'n wet administreer betreffende 'n
aangeleentheid wat die omgewing raak met betrekking tot
daardie aansoek vir 'n omgewingsmagtiging wanneer 'n
aansoek oorweeg word.
Die Departement van Waterwese, Mpumalanga se
Departement van Ekonomiese Ontwikkeling, Omgewing en
Vervoer, ander direktorate van die Departement van
Omgewingsake, die Nkangala-distriksmunisipaliteit en die Victor
Khanye Plaaslike Munisipaliteit (Delmas) is gevolglik
kommentaarowerhede in hierdie proses.
Hierdie
proses
sluit
in
Omvangbepaling
en
Omgewingsimpakverslag (O&OIV)-fases, wat van toepassing is
op alle projekte wat as gevolg van hulle aard of omvang
waarskynlik beduidende omgewingsimpakte sal hê, aktiwiteite
geassosieer
met
potensieel
hoë
vlakke
van
omgewingsagteruitgang, of aktiwiteite waarvoor die impakte
nie maklik voorspel kan word nie.
Ingevolge Goewermentskennisgewing R.544 van 2010 moet 'n
Basiese Bepaling vir die volgende gelyste aktiwiteite vir die
voorgestelde projek gedoen word (hierdie aktiwiteite het 'n
ligter impak as dié van die aktiwiteite waarvoor 'n O&OIV nodig
is en sal meebring dat een OIB vir die voorgestelde projek
gedoen word):
 Aktiwiteit 2: Steenkool sal van die Delmasmyn na die
kragstasie vervoer word. 'n Houfasiliteit vir steenkool sal by
die stasie nodig wees as bufferberging.
 Aktiwiteit 11: Brugkruisings kan nodig wees vir die
oorplasing van steenkool, as, afval en/of water,
afhangende van die finale terreinkeuringscenario.
 Aktiwiteit 12: Water- en stormwaterbergingsfasiliteite op
die terrein sal nodig wees as deel van die





waterbestuurinfrastruktuur vir die kragstasie. Dit kan meer
as 50 000 m3 wees, afhangende van die terreinspesifieke
dreineertoestande.
Aktiwiteit 13: Gevaarlike goedere kan op die terrein geberg
word, soos diesel en chemiese reagense. Dit is
onwaarskynlik dat die bergingskapasiteit meer as 500 m3
sal wees.
Aktiwiteit 18: Vervoerbande kan waterlope kruis, wat tot
die versteuring van oewers lei.
Aktiwiteit 20: Die kragstasie sal binne die mynregtegebied
van die Kuyasa-myn val, en die mynregte sal vir die projek
gewysig moet word.
Aktiwiteit 22: 'n Toegangspad na die kragstasie sal gebou
moet word. Dit sal aansluit by die bestaande provinsiale
pad noord van die myn.
Aktiwiteit 47: Bestaande toegangspaaie sal moontlik
verbreed moet word.
Goewermentskennisgewing R.545 van 2010 vereis dat 'n O&OIV
vir die volgende gelyste aktiwiteite gedoen word, en dit is op
hierdie voorgestelde projek van toepassing:
 Aktiwiteit 1: 'n Voorgestelde kragstasie van 600 MW.
 Aktiwiteit
5:
'n
Lugemissielisensie
en
'n
watergebruiklisensie sal vir die kragstasie verkry moet
word.
 Aktiwiteit 6: Vervoerbande vir die vervoer van as en
steenkool sal nodig wees.
 Aktiwiteit15: Die kragstasie sal meer as 20 hektaar nodig
hê, en moontlik tot 40 hektaar.
Goewermentskennisgewing R.546 van 2010 vereis dat 'n O&OIV
vir die volgende gelyste aktiwiteit gedoen word, en dit is op
hierdie voorgestelde projek van toepassing:
 Aktiwiteit 14: Die skoonmaak van 'n gebied groter as 5
hektaar buite 'n stedelike gebied.
Gevolglik moet 'n Omvangbepalings- en Omgewingsimpakbepalingsverslag (O&OIV) gedoen word.
NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT
Met die proklamering van die National Environmental
Management: Waste Act (NEM:WA), No 59 van 2008, is alle
afvalverwante aktiwiteite wat voorheen ingevolge die Wet op
Nasionale Omgewingsbestuur (NEMA), No 107 van 1998, gelys
is, herroep en word dit nou ingevolge die NEM:WA gelys.
Goewermentskennisgewing R.718 ingevolge die NEM:WA
bepaal die afvalbestuursaktiwiteite waarvoor omgewingslisensiëring vereis word. Ingevolge hierdie kennisgewing is
magtiging vir die volgende aktiwiteite nodig:
 Kategorie A 3(1): Na verwagting sal meer as 100 m3
algemene afval op die terrein geberg word, veral
gedurende die konstruksiefase van die kragstasie.

Kategorie A 3(2): Na verwagting sal meer as 35 m
gevaarlike afval op die terrein geberg word, veral
gedurende die konstruksiefase.

Kategorie A 3(5): By die afvalhersikleeraanleg/
herwinningswerf sal meer as 1 ton algemene afval per dag
vir hersiklering gesorteer word.

Kategorie A 3(9): Indien 'n tuinafvalkomposteeraanleg
3
gebou word, sal dit die kapasiteit hê om meer as 10 m
tuinafval per dag te behandel.

Kategorie A 3(11): Meer as 2 000 m maar minder as
15 000 m3 rioolwater per jaar sal by die rioolwerke op die
terrein behandel word.
3
3

Kategorie A 3(12): Gedurende die konstruksie- en die
bedryfsfase sal diesel- en oliestortings waarskynlik op die
plek behandel word.

Kategorie A 3(18): Die konstruksie van fasiliteite vir enige
van bogenoemde gelyste aktiwiteite (Kategorie A 3(1, 11
en 12)).

Kategorie B 4(9): Hierdie aktiwiteit word gesneller deur
die wegdoen van die ketelas na 'n afvalwegdoenfasiliteit.

Kategorie B 4(10): Hierdie aktiwiteit word gesneller deur
die wegdoen van die ketelas na 'n afvalwegdoenfasiliteit
as die as as gevaarlik geklassifiseer is.
Soos in die regulasies bepaal word, moet 'n persoon wat 'n
aktiwiteit wat onder hierdie Kategorie gelys is, wil begin,
onderneem of uitvoer, 'n Omgewingsimpakbepaling (OIB)proses doen soos bepaal in die OIB-regulasies uitgevaardig
kragtens artikel 24(5) van die NEMA, as deel van 'n aansoek vir
'n afvalbestuurlisensie.
Gevolglik moet 'n aansoek vir 'n afvalbestuurlisensie asook 'n
Omvangbepalings- en Omgewingsimpakverslag (O&OIV) vir
die voorgestelde ontwikkeling aan die Departement van
Omgewingsake voorgelê word.
NASIONALE WATERWET
n Geïntegreerde Water- en Afvalbestuursplan (GWABP) asook 'n Geïntegreerde Watergebruiklisensie word vereis ingevolge
artikel 21 van die Nasionale Waterwet (No 36 van 1998). Verskeie ander watergebruike tydens konstruksie en bedryf sal
gelisensieer moet word.
'n Volledige lys watergebruike wat gelisensieer moet word, sal in die vroeë stadiums van hierdie OIB-proses geïdentifiseer word
NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT
Vir alle kragstasies word 'n Emissielisensie vereis ingevolge die National Environmental Management: Air Quality Act (No 39 van
2004) (NEM: AQA). 'n Omvattende hersiening van wetgewing rakende alle luggehaltevereistes van toepassing op kraginstallasies
en steenkoolmyne sal gedoen word voordat hierdie studie begin. Daar sal verwys word na die NEM:WA asook die ‘National
Ambient Air Quality Standards’ en die Minimum Emissiestandaarde vir Gelyste Aktiwiteite.
VICTOR KHANYE PLAASLIKE MUNISIPALITEIT
Alle eiendomme wat vir hierdie voorgestelde projek gebruik gaan word, moet ook behoorlik hersoneer word volgens die vereistes
van die Victor Khanye Plaaslike Munisipaliteit of die Wet op Ontwikkelingsfasilitering.
O MGEWINGSIMPAKBEPALING
'n Omgewingsimpakbepaling (OIB) is 'n instrument vir beplanning en besluitneming wat ingevolge die Wet op Nasionale
Omgewingsbestuur (NEMA), No 107 van 1998, gedoen word. Vir dié projek sal al die ander omgewingsprosesse tot die OIB bydra.
TEGNIESE PROSES EN PROSES VAN OPENBARE DEELNAME
'n OIB het twee parallelle en geïntegreerde prosesse, naamlik 'n
tegniese proses en 'n proses van openbare deelname.
Die tegniese proses ondersoek "harde" inligting: feite gebaseer
op wetenskaplike en tegniese studies, statistieke of tegniese
data. Dit identifiseer die potensiële negatiewe en positiewe
gevolge van 'n voorgestelde projek of ontwikkeling in 'n vroeë
stadium en beveel maniere aan om positiewe impakte te
vergroot en negatiewe impakte te vermy, te verminder of te
versag.
Die OIB-regulasies bepaal dat 'n Omgewingsbestuursprogram
(OBProg) ontwikkel moet word. Die OBProg bevat aanbevelings
oor hoe om die projek te bedryf en te implementeer. Die
bepalings van die OBProg is wetlik bindend vir die ontwikkelaar
en sy kontrakteurs.
Openbare deelname verseker dat die OIB-proses billik, oop en
deursigtig is. Dit bied ook aan belanghebbendes genoeg
inligting en gee hulle 'n geleentheid om by te dra deur die
inligting na te gaan en kommentaar daarop te lewer.
Reëlings oor onderhandelinge met grondeienaars, indien nodig,
vir grond, serwitute en vergoeding sal gedurende die proses van
openbare deelname van die OIB met die belanghebbendes
gedeel word.
Hierdie onderhandelinge sal egter in 'n afsonderlike proses
plaasvind. Die bevindings van die OIB sal grondeienaars en
KiPower help om die omvang van plaaslike impakte te bepaal
ter stawing van enige nodige onderhandelinge.
Die proses van openbare deelname is bedoel om voldoende
en toeganklike inligting op 'n objektiewe wyse aan
Belanghebbende en Geaffekteerde Partye (B&GP's) te verskaf
om hulle te help om:
 Kwessies te opper en voorstelle vir alternatiewe en groter
voordele te maak;
 Plaaslike kennis by te dra;
 Seker te maak dat hulle kwessies opgeneem en oorweeg is
deur die tegniese ondersoeke;
 Kommentaar te lewer op die bevindings van die OIB.
F ASES IN ' N OIB
OMVANGBEPALINGSFASE
Die eerste fase van 'n OIB is die Omvangbepalingsfase, wat
gedoen word om 'n begrip te kry van die potensiële
omgewingskwessies wat met die projek verband hou en om te
bepaal waar verdere inligting nodig is in die vorm van
spesialisstudies/ondersoeke.
Die Omvangsverslag en Studieplan
n vir die OIB word aan die
bevoegde owerheid voorgelê vir oorweging en om die
edetailleerde ondersoek wat
voorgestelde benadering tot die ge
in die volgende fase nodig is, goed te
e keur.
Aktiwiteite in die Omvangbepalingsffase sluit in:
 Vergaderings met owerhede
e om oor proses- en
studievereistes ooreen te kom;
 Aanvanklike kennisgewings aaan die publiek en grondeienaars, wat insluit die aanbring van terreinkennisgewings,
die uitstuur van briewe, hierdie Agtergrondinligtingsdokument en 'n uitnodiging om tot die OIB-proses by te dra
e verder;
aan B&GP's in die projekgebied en
 Advertensies in plaaslike en streekkoerante om geleenthede
vir deelname bekend te maak;
 Vo
orderingsterugvoerbrief en aankon
ndigings oor die
beskikbaarheid van die Konsep-Omvaangbepalingsverslag
OV) en die Kwessiesverslag (KV);
(KO
 Veerspreiding van 'n KOV, insluitende KV, vir kommentaar;
 'n Vergadering met belanghebbendes in die projekgebied
om
m kommentaar op die KOV te kry;
 Vo
oorlegging van 'n Finale Omvangbepaalingsverslag (FOB),
meet alle kwessies wat vir die impakbepaling geopper is, aan
diee DOS;
 Vo
oorlegging van die Studieplan vir die OIB
B aan die DOS;
 Veerspreiding van die FOB vir kommentaar; en
 Veerspreiding van
n vorderingsteerugvoerbrief aan
belanghebbendes.
OMGEWINGSIMPAKVER
RSLAGFASE
Die tweede fase is die Omgewingsimpakverslag (OIV)-fase, wat
mestelling van 'n Konsep-OIV
verskeie spesialisstudies en die sam
behels.
O
As deel van die bepaling sal 'n Omgewingsbestuursprogram
(OBProg) en n Bedryfsplan ook aan die Departement van
v goedkeuring. Deur die
Omgewingsake voorgelê word vir
OBProg te volg, sal KiPower en sy kontrakteurs nakoming van
omgewingsregulasies verseker tyde
ens beplanning, konstruksie,
bedryf en uitdiensstelling (indien van toepassing).
Die ge dentifiseerde spesialisstudies wat vir hierdie OIV vereis
g
(alle seisoensafhanklike
word (tot dusver), word hieronder gelys
studies sal in die nat seisoen gedoen
n word):
 Verkeer;
 Luggehalte;
 Grondsoorte;
 Sosio-ekonomies;
 Erfenis;
 Grondwater;
 Biodiversiteit;
 Oppervlakwater;
 Kosteraming vir vervoeralternattiewe;
 Geotegnies;
 Geraas; en
 GIS vir karteerdoeleindes.
Die naame van die spesialiste wat hierdie studies sal doen, kan
van die kantoor vir openbare deelname verkry word.
Spesiffieke aktiwiteite in hierdie fase sluit in:
 Spesialisstudies wat fokus op uittkomste van die
mvangbepalingsfase en belanghebbend
des se kwessies;
Om
 Vo
orderingsterugvoer aan belanghebbend
des;
 Samestelling van 'n Konsep-OIV en OBPrrog met aanduiding
van die potensiële positiewe en negaatiewe impakte en
maaatreëls om positiewe impakte te verggroot en negatiewe
impakte te verminder of te vermy;
 Om
mgewingsimpakverklaring
met
aanduiding
van
voorkeuralternatief en redes daarvoor;
 Ad
dverteer die beskikbaarheid van die Kon
nsep-OIV en OBProg
in plaaslike en streekkoerante;
 Veerspreiding van die Konsep-OIV en OBProg,
O
insluitende
Kw
wessiesverslag, vir kommentaar;
 Veergadering met belanghebbendes in die projekgebied om
diee bevindings van die OIV voor te hou vir kommentaar; en
 Veerspreiding van die Finale OIV en OBPro
og vir kommentaar.
Die OIIV en OBProg sal dan gefinaliseer en aaan die Departement
van Omgewingsake voorgelê word vir magtigging.
Tegnieese verslae van al die omgewingstudiess gedurende hierdie
projekk sal gedurende hierdie fase beskikb
baar wees vir insae
deur die
d publiek.
BESLUITNEEMFA
ASE
Die derde fase behels kennisgewingg aan die geregistreerde B&GP's van die besluit van die Bevoegde Owerheid,, die Departement
van Omgewingsake in hierdie geval.. Die Departement van Omgewingsake moet hierdie verslag binne 105 dae aaanvaar of verwerp.
Belanghebbendes sal van die Deparrtement se besluit in kennis gestel wo
ord as Omgewingsmagtiging verleen iss of nie en van die
app lprosedure as hulle teen die besluit sou wou appelleer.
Kontak Ons
Openbare Deelname Kantoor
K
:
Andre Jouberrt
Zitholele Consulting
Posbus 6002,,
Halfweghuis, 16
685
Tel: 011 207 20
077
Faks: 086 676 99
950
E-pos: [email protected]
4 November 2013
Our Ref: C182
Your Ref:
C182-00_I&AP_Notification let_Rev 1_AL_20131022
Attention: Stakeholder
Environmental authorisations for the proposed construction of a 600 Mega Watt
(MW) Independent Power Producer (IPP) coal fired power plant and associated
infrastructure for KiPower near Delmas in Mpumalanga
(DEA Ref No.: 12/12/20/2333; NEAS Ref No.: DEA/EIA/0000364/2011; AEL Ref No.: 17/4/AEL/MP311/13/01)
An integrated process for the Environmental Impact Assessment (EIA) and the other licence
applications listed below is being undertaken for the proposed construction of a 600MW
Independent Power Producer (IPP) coal fired power plant and associated infrastructure for
KiPower (Pty) Ltd near Delmas in Mpumalanga by Jones & Wagener (Pty) Ltd (J&W). KiPower
(Pty) Ltd is a subsidiary of Kuyasa Mining (Pty) Ltd, which also owns the Delmas Coal and Ikhwezi
Colliery, both located about 20 km south-east of Delmas in Mpumalanga Province.
KiPower wishes to establish a 600 MW power plant in close proximity to Delmas Coal, utilising
coal from this mine to fuel for the power plant. Associated with the power plant, is a proposed ash
disposal facility that will be located near the plant.
Associated infrastructure includes:
•
•
•
•
Access roads from the nearby R50 provincial road;
Coal and ash haul route (road and conveyor);
Contractors camp (for the construction phase); and
Bulk water supply pipeline (separate Basic Assessment process is currently being
undertaken by J&W).
The proposed project and associated infrastructure requires a Scoping and Environmental Impact
Reporting (S&EIR) process in terms of the National Environmental Management Act (NEMA), No
107 of 1998 and the EIA regulations (Government Notice Regulation R.543 to 546, published in
June 2010). An environmental authorisation from the Department of Environmental Affairs (DEA)
is therefore required in order to construct and operate the proposed power plant. In addition to
the application under NEMA for environmental authorisation, KiPower is also applying for:
•
A Waste Management Licence in terms of the National Environmental Management:
Waste Act (NEM:WA), No 59 of 2008 from the DEA;
•
A Water Use Licence in terms of the National Water Act (NWA), No 36 of 1998 from the
Department of Water Affairs (DWA). The application is supported by an Integrated
Water and Waste Management Plan (IWWMP);
JO N ES & W AGEN ER (PT Y) LT D
REG NO. 1993/02655/07 VAT No. 4410136685
DIRECTORS: PW Day (Chairman) PrEng DEng HonFSAICE D Brink (CEO) PrEng BEng(Hons) FSAICE PG Gage PrEng CEng BSc(Eng) GDE MSAICE AIStructE JP van der Berg PrEng PhD MEng FSAICE
TT Goba PrEng MEng FSAICE GR Wardle (Alternate) PrEng MSc(Eng) FSAICE
TECHNICAL DIRECTORS: JR Shamrock PrEng MSc(Eng) MSAICE MIWMSA JE Glendinning PrSciNat MSc(Env Geochem) NJ Vermeulen PrEng PhD MEng MSAICE A Oosthuizen PrEng BEng(Hons) MSAICE
HR Aschenborn PrEng BEng(Hons) MSAICE M van Zyl PrSciNat BSc(Hons) MIWMSA MW Palmer PrEng MSc(Eng) AMSAICE TG le Roux PrEng MEng MSAICE
ASSOCIATES: BR Antrobus PrSciNat BSc(Hons) MSAIEG AJ Bain BEng AMSAICE PJJ Smit BEng(Hons) AMSAICE R Puchner PrSciNat MSc(Geol) IMSAIEG MAEG M van Biljon MSc(Hydrogeology)
JS Msiza PrEng BEng(Hons) MSAICE MIWMSA RA Nortjé PrEng MScEng MSAICE MIWMSA GB Simpson PrEng MEng MSAIAE
CONSULTANT: JA Kempe PrEng BSc(Eng) GDE MSAICE AIStructE
FINANCIAL MANAGER: HC Neveling BCom MBL
2
•
An Atmospheric Emissions Licence Application (AEL) in terms of the National
Environmental Management Air Quality Act (NEM:AQA), No 39 of 2004 from the
Nkangala District Municipality;
•
An Environmental Management Programme Report (EMPR) Amendment and Closure
application for the Pit H area of Ikhwezi Colliery in terms of the Mineral and Petroleum
Resources Development Act (MPRDA), No 28 of 2002 from the Department of Mineral
Resources (DMR) in Mpumalanga;
•
An application for rezoning of Portions 3, 4 and 5 of Haverklip 265 IR was submitted to
the Victor Khanye Local Municipality in April 2013. On 23 August 2013 the rezoning of
these portions of land was approved for use as a residue facility. An application for
rezoning of the power plant footprint has not yet been submitted to the municipality. This
land is still in the process of being transferred to Kuyasa Mining from BHP Billiton Energy
Coal South Africa (BECSA). Once the transfer agreement is finalised, the rezoning
application will be submitted.
The EIA process for the above project began in 2007 and the scoping phase was completed in
2012 when the DEA approved the Final Scoping Report on 7 November 2012.
There are a number of specialist assessments being completed for the project. The Terms of
Reference for these assessments were published in the Scoping Report which was available for
stakeholder review and comment. The specialist studies have taken longer than initially
anticipated due to several factors, namely: seasonal requirements and changes in the level of
detail required for several investigations. These studies, when completed will form part of the
Draft Environmental Impact Report (DEIR) and Environmental Management Programme (EMPr)
that will be made available for public review. The DEIR and EMPr provide an integration of the
findings, potential impacts during construction and operation and mitigation measures to minimise
the potential impacts.
It is anticipated that the DEIR and EMPr will be available for stakeholder and authority review
early next year (2014). Part of the review process will include meetings with authorities and
stakeholders. Notifications of when the report will be made available and when meetings are
proposed will be distributed early in 2014.
If you haven’t already done so, you are encouraged to register as an Interested and Affected
Party (I&AP), and submit any comments, questions or issues that you may have about the
proposed project to Anelle Lötter or Sibongile Bambisa, Jones & Wagener, Tel (012) 667-4860 or
email [email protected] / [email protected].
Yours sincerely,
Anelle Lötter
for Jones & Wagener
Document source: M:\C182 - KiPower EIA (ENV)\Correspondence\C182-00_IAP_Notification let_Rev 1_AL_20131022.docx
Document template: corLet_13r1
C182-00_IAP_Notification let_Revc_ALjh_20131023
23 January 2014
Our Ref: C182
Your Ref:
C182_StakeholderNotificationLetter-jh-AL_20140123
Attention: Stakeholder
Environmental authorisations for the proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal fired power plant and associated
infrastructure for KiPower near Delmas in Mpumalanga
(DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.: 17/4/AEL/MP311/13/01,
Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Draft reports available for public review




Environmental Impact Assessment (EIA) Report;
Environmental Management Programme (EMPr);
Waste Management Licence Application (WMLA) Report; and
Atmospheric Emissions Licence (AEL) Application.
An integrated process for the Environmental Impact Assessment (EIA) process and the other
licence applications (listed below) is being undertaken for the proposed construction of a
600 MW Independent Power Producer (IPP) coal fired power plant and associated infrastructure
for KiPower (Pty) Ltd near Delmas in the Mpumalanga Province by Jones & Wagener (Pty) Ltd
(J&W). KiPower is a subsidiary of Kuyasa Mining (Pty) Ltd, which also owns Delmas Coal and
Ikhwezi Colliery, both located about 20 km south-east of Delmas in the Mpumalanga Province.
1.
DRAFT REPORTS AVAILABLE FOR YOUR REVIEW
The Draft Environmental Impact Assessment Report (DEIR), Draft Waste Management Licence
Application Report and Draft Atmospheric Emissions Licence Application Report have been
finalised and will be made available for a public review period. The draft reports contain the
studies done by the various specialists, the integrations of the findings and an Environmental
Management Programme (EMPr), which prescribes how the proposed project should be
managed before, during and after its proposed construction.
The draft reports will be available for public review from Friday, 7 February to Tuesday, 18
March 2014. The reports will also be submitted to the Department of Environmental Affairs
(DEA) and other relevant authorities for their comment and review.
Please use the enclosed form to request your own CD copy of the draft reports if you intend to
comment. In addition, the draft reports will be available on the J&W website (www.jaws.co.za)
and at the public places listed below as from 7 February 2014:
2
Contact
Ms N Potgieter
Ms Nelia Nienaber
Ms Lydia Mehlape
Reception
Electronic copies
Anelle Lötter/ Sibongile Bambisa
Location
Leandra Public Library
Devon Public Library
Delmas Public Library
Delmas Coal
www.jaws.co.za / phone and request a CD copy
Contact Tel
017 683 1148
017 688 0028
013 665 1831
013 665 7000
012 667 4860
You are encouraged to comment on the draft reports in any of the following ways:
 By completing the comment sheet enclosed with reports;
 By writing a letter, or producing additional written submissions;
 By emailing or contacting the public participation office; or
 By attending the open house and stakeholder meeting (see details below).
2.
INVITATION TO AN OPEN HOUSE AND STAKEHOLDER MEETING
You are invited to attend an open house and a stakeholder meeting where the contents of the
draft reports will be presented and discussed. Please note that informal discussions will take
place during the open house whereas a formal presentation will be made by the Environmental
Assessment Practitioner (EAP) at the stakeholder meeting. The presentation will be a summary
of the draft reports. Should you wish to have a one-on-one discussion with the EAP – it is
recommended that you attend the open house as well. The details of the open house and
stakeholder meeting are as follows:
Date:
Venue:
Time - open house meeting:
Time - stakeholder meeting:
Wednesday, 26 February 2014
Delmas Agricultural Hall / Lapa (contact us for directions)
10:00 - 17:00
18:00 - 20:00
It is important that you register in advance so that we can make the necessary arrangements.
Please use the enclosed form and return it by 14 February 2014. Kindly send your reply to
Anelle Lötter/ Sibongile Bambisa at the Public Participation Office on tel: (012) 667 - 4860, fax:
012 667 6128 or email: [email protected]/ [email protected].
3.
PROJECT DESCRIPTION AND HISTORY
KiPower proposed to establish a 600 MW power plant in close proximity to Delmas Coal,
utilising coal from this mine to fuel for the power plant. Associated with the power plant, is a
proposed ash disposal facility that will be located near the plant.
Associated infrastructure includes, amongst others:
•
•
•
•
Coal and ash conveyors;
New access roads;
Contractors camp (for the construction phase); and
Bulk water supply pipeline (separate Basic Assessment process is currently being
undertaken by J&W).
The proposed project and associated infrastructure requires a Scoping and Environmental
Impact Reporting (S&EIR) process in terms of the National Environmental Management Act
(NEMA), No 107 of 1998 and the EIA regulations (Government Notice Regulation R.543 to 546,
published in June 2010). An environmental authorisation from the Department of Environmental
Affairs (DEA) is therefore required in order to construct and operate the proposed power plant.
In addition to the application under NEMA for environmental authorisation, KiPower is also
applying for:
C182_Stakeholder Notification Letter
3
•
A Waste Management Licence in terms of the National Environmental Management:
Waste Act (NEM:WA), No 59 of 2008 from the DEA;
•
A Water Use Licence in terms of the National Water Act (NWA), No 36 of 1998 from
the Department of Water Affairs (DWA). The application is supported by an Integrated
Water and Waste Management Plan (IWWMP). The Integrated Water Use Licence
Application (IWULA) report will be made available for public review at a later stage;
•
An Atmospheric Emissions Licence Application (AEL) in terms of the National
Environmental Management: Air Quality Act (NEM:AQA), No 39 of 2004 from the
Mpumalanga Department of Economic Development, Environment and Tourism
(MDEDET);
•
An Environmental Management Programme Report (EMPR) Amendment and Closure
application for the Pit H area of Ikhwezi Colliery in terms of the Mineral and Petroleum
Resources Development Act (MPRDA), No 28 of 2002 from the Department of Mineral
Resources (DMR) in Mpumalanga. This report will be made available for public review
at a later stage;
•
An application for rezoning of Portions 3, 4 and 5 of Haverklip 265 IR was submitted to
the Victor Khanye Local Municipality in April 2013. On 23 August 2013 the rezoning of
these portions of land was approved for use as a residue facility. An application for
rezoning of the power plant footprint has not yet been submitted to the municipality.
This land is still in the process of being transferred to Kuyasa Mining from BHP Billiton
Energy Coal South Africa (BECSA). Once the transfer agreement is finalised, the
rezoning application will be submitted.
Documents to announce this process were sent to you during July 2011. The Final Scoping
Report was made available for public review from 27 June to 20 July 2012. The Competent
Authority (CA), the Department of Environmental Affairs (DEA) approved the Scoping Report in
November 2012 and all stakeholders were notified of the approval. As such, the Scoping Phase
for the proposed project was concluded and the Impact Assessment phase commenced.
4.
THE WAY FORWARD
In terms of the EIA and associated processes being followed, the draft reports will be finalised
after the public review period. The final reports will be compiled and will also be made available
for public review. A notification of the public review of the final reports will be sent to all
stakeholders.
Included in this letter is a copy of a non-technical summary of the DEIR. This document
provides you with a brief summary of the findings of the DEIR and stakeholders are encouraged
to also read it in conjunction with the DEIR for clarification on the details.
We are looking forward to your response to this letter.
Yours faithfully
Anelle Lötter
for Jones & Wagener
Document source: M:\C182 - KiPower EIA (ENV)\Public Participation\Impact Assessment Phase\Preparations for public
review\DEIR_Notification_Letter\C182_StakeholderNotificationLetter-jh-AL_20140123.docx Document template: corLet_13r1
C182_Stakeholder Notification Letter
C182 – Stakeholder database
Mr Adriaan Nel
Haverklip
P O Box 163
DELMAS 2210
Email:
TEL(071) 715-0089
CELL071 715 0089
CELL083 282 666
[email protected]
Mr Agriba Sibanyoni
Regional Manager: Northern Region
South African National Roads Agency Limited
Private Bag X17
LYNNWOOD RIDGE 0040
Email:
TEL(012) 426 6200
FAX(012) 348 - 0883
CELL083 283 6038
[email protected]
Ms Aletta Moletsane
Chief Social Worker
Department of Social Development
P O Box 2334
BRONKHORSTSPRUIT 1020
TEL(013) 932 2965
FAX(013) 932 0025
Ms Aletta Venter
Andries Schoeman Brakfontein Boerdery (Pty) Ltd
P O Box 270
Delmas
2210
Mrs Allison Hernandez-Maldonaldo
Personal Assistant to Chief Director
Department of Water Affairs (DWA)
Private Bag X9506
POLOKWANE 0700
Email:
Email:
TEL(015) 290-1215
FAX(015) 295-2295
CELL082 809 5604
FAX(086) 512-9315
[email protected]
[email protected]
Ms Amanda Botha
Editor
TEL(013) 656 2490
FAX(013) 656 5335
1
C182 – Stakeholder database
Witbank News
P O Box 36
WITBANK 1035
Email:
[email protected]
Ms Anna-Martha Ott
Middelburg Chamber of Commerce and Industry
292 Walter Sisulu Street, Middelburg
1050
Email: [email protected]
TEL: 013 243 2253
CELL: 083 458 2865
Mr André Botha
Manager: Birds of Prey Working Group
Endangered Wildlife Trust
Private Bag X11
PARKVIEW 2122
Email:
TEL(011) 486 1122
FAX086 606 2887
CELL082 962 5725
[email protected]
Mr Andre Viljoen
Attorney
TEL: 017 620 9000
Email: [email protected]
Ms Angela Shalang
TEL: (011) 800 2264
Eskom: Transmission and Distribution infrastructure
P O Box 1091
Johannesburg
2000
Email: [email protected]
Mr April Leketa
Manager
Telkom (Witbank)
Email:
[email protected]
TEL(013) 249 6515
FAX(013) 246 2767
CELL082 783 0748
Ayanda Bam
KiPower
Email:
TEL(013) 665-7000
[email protected]
2
C182 – Stakeholder database
Mr Bheki Mthethwa
Delmas Coal
Email:
[email protected]
TEL(013) 665-7000
Mr Boet Conradie,
Environmental Manager – Pan Africa Mine Portion 7 of Watervalshoek
Email: [email protected]
Mr Bobby Peek
groundWork, Friends of the Earth, South Africa
P.O. Box 2375, Pietermaritzburg
3200
Email: [email protected]
TEL: 017 620 1782
Tel: 033 342 5662
Fax: 033 342 5665
Cell: 082 464 1383
Mr Bongani Hlatshwayo
Editor
Mpumalanga News
P O Box 246
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 754 1600
FAX(013) 755 2414
Mr Brent Parrott
Chairperson
Schoeman Boerdery
PO Box 33
DELMAS 2210
TEL(013) 665-7721
FAX(013) 665-1646
CELL071 678 3730
Email:
[email protected]
Mr Bruce van den Heuvel
Head: Safety, Health and Environmental RQ
Sasol Gas
P O Box 1234
RANDBURG 2125
Email:
[email protected]
TEL(011) 865 8563
FAX(011) 865 8591
CELL082 450 2822
Mr Buti Phungwayo
Steenkoolspruit
Embalenhle Ext 1, Ndlovu Street
TSAKANE 1550
CELL072 560 9540
3
C182 – Stakeholder database
Ms Carla Davis
Engineering Manager
Trans African Concessions (Pty) Ltd
P O Box 4356
NELSPRUIT 1200
Web Site:
Email:
TEL(013) 755 3316
FAX(013) 752 6934
CELL082 887 4941
www.tracn4.co.za
[email protected]
Mrs Carla Hudson
Regional Manager
Wildlife and Environment Society of South Africa
(WESSA)
P O Box 435
FERNDALE 2160
Email:
[email protected]
TEL(011) 462 5663
FAX(011) 462 8364
CELL083 756 0072
Ms Cathy Grosvenor
Editor/Advertiser
Springs Advertiser (Springs Chamber of Commerce)
P O Box 761
SPRINGS 1560
Email:
[email protected]
Email:
[email protected]
TEL(011) 812 4800
FAX(011) 362 1674
Ms Cecilia Russell
Editor
The Star Newspaper
P O Box 1014
JOHANNESBURG 2000
Email:
[email protected]
TEL(011) 633 9111
FAX(011) 836 6186
Mr Charles Magagula
CELL: (082) 713 1494
Emalahleni Community Radio
013 656 2897
PO Box 17024
Witbank
1035
Email: [email protected]
FAX:
4
C182 – Stakeholder database
Ms Cindy Smith
Anglo Operations (Pty) Ltd
Building B, New Largo Project, Landau
Witbank
1038
Email: [email protected]
Tel: (013) 691 5117
Cell: 083 659 2194
Mr Cornelius Tsepetsi
Regional Accounts Executive
Rand Water
P O Box 1127
JOHANNESBURG 2000
Email:
[email protected]
TEL(011) 682-0214
FAX(086) 630-5293
CELL078 428 1639
Mr David Kleyn
Directorate: Land Use and Soil Management
Department of Agriculture, Forestry and Fisheries
(DAFF) (NW)
Private Bag X120
PRETORIA 0001
Email:
[email protected]
CELL082 789 6915
Mr David & Sicelo Mbonani
Steenkoolspruit/ Somphalali Siyabuyela Communal Property Trust
4234 Singa Street
TSAKANE 1550
Email: [email protected]
CELL072 399 8068
Mr Deon du Plessis
Regional Manager
Department of Mineral Resource
Private Bag X7279
WITBANK 1035
Email:
[email protected]
TEL(013) 656 1448
FAX(013) 690 3285
CELL082 465 6154
Ms Dineo Tswai
Senior Environmental Officer
Mpumalanga Department of Economic Development,
Environment and Tourism
(MDEDET)
Private Bag X7255
WITBANK 1035
TEL(013) 690 1279
FAX(013) 695 3928
Cell:072 539 2052
5
C182 – Stakeholder database
Email:
[email protected]
Mr Dries Fella
Maintenance of exchanges
Telkom Witbank CNFO
P O Box 17403
WITBANK 1035
Email:
[email protected]
TEL(013) 690 3500/1120
FAX(013) 690 1120
CELL082 454 2633
CELL081 414 7157
Mr Dumisane Makhubela
Department of Health
Private Bag X11285
NELSPRUIT 1200
TEL(013) 766 3429
FAX(013) 766 3458
TEL(013) 766-3430
Mr Dumisani Sibayi
Executive Officer: Heritage Branch
South African Heritage Resource Agency (SAHRA)
P O Box 4637
CAPE TOWN 8000
Email:
[email protected]
TEL(021) 462 4502
FAX(021) 462 4509
Ms E K Tshabalala
Manager of Social Services
Nkangala District Municipality
P O Box 437
MIDDELBURG 1050
Email:
[email protected]
TEL(013) 249-2000
Ms Elise Tempelhoff
Senior Environmental Reporter
Beeld Newspaper
P O Box 333
AUCKLAND PARK 2006
Email:
[email protected]
TEL(011) 713 9182
FAX(011) 713 9956
CELL083 309 1192
Mr Eric Van Der Merwe
Transnet
P O Box 13323
NORKEM PARK 1618
Email:
[email protected]
TEL(011) 978 2530
FAX(011) 978 2533
CELL083 286 5031
Mr Ernst De Jager
Hawerklip Silo Manager
Email:
[email protected]
CELL082 554 0915
Ms Eva Makhabane
Executive Mayor
TEL
FAX
6
(013) 665 6000
(013) 665 6969
C182 – Stakeholder database
Victor Khanye Local Municipality
P O Box 6
DELMAS 2210
Email:
[email protected]
Ms Fiona Grimett
Department of Environmental Affairs
Email:
[email protected]
TEL(012) 395-1793
Ms Fozia Ismail
Clyde Bergemann Africa (Pty) Ltd
Sales Co-Ordinator
Email: [email protected]
Tel: (011) 704 0580
Fax: (086) 734 0134
Mr G J J Borman
P O Box 168
DELMAS 2210
Email:
[email protected]
TEL (013) 665-5122
CELL: 082 324 2629
Ms G W Langa
Deputy Chief Executive Officer
South African Local Government Association (SALGA)
P O Box 1693
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 752 1200
FAX(013) 752 5575
Dr George Prinsloo
Steenkoolspruit/ Prinsloo Kindertrust
P O Box 355
DELMAS 2210
Email: [email protected]
TEL(013) 665-2530
FAX(013) 665 2530
Mr Gerrit Borman
Haverklip
Email:
[email protected]
TEL(013) 665-5122
Mr Graeme Campbell
Editor
Streeknuus
P O Box 2333
BRONKHORSTSPRUIT 1020
Email:
[email protected]
TEL(013) 932 3031
FAX(013) 932 3033
CELL082 921 7282
Dr Hannes Botha
Mpumalanga Tourism and Parks Agency
P O Box 1250
GROBLERSDAL 0470
TEL(013) 262 4844
FAX(013) 262 4858
CELL082 575 4240
TEL(013) 262 4845
7
C182 – Stakeholder database
Email:
Email:
[email protected]
[email protected]
Mr Hannes van Dyk
Owner
Plaas Brakfontein
P O Box 609
DELMAS 2210
TEL(013) 665 3983
CELL082 633 8803
CELL072 016 9350
Mr Hernus Claassen
Haverklip & Vanggatfontein
P O Box 37
DELMAS 2210
Email:
[email protected]
CELL082 616 7788
Ms Isabel Knox
Haverklip
P O Box 300
DELMAS 2210
Email:
[email protected]
TEL(013) 665-7000
CELL082 889 1325
Mr Jacob Mahlangu
CPA - Steenkoolspruit
PO Box 3891
EMPUMALANGA 0458
Email:
[email protected]
CELL076 400 8860
Mr Jacob Malesa
Water Pollution Control Officer
Department of Water Affairs (DWA)
Private Bag X10528
BRONKHORSTSPRUIT 1020
Email:
[email protected]
TEL(013) 932 2061
FAX(013) 932 2071
CELL082 603 9187
CELL076 738 0033
Mr Jai Braithwaite
Manager
Telkom SA
Private Bag X055
VEREENIGING 1930
Email:
[email protected]
TEL(016) 455-5090
FAX(016) 455-5090
CELL082 564 4303
TEL(081) 354-1311
Mnr Jan Boshoff
Plaas Brakfontein 310-Ged 20/ Kromdraai
Jan Boshoff Boerdery
Posbus 354
LESLIE 2265
TEL(017) 683 0930
FAX086 666 0930
CELL082 388 0912
8
C182 – Stakeholder database
Email:
[email protected]
Mr Jan de Klerk
CELL: 083 633 2931
Eskom: Eskom: Transmission Lands & Rights
P O Box 1091
Johannesburg
2000
Email: [email protected]
Mr Jan Oliver
National Roads Agency Northern Section
Private Bag X17
LYNNWOOD RIDGE 0040
Email:
[email protected]
TEL(012) 844-8105
FAX(012) 348-0883
CELL083 283 6083
Mr Jan Moolman
Landowner: Portion 24 of Brakfontein
CELL: 083 229 4406
Email: [email protected] or [email protected]
Mr Jan Stander
Telkom South Africa
P O Box 7434
MIDDELBURG 1050
Email:
[email protected]
TEL(013) 246 2227
FAX(013) 246 2380
CELL082 781 3057
Mr Jan Steenkamp
Deputy Manager: Corporate Services
Victor Khanye Local Municipality
P O Box 6
DELMAS 2210
Email:
[email protected]
TEL(013) 665-4825
FAX(013) 665 4804
Mr Jan Venter
Mpumalanga Department of Agriculture, Rural Development and Land
Administration
Private Bag X9019
Ermelo
2350
Email: [email protected]
Ms Janine Stoop
Telkom SA
P O Box 1352
MIDDELBURG 1050
Email:
[email protected]
TEL: (017) 819-2076
CELL: 082 653 7611
TEL(013) 249-6246
FAX(013) 282-5073
CELL082 899 5299
9
C182 – Stakeholder database
Mr Jeff Scrooby
Transnet Pipelines
P O Box 3113
DURBAN 4000
Email:
[email protected]
TEL(031) 361 1343
FAX(031) 361 1534
CELL083 284 1078
Mr Jeremy Kirsch
CBA
PO Box 374 Kyasands
Randburg
2163
Email: [email protected]
Tel: (011) 704 0584
Fax: (086) 734 0134
Mr Johan Smit
Domain Estates
Email:
[email protected]
CELL083 521 7411
Mr Johan van Dyk
Haverklip
P O Box 609
DELMAS 2210
CELL072 135 8412
Mr Johan Claassens
Haverklip & Vanggatfontein
P O Box 37
DELMAS 2210
Email:
[email protected]
CELL082 944 4590
CELL082 616 7788
Julian Eslait
Anglo American-Project Manager
55 Marshall Street, Johannesburg, 2001
Email: [email protected]
TEL: (011)638 5135
CELL: (083) 285 9355
FAX: (011) 638 2645
Mr/Mev Johan & M Gericke
Plaas Brakfontein
Posbus 25, Williamsweg
BEYERSPARK 1459
Email:
[email protected]
TEL(013) 665 1694
CELL083 263 8660
Mr Johan Odendaal
Odendaal & Kruger Prokureurs
TEL: 013 665 5088
Email: [email protected]
Mr Johann van Aswegen
Director: WRM
TEL(013) 932 2042
FAX(013) 932 2071
10
C182 – Stakeholder database
Department of Water Affairs (DWA)
Private Bag X11259
BRONKHORSTSPRUIT 1200
Email:
[email protected]
CELL082 807 4198
Mr Johann Minnaar
JM Property and Mineral Rights Consultants
Email:
[email protected]
CELL076 643 8750
Mr John Broodryk
Chairman
Birdlife of South Africa
P O Box 19334
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 753 3238
FAX(013) 753 3239
CELL083 254 0896
Mr Johan Claassens
Email: [email protected]
Cell: 082 944 4590
Mr John Wesson
Region Manager: North West
Wildlife and Environment Society of South Africa
(WESSA)
P O Box 916
HARTBEESPOORT 0216
Email:
[email protected]
TEL(012) 504 1408
FAX(086) 614 2338
CELL083 444 7649
Mr Joppie Victor
P O Box 612
DELMAS 2210
Email:
[email protected]
TEL(013) 665-5122
CELL082 944 6080
Ms Joyce Lekoane
Department of Water Affairs (DWA)
Private Bag X10580
BRONKHORSTSPRUIT 1020
Email:
[email protected]
TEL(013) 932 2061
FAX(013) 932 2071
Ms Joyce Botha
Mpumalanga Tourism and Parks Agency
P O Box 1250
GROBLERSDAL 0470
TEL(013) 262 4844
FAX(013) 262 4858
Ms Julie Wolfaardt
Senior Marketing Officer
Sasol Gas
P O Box 1234
TEL(011) 889 9017
FAX(011) 522 2508
CELL082 777 1023
11
C182 – Stakeholder database
RANDBURG 2125
Email:
[email protected]
Ms Karlinka Bezuindenhout
Stuart Coal (Pty) Ltd, SHE Manager
Email: [email protected]
Mr Kevin Rudd
Assistant Property Management
Email:
[email protected]
Tel:
(013) 665-8930/1
FAX: : (013)665-8932
TEL
FAX
CELL
CELL
(031) 940-1260
(031) 267-2603
082 886 8861/ 082 886 8811
Mr Kgopana Mohlasedi
Head of Department
Department Public Works, Roads and Transport:
Mpumalanga
Private Bag X11310
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 766-6554
FAX(013) 766-8449
Dr Koos Pretorius
Director
Federation for a Sustainable Environment (FSE)
P O Box 201
BELFAST 1100
Email:
[email protected]
TEL(013) 253 0051
FAX(086) 514 6085
CELL083 986 4400
Mr Koos Liebernberg
Matjiesoebrai
Email:
[email protected]
CELL082 389 9526
Mr Koos Uys
Koos Uys & Seun Boerdery CC - Crops and grazing
Landowner: Portion 16 of Brakfontein
Email: [email protected]
Tel: 071 356 1230 /
Mr Langa Zitha
Director
Department of Agriculture, Forestry and Fisheries
(DAFF)
Private Bag X250
NELSPRUIT 1200
Email:
[email protected]
TEL(012) 319-7300
Mr Lazarus Moloto
Tel: 013 665 2971
Mr LeBeau Labuschagne
Deputy Director: Environment and Mineral Policy
TEL(012) 317 8300
FAX(012) 320 6786
12
C182 – Stakeholder database
Department of Mineral Resources
Private Bag X59
PRETORIA 0001
Email:
[email protected]
CELL082 453 6760
Mrs Lebo Mosoa
Assistant Director: Integrated Water Resource
Planning North
Department of Water Affairs (DWA)
Private Bag X313
PRETORIA 0001
Email:
[email protected]
TEL:(012) 336 7564
FAX:(012) 336-6731
CELL:082 885 1965
Ms Lerato Mautjana
Department of Water Affairs (DWA)
Private Bag X10580
BRONKHORSTSPRUIT 1020
Email:
[email protected]
TEL(013) 932 2061
FAX(013) 932 2071
CELL082 608 0080
Mr Leonard van der Walt
Eskom
Email: [email protected]
TEL: 011 8002268
Ms Louise Human
(011) 800 2264
TEL:
Cell:
083 233 6727
Eskom: Transmission and Distribution infrastructure
P.O.Box 579 Nelspruit 1200
Email:
[email protected]
Mr Love Shabane
TEL
(013) 766 6020
Department of Agriculture, Rural Development and
Land Administration
FAX
(013) 766 8429
Private Bag X11219
NELSPRUIT 1200
Email: [email protected]
Mr Lucas Mahlangu
Deputy Director: Waste Management
Department of Environmental Affairs (DEA)
Private Bag X447
PRETORIA 0001
Email:
[email protected]
TEL(012) 310 3536
FAX(012) 320 1167
CELL082 656 6652
Mr Lucky Mochalibane
TEL(012) 337 2057
13
C182 – Stakeholder database
Chief Director: Communication
Department of Public Works
Private Bag X65
PRETORIA 0001
Email:
[email protected]
Email:
[email protected]
FAX(012) 323 2856
CELL082 899 9775
Mrs Lydia Mehlape
DelmasPublic Library
Cnr Cilliers & van Riebeeck Streets
Delmas
2210
Tel: 013 665 1831
Mr M A Schalekamp
Haverklip
P O Box 1035
DELMAS 2210
Email:
[email protected]
CELL082 492 2170
Mnr Maarten Schalekamp
Haverklip, Rietkuil
Email:
[email protected]
CELL082 492 2170
Mrs Magadi Ratema
Administrator
Telkom Head Office
P O Box 925
PRETORIA 0001
Email:
[email protected]
TEL(012) 311 3489
Mev Magda Kleyn
Straffontein Farm
Posbus 888
DELMAS 2210
Email:
[email protected]
TEL(013) 648 1714
CELL082 524 9067
Mr Makoma Lekalakala
Sustainable Energy and Climate Change
Programme officer
Earthlife Africa Johannesburg
Email: [email protected]
TEL: 011 339 3662
Mrs Makulana Joyce Phora
TEL: 013 944 8901
Station Manager: Moutse Community Radio Broadcast
013 944 8902
Email: [email protected]
FAX:
14
C182 – Stakeholder database
Ms Mamogala Kadiaka
Director: Water Sector Regulation and Use
Department of Water Affairs (DWA)
Private Bag X11259
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 755-1678
CELL083 492 9690
Mr Mandla Mazibuko
Head of Department
Department of Economic Development, Environment
and Tourism(LEDET)
Private Bag X11205
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 766-4572
FAX(013) 766-4617
CELL071 674 6362
Ms Mandy Driver
SANBI
Private Bag X7
CLAREMONT 7735
Email:
[email protected]
TEL(021) 799-8838
FAX(086) 520-7529
CELL083 468 8257
Ms Marianna Niewoudt
Communications Consultant
Olifants River Forum
P O Box 2189
SECUNDA 2302
Email:
[email protected]
TEL(017) 634 7208
FAX(017) 634 7208
CELL082 459 1021
Mrs Mariette Liefferink
Chief Executive Officer
Federation for a Sustainable Environment (FSE)
Postnet Suite 87, Private Bag X033
RIVONIA 2128
Email:
[email protected]
TEL(011) 787 7965
FAX(011) 781 6154
CELL073 231 4893
Ms Martha Mokonyane
Department of Mineral Resources
Private Bag X7279
Emalahleni
1035
Email: [email protected]
TEL: 013 653 0500
CELL: 073 154 8204
Ms Merriam Ngwekazi
Eskom: Transmission and Distribution infrastructure
P O Box 1091, Johannesburg
2000
Email: [email protected]
TEL: (011) 800 2264
15
C182 – Stakeholder database
Mr Marius Keet
Deputy Director: Water Quality Management
Department of Water Affairs (DWA)
Private Bag X313
PRETORIA 0001
Email:
[email protected]
TEL(011) 392-1300
CELL082 807 3522
Mr Martin Creamer
Editor
Engineering News and Mining Weekly
P O Box 75316
GARDEN VIEW 2047
Email:
[email protected]
Email:
[email protected]
TEL(011) 622 3744
FAX(011) 622 9350
Mr Meshack Malinga
MEC
Department of Agriculture, Rural Development and
Land Administration
Private Bag X11219
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 766 6074
FAX(013) 766 8437
CELL086 697 8998
Mr Michael Yorke-Hart
Project Engineer: North West, Gauteng, Mpumalanga
and Limpopo
South African National Roads Agency Limited
(SANRAL)
Private Bag X17
LYNNWOOD RIDGE 0040
Email:
[email protected]
TEL(012) 426 6227
FAX(012) 348 1512
CELL083 283 6087
CELL083 283 6089
Ms Minah Maredi
Victor Khanye Local Municipality
Municipal Manager
P O Box 6
DELMAS
2210
Email:[email protected] /
[email protected]
TEL (013) 665 6000
FAX (013) 665 2913
Mr Milton Moloko
TEL: (011) 800 2264
Eskom: Transmission and Distribution infrastructure
P O Box 1091
Johannesburg
16
C182 – Stakeholder database
200
Email: [email protected]
Mr Mohammed
Tegeta Exploration and Resources (Pty) Ltd
Email: [email protected]
TEL: 011 430 7640
Mr Molefe Morokane
Deputy Director: Resource Protection and Waste
Department of Water Affairs (DWA)
Private Bag X313
PRETORIA 0001
Email:
[email protected]
TEL(012) 336 8697
FAX(012) 323 0321
CELL082 883 7890
Mr MJ Mojapelo
Mpumalanga: Department of Public Works, Roads and Transport
Acting Chief Engineer
Email:[email protected]
Ms Mokgadi Maloba
Department of Water Affairs
22 Rooth Street
Bronkhorstspruit
1020
Email: [email protected]
Tel: 013 766 8620 /
Cell: 079 124 7820
Cell: 082 870 7150
Mr Mpumelelo Saliwa
Kuyasa Mining/ KiPower
Private Bag X7250
WITBANK 1035
Email:
[email protected]
TEL(013) 665-7004
CELL071 681 0661
TEL(013) 665-7000
Ms Nelisiwe Sithole
Head of Department
Department of Agriculture, Rural Development and
Land Administration
Private Bag X11219
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 766 6020
FAX(013) 766 8429
Mr Ntika Maake
TEL: (011) 800 2264
Eskom: Transmission and Distribution infrastructure
P O Box 1091
Johannesburg
17
C182 – Stakeholder database
2000
Email:
[email protected]
Ms Nyiko Ngoveni
Environmental Officer
Department of Environmental Affairs
Private Bag X447
PRETORIA 0001
Email:
[email protected]
TEL(012) 395 1694/1768
FAX(012) 320 7539
Ms Pam Hughes
Shop
Birdlife of South Africa
P O Box 4113
NELSPRUIT 1200
TEL(013) 744 7356
Mnr Peet Bezuidenhout
Director
Welgelegen Farm
Posbus 270
DELMAS 2210
Email: [email protected]
TEL(013) 665 3604
FAX(013) 665 3604
CELL082 524 8365
Mr Peter Thabethe
Department of Agriculture, Forestry and Fisheries
(DAFF)
Private Bag X250
NELSPRUIT 1200
Email:
[email protected]
Email:
[email protected]
TEL(012) 319 7300
FAX(012) 319 7135
Mr Peter Molapo
Department of Labour
Private Bag X7263
WITBANK 1035
Email:
[email protected]
TEL(013) 655 8733
FAX(013) 655 8878
Mr Phillip Hine
Archaeology, Paleontology and Meteorite Unit
South African Heritage Resources Agency (SAHRA)
P O Box 4637
CAPE TOWN 8000
Email:
[email protected]
TEL(021) 462-4502
FAX(021) 462-4509
Mr Pierre Rossouw
Environmental Health Officer
Nkangala District Municipality
P O Box 437
TEL(013) 249 2127
FAX(086) 536-0378
18
C182 – Stakeholder database
MIDDELBURG 1050
Email:
[email protected]
Mr Piet Combrink
Brakfontein
Email:
[email protected]
CELL082 665 3729
Mr Piet Combrink
Brakfontein
P O Box 605
DELMAS 2210
Email:
[email protected]
TEL(013) 665-3729
CELL082 452 2832
Mr Piet Schutte
Haverglen 269 IR
Email: [email protected]
Tel: 013 665 4153
Cell: 082 524 8328
Mr Pieter Combrink
Email: [email protected]
Cell: 082 452 2832
Ms Pricilla Ntombizodwa Nkomo
Landowner: Portion 5 of Watervalshoek
32 Mqantsa Section,
Tel: 011 920 2531
Cell: 082 652 8822
Tembisa 1632
Email: [email protected]
Mr Riaan Fourie
Development Bank of South Africa
P.O. Box 1234, Halfway House
Midrand
1685
Email: [email protected]
Tel: (011) 313 5235
Cell: (078) 803 9615
Mr Rico Euripidou
GroundWork - Friends of the Earth South Africa
P O Box 2375
PIETERMARITZBURG 3200
Email:
[email protected]
TEL(033) 342 5662
FAX(033) 342 5665
CELL083 519 3008
Mr Robert van Bulderen
Servitude Supervisor
Transnet Pipelines
P O Box 1802
STANDERTON 2430
Email:
[email protected]
TEL(017) 727-8300
FAX(017) 727-8305
CELL083 458 1358
CELL083 458 1793
19
C182 – Stakeholder database
Mr Reggie Nkosi
Tel: (013) 755 3316
Trans African Concessions (Pty) Limited
Environmental Coordinator
Email: [email protected]
Fax: (013) 752 6934
Mr Rudolph Sambo
MYACC
Cell: 071 243 8342
Mr S X A Dongwana
Director General
Department of Public Works
Private Bag X65
PRETORIA 0001
Email:
[email protected]
TEL(012) 310 5034
FAX(012) 310 5185
Mr Salmon Dan Masango
Steenkoolspruit
1743 Majosa Street
TSAKANE 1550
CELL082 399 8068
Mr Sifiso Dlamini
Project Engineer: NMPP Project
Transnet Projects
Private Bag X1510
GALLO MANOR 2052
Email:
[email protected]
TEL(011) 287 9735
FAX(011) 258 8792
CELL082 773 0857
Ms Sinazo Mgolozeli
Graduate Trainee
Department of Water Affairs
BHT Water Quality
Private Bag X10580
BRONKHORSTSPRUIT 1020
Email:
[email protected]
TEL(013) 932 2061
FAX(013) 932 2071
CELL083 306 7737
Siziwe Khanyile
Climate and Energy Justice Campaigner
Ground Work, Friends of the Earth South Africa
Email: [email protected]
TEL: 033 342 5662
Ms Stephanie Aken
Wildlife & Energy Program Manager
Endangered Wildlife Trust
Email: [email protected]
TEL: 011 372 3600
FAX: 011 608 4682
CELL: 082 688 8430
Mr Suran Pillay
TEL: 082 306 2940
20
C182 – Stakeholder database
Watervalshoek RE
57 Walsingham Road
Glenvista 2091
Email: [email protected]
Mr Speedy Mashilo
Executive Mayor
Nkangala District Municipality
P O Box 437
MIDDELBURG 1050
Email:
[email protected]
TEL(013) 249 2008
FAX(013) 249 2056
CELL082 419 0929
Mr Stanford Macevele
Deputy Director
Department of Water Affairs (DWA)
Private Bag X11259
NELSPRUIT 1200
Email:
[email protected]
TEL(013) 932 2061
FAX(086) 661-7621
CELL078 460 3439
TEL(013) 932 2064
Mr Sunil Mungaroo
Shanduka Coal Mine/ Springboklaagte Mine
TEL: 013 244 8001
Email: [email protected]
Mr Tariq Aziz
Black & Veatch
Email:
[email protected]
TEL62 129 441 7026
Mr TC Makola
Municipal Manager
Nkangala District Municipality
P O Box 437
MIDDELBURG 1050
Email:
[email protected]
TEL(013) 249 2000
FAX(013) 249 2087
CELL082 853 4345
CELL082 558 2803
Mr Thami Hadebe
Transnet Pipelines
P O Box 3113
DURBAN 4000
Email:
[email protected]
TEL(031) 361-1454
FAX(031) 361-1534
CELL084 899 7517
Ms Thandi Magagula
Delmas Coal
Email:
[email protected]
TEL(013) 665-7019
Dr Thuli Mdluli
TEL
(012) 310 3436
21
C182 – Stakeholder database
Chief Director: Air Quality Management
FAX
(012) 322 1320
Department of Environmental Affairs (DEA)
Private Bag X447
PRETORIA 0001
Email:
[email protected]
Mrs Thizwikoni Ramavhona
Department of Agriculture and Environmental Affairs
Email:
[email protected]
TEL(012) 310-3142
The Managing Director
TEL
(011) 317-1700
Keaton Energy
Postnet Suite 6464, Private Bag X51
BRYANSTON 2021
Email:
[email protected]
Mr Tienie Schalekamp
Haverklip
Email:
CELL082 492 2170
[email protected]
Mr Tobie van den Berg
Editor
Middelburg Observer/Daller
P O Box 36
MIDDELBURG 1050
Email:
[email protected]
TEL(013) 243 1434
FAX(013) 282 7477
CELL072 220 1568
Mr Tristen Taylor
Project Co-ordinator
Earthlife Africa (Jhb)
P O Box 32131
BRAAMFONTEIN 2107
Email:
[email protected]
TEL(011) 339 3662
FAX(011) 339 3270
CELL084 250 2434
Ms Tshifhiwa Nekhavhambe
(011) 800 2264
Eskom: Transmission and Distribution infrastructure
P O Box 1091
Johannesburg
2000
Email: [email protected]
TEL:
Ms Thoko Buthelezi
Tel: (012) 3197508
22
C182 – Stakeholder database
DAFF
Delpen Building, Cnr Annie Botha & Union Street,Arcadia , Pretoria
Email: [email protected]
Mr Valmon Muller
Eskom
Email: [email protected]
Mr Vere Jansen van Vuuren
Telkom South Africa
P O Box 1352
MIDDELBURG 1050
Email:
[email protected]
TEL(013) 249 6250
FAX(013) 282 8101
Mr Vikash Rampathi
Senior Sales Engineer
PS-PSPG-Power Generation
Email: [email protected]
Tel: : +27 10 202 5605
Fax:
Mr Vusi Buda
TEL
(013) 665 5754
MMC: Infrastructure
FAX
(013) 665 2913
Victor Khanye Local Municipality
P O Box 6
DELMAS 2210
Email:
[email protected]
Email:
[email protected]
CELL
Ms Victoria Moshapo
Department of Mineral Resources
Private Bag x7279
Emalahleni
1035
Email: [email protected]
084 516 2634
TEL: 013 653 0500
FAX: 013 656 0932
Mr Waldimar Pelser
Editor
Rapport
P O Box 8422
JOHANNESBURG 2000
Email: [email protected]
TEL(011) 713 9002
FAX(011) 713 9977
Mr Wessel Venter
Haverklip/ Steenkoolspruit
P O Box 701
DELMAS 2210
Email:
[email protected]
CELL082 447 5536
23
C182 – Stakeholder database
Mr Willie de Beer
Manager in the CEO's Office PROPNET
Transnet
P O Box 992106, Carlton Centre
JOHANNESBURG 2000
Email:
[email protected]
TEL(011) 3081526
CELL083 292 0849
Ms Wilma van Vuuren
Editor
Ridge Times/The Echo
P O Box 893
SECUNDA 2302
Email:
[email protected]
TEL(017) 634 7697
FAX(017) 634 3427
Ms Xanthe Taylor
Cleanstream Environmental Consultants (Pty) Ltd
(Junior Environmental Consultant)
Email: [email protected]
Mr Zaheeb Khan
Editor
Middelburg Herald
P O Box 1517
MIDDELBURG 1020
Email:
[email protected]
TEL(013) 282-0103
FAX(086) 544-6310
Cllr Zonke Zullu
Victor Khanye Ward councillor
Cell: 082 765 1577
Email: [email protected]/ [email protected]
Ms Lebogang Mokoena
TEL: 013 944 8901
Receptionist: Moutse Community Radio Broadcast
FAX: 013 944 8902
Dr Willem du Toit
Station Manager: Radio Kragbron
PO Box 8928 Die Heuwel
Witbank 1042
TEL: (013) 697 1191
FAX: (013) 697 1195
Mr Joe Smith
TEL: (013) 697 1191
24
C182 – Stakeholder database
Programme Manager: Radio Kragbron
FAX: (013) 697 1195
PO Box 8928 Die Heuwel
Witbank 1042
Mr Morne Geyser
TEL: (013) 697 1191
Advertising and Promotional Manager
FAX: (013) 697 1195
PO Box 8928, Die Heuwel
Witbank 1042
Email: [email protected]
Greater Middelburg FM
(013) 242 1803/4
P O Box 28, Mhluzi, 1053
(086) 622 8584
TEL:
FAX:
Email: [email protected]
Mr Alex
Middelburg
258 5212
CELL: 083
Email: [email protected]
Ms Emmerentia van der Merwe
Abundant Development (Pty) Ltd
P O Box 1092
Delmas
2210
Mr Lourens Nel Hoffman
Hofflou Boerdery (Pty) Ltd
P O Box 79, Delmas, 2210
TEL: (017) 863 1913
FAX: (013) 683 0160
CELL: 083 454 0977
Ms Cecilia Jacoba de Bruin
PJ De Bruin Boerdery (Pty) Ltd
25
C182 – Stakeholder database
P O Box 358, Delmas, 2210
Mr Petrus Johannes Bezuidenhout
Welgelegen Farm, PO Box 270
Delmas
2210
TEL: (013) 665 3604
FAX:
(013) 665 3604
Ms Ella Maria Brown
P O Box 300
Delmas
2210
Ms Maria Johanna Cloete
16 Ormonde Close, Upavon Street
TEL: (011) 418 6568
FAX: (011) 907 3650
Ormonde
2091
CELL: 083 302 2149
Ms Hanneli Cloete
7 Evans Street, Alrode South,
Alberton
1450
Email: [email protected]
TEL: (011) 868-5451/ 2
Mr Izak Daniel de Lange
Enkeldebosch 301 p4, Steenkoolspruit 302
P O Box 931
Delmas
2210
TEL: (013) 665 3215
CELL: 082 920 8004
Mr Adrian Charles de Vos
CJ Williams & Seuns Boerdery (Pty) Ltd
P O Box 3338
Florida
1710
Ms Margaretha Johanna de Wet
Enkelbosch 301 p11
TEL: (021) 913 7499
CELL: 082 456 1846
26
C182 – Stakeholder database
Tyger Valley
7536
Ms Christina Maria Dreyer
Moabsvelden
Bowenlaan 4
Glenmore
4001
TEL: (031) 261 3943
FAX: (031) 460 6164
CELL: 083 982 6419
Mr Kobus Duvenage
CELL: 082 466 2384
Bronkhorstspruit & Wilge River Conservancies
Email: [email protected]
Mr Hendrik Gericke
22 Manie Maritz Street, Beyers Park
Boksburg
1459
TEL: (011) 894 7383
FAX: (011) 811 1580
Mr/Ms Johan & M Gericke
Plaas Brakfontein
Posbus 25, Williamsweg
Beyerspark
1459
Email: [email protected]
TEL: (013) 665 1694
CELL: 083 263 8660
Mr Michael Ian Gobson
Norwesco Investment (Pty) Ltd
P O Box 14212
Leraatsfontein
1038
TEL: Wrong number
Mr Louis Gouws
Moabsvelden
Mr Rajesh Kumar Gupta
27
C182 – Stakeholder database
Confident Concept (Pty) Ltd
P O Box 7540
Halfway House
1685
Mr Sam Max Hirschowitz
P O Box 163
Waterberg
3233
TEL: (031) 572 4823
CELL: 082 424 3070
Mr Andre Knopje
SamQuartz (Pty) Ltd
94 Hartebeeshoek
Delmas
2210
Email: [email protected]
TEL: (013) 665 7241
Mr December Jacob Mahamba
Steenkoolspruit 302
P O Box 263
Winterveld
0198
TEL: (012) 329 3606
CELL: 082 969 9281
Mr Jan Morgan
Cowenburg Boerdery (Pty) Ltd
P O Box 127
Persequor Park
0020
Mr Daniel Jacobus Opperman
Vogelfontein 222
P O Box 277
Delmas
2210
TEL: (013) 665 3600
CELL: 073 147 2827
Mr Johannes Jacobus Potgieter
Bhubesi Prop cc
P O Box 395
Delmas
2210
28
C182 – Stakeholder database
Mr Gustav Marthinus Rappard
Middelburg Alias Matjesgodkuil 266
P O Box 74529
Pretoria
0001
CELL: 082 490 2065
Mr Johann Gerhardus Schalekamp
Rietkuil 249
P O Box 1034
Delmas
2210
Ms Cornelia Maria
Middelburg Alias Matjesgodkuil 266
P O Box 239
Delmas
2210
TEL: (011) 811 1890
CELL: 083 280 8689
Mr Karel Schoeman
Hendrik Schoeman & Seuns (Pty) Ltd
P O Box 33
Delmas
2210
Mr Petrus Johannes Schutte
Moabsvelden
P O Box 367
Delmas
2210
Mr Johannes Hendrik Snyman
Rietkuil 249
P O Box 259
Delmas
2210
TEL: (013) 665 1462
Mr Gert Johannes van der Merwe
Staffontein 252
P O Box 579
Delmas
2210
TEL: (013) 648 1756
CELL: 082 578 2259
29
C182 – Stakeholder database
Mr Jacobus Jansen van Rensburg
Moabsvelden 248
P O Box 842
Delmas
2210
TEL: (013) 648 1629
CELL: 082 524 8387
Mr Johannes & Frederika
Enkeldebosch 301
P O Box 21293
Valhalla
0137
TEL: (012) 668 1908
Mr Jozef Johannes Markus Victor
Steenkoolspruit 302
P O Box 612
Delmas
2210
Email: [email protected]
TEL: (013) 665-5122
CELL: 082 944 6080
Afrgri Operations (Pty) Ltd
P O Box 11054
Centurion
0046
Email: [email protected]
TEL:(011) 063 2347
The General Manager
BHP Billiton Energy Coal SA Ltd
P O Box 61820
Marshalltown
2107
The General Manager
Eersteklas Boerdery (Pty) Ltd
P O Box 1352
Springs
1560
The General Manager
Exxaro Coal (Pty) Ltd
TEL: (012) 307 5000
30
C182 – Stakeholder database
P O Box 9229
Pretoria
0001
The General Manager
Ikhwezi Colliery (Pty) Ltd
Private Bag X7250
Emalahleni
1035
TEL: (013) 656 3659
FAX: (013) 690 3545
The General Manager
Keaton Mining (Pty) Ltd
Eland House, The Braes, 3 Eaton Avenue
Brayanston
2194
Email: [email protected]
TEL: (011) 317 1700
The General Manager
Phillem Investment (Pty) Ltd
P O Box 14186
Bredell
1623
The General Manager
Transnet Ltd
The Carlton Centre, 150 Commissioner Street
Johannesburg
2001
TEL: (011) 308 3000
FAX: (011) 308 2638
Ms Daphney Makua
Subhighway Community member
Cell: 078 207 6164
Mr Thabang Makua
MYACC
Cell: 079 184 9194
Mr Teboho Nthotho
Subhighway Community member
Mr Teboho Thys
Cell: 078 379 6030
Cell: 078 608 3402
31
C182 – Stakeholder database
Subhighway Community member
Mr Themba Msweli
Subhighway Community member
Cell: 076 776 9808
Ms Susane Marema
Subhighway Community member
Cell: 082 480 6626
Mr Stanley Mndaweni
Subhighway Community member
Cell: 076 595 8124
Ms Palesa Ntuku
Subhighway Community member
Cell: 073 352 0733
Ms Mastrong Sibeko
Subhighway Community member
Cell: 073 830 7791
Mr J Gericke
Brakfontein Meat Market
Tel: 013 665 1694/ 013 668 0911
Mr/Ms LMB Zulu
Cell: 083 728 3162
Mr Jan Phura
ANC
Cell: 074 334 9697
Mr Sipho Shabangu
616 Masunyane
Delmas
2210
Email: [email protected]
Cell: 076 831 8730
Mr Dan Mlambo
ANC
4647 Richard Street
Delmas
2210
Cell: 071 339 4069
32
C182 – Stakeholder database
Mr Doctor Manana
1032 Mohape Street
Delmas
2210
Cell: 073 302 6744
Mr Thulane Moyana
ANC Youth League
Cell: 073 495 1716
Mr Tshepo Masilela
MYACC
Cell: 072 707 0383
Mr Mduduzi Mabena
ANC Youth League
Cell: 078 767 6457
Mr Kgaogelo Mabitse
Greater Middelburg Residents’ Association
Email: [email protected]
Cell: 073 558 0844
Ms Portia Peterson
ABB
Email: [email protected]
Tel: 010 202 5430
Cell: 082 433 9213
Mr Vikash Rampathi
ABB
Email: Vikash.rampathi.za.abb.com
Cell: 072 852 3479
Ms Yvonne Madonsela
Cell: 083 588 7310
Mr Mokato Makoepea
Delmas Coal Mine
Email: [email protected]
Cell: 082 905 1852
Mr Xolani Khanyezi
Delmas Coal Mine
Email: [email protected]
Cell: 082 901 2203
Mr Siphamandla Mabena
Cell: 073 975 7017
33
C182 – Stakeholder database
723 Moloi Street, Botleng
Delmas
2210
Email: [email protected]
Mr Zwelethu Mabena
2184 Kgomo Street, Botleng
Delmas
2210
Cell: 073 767 0468
Mr Sello Shakwane
12 Motloung Street
Delmas
2210
Cell: 076 077 0187
Mr/Ms Tiego Ralele
824 Vilakazi Street, Botleng
Delmas
2210
Cell: 078 870 8316
Ms Betty Ralele
824 Vilakazi Street, Botleng
Delmas
2210
Email: [email protected]
Cell: 076 690 5839
Ms Lydia Ngwenya
GECS
Email: [email protected]
Cell: 082 349 9404
Ms Cynthia Mbonani
13 Motloung Street, Botleng
Delmas
2210
Cell: 072 241 4233
Ms Nomasonto Pumo
Cell: 076 834 0627
Ms Gabisile Ralele
824 Vilakazi Street, Botleng
Delmas
Cell: 073 074 9592
34
C182 – Stakeholder database
2210
Ms Engeline Ndlovu
125 Dlamini Street
Delmas
2210
Cell: 083 947 2155
Ms Portia Myati
1925 Dibethe Street
Delmas
2210
Ms Daisy Maseko
Mancamne Trade
PO Box 2915
Delmas
2210
Email: [email protected]
Cell: 083 449 2823
Ms Adri Venter
Dewtar Properties
PO Box 167
Delmas
2210
Email: [email protected]
Cell: 083 226 0784
Ms Louise Korb
Dewtar Properties
PO Box 110
Delmas
2210
Email: [email protected]
Cell: 083 952 5591
Ms Cynthia Mbonani
7899 Ext5 N12
Delmas
2210
Cell: 081 827 0305
Ms Lindiwe Mkabela
5249 RDP Ext 4
Delmas
Cell: 079 684 8049
35
C182 – Stakeholder database
2210
Ms Winnie Mbonani
1043 Khoda Street
Delmas
2210
Cell: 073 992 8996
Ms Nonhlanhla Sibanyoni
194 Motloung Street
Delmas
2210
Tel: 073 556 1051
Ms Prudence Dlamini
Cell:073 492 4219
Mr/Ms Masenty Mbonani
13 Motloung Street
Delmas
2210
Cell: 072 241 4233
Ms Nokuthula Mabena
510 Mahlangu Street
Delmas
2210
Cell: 072 880 7063
Ms Anelisa Ngxwashura
1925 Dibethe Street
Delmas
2210
Cell: 071 823 5913
Mr/Ms LB Zulu
Cell: 083 728 3160
Mr Irvin Rakoena
Cell: 078 083 7576
Mr Piet Schutte
Email: [email protected]
Cell: 082 524 8328
36
C182 – Stakeholder database
Mr/Ms T Sibeko
Cell: 082 880 6205
Mr Sunday Nkuna
NUM
Email: [email protected]
Cell: 078 640 4215
Mr Darly Ndlovu
NUM
Email: [email protected]
Cell: 073 293 6342
Mr Siyabonga Msobhozi
Delmas Coal
Email: [email protected]
Cell: 079 511 0202
Fax: 013 665 7016
Mr Thomas Mnguni
GMRA
Email: [email protected]
Cell: 072 449 5655
Mr Lwadile Mzaku
Delams Coal
Email: [email protected]
Cell: 072 876 8612
Fax: 013 665 7062
Ms Nomcebo Makhubelo
Mpumalanga Youth Against Climate Change
(MYACC)
Email: [email protected]
Cell: 072 120 1626
Mr Tshepo
Tshekatso Civils
Email: [email protected]
Cell: 082 224 6576
Mr Andile Mayisela
Delmas Coal
Email: [email protected]
Cell: 073 205 0833
37
C182 – Stakeholder database
Mr Stanley Mndaweni
Delmas Coal
Cell: 076 595 8124
Ms Maria Nkosi
Delmas Coal
Mr Samuel Mlambo
NUM
Cell: 079 401 2431
Mr Dennis Martin
GMRA
Email: [email protected]
Cell: 079 326 7470
Mr Michael Malemane
Delmas Contractor
Mr Vidalis Mokone
Delmas Coal
Cell: 073 656 7307
Ms Palesa Ntoko
Delmas Coal
Cell: 073 352 0733
Ms Mathabang Motau
Delmas Coal
Cell: 071 369 0665
Ms Pontsho Makua
Delmas Coal
Email: [email protected]
Cell: 078 207 6164
Ms Deborah Makua
Delmas Coal
Ms Eunice Malemane
Delmas Coal
Cell: 079 629 1908
38
C182 – Stakeholder database
Ms Lydia Ngwenya
GECS
Email: [email protected]
Cell: 082 349 9404
Mr Kgaugelo Mabitse
Middelburg Residents’ Association
Email: [email protected]
Cell: 073 558 0844
Mr Benjamin Mtsweni
Delmas Forum
Cell: 072 849 1835
Mr Samuel Sindane
Gifsa Holdings(Pty) Ltd
Email: [email protected]
Cell: 082 071 9929
Mr Gift Mnguni
Gifsa Holdings (Pty) Ltd
Cell: 078 676 0116
Ms Ntombizodwa Rumo
Cell: 071 008 5665
Ms Precious Mahlangu
Cell: 076 949 8217
Ms Patricia Rumo
Cell: 072 970 7106
Ms Pretty Masilela
MYACC
Cell: 079 464 6340
Ms Brenda Felicity Ross
Cell: 076 467 4932
39
C182 – Stakeholder database
Ms Charlotte Makua
Cell: 079 171 9836
Mr Duma Kutumane
GMRA
Email: [email protected]
Cell: 072 738 0015
Mr Tshepo Vilane
MYACC
Cell: 079 353 1151
Mr Irvin Rakoena
Cell: 078 083 7576
Mr Doctor Mofokeng
Cell: 078 059 8985
Mr John Maya
Cell: 071 526 9695
Mr Thapelo Mathibela
Email: [email protected]
Cell: 072 541 9501
Mr Bricks Mabena
Delmas Coal
Cell: 082 907 2235
Mr Mopale Nyakale
Cell: 072 770 4276
Fax: 086 609 9804
Email: [email protected]
Mr Graeme Campbell
Streeknuus
Email: [email protected]
Cell: 082 921 7282
Fax: 013 932 3033
40
PBO No. 930003292
rd
3 Floor Greenmarket Place • 54 Shortmarket Street • Cape Town 8001 • South Africa • www.lrc.org.za
PO Box 5227 • Cape Town 8000 • South Africa • Tel: (021) 481 3000 • Fax: (021) 423 0935 email: [email protected]
Your Ref:
Our Ref: AA
7th April 2014
Jones and Wagener
P O Box 1434 Rivonia
2128
Email: [email protected]
and to:
Dear Sir/Madam,
RE: ENVIRONMENTAL AUTHORISATIONS FOR THE PROPOSED CONSTRUCTION OF A
600 MEGAWATT (MW) INDEPENDENT POWER PRODUCER (IPP) COAL FIRED POWER
PLANT AND ASSOCIATED INFRASTRUCTURE FOR KIPOWER NEAR DELMAS IN
MPUMALANGA
(DEA
REF
NO:
12/12/20/2333;
NEAS
REF
NO:
DEA/EIA/0000364/2011; AEL REF NO.: 17/4/AEL/MP311/13/01, IKHWEZI COLLIERY
DMR REF NO.: MP30/5/1/2/2/425MR)
We act for the Federation for a Sustainable Environment (FSE). Our client is an alliance
of community based civil society organisations committed to the realisation of the
constitutional right to an environment that is not harmful to health or well-being, and
to having the environment sustainably managed and protected for future generations.
Their mission is specifically focussed on addressing the adverse impacts of mining and
industrial activities on the lives and livelihoods of vulnerable and disadvantaged
communities who live and work near South Africa’s mines.
We make these submissions opposing the granting of authorisation in terms of section
24 of the National Environmental Management Act1 (NEMA). Our submissions on
behalf of FSE are limited to two issues. In respect of the other concerns our clients
have with the environmental impact assessment (EIA) they support the submissions
made by the Center for Environmental Rights on behalf of civil society organisations.
1
Act 107 of 1998
National Office:
Cape Town:
Durban:
Grahamstown:
Johannesburg:
Constitutional Litigation Unit:
:
J Love (National Director), K Reinecke (Director: Finance)
S Magardie (Director), A Andrews, S Kahanovitz, WR Kerfoot, C May, M Mudarikwa, HJ Smith
MR Chetty (Director), EJ Broster, FB Mahomed, A Turpin
S Sephton (Director), C McConnachie
N Fakir (Director), T Mbhense, C van der Linde
T Ngcukaitobi (Head of CLU), M Bishop, G Bizos SC, J Brickhill, S Nindi, B Sibiya, W Wicomb
2
1. Summary of submissions
1.1
Our first submission is that the authorisation should not be granted as it fails to
comply with the regulatory scheme for impact assessment and environmental
authorization under NEMA. We base this submission on the following points:
a. NEMA requires an assessment of the socio economic impacts of the activity
applying for authorisation in terms of section 24 of NEMA.
b. This assessment requires the application of the NEMA principles including the
choice of the best practicable environmental option (BPEO).
c. The best practicable environmental option requires a cost benefit analysis of
the alternatives to the plant as well as the plant itself. The regulation for EIA’s
set out the requirements for the consideration of alternatives.
d. This was not done and hence the application is not complaint.
1.2
Our second submission is that application is also not compliant in that it has
failed to properly assess the costs and benefits of the proposed plant as required by
the Department of Water and Environmental Affairs.2
2.
Requirements for impact assessment under NEMA.
2.1
NEMA defines the general objectives of “integrated environmental
management” in section 23 and sets out the steps that need to be taken in
order to give effect to these objectives, in section 24. According to Section 23
the general objective of integrated environmental management are to:
(a) promote the integration of the principles of environmental management set
out in section 2 into the making of all decisions which may have a significant
effect on the environment;
(b) to identify, predict and evaluate the actual and potential impact on the
environment, socio-economic conditions and cultural heritage, the risks and
consequences and alternatives and options for mitigation of activities, with
a view to minimizing negative impacts, maximizing benefits, and promoting
compliance with the principles of environmental management set out in
section 2;
(c) to ensure that the effects of activities on the environment receive adequate
consideration before actions are taken in connection with them;3
2.2
In order to give effect to these objectives, section 24 requires the potential
consequences for or impacts on the environment of listed activities or specified
activities to be considered, investigated, assessed and reported on to the
2
3
Letter setting out DEA requirements in response to the scoping report dated 07 /11/2012
Section 23 (2) (a), (b) and (c).
3
competent authority or the Minister of Minerals and Energy, as the case may
be, except in respect of those activities that may commence without having to
obtain an environmental authorization in terms of this Act.4
In summary, the NEMA principles must be integrated into decision making including
the authorization of activities listed under section 24. Actual and potential socioeconomic impacts, risks and consequences, and alternatives and options for mitigation
must be considered, with a view to their minimization. Socio economic impacts are
not defined in NEMA. It is submitted that these must at minimum include the actual as
well as the externalized costs of the KIPOWER plant, on water, and air quality.
3.
Relevant NEMA principles.
3.1
The NEMA principles5 apply throughout the Republic to the actions of all organs
of state that may significantly affect the environment and apply alongside all
other appropriate and relevant considerations.6 They serve as the general
framework within which environmental management and implementation
plans must be formulated.7 They serve as guidelines by reference to which any
organ of state must exercise any function when taking any decision in terms of
this Act or any statutory provision concerning the protection of the
environment.8 They serve to guide the interpretation, administration and
implementations of the Act.9
3.2
The following NEMA principles are of immediate relevance to the EIA for
KIPOWER.
- Section (3):
Development must be socially, environmentally and economically sustainable.
- Section (4) (a):
Sustainable development requires the consideration of all relevant factors
including the following:
(b) Environmental management must be integrated, acknowledging that all
elements of the environment are linked and interrelated, and it must take into
account the effects of decisions on all aspects of the environment and all people
in the environment by pursuing the selection of the best practicable
environmental option.
4
Section 24 (1).
Section 2(1)
Section 2(1)(a)
7
Section 2(1)(b)
8
Section 2(1)(c).
9
Section 2(1)(d).
5
6
4
“best practicable environmental option”(BPEO) means the option that provides
the most benefit or causes the least damage to the environment as a whole, at
a cost acceptable to society, in the long term as well as in the short term;10
- Section 4 (i):
the social , economic and environmental impacts of activities, including
disadvantages and benefits, must be considered, assessed and evaluated and
decisions must be appropriate in the light of such consideration and
assessment.
It is submitted that the mandatory application of the above principles and sections 23
of NEMA, to the environmental impact assessment requires a consideration of
alternatives in order to determine the best practicable environmental option. The
consideration envisages at the very least a cost benefit analysis, given that the BPEO
requires that the benefit as well as the potential damage must be assessed and the
acceptable cost to society then determined. Such assessment must consider the social,
economic as well as environmental cost of the plant.
However in conflict with these requirements the scoping report confines the
assessment to the plant only, avoiding a consideration of the best practicable
environmental option and of the possible impacts and costs of alternatives. It is
submitted that this has rendered the process flawed.
4.
Requirements for the consideration of alternatives
4.1
In terms of regulation 31 of the Environmental Impact Assessment Regulations
promulgated under NEMA11 an environmental impact assessment report must
contain all information that is necessary for the competent authority to
consider the application and to reach a decision contemplated in regulation 35,
namely to grant authorisation.12 This includes the following information
regarding the issue of alternatives to the project
Regulation 31(2)(g)
(g)
10
11
12
a description of the identified potential alternatives for the proposed
activity including advantages and disadvantages that the proposed
activity or alternatives may have on the environmental and the
community that may be affected by the activity;
Section 1 definitions.
GNR 543 of 18 June 2010 regulation 31(2).
Regulation 31(2). These requirements are repeated in the guidelines for the compiling of impact assessments under the Act, GN
805 of 10 October 2012: Publication of the Companion Guideline on the Implementation of the Environmental Impact Assessment
Regulations, 201O (Government Gazette No. 35769) in section 7.
5
(i)
a description and comparative assessment of all alternatives identified
during the environmental impact assessment process;
(j)
a summary of the findings and recommendations of any specialist report
or report on a specialised process;
(k)
a description of all environmental issues that were identified during the
environmental impact assessment process, an assessment of the
significance of each issue and an indication of the extent to which the
issue could be addressed by the adoption of mitigation measures;
4.2 Reading the requirement to consider the best practicable environmental option
together with these regulations, results in the necessary conclusion that before the
decision maker can exercise discretion whether to authorise the plant it must have
sufficient information on alternatives, their costs and benefits to determine
whether the plant is in fact the best practicable environmental option. It cannot
simply rely on broad policy considerations about future energy to exclude the
consideration of alternatives. These considerations, drawn from the Integrated
Resource Plan 2010 are in any event under review currently and are not written in
stone. The Integrated Resource Plan envisages a two year review and is currently
undergoing an update.13 The EIA has failed to follow this approach rendering any
decision to authorize the plant that is based on it non-compliant with NEMA and
the Promotion of Administrative Justice Act 2 of 2000 (“PAJA”) section 6(2)(b).
5. Failure to properly assess the costs and benefits of the plant.
The DEA, in its letter from the Chief Director Mark Gordon to Mr M van Zyl
dated 07/11/2012 (which deals with the evaluation of the scoping report for the
project) requires the following information to be included in the EIA report:
“p) The EWIR should include information on the following:
-
Environmental costs vs benefits of the facility and
Economic viability of the facility and how the local community will benefit”
This means that the EIA is required to undertake an environmental cost benefit
analysis of the KIPOWER plant. The project is expected to incur external costs on a
regional as well as local level. External costs on the local community are estimated at
close to R 16m (R7m gross value added) and are expected to be largely offset by the
direct increases in local income levels projected to be in the region of R 109m per
annum.
13
www.doe-irp.co.za
6
The project proponent has provided an assessment of the external costs of the project
(totaling R 17.6 million/year). However our client submits that this assessment of
external costs is inadequate.
The cost benefit analysis for the KIPOWER Plant is contained in Annexure L 11 "Draft
Socio-Economic Impact Assessment Report." (Details of the issues/costs considered
are annexed hereto marked “Annexure A”). This document attempts to provide an
environmental cost-benefit analysis of the project, but is deficient in the following
respects.
5.1
The report notes that “[e]xternal costs from coal fired power stations are wellknown for relatively high costs imposed on the larger community mainly through… the
release of Carbon, Particle Matter, Sulphur dioxide, Nitrogen oxide (NOx), mercury and
radioactive matter.” Annexure L 11, Draft Socio-Economic Impact Assessment Report
for the Kuyasa Independent Power Producer’s Proposed Power Generation Plant in the
Delmas Area, Mpumalanga Province. However, after stating that the costs are wellknown, the report fails to assign any meaningful cost estimates to the impacts
associated with the proposed project. For most externalities listed, the report fails to
assign any value. In addition, the report leaves out important impacts that should also
have costs assigned to them. For example, the material in Appendix L 11 identifies
these costs:
a.
The impact on climate change affecting weather patterns and associated costs.
b.
Potential impact on human health (including direct medical expenses, lost
income resulting from absenteeism from work, decreased productivity and
lower life expectancy.
It is not difficult to assign values to some of these costs. For example, one could use
the U.S. Environmental Protection Agency’s as one method of estimating the social
costs of carbon (SCC) to assign value to the facility’s predicted carbon emissions.14 The
European Commission has also published guidelines about how external costs and
benefits for power plants could be calculated. These guidelines may serve as a
framework for both the quantification and the monetary valuation of the proposed
14
U.S. Environmental Protection Agency’s estimates of the social costs of carbon (SCC) to assign value to the
facility’s predicted carbon emissions. The EPA explains:
The SCC is an estimate of the economic damages associated with a small increase in carbon dioxide (CO2)
emissions, conventionally one metric ton, in a given year. . . .
The SCC is meant to be a comprehensive estimate of climate change damages and includes, but is not
limited to, changes in net agricultural productivity, human health, and property damages from increased
flood risk. However, given current modeling and data limitations, it does not include all important
damages. As noted by the IPCC Fourth Assessment Report, it is ‘very likely that [SCC] underestimates’ the
damages.
U.S. EPA website, http://www.epa.gov/climatechange/EPAactivities/economics/scc.html (visited 1 April 2014).
7
coal plant’s external costs: http://bookshop.europa.eu/en/externe-externalities-ofenergy.-vol.1-summary-pbCGNA16520/downloads/CG-NA-16-520-ENC/CGNA16520ENC_001.pdf;pgid=y8dIS7GUWMdSR0EAlMEUUsWb0000fgPpuhSh;sid=
QKg_1NQXAVM_yIWx1Chc7YyR3s5B9PERns=?FileName=CGNA16520ENC_001.pdf&SKU=CGNA16520ENC_PDF
&CatalogueNumber=CG-NA-16-520-EN-C.
This submission does not advocate the use of any particular jurisdiction’s methods of
estimating these values but merely includes these two examples in order to guide
decision making in this matter.
Using the EPA’s 3% discount rate figures for the SCC, the external costs of carbon
dioxide emissions from the proposed KIPOWER plant are likely to start at US$175
million per year (R 1.858 billion/year) in 2015 and increase to US$225 million per year
(R 2.389 billion) by 2025. See attached spreadsheet (Annexure B).
This value is just one of the values that should have been included in the reports
analysis of the external costs of the project.
5.2
The assessment of the external costs of the project does not include values for
costs that others who have prepared environmental cost-benefit analyses of proposed
coal-fired power plants have included, more particularly SO2, NOx, particulate matter
(PM), volatile organic compounds (VOC’s), and NH3.
Although the proponents of the KIPOWER plant state that it will have lower than
conventional SO2 and NOx emissions, the cost of the health impacts of particulate
matter (PM), volatile organic compounds (VOC’s), mercury emissions, and NH3 have
not been estimated for the EIA which is a glaring omission given the high levels of
particulates in the prevailing ambient air environment where the plant will be built.
The extent to which carbon capture removes SO2 as compared with conventional coal
fired power plants, as well as the extent of the reduction of NOx emissions, needs to
be estimated so that the costs of SO2 and NOx emissions can be established.
Environmental cost-benefit analyses of the proposed KIPOWER coal-fired power plant
should not be considered adequate or complete without proper information and
costings for impacts to health of emissions of sulphur dioxides, nitrous oxides, and
particulate matter.
For examples of studies that have estimated these costs this submission refers you to
the following articles which contain such estimations.
5.2.1 Riekert, J. W., & Koch, S. F. (2012). Projecting the external health costs of a
coal-fired power plant: The case of Kusile.
http://www.erc.uct.ac.za/jesa/volume23/23-4jesa-riekert-koch.pdf
This article states:
8
“We examine an important subset of the expected health costs associated with the
commissioning of Kusile, a new coal-fired electricity generation plant in South Africa.
The subset of health impacts focuses on sulphur dioxides, nitrous oxides and large
particulate matter (greater than 10 mm). The analysis makes use of the Impact
Pathway Approach combined with the data transfer methodology. The plant, which is
expected to contribute 4 800 MW of additional electricity to the South African grid is
found to have modest health impacts, partly due to the limited additional pollutant
emissions expected at the plant. Specifically, additional localised external health costs
are found to be in the region of 0.09c/kWh to 6.08c/kWh. Limitations of the analysis
are also examined.”
5.2.2 For a more robust valuation of the impacts of coal fired power generation this
submission refers you to studies that have been done for other coal projects. For
example the following study summarizes the estimated costs of coal powered
electricity generation in Minnesota in the U.S. The report uses the U.S. EPA’s estimates
of the SCC (referred to above) to measure the net monetized damages associated with
the common pollutants from coal production. It is submitted that this is a good
example of how values can be assigned to the costs of coal:
Goodkind, A. L., & Polasky, S. (2013). HEALTH &ENVIRONMENTAL COSTS OF
ELECTRICITY GENERATION IN MINNESOTA.
http://www.minnpost.com/sites/default/files/attachments/Polasky%20report%20on%
20externality%20costs.pdf
5.2.3 Penney, S., Bell, J., & Balbus, J. (2009). Estimating the health impacts of coalfired power plants receiving international financing. Report at ENVIRONMENTAL
DEFENCE FUND.
http://www.edf.org/sites/default/files/9553_coal-plants-health-impacts.pdf
9
5.2.4 See also Ontario Ministry of Energy (2005). Cost Benefit Analysis: Replacing
Ontario’s Coal-Fired Electricity Generation.
In 2005, the Ontario Ministry of Energy in Canada commissioned a cost-benefit analysis
of “the financial costs and health and environmental damages associated with four
electricity generation scenarios” including continued use of existing coal-fired power
plants without change, running the units with the best emission control technologies
available, replacing the units with gas generation units, and replacing the units with a
combination of gas and nuclear units. The report prepared for the Ministry is available
here: http://www.energy.gov.on.ca/docs/en/coal_cost_benefit_analysis_april2005.pdf
Comment:
An environmental cost-benefit analyses of the proposed KIPOWER coal-fired power
plant should not be considered adequate or complete without comprehensive
information about the impacts to health of emissions of sulphur dioxides, nitrous
oxides, and particulate matter, as well as VOC’s, mercury, and NH3. The above articles
10
provide examples of the external costs of coal-fired power plant emissions on human
health.
With respect to the other impacts of proposed KIPOWER coal-fired power plant at
least the following additional external costs need to be quantified:
a.
the external cost of the proposed ash disposal facility. According to Annexure
L 11: “An additional area of approximately 200ha will be used for ash disposal.”
The ash disposal facility would be a permanent, barren, and potentially
polluting part of the South African landscape. The externalities of losing the
environmental and social benefits provided by this 200ha area need to be
quantified.
b. Mining raw materials that the project would require (including 440,000 tonnes
of limestone per year, and 2,880,000 tonnes per year of low quality coal).
Obtaining raw materials, including mining of limestone and coal, can cause
large external costs that need to be included in any environmental cost-benefit
analysis for the proposed KIPOWER plant. An article by Nonophile P. Nkambule
& James N. Blignaut titled The External Costs of Coal Mining: The case of
collieries supplying Kusile power station (2012), quantifies the external costs
associated with coal mining in South Africa, and discusses how to assess
monetary value to the related damage to human health, water pollution &
consumption, loss of agricultural potential, and loss of ecosystem (pgs. 88-91),
available at: http://www.erc.uct.ac.za/jesa/volume23/23-4jesa-nkambuleblignaut.pdf.
c. Water consumption. According to Appendix L 11: “KIPOWER plans to bring in
potable water by tapping into a Rand Water line that runs between Springs and
Devon to the south of the mine. Other potential sources of water are also being
investigated to reduce and/or supplement this source of water in the long term
(see Surface Water specialist report for more detail). The power plant, although
equipped with a dry cooling system, requires approximately 40,000 cubic
meters of water per month on an annual average basis under annual average
ambient conditions.” Water consumption by the proposed KIPOWER plant
would make water less available or mostly costly for other uses. The external
costs of this water consumption need be included in any environmental costbenefit analysis for the proposed KIPOWER plant.
5 Conclusion.
The scoping report and EIA have only considered a cost benefit analysis of the
proposed plant itself and not its alternatives despite the fact that this was raised as an
issue on several occasions by our client.15 The EIA does not dispute that there could
be alternatives eg wind and other power. However other energy sources and hence
15
Email dated 12/07/2012;16/08/2012
11
their costs and benefits were not considered by the applicant.16 The reason for failing
to consider alternatives was the local availability and the alleged affordability of coal
based electricity and the fact that that macro energy planning has indicated that there
will be a growth in coal based power supply over the next two decades, albeit at a
slower rate than currently.17 Hence the consideration of alternatives is ruled out on
the basis of macro electricity planning which is in fact not complete. The integrated
resource plan is currently being updated.
The only conclusion that the decision maker will be able to draw on the basis of the EIA
is that the only potential alternative is the coal fired power plant. It will not be able to
determine the best practicable environmental option which it is also required to do in
terms of the NEMA principles, because no cost benefit analysis of the alternatives as
envisaged by the best practicable environmental option has been undertaken. It will
also not be able to consider properly whether the plant should be authorized at all (the
no-go option) in light of the fact that the cost benefit analysis for the plant is
inadequate, by local and international standards. As such the EIA is not compliant
with the requirements for assessing impacts and any decision to authorize the plant
based on this version of the EIA stand to be challenged as unlawful for failure to
comply with section 24 of NEMA.
A decision making process based on the current EIA will also be materially deficient in
that all relevant considerations have not been placed before the decision maker before
the decision is to be taken, which is in conflict with the requirements of section 6(2)
(e) (11) of the Promotion of Administrative Justice Act, no 3 of 2000.
Yours faithfully
LEGAL RESOURCES CENTRE
Per:
MS A ANDREWS
16
17
EIA page 69
EIA page 57
12
ANNEXURE A
Annexure L 11
DRAFT SOCIO-ECONOMIC IMPACT ASSESSMENT a s part of the ENVIRONMENTAL
IMPACT ASSESSMENT PROCESS for the
KIPOWER INDEPENDENT POWER
PRODUCER’S PROPOSED POWER GENERATION PLANT IN THE DELMAS AREA,
MPUMALANGA PROVINCE
Externalities Associated With the Development
While the local employment and income impact of the power plant and ash stack is
expected to be substantial, it is important to incorporate expected net external costs
(costs minus benefits) incurred during the operational phase of the plant. This include
all costs that are not included in the operational expenses of the plant but that will be
carried by third parties albeit by consumers, adjacent farmers or people susceptible to
respiratory disease living in the town nearby.
External costs from coal fired power stations are well-known for relatively high costs
imposed on the larger community mainly through air pollution due to the release of
Carbon, Particle Matter, Sulphur dioxide, Nitrogen oxide (NOx), mercury and
radioactive matter. The air pollution costs are not captured in the operational costs
and could potentially reduce the income levels of the larger local community mainly
due to:
The impact on climate change affecting weather patterns and associated costs
(broader regional impacts on crops, property due to global changes in weather
patterns);
Local impacts on agricultural production through the direct impact of air pollution
on crop yields and livestock production;
Decline in agricultural property values due to the high visibility of the power station
and perceptions of pollution costs attached to coal power stations property effect –
i.e. the property effect;
Decrease in tourism activities due to visible effects of pollution;
Potential impact on human health (including direct medical expenses, lost income
resulting from absenteeism from work, decreased productivity and lower life
expectancy); and
13
Increase in transport pollution costs due to larger number of employees driving to
and from work as well as and other business activities within the site.
Apart from potential income losses associated with air pollution, other income losses
could be incurred due to:
Direct physical displacement of agricultural land and the associated loss of potential
farm income due to the construction of the plant and ash stack;
Decrease in tourism due to shortages in accommodation;
Lower investment in physical capital (machinery etc) within the agricultural sector
due to the perception of mining as priority in the area – i.e. the investment effect; and
Potential income losses could come from higher crime mainly due to the greater
influx of (unskilled) job seekers to the area and deterioration of security fencing due to
rust caused by air pollution from adjacent sources as well as the proposed power
station.
The main external benefits include:
Use of appropriate technology to meet air quality standards and allow for use of low
quality coal.
Increase in access to electricity supply and a more stable electricity supply to the
broader region with positive spin-offs mainly in the form of overall productivity
increases;
The reduction of pollution costs of transporting of coal from Delmas colliery over
long distances. Since the proximity of the power station eliminates the need to
transport the coals of Delmas colliery over long distance, the saving of the external
costs related to fuel pollution needs to be added as external benefit related to this
project;
Income from health expenses to local medical practitioners; and
Reduction of local fire risks and costs due to discard dumps being used in the plant.
Establishing the net loss of income due to externalities:
While the plant will be located in an area that is already highly compromised in terms
of air quality (the Highveld priority area) measuring the potential external costs
associated with this plant in particular should be dealt with as a separate issue and not
be confused with external costs incurred by other activities (mainly coal mining) in the
14
vicinity. The combined effect of these externalities will be discussed in more detail
under cumulative issues below.
The proposed plant differs from conventional coal power stations making use of
supercritical Circulating Fluidised Bed (CFB) technology. The key advantages of CFB are
that it is able to make use of low grade coal and that pollution control is built right into
the combustion process. CFB was promoted in the 1980s as a solution to deal with
sulphur dioxide (SO2), nitrous oxides (NOX) and other pollutants produced by burning
coal. By adding low-cost limestone or dolomite into the CFB, SOX is captured and
removed right at the point where it is formed as the fuel burns. The material from the
plant is furthermore below the limit set for material to be considered as radioactive.
Assuming very conservative conditions, the potential radiological impact to members is
below the regulatory criteria for the radiological protection of members of the public.
The CFB’s low combustion temperature minimizes NOX formulation. While the
significant reduction in SOX and NOX emissions reduces local economic impacts of the
plant to insignificant levels, the CO2 levels are not lower than a conventional
pulverised coal power plant and the plant is therefore still expected to have a broader
regional impact on climate change. Based on information received from the project
developer 4.2 m tonnes of CO2 emissions are expected annually – within the broad
range of conventional PC plants. Given that the development of coal power still falls
within government policy through the Integrated resource Plan (2010) the net regional
benefits of the project compared to conventional power plants will be discussed in
more detail in section 3.4. Institutional and Legal Processes below. The focus of the
table below is on the individual hidden costs and benefits for the local community.
15
16
The project is expected to incur external costs on a regional as well as local level.
External costs on the local community is estimated at close to R 16m (R7m gross value
added) and is expected to be largely offset by the direct increases in local income
levels projected to be in the region of R 109m per annum.
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Anelle Lotter
Jones and Wagener Consulting Civil Engineers (Pty) Ltd
By email: [email protected]
Sibongile Bambisa
Jones and Wagener Consulting Civil Engineers (Pty) Ltd
By email: [email protected]
Copies to:
Fiona Grimett
Department of Environmental Affairs
By email: [email protected]
Mandla Mahlalela
Mpumalanaga Department of Economic Development, Environment and Tourism
By email: [email protected]
Mokgadi Maloba
Department of Water Affairs
By email: [email protected]
Martha Mokonyane
Department of Mineral Resources
By email: [email protected]
Your ref: DEA Ref No: 12/12/20/2333;
NEAS Ref No: DEA/EIA/0000364/2011;
AEL Ref No.: 17/4/AEL/MP311/13/01,
Ikhwezi Colliery DMR Ref No.:
MP30/5/1/2/2/425MR
Our ref: CER/34.18
Date: 4 April 2014
Dear Mesdames
Comments on the following draft documents for the proposed KiPower (Pty) Ltd power station:
Environmental Impact Assessment Report; Environmental Management Programme; Waste Management Licence
Application Report; and Atmospheric Emission Licence Application
2nd Floor, Springtime Studios,
1 Scott Road, Observatory, 7925
Cape Town, South Africa
Tel 021 447 1647, Fax 086 730 9098
Email [email protected], www.cer.org.za
Centre for Environmental Rights NPC is a non-profit company with registration number 2009/020736/08, NPO Ref 075-863, PBO No. 930032226 and a Law Clinic registered with the Law Society of the
Cape of Good Hope I Directors: Carolyn Elizabeth Ah Shene, Joanna Amy Eastwood, Mohamed Saliem Fakir, Melissa Fourie (Executive), Stephen Mark Law (Chair), Karabo Maelane
Attorneys: Tracey Laurel Davies, Melissa Fourie, Catherine Horsfield, Robyn Elizabeth Hugo, Sylvia, Kamanja, Marthán Theart I Candidate Attorneys: Matome Lethabo Kapa, Teboho Moses Sebogodi
TABLE OF CONTENTS
1.
Introduction………………………………………………………………………………………………………………………………………………………. 3
1.1
Licences required .............................................................................................................................................. 4
1.2
Requirements of environmental assessment ................................................................................................... 5
1.3
Summary of issues ............................................................................................................................................ 8
2.
Methodology adopted for impact assessment ....................................................................................................... 10
2.1
Submission of an additional 1 400 MW of coal fired power plant to be developed on site .......................... 10
2.2
Competency of applicant ................................................................................................................................ 12
2.3
Expert reports ................................................................................................................................................. 12
2.4
Failure to provide all relevant information ..................................................................................................... 12
2.5
Failure to assess cumulative impacts .............................................................................................................. 13
3.
Justification of need and desirability for a coal power station in the Highveld Priority Area ................................ 13
3.1
Increasing demand for coal-based electricity ................................................................................................. 13
3.2
Technology adopted ....................................................................................................................................... 16
3.3
Use of coal discard .......................................................................................................................................... 16
3.4
Downstream opportunities ............................................................................................................................. 17
4.
Location within HPA: Importance of cumulative effect of air quality .................................................................... 19
5.
Biodiversity implications: Location within a sensitive wetland area ...................................................................... 22
6.
Failure to investigate alternatives .......................................................................................................................... 24
7.
Non-compliance of Delmas Coal and Ikhwezi Colliery ............................................................................................ 27
8.
Effect on water resources ....................................................................................................................................... 29
8.1
Water deficit ................................................................................................................................................... 30
8.2
Water quality implications .............................................................................................................................. 31
9.
Waste Implications.................................................................................................................................................. 33
10.
Air quality impact ................................................................................................................................................ 34
10.1
Point source emissions.................................................................................................................................... 34
10.2
Impact on climate change ............................................................................................................................... 35
10.3
Incomplete information .................................................................................................................................. 36
2
11.
Health Impacts .................................................................................................................................................... 37
12.
Conclusion ........................................................................................................................................................... 37
1.
Introduction
We make these submissions on behalf of groundWork, and the following community groups:
Greater Middelburg Residents’ Association; Guqa Environmental Community Service; Highveld Environmental
Network; Association for Environmental Defence; Mpumalanga Youth Against Climate Change and
Wonderfontein Resettlement Forum in response to the draft environmental impact assessment (“EIA”),
environmental management programme (“EMPR”), waste management licence application and atmospheric
emission licence (“AEL”) with supporting documents published by Jones & Wagner (“JaW”) as environmental
assessment practitioners on behalf of the applicant (collectively the “draft EIA reports”).1 These submissions
should be read together with those submitted by groundwork on 18 May 2012, 14 August 2013 and 17
October 2013,2 to which no formal substantive response was received.
KiPower (Pty) Ltd, the applicant proposing to establish the coal fired power station subject to this application
(the “proposed coal station”), is a subsidiary of Kuyasa Mining which also owns Delmas Coal and iKhwezi
Colliery, all located in the Highveld Priority Area (“HPA”) approximately 20km to the south-east of the town of
Delmas in the Victor Khanye Municipality within the Nkangala District Municipality of Mpumalanga, South
Africa. We submit these comments on behalf of groundWork .
The underlying premise of the proposed coal station is its proximity to Delmas Coal and iKhwezi Colliery. This
is because of the applicant’s intention that the proposed coal station functions on a low cost basis to use the
discard low grade coal of Delmas Coal and to rehabilitate an open cast pit of iKhwezi Colliery (which is
threatening to contaminate the surrounding environment with pollutants such as acid mine drainage due to
the applicant’s failure to comply with its requirements in terms of the Mineral and Petroleum Resources
Development Act, 2002 (“MPRDA”), and the National Environmental Management Act, 1998 (“NEMA”)) for
use as the ash disposal facility (“ADF”) for the proposed coal station. The term “low cost” is used in relative
economic terms - the applicant submits that alternatives further away from Delmas Coal and iKhwezi Colliery
cannot be considered for “economic reasons” and, furthermore, appears to justify the proposed coal station
due its provision of a lower financial cost solution to the pollutant problems and potentially extensive
liabilities of Delmas Coal and Ikhwezi Colliery. The applicant provides no attempt to justify the best
practicable environmental option, as required by NEMA, nor does it provide any substantiation for these
“economic reasons”.
The applicant submits that the proposed coal station will entail circulating fluidised bed (“CFB”) technology to
burn coal and produce electricity so as to make use of Delmas Coal’s lower grade discard coal and to control
the emissions emanating from the station. This submission does not address whether any additional coal
power generation projects - and the emissions these entail - should be considered at all within the Highveld
Priority Area (“HPA”), why such technology cannot be employed elsewhere outside the HPA, or why an
1
The application entails the more comprehensive scoping and environmental impact assessment procedures due to the nature
of the activities entailed.
2
As included with Appendix K to the EIA, the Public participation report.
3
alternative use for the discard coal and pit rehabilitation - which does not entail the use of non-renewable
energy and greenhouse gas emissions – cannot be considered.
The HPA was declared a priority area in terms of section 18(1) of the National Environmental Management: Air
Quality Act, 2004, (“NEMAQA”) in 2007, due to the concerns of the then Minister for Environmental Affairs
that the area’s ambient air quality exceeded or might exceed ambient air quality standards, or that there was
or might be significantly negative impacts on the area’s air quality which required rectification by “specific air
quality management action.” Our understanding of “ambient air quality” in this context is broad - the
definition under NEMAQA excludes only “air regulated by the Occupational Health and Safety Act, 1993”.3
An air quality management plan for the HPA was promulgated in 2012 (the “HPA Management Plan”). The
HPA Management Plan applies to the entire priority area, including that in which the proposed coal station,
Delmas Coal and Ikhwezi Colliery are located,4 in light of the “total estimated emissions” of the HPA and so as
to “achieve and maintain compliance with the ambient air quality standards across the HPA, using the
Constitutional principle of progressive realisation of air quality movements.”5 As further detailed below, our
clients submit that there is no basis for the applicant’s nonsensical and opportunistic suggestion that the HPA
Management Plan applies only to previously established point source emissions and does not include the
cumulative emission contributions from future point sources in the HPA. In fact, the applicant itself submits
that the focus of air pollution control is on the receiving environment and not the source.6
1.1
Licences required
The licences and approvals required for the authorisation of the proposed coal station (including, but not
limited to those subject to the current application) are:
x
x
x
x
x
the environmental impact authorisation of those activities listed under NEMA to be issued by the
Department of Environmental Affairs (“DEA”), following a full assessment procedure (the draft application
for which is included in the draft EIA reports);
an atmospheric emission licence under NEMAQA (based on minimum emission and ambient air quality
standards), to be issued by the Mpumalanga Department of Economic Development Environment and
Tourism (“MDEDET”);
a waste management licence for those activities listed under the National Environmental Management:
Waste Act, 2008 (“NEMWA”), to be issued by the DEA (application for which is included in the draft EIA
reports);
an environmental management programme report (“EMPR”) amendment and closure licence (for the pit at
Ikhwezi Colliery to be used as the ADF), to be issued by the Department of Mineral Resources (“DMR”)
(application for which is included in the draft EIA reports);
the submission of the transfer of liability from Ikhwezi Colliery to KiPower, to be submitted to the DMR
(apparently to be submitted once “these agreements are finalised”);7
3
NEMAQA section 1.
As delineated at Figure E1 of the air management plan and covering an area of 31 106 km2.
5
Executive summary, page 6 of the HPA Management Plan.
6
Appendix L1, Air impact assessment report, Annexure L1.
7
EIA page 15.
4
4
x
an integrated water use licence (“IWULA”) to be issued by the Department of Water Affairs (“DWA”)
(application for which is to be supported by an Integrated Water and Waste Management Plan and
submitted with the final EIA reports);
a licence from the National Energy Regulator of South Africa (“NERSA”) for the generation and distribution
of electricity as an independent power producer (the applicant submits that this has been awarded, but
provides no details of the contract);8
the approval of rezoning in respect of the land proposed for the ADF and proposed coal station (that for the
ADF has been approved by the Victor Khanye Local Municipality, whilst that for the coal station is to be
submitted pending the transfer of this land from BHP Billiton to Kuyasa Mining); and
various additional licences, including those to be issued by the South African Heritage Resource Agency, the
South African National Roads Agency Limited and Transnet.9
x
x
x
We note the applicant’s submission that no building plans are to be submitted regarding change of land use.10
1.2
Requirements of environmental assessment
The National Environmental Management (NEM) Principles contained in NEMA serve as guidelines by
reference to which any organ of state must exercise any function when taking any decision in terms of NEMA
or other laws concerning the protection of the environment.11
The NEM Principles include that of sustainable development, which requires the consideration of all relevant
factors including that:
x
x
x
x
x
x
pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided,
are minimised and remedied;
the use and exploitation of non-renewable natural resources is responsible and equitable, and takes into
account the consequences of the depletion of the resource;
the development, use and exploitation of renewable resources and the ecosystems of which they are part
do not exceed the level beyond which their integrity is jeopardised;
a risk-averse and cautious approach is applied, which takes into account the limits of current knowledge
about the consequences of decisions and actions;
the participation of all interested and affected parties in environmental governance must be promoted,
and all people must have the opportunity to develop the understanding, skills and capacity necessary for
achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons
must be ensured; and
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.12
According to the NEM Principles, environmental management must be integrated, acknowledging that all
elements of the environment are linked and interrelated, and it must take into account the effects of decisions
on all aspects of the environment and all people in the environment by pursuing the selection of the best
8
Appendix G, Waste licence application report.
As listed at page 15 of the EIA.
10
Appendix E, Licensing information report, page 8.
11
NEMA s.2(1)(c).
12
NEMA s.2(4)(a).
9
5
practicable environmental option.13 “Best practicable environmental option” is defined in NEMA as “the
option that provides the most benefit or causes the least damage to the environment as a whole, at a cost
acceptable to society, in the long term as well as in the short term”.14
Responsibility for the environmental health and safety consequences of a policy, programme, project,
product, process, service or activity exists throughout its life cycle.15 The social, economic and environmental
impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and
decisions must be appropriate in the light of such consideration and assessment.16
Any environmental decisions taken must ensure that the environment is held in public trust for the people,
the beneficial use of environmental resources must serve the public interest and the environment must be
protected as the people’s common heritage.17
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.18 This is known as the “polluter pays” principle.
The NEM Principles are further detailed in the Environmental Impact Assessment Regulations, 2010 (“EIA
Regulations, 2010”) with provisions including that:
x
x
x
when considering an application, the competent authority must have regard to NEMA sections 24O and
24(4) “as well as the need for and desirability of the activity”;19 and
a scoping is to contain all scoping report information necessary for the proper understanding of the
identified issues identified, and must include a description of “any feasible and reasonable alternatives”
identified,20 a description of identified potential alternatives “including advantages and disadvantages that
the proposed activity or alternatives may have on the environment and the community that may be
affected by the activity”;21 “a description of the need and desirability of the proposed activity”;22 and
an environmental impact assessment report is to contain all information necessary for the competent
authority to consider the application and reach a decision including “a description of the environment that
may be affected by the activity and the manner in which the physical, biological, social, economic and
cultural aspects of the environment may be affected by the proposed activity”,23 “a description of the need
and desirability of the proposed activity”,24 “a description of identified potential alternatives to the
proposed activity, including advantages and disadvantages that the proposed activity or alternatives may
have on the environment and the community that may be affected by the activity”,25 “a description and
13
NEMA s.2(4)(b).
NEMA s.1.
15
NEMA s.2(4)(e).
16
NEMA s.2(4)(i).
17
NEMA s.2(4)(o).
18
NEMA s.2(4)(p).
19
EIA Reg 8.
20
EIA Reg 28(c).
21
EIA Reg 28(j).
22
EIA Reg 28(i).
23
EIA Reg 31(2)(d).
24
EIA Reg 31(2)(f).
25
EIA Reg 31(2)(g).
14
6
comparative assessment of all alternatives identified during the environmental impact assessment
process”26 and “an assessment of each identified potentially significant impact, including— (i) cumulative
impacts…”.27
The NEM Principles are carried through to the MPRDA which provides that:
“(1)
(2)
The principles set out in section 2 of the National Environmental Management Act, 1998 (Act No.
107 of 1998)—
(a)
apply to all prospecting and mining operations, as the case may be, and any matter or
activity relating to such operation.
(b)
serve as guidelines for the interpretation, administration and implementation of the
environmental requirements of this Act.
Any prospecting or mining operation must be conducted in accordance with generally accepted
principles of sustainable development by integrating social, economic and environmental factors
into the planning and implementation of prospecting and mining projects in order to ensure that
exploitation of mineral resources serves present and future generations.”28
The interpretation and application of NEMAQA is specifically guided by the NEM Principles.29 The application
of NEMAQA to the receiving environment, as opposed to the source of the emissions, is evident in NEMAQA
section 8, which provides for the municipal and provincial monitoring of ambient air quality as well as the
municipal “point, non-point and mobile source emissions”.30 The objects of NEMAQA are:
“(a) to protect the environment by providing reasonable measures for—
(i)
the protection and enhancement of the quality of air in the Republic;
(ii)
the prevention of air pollution and ecological degradation; and
(iii)
securing ecologically sustainable development while promoting justifiable economic and
social development; and
(b) generally to give effect to section 24 (b) of the Constitution in order to enhance the quality of ambient
air for the sake of securing an environment that is not harmful to the health and well-being of
people.”31
Similarly, the purpose of the National Environmental Management: National Water Act, 1998 (“NWA”)
includes the promotion of “the efficient, sustainable and beneficial use of water in the public interest” 32 and
the reduction and prevention of pollution and water resource degradation33, whilst the obligations enforced
under the NWA include the prevention of pollution34 and the authorisation of water use.35
26
EIA Reg 31(2)(k).
EIA Reg 31(2)(l)(i).
28
MPRDA section 37.
29
NEMAQA s. 5(2).
30
Section 8(a)(ii).
31
NEMAQA s.2.
32
NWA section 2(d).
33
NWA section 2(h).
34
NWA section 19.
35
NEA section 22.
27
7
1.3
Summary of issues
It follows from the content of the draft EIA reports, read with these requirements, that the primary concerns
with this application are:
x
Discrepancies in the procedure underlying these reports in that the applicant fails to:
o
o
o
o
o
o
x
submit considerations independent of the submission that ultimately the proposed coal power
station is to generate 2 000 MW, and not the 600 MW apparently subject to the current EIA process;
comply with the requirements for public participation, so as to ensure transparency and
accountability;
prove the required experience in environmental management, so as to ensure the pollutant control
and mitigation of the proposed coal power station;
ensure the undertaking of the specialist expert reports in a comprehensive, transparent and
accountable manner;
ensure that all relevant information is considered and that irrelevant considerations are not taken
into account; and
recognise the integral requirement that the cumulative impacts of environmental consequences be
assessed.
The applicant’s failure to establish the need and desirability of the proposed coal power station in that it:
o
o
o
o
refers to the need for coal-based electricity in a misleading and outdated manner that confuses the
increasing demand for electricity with the imperative that this electricity be coal-based, conflates
the need for new coal-based electricity (particularly that from domestic sources) and attempts to
detract from the requirements for rigorous assessment of the project and available alternatives;
elevates the benefits of CFB technology, if properly employed, above that which is to become a
standard requirement for all new coal-based power generation and in disregard for the need for
carbon capture and storage (CCS) mechanisms so as to control climatic impacts;
places a high value on the use of low grade coal discard by the proposed coal power station in
disregard for the abundance of South African coal, Kuyasa Mining’s obligations to manage its coal
discard (regardless of the establishment of the proposed coal power station), the prerogative of new
coal-based power generation to use CFB technology so as to use lower grade coal, and the national
policy and obligations to diversify energy supply sources and control climate change; and
over-emphasises and misconstrues the creation of downstream opportunities.
x
The applicant’s failure to investigate alternatives in any real sense, in its basis of the project on the use of
coal discard at Delmas Coal and the cleaning up of the pollution incurred at Ikhwezi Colliery, as well as its
assumption that proximity to Delmas Coal and Ikhwezi Colliery are non-negotiable factors due to “economic
reasons”, despite the related environmental impacts.
x
The premise of the project on the failure of Delmas Coal to manage its discard coal and the failure of Ikhwezi
Colliery to comply with the required rehabilitation and closure schemes with the concurrent environmental
liabilities. As such, the applicant overlooks the responsibilities of Delmas Coal and Ikhwezi Colliery in
accordance with the “polluter pays principle”, regardless of any further developments in respect of the
proposed coal station, and assumes the faith of the decision-maker in its abilities to mitigate the
8
environmental impacts of the proposed coal power station, despite these past environmental
transgressions.
x
The applicant’s failure to prioritise the location of the proposed coal power station within a sensitive
wetland area bordering on the sensitive Wilge River, catchment and tributaries.
x
The applicant’s failure to recognise the legal and factual importance of the location of the proposed coal
station within the HPA and, concurrently, the importance of the cumulative effect of emissions within this
area. The applicant’s attempts to undermine the importance of the definition of the HPA by focussing on
the proposed coal power station being a future project outside the air emission “hot spots” (despite the
clear application of cumulative air quality and the dispersive nature of air impacts and the forward-looking
nature of the HPA Management Plan) is, our clients submit, nonsensical and opportunistic, and is contrary to
the focus of the air pollution control on the receiving environment as opposed to the source.
x
The problematic nature of the applicant’s point source emissions, including the applicant’s failure to
consider the impact of the proposed coal power station on climate change, both in terms of its real effects
and its violation of South Africa’s international obligations to reduce greenhouse gas emissions.
The applicant’s wholly inadequate assessment of the waste implications of and procedures for the proposed
coal power station with the associated ADF, despite the potentially severe environmental implication of the
development including the effects of hazardous waste streams (involving boiler ash and waste water), ash
radioactivity and contaminated land;
x
x
The applicant’s avoidance of a proper analysis of the water uses necessary for the proposed coal station, as
required at the draft EIA stage, by inferring that this will be conducted during the IWULA as part of the final
EIA reports.
x
The effect of the proposed coal power station on the vital water sources in area in that:
o
o
o
x
36
the large scale water need of coal-based power generation will be drawn from an overburdened
source in a water deficit area, with no proper investigation of alternatives, despite the request from
the DWA that alternate sources be identified;
the proposed location of the development in an area of such significant hydrological sensitivity that
the DWA has made public its intention to declare the Wilge River catchment “a Class 2 river system
in order to seek to protect Mpumalanga’s water resources” meaning that “no new impacts will be
tolerated within this catchment”36- this sensitivity is exacerbated because the primary aquifer in the
area is highly susceptible to surface-induced impacts and activities due to its intrinsic unconfined
and semi-unconfined piezometric conditions; and
the significant discrepancies in the applicant’s hydrological assessment procedures, together with
Kuyasa Mining’s history of environmental non-compliances, raise concerns about the applicant’s
ability to ensure the containment of all contaminants and, thereby, to validate the proposed
mitigation measures.
The applicant’s failure to consider the health impacts of the proposed coal power station, regardless of the
indications that the potential health impacts and economic burden associated with the project would be
EIA, page 82.
9
substantial in relation to the economic value created, as well as in relation to the costs of alternative non
coal-based technologies with significantly lower public health impacts.
These concerns are detailed below.
2.
2.1
Methodology adopted for impact assessment
Submission of an additional 1 400 MW of coal fired power plant to be developed on site
Although the EIA is conducted on the basis of a 600 MW coal power plant, the applicant approaches the draft
EIA reports on the basis that ultimately it intends to develop a 2 000 MW coal power plant on the site: the EIA
refers to the initial 600MW proposal as “the first-phase of this KiPower Project”.37
The EIA may not seek any degree of recognition of an intention to develop an additional 1 400 MW of coalfired plant, without undertaking the full assessment of this proposition in terms of NEMA and other relevant
legislation. Such an assessment would relay the source of the surplus coal intended to fuel the additional 1
400 MW of power and clarify whether Delmas Coal is able to provide for this surplus or whether discard coal is
ultimately to be imported into the area. Even more pertinent with respect to the current application is that
the applicant only considers sites with the potential to accommodate a 2 000 MW power plant: the applicant
submits in the EIA that “sites that would allow for expansion within its footprint were favoured.”38
If a 2 000 MW plant is ultimately the premise of crucial aspects of the project development, it suggests that
this large scale is inherent to the value proposition of the project- the applicant’s submission of the financial
statements for the development, which have been omitted from the draft EIA reports, would allow for further
substantiation in this regard.39 The applicant’s attempt to legitimise a further 1 400 MW coal power plant
fuelled by additional coal mining also extends into the “Project motivation” section of the Executive Summary
in the EIA, where the “wishes” and “vision” of the applicant are presented as if they were already assured
impacts of the project for which they are seeking approval.40
2.2
Public participation
The NEM Principles require decision-making in an open and transparent manner with access to information
provided in accordance with the law.41 This requirement applies the constitutional rights of access to
information and just administrative action.
Section 32(1) of the Constitution provides that “(e)veryone has the right of access to - (a) any information held
by the state; and (b) any information that is held by another person and that is required for the exercise or
protection of any rights.” The public’s access to information determines whether all stakeholders are able to
participate in those decisions affecting them in any meaningful way and acts as a check on administrative
actions. In Aquafund (Pty) Ltd v Premier of the Western Cape it was held that:
37
EIA, page 58.
EIA, page 62.
39
No financial provisions are attached to the application (Appendix E, Licensing Information, page 16).
40
As submitted in accordance with analysis by independent researcher Richard Worthington.
41
NEMA, s 2(4)(k).
38
10
“[i]f it is accepted that every person is entitled to lawful administrative action, it must follow that in
a legal culture of accountability and transparency . . . manifested in the constitution, a person must
be entitled to such information as is reasonably required by him to determine whether his right to
lawful administrative action has been infringed or not. If a person is not able to establish whether his
rights have thus been infringed, he will clearly be prejudiced.”42
Under section 33(1) of the Constitution, “(e)veryone has the right to administrative action that is lawful,
reasonable and procedurally fair.” In the case of Director: Mineral Development, Gauteng region and another
v Save the Vaal Environment and others,43 the Supreme Court of Appeal confirmed the fundamental nature of
the public’s right to be heard as a component of lawful, reasonable and procedurally fair administrative
action, particularly in light of the “enormous damage” that can be caused by mining activity. In the case of
Earthlife Africa (Cape Town) v Director General Department of Environmental Affairs and Tourism and
Another, 44 the Court took the view that this right to be heard can apply at various stages in an application
process.
Despite these public participation requirements, it was submitted in the community engagement sessions
recently conducted by JaW that the community that has settled adjacent to the site of the proposed coal
power station did not know or had a very limited understanding about the proposed coal power station and
the public participation procedure. This is clearly in breach of the requirements in the EIA Regulations, 2010,
that notice be given to all interested and affected parties and to employ “reasonable alternative methods, as
agreed to by the competent authority, in those instances where a person is desiring of but unable to
participate in the process due to (i) illiteracy; (ii) disability; or (iii) any other disadvantage.”45 There was also a
discussion on whether people would be relocated for this development and there was no clarity from the
proponent or JaW on this.
The applicant’s submission, in its prior reports of the public participation process, that the summary
documents have been translated into Xhosa and Zulu is clearly insufficient to comply with these
requirements.46 Additionally, the applicant’s submission, in these prior public participation reports, that the
proposed coal power station will not require the relocation of people, is clearly misplaced and reflects, it is
submitted, the applicant’s removal from the concerns and reality of the local people at the site.47
In any event, the information circulated by the applicant to interested and affected parties is neither
transparent nor accountable for the reasons detailed in the balance of this submission. As such, interested
and affected parties have not been afforded the opportunity to comment in any meaningful way. We are
instructed that local people were required to sign documents that they did not properly understand, and no
copies of the documents signed were left with those who signed. This is not acceptable to our clients.
42
Page 5-42.
(133/98) [1999] ZASCA 9.
44
(7653/03) [2005] ZAWCHC 7.
45
EIA Regulations, 2010, Reg 54(2)(e).
46
Appendix K, Public participation report, Comments and responses report, page 22.
47
Above.
43
11
2.2
Competency of applicant
The applicant is open about its inexperience in pollutant control and mitigation of the proposed coal power
station in its admission that, as the ADF is a new venture, it does not yet know how it will ensure and maintain
its technical competency.48 This admission is even more striking - and of serious concern to our client - in the
light of the non-compliances of Kuyasa Mining’s Ikhwezi Colliery and Delmas Coal.
In the applicant’s meeting with the DMR on 25 February 2013, the DMR came to the general conclusion that
the applicant would need to prove environmental management experience if it is to undertake the liability for
Ikhwezi Colliery’s environmental transgressions.49 This conclusion emphasises the applicant’s inexperience in
environmental management as well as the function of the proposed coal power solution as a solution to
Ikhwezi Colliery’s environmental transgressions (see section 7 below).
2.3
Expert reports
A number of the experts responsible for the formulation of the expert reports that support the EIA are
employed by JaW (namely Mr Anton Bain as engineering consultant, Ms Anelle Lotter as public participation
practitioner, Mr Gareth Simpson as surface water specialist, and Mr Bryan Antrobus as geotechnical
specialist). We further note JaW’s involvement in the assessment of Delmas Coal, as well as that in the
KiPower pipeline (the latter, for some reason, undertaken separately from the EIA process for the proposed
coal power station). These intertwining interests render the failure of JaW, on behalf of the applicant, to
submit all relevant information and to ensure a comprehensive, transparent and accountable process
particularly problematic.
We further note that a number of primary expert reports are not yet in finalised form, including the
geohydrology and socio-economic reports.
2.4
Failure to provide all relevant information
The applicant’s failure to provide all relevant information is dealt with in further detail in the balance of this
report. The applicant’s failure to provide such information means that any decision taken in this regard will be
subject to review in terms of section 6(2)(e)(iii) of the Promotion of Administrative Justice Act, 2 000, which
makes provision for judicial review, inter alia, where “irrelevant considerations were taken into account or
relevant considerations were not considered”.
In addition to the discrepancies noted elsewhere in this submission, the applicant fails to provide a proper
account of information including:
x
the details of the intended transport routes- there is no adequate explanation of:
o
o
48
49
the destination of the balance of the coal from Delmas Coal;
the alternative destinations for the coal, should the proposed coal power station be located
elsewhere or should the coal be re-routed to alternate end users;
Appendix E, Licensing Information, page 15.
Appendix K, Public participation report, page 135.
12
o
o
o
2.5
why Delmas Coal’s pre-existing use of the Transnet line cannot entail the transport of
“discard coal” for use at a coal-fired power station outside the HPA;
the connection of the proposed coal power station to the grid, including the establishment of
underground electrical cable duct runs; and
the environmental impact of the conveyance of limestone from South Limpopo;
x
details concerning the contemporary flooding potential of the area during the wet summer months;
x
financial information, both for the proposed coal power station and for the seemingly intertwined
financial condition of Ikhwezi Colliery and Delmas Coal (the latter two pieces of information to cover
both contemporaneous data and the considerations relevant at the time of Kuyasa Mining’s purchase
of these entities); and
x
the macro-economic benefits and social funds envisaged to flow from the proposed coal power
station.50
Failure to assess cumulative impacts
The applicant’s failure to recognise that the assessment of environmental impacts includes that of cumulative
impacts is dealt with in further detail at sections 0 and 10 below. The applicant’s submission that emissions
from the proposed coal power station will meet national standards for new emitters fails to deal at all with
the requirements under NEMA and NEMAQA.
3.
3.1
Justification of need and desirability for a coal power station in the Highveld Priority Area
Increasing demand for coal-based electricity
The applicant confuses the increasing demand for electricity with the imperative that this electricity be coalbased. The increase of large coal-fired electricity generation facilities is part of a development paradigm that
has failed adequately to address energy access – perpetuating this paradigm could well be exacerbating
shortcomings in addressing energy access, as is argued in “Smart Electricity Planning”.51 Increasing the
contribution of coal to electricity generation is not consistent with the National Strategy for Sustainable
Development as it involves a progressively increasing risk of stranded assets in the electricity supply industry,
as detailed in ‘Unburnable Carbon: budgeting carbon in South Africa’,52 and entrenches national dependence
on finite resources.53
In any event, the applicant’s references to the requirements in the Integrated Resource Plan 2010 dated
March 2011 (“IRP 2010”) are misleading and outdated. The applicant claims “(t)he document concludes that
coal based electricity generation will continue to grow in South Africa for the foreseeable future while other
50
See incomplete information at EIA, page 171.
Dr Y Abrahams, R Fischer, B Martin, l McDaid Smart Electricity Planning - Fast-tracking our transition to a healthy, modern,
affordable electricity supply for all (March 2013) a publication of the Electricity Governance Initiative.
52
Sinco, Trucost, WWF South Africa and WWF UK Unburnable Carbon: budgeting carbon in South Africa (November 2012)
Carbon Tracker - [email protected].
53
As in accordance with analysis by Richard Worthington.
51
13
forms of electricity are developed.” 54 Unless one takes a very limited view of what constitutes the
“foreseeable future”, the accurate account of the document’s conclusion appears further down in the same
paragraph: “The Department of Energy IRP indicates that it wishes to reduce dependence on coal, but in terms
of security of supply, coal-based electricity will continue to dominate South Africa’s energy sources…”55 The
Department of Energy’s (“DoE”) wish to reduce coal dependence, amidst its admission of the dominance of
coal-based electricity, renders any increase in coal-based electricity above the threshold of necessity
undesirable.
The applicant refers to the IRP 2010 requiring 6.3 GW of new coal based electricity with the proposed coal
station expected to generate 523.6 MW in an apparent move toward fulfilling this demand.56 This demand is
outdated, as relayed by the IRP 2010-2030 Update Report released in 2013 (the “IRP Update Report”).
Although IRP 2010 remains the official government plan for new generation capacity until it is replaced in full
(as expected in 2014),the IRP Update Report relays critical changes relevant to key decisions and indicates the
direction that will be taken in the next official version of the integrated resource plan.57 As specified by IRP
2010, “(t)he Integrated Resource Plan (IRP) is a living plan that is expected to be continuously revised and
updated as necessitated by changing circumstances.”58
In the IRP Update Report, the Department of Energy (“DoE”) significantly decreased the requirement for new
coal-based electricity to 2,45 GW.59 This decrease was due to factors including: the drop in actual electricity
demand, the extended life of existing coal plants, the increase in projected gas capacity and the increased
reliance on certain renewable sources and a shift away from energy-intensive industries. The reference in the
IRP Update Report to regional coal power (where pricing is competitive) because of “emissions not accruing to
South Africa” implies that the preference is for such new coal-based electricity to be produced outside South
Africa.60 The IRP Update Report refers to the importation of 1,2 GW of electricity from a proposed new coalfired power station in Botswana.61
The new coal-fired power generation outlined in the IRP Update Report for 2020 to 2025 is likely to be less
than 1 GW, with the preference for a regional coal project “above all other coal options because it is expected
that the emissions from the generation will not count to the South African total in a future global emission
targeting regime.”62 It appears that the first “major decision point” for this additional coal capacity is to occur
in 2014.63
The application refers to the South African Government’s 2003 decision to split future power generation
70/30 between Eskom and independent power suppliers (“IPPs”). Any such decision is unavoidably outdated
in light of the interim promulgation of IRP 2010 and the IRP Update Report, as well as significant framework
54
EIA, page 57, section 2.10.3.
Above.
56
EIA, page 57.
57
IRP Update Report pages 8-9 and page 10, para 2.3.
58
IRP 2010, page 7, para 1.1.
59
IRP Update Report, page 20.
60
IRP Update Report, page 8.
61
IRP Update Report, page 32, par 7.3.
62
IRP Update Report, page 44, par 12.7.
63
Above at par 12.8.
55
14
legislation such as the Electricity Regulation Act, 2006, and the National Energy Act, 2008. According to IRP
2010:
“The New Generation Regulations require a feasibility study on the potential capacity identified in
the IRP to provide input to the Ministerial determination between Eskom build and procurement
from Independent Power Producers (IPPs). This feasibility study needs to be undertaken as soon as
the IRP is promulgated to give impetus to the decisions.”64
Table 5 of IRP 2010 (“Commitments before next IRP”) depicts 100 MW of coal new-builds (500 MW in 2014
and 500 MW in 2015) as those to be built, owned and operated by IPPs.65 This is significantly less than the
demand relayed by the applicant. Moreover, even in IRP 2010 (absent the adjustments introduced in the IRP
Update Report) South Africa’s lack of reliance on this commitment is relayed in its indication that, by 2018,
there is likely to be a reserve margin for electricity generated well in excess of the 17-18% and that
cancellations of 1 GW of IPP FBC will not compromise security of supply and can be easily mitigated (for
example, through increased renewable energy build):
“IPP-operated coal FBC units: If the coal units expected to be commissioned in 2014 and 2015 are
not built, or are not built in a timely manner, the reserve margin from these years on will be roughly
1,0 GW lower. Until 2020, the reserve margin is substantial (approximately 20%) and a cancellation
or delay of these coal FBC units is unlikely to jeopardise security of supply before 2020. This provides
sufficient time to implement mitigation measures.”66
Even assuming the current accuracy of the applicant’s statement regarding the split of future power
generation (which our clients do not admit), and not accounting for the move toward regional power
producers filling IPP roles, the application of a 70/30 ratio to new coal-fired power generation requires that
only 300MW of the new coal-fired power generation emanate from IPPs such as the applicant.
We note that, whilst the applicant alleges that it has received a NERSA licence for the generation of electricity,
it fails to attach this licence or provide any detail as to its content. The Electricity Regulations on New
Generation Capacity, 2011, detail the requirements of a power purchase agreement between the buyer and
an IPP, including that the agreement be “value for money”.67 Disclosure of these requirements, as detailed in
such an agreement, will facilitate the assessment of the applicant’s vague reference to “economic reasons” for
the location and construction of the proposed coal station.
It follows that scrutiny of the IRP 2010, read with the IRP Update Report, brings into question the extent of the
need for new coal capacity, particularly when this need is held to prevail over prioritised environmental
considerations and to cloud the consideration of sustainability and the determination of the best practicable
environmental option. According to the Socio Economic Report (“SER”) at Annex L11 to the EIA, Eskom is
already envisaging a new 5 GW coal fire power station for 2020, with two other IPPs planning close to 1 GW of
coal power.68 This brings into question whether the proposed coal station is needed at all.
64
IRP 2010, page 15, para 6.1.
IRP 2010, page 16.
66
IRP 2010, page 21, para 6.9.3.
67
Electricity Regulations on New Generation Capacity, Reg 9(a).
68
Appendix L11, page 68.
65
15
In any event, and regardless of the apparent capacity requirements, the potential benefits of increased
electricity generation capacity in no way detract from the requirements for rigorous assessment of the project
and alternatives available within the same timeframe.
3.2
Technology adopted
Any acknowledgement of the benefits of CFB technology, if properly operated, does not imply the
condonation of the proposed coal station in its current form and location. According to the South African
National Energy Development Institute (“SANEDI”), regardless of the base load power chosen, the use of CFB
technology will grow in South Africa.69 In the IRP Update Report, the DoE projects that all new coal-fired
generation will apply CFB technology.70 These reports imply that the application of CFB technology for all new
coal-fired power generators, whether independent or those of Eskom, is standard and should not provide
motivation for the award of authorisations, particularly when the intention is to apply such technology in an
area prioritised because of its high air pollution levels.
Ultimately, the application of CFB technology does not answer the question why a further coal-fired power
station should be established in the HPA, especially when it will add to the cumulative emissions, nor why the
low grade coal discard cannot be transported, using the nearby railway, for use elsewhere.
Moreover, the applicant has failed to consider the reduction of carbon emissions and the mitigation of the
climate change impacts from coal-generated power through other topical means - such as CCS mechanisms.
The proposed coal power station does not include CCS - such technology is still in the process of development.
Although the consideration of the CCS mechanism would raise additional questions regarding the efficacy and
financial feasibility of the mitigation measures to be entailed in the proposed coal power station, the
applicant’s failure to consider such mechanisms highlights the incomplete nature of the assessment.
3.3
Use of coal discard
In motivation of the project, the applicant proposes that a distinct value proposition exists as “(c)oal discard
could be used as an energy source, thereby optimising the use of coal reserves and removing discard dumps,
which are sources of air and water pollutants.”71 The applicant submits that the apparent benefits of CFB
technology include that it can use low grade coal that would otherwise be discarded. Apparently, the coal
produced by Seam 4 of Delmas Coal is of such a low grade that it is not suitable for use in Eskom’s power
stations, but can be used in a CFB boiler because of its lower combustion temperatures.72
These submissions are faulty for the following reasons:
x
Comment on optimising the use of reserves is irrelevant as South Africa has an abundance of coal.
69
SANEDI’s South African Coal Roadmap, page 32:
(http://www.sanedi.org.za/archived/wp-content/uploads/2013/08/sacrm%20roadmap.pdf as accessed on 20 March 2013).
70
IRP Update Report, page 24, par 5.6.
71
EIA, page ii.
72
EIA, pages 58 and 60.
16
x
In accordance with the “polluter pays” principle, the cost of remedying pollution and other adverse
effects of the coal discarded at Delmas Coal is the responsibility of Kuyasa Mining. 73 As Kuyasa Mining,
failing a valid transfer of this legal liability, is obliged to manage the problem of coal discard regardless
of the establishment of the proposed coal station, the existence of coal discard is a factor that should
be viewed separately from - and cannot be offset against - the impacts of the proposed coal station.
x
The applicant’s claim of Eskom’s inability to use this lower grade coal discard ignores the prerogative
relayed in the IRP Update Report that all new coal power stations, including those owned by Eskom,
are to apply CFB technology. In the scenario predicted by the IRP Update Report and SANEDI, lower
grade coal discard such as that produced by Delmas Coal, can be used by all new coal-fired power
stations.
x
Diversification of energy supply sources is a national policy objective and coal accounts for 92% of
South Africa’s electricity supply. The commissioning of Medupi and Kusile will increase the size of our
coal-fired electricity generation fleet by more than 25%. Adding a further 2 000 MW of coal-fired
generation, or even the more modest 600MW, would be contrary to the diversification policy.
x
As detailed further at section 10 below, any proposal for burning coal for power generation in South
Africa, additional to the existing fleet and the Medupi and Kusile plants under construction, is contrary
to South Africa’s international commitments to climate change mitigation action, specifically those
made at the 2009 “COP” 15 in Copenhagen.
Furthermore, the combustion of dumped discards is a different proposition to the new mining of low grade
coal for power generation and the attributes of the former should be assessed independently, and not
confused or conflated with the relative merits and demerits of the latter.74
3.4
Downstream opportunities
The findings of the Socio Economic Report (“SER”) are not adequately traversed in the EIA. The SER concludes
that “(w)hilst positive impacts may not be outweighed by negative impacts, the negative impacts have the
potential to overshadow any good that may come from the project if not managed appropriately.” 75
Consequently, the effect of any positive social impacts of the proposed coal station is reliant on the applicant’s
proper employment of mitigation measures. Such a reliance is impractical, not only in light of the applicant’s
history of non-compliance (as addressed in section 7 below) but also because of the applicant’s employment
of a foreign contractor during the construction phase and the difficulty of enforcing mitigation measures such
as the employment of local labour upon such a foreign contractor.76
The SER warns that projects such as large-scale mining projects tend to attract an influx of young single males
to an area, which influx could, in fact, lead to increased unemployment (particularly if these young males
choose to settle in the area to await future opportunities following the construction phase) as opposed to the
promised job creation.77 This demographic influx might contribute even further to increased poverty levels in
73
NEMA s.2(4)(p).
As submitted in accordance with analysis by Richard Worthington.
75
Appendix L11, SER, page 89.
76
Appendix L11, SER, page 88.
77
Appendix L11, SER, pages 51 and 88.
74
17
the area, because its income tends to be sent “home” to places outside the area. Furthermore, because it
tends to have a lower number of dependants than local inhabitants, they are able to settle for lower wages
and to contribute less to general poverty alleviation.78
According to the applicant, the operational phase of the power station is estimated to create over one
hundred jobs for local unskilled and semi-skilled people for the 30 year period of the proposed coal station. 79
Due to the duration of the operation phase, the local employment opportunities are less likely (although not
unlikely) to be offset by the influx of young male job-seekers than the construction phase. However, both
phases are likely to attract employment from the local agricultural sector, thereby threatening the
sustainability of the agricultural sector and doing little to reduce poverty levels or increase the employment
rate in the area.80
It appears that the applicant intends to provide no staff accommodation for staff on site, despite the nearest
towns being around 20 kms from the proposed coal station. This has a number of repercussions:
x
The employees will have to be transported to the site. The SER estimates that transport of
employees from the surrounding towns could entail up to 20 bus loads (with 150 people per bus)
twice a day, resulting in a negative effect on ambient air quality and the conditions of the local
roads.81 The SER submits that this increased traffic will be offset by the traffic reduction resulting
from the proximity of Delmas Coal to the proposed coal station.82 This implies that the proximity of
the coal mine to the power station - a key factor underlying the applicant’s proposal – may, in fact,
have limited net benefits.
x
The surrounding towns will need to have sufficient capacity (including municipal facilities) to
accommodate a predicted influx of up to 3 000 workers at peak times (particularly during
construction), despite the EIA83 and SER84 reflecting the sub-standard quality of service delivery in
the Delmas area. Demand for water in the area already exceeds that for supply and the sewage
systems are overwhelmed.85 Currently (that is prior to any population influx) there is only one police
officer for every 406 citizens.86
x
It is likely that the pre-existing informal settlement, located around 1.7km from the site, will expand
with the work force for the proposed coal station. The SER details the poor socio-economic
conditions in informal settlements and that the more such settlements grow, the more conditions
deteriorate and the more the quality of life of those who are in the vicinity of the settlement is
affected because increasing numbers of people try to access the same scarce resources.87
78
Appendix L11, SER, page 58.
Appendix L11, SER, page 51.
80
Appendix L11, SER, page 58.
81
Appendix L11, SER, page 87
82
Appendix L11, SER, page 56.
83
EIA, page 93.
84
Appendix L11, SER, pages 60 to 65.
85
Appendix L11, SER, page 62.
86
Appendix L11, SER, page 63.
87
Appendix L11, SER, pages 69-70.
79
18
The SER approximates the net external costs (excluding the cumulative effects of air pollution) of the
proposed coal station as R16 million. It is alleged that these external costs should be offset by the local
income generated by the project. However, any offset assumes such local income generation is not
undermined by the population influx and trans-sectoral work force movement mentioned above.
Additionally, the effect of impacts such as air pollution will disperse and extend beyond the local area.88
The SER makes brief mention of the social contributions envisaged by the applicant such as the promised
establishment of a local science academy in line with black economic empowerment.89 There is no motivation
as to why such social contributions need to be in respect of a coal power station in the HPA, nor confirmation
that such contributions will in fact occur. Moreover, the SER goes so far as to conclude that “(a) BEE
compliance approach to corporate social investment is not considered sufficient if the potential net local
external costs of around R 17 mm are taken into consideration”.90
4.
Location within HPA: Importance of cumulative effect of air quality
Section 18 of NEMAQA provides for the declaration of a priority area as follows:
“18. Declaration of priority areas.—(1) The Minister or MEC may, by notice in the Gazette, declare an area
as a priority area if the Minister or MEC reasonably believes that—
(a) ambient air quality standards are being, or may be, exceeded in the area, or any other situation exists
which is causing, or may cause, a significant negative impact on air quality in the area; and
(b) the area requires specific air quality management action to rectify the situation.
(2) The Minister may act under subsection (1), if—
(a) the negative impact on air quality in the area—
(i) affects the national interest; or
(ii) is contributing, or is likely to contribute, to air pollution in another country;
(b) the area extends beyond provincial boundaries; or
(c) the area falls within a province and the province requests the Minister to declare the area as a priority
area.
(3) The MECs of two or more adjoining provinces may by joint action in terms of subsection (1) declare an
area falling within those provinces as a priority area.
(4) Before publishing a notice in terms of subsection (1), the Minister or the relevant MEC or MECs must
follow a consultative process in accordance with sections 56 and 57.
(5) The Minister or MEC may, by notice in the Gazette, withdraw the declaration of an area as a priority area
if the area is in compliance with ambient air quality standards for a period of at least two years.”
Section 18(1) clearly distinguishes between “ambient air quality standards” (at section 18(1)(a)) and “specific
air quality management” (at section 18(b)). In accordance with section Error! Reference source not found.
88
Appendix L11, SER, pages 55-57.
Appendix L11, SER, page 58.
90
Appendix L11, SER, page 58.
89
19
bove, this distinction is reinforced by the NEMAQA definition of “ambient air quality” in a broad sense - which
excludes only “air regulated by the Occupational Health and Safety Act, 1993”.91
In 2007, the then Minister of Environmental Affairs, Mr Marthinus van Schalkwyk, declared the Highveld area,
including the locations of Delmas Coal, Ikhwezi Colliery and the proposed coal power station, a priority area in
terms of NEMAQA section 18(1), because of his belief that the area’s ambient air quality exceeded or might
exceed ambient air quality standards, or that “a situation exists within the Highveld Priority Area, which is
causing or may cause a significant negative impact on air quality in the area, and that the area requires
specific air quality management action to rectify the situation.”92 The Honourable Minister’s concern for
excessive ambient air quality standards can only be understood as including the cumulative impact of emitters
within this area - his declaration clearly relays his concern for the area and not for point source pollutants as
such. In any event, our clients submit that the diffusive qualities of air pollutants render the exclusion of
cumulative impacts nonsensical (and, in the case of applicant, wholly opportunistic).
Following the 2007 declaration, a priority air quality management plan was prepared for the area, as required
by NEMAQA.93 The HPA Management Plan was promulgated in 2012, with its primary motivation to “achieve
and maintain compliance with the ambient air quality standards across the HPA, using the Constitutional
principle of progressive realisation of air quality improvements.”94 The NEM Principles specifically applicable
to the formulation of the HPA Management Plan include those of “polluter pays”, sustainability, the best
practicable environmental option and integration (whereby “Environmental management and by inference
[Air Quality Management] must be integrated, acknowledging that all elements of the environment are linked
and interrelated, and it must take into account the effects of decisions on all aspects of the environment and
all people in the environment.”)95 National emission standards continue to apply to the HPA, although stricter
emission standards may be enforced in order to alleviate ambient pollutant levels.
The HPA Management Plan applies to air quality in the HPA as a whole, and refers to the total estimated
annual emissions across the entire area, as well as the dispersion characteristics of air pollution.96 In line with
this approach, the HPA even applies to certain emissions from sources outside the HPA.97 The importance of
the cumulative impact of air quality is further conveyed in the Regulations prescribing the format of the
Atmospheric Impact Report,98 when a dispersion modelling exercise is required to assess the atmospheric
impact of a facility. This assessment “should take the emissions of the facility under consideration into
account as well as prevailing ambient air concentrations during this assessment.”99 When assessing the impact
of the facility on the environment, the assessment may include - but is not limited to - soil and water bodies
(rivers, dams, lakes).100
91
NEMAQA section 1.
GNR 1123 of 23 November 2007.
93
NEMAQA section 18.
94
GN 144 of 2 March 2012, page 6.
95
HPA Management Plan pages 50 and 51.
96
For example at pages 7, 84 and 86.
97
HPA Management Plan, page 70.
98
GN 747 of 11 October 2013.
99
Regulations 5.1 and 5.2.
100
Regulation 5.2.
92
20
It follows that air quality management for a plant within a high air quality priority area ought to include a
strategic air quality assessment that establishes the carrying capacity of the airshed. It may well be the case
that the individual sources may be meeting the compliance limit in terms of the emissions standards but,
considered collectively, the threshold could be breached or be at the verge of being breached. Only an
integrated collective assessment will provide these answers.
The dispersive nature of air quality impacts is recognised in the recent draft Guidelines for Air Dispersion
Modelling for Air Quality Management in South Africa (the “Air Dispersion Draft Guidelines”).101 The Air
Dispersion Draft Guidelines apply to the development of air quality management plans, atmospheric impact
reports and specialist air quality impact assessment studies in order to recognise the effects of air pollution of
spatial and temporal ranges.102
The recognition of the cumulative effects of air impacts recently bore fruit in the rejection by the Nkangala
District Municipality - in which KiPower would be located - of Eskom's request to allow it to emit more
pollution than provided for in its AEL in respect of the Kriel power station located within the HPA.103 According
to the municipality, Eskom had failed to properly assess the cumulative impact of their plants on the
environment. (Coincidentally the Nkangala District Municipality also found that Eskom’s modelling of potential
pollution was not sufficiently thorough and did not look at incidents under different weather conditions.)104
In the face of the provisions outlined above, the applicant’s singular focus on the location of “hot spots”
within the HPA Management Plan is opportunistic. The applicant relies on the location of the proposed coal
station outside the specific “hot spots” detailed in the HPA Management Plan, so as to undermine the
cumulative effect of air quality emissions despite the clear application of cumulative air quality and the
dispersive nature of air impacts. The HPA Management Plan specifically recognises a shortcoming of the “hot
spot” approach to be the “inability to illustrate the relative contribution of emission sources that have a
relatively limited spatial effect, e.g. mining, residential fuel burning and motor vehicles, where these sources
will dominate.”105
Notwithstanding the applicant’s arguments reflected in the EIA, the SER specifically records the cumulative
impacts of the developments in the Delmas area (including the proposed coal station) as negatively affecting
poor air quality in an area defined as a high priority air pollution area. In the face of these negative effects,
the SER emphasises the lack of appropriate national and local policy guidelines in relation to integrated coal
development planning, energy licensing monitoring within the framework of the IRP and strong spatial
management of the area. The SER concludes:
“(i)f the current expansion of coal mining and coal power applications within Victor Khanye and the
broader Nkangala district continues unabated the area could reach a tipping point in development
where projects with more pronounced negative environmental impacts become the most viable
option financially for all parties concerned. Land values for farming purposes could decline below
market value due to the large external costs imposed by air and water pollution and the visual
101
Notice 1035 of 2012.
Air Dispersion Draft Guidelines sections 1.1 and 4.
103
http://cer.org.za/news/eskoms-application-for-increased-pollution-from-kriel-power-station-refused
104
Mail & Guardian” Pollution vs power output at Eskom's Kriel” 25 March 2014, http://mg.co.za/article/2014-03-24-eskomapplication-to-pollute-more-rejected accessed 25 March 2014.
105
HPA Management Plan, page 89.
102
21
degradation of the area, rendering rezoning for mining purposes increasingly attractive as an
alternative (perhaps even as only) land-use in the area. This could have implications for food security
as well as the long term environmental sustainability of the area.”106
Air quality management is, by its very nature, forward-looking: a management plan can only relate to future
activity. The achievement and maintenance of compliance by the HPA Management Plan would be frustrated
if this plan were to apply only to current and not future projects, as the applicant opportunistically suggests.
Conversely, the development of projects in the area proposed after the formulation of the HPA Management
Plan is clearly contrary to the maintenance and compliance objectives of this plan and will be in frustration of
the reduction of any ambient air quality levels in the area, regardless of the precise point source emissions of
the proposed coal station.
5.
Biodiversity implications: Location within a sensitive wetland area107
Over and above the location of the proposed coal station within the HPA, the position of this project (together
with the associated ADF and transportation and services linkages) is problematic from a biodiversity
perspective. The site is located within the Eastern Highveld Grassland Threatened Ecosystem.108 It is a National
Priority Area109 because of the growth of Moist Grasslands in the site. In accordance with the Mpumalanga
Conservation Plan, developments in the area most antagonistic to biodiversity should be discouraged. 110
The water resources in the area have been classified and are of strategic importance to the region, including the
Olifants River system. Even the Specialist Biodiversity assessment report recognises that the “loss of wetland
buffer will also potentially impact on the functioning of the wetland systems”.111 The National Freshwater
Ecosystem Priority Areas (“NEFEPA”) Project recognises the pan systems on the southern boundary of the site
as “Wetland Clusters”.112 In terms of provincial guidelines, all wetlands, regardless of the disturbance status, are
to be designated as sensitive.113 The guidelines for these wetland clusters state that “mining in any form should
not be permitted in wetland FEPAs, or within 1km of a wetland FEPA buffer”.114 In accordance with the
Gauteng Department of Agriculture and Rural Development Requirements for Biodiversity Assessment, 2012,
“(t)he wetland and a protective buffer zone, beginning from the outer edge of the wetland temporary zone,
must be designated as sensitive” and “(t)he catchment of all pan wetlands must be designated as sensitive.”115
The construction of the conveyor lines for the proposed coal station will cross a number of natural habitats,
including the un-channelled valley bottom of the wetland and the associated Seasonally Moist Grassland (both
rated as having a High Conservation Concern), the Dry Hillside Grassland (rated as a Medium to High
Conservation Concern), and the Wilge floodplain and the area of dry exposed bedrock (habitats of High
106
Appendix L11, SER, page 84.
As submitted in accordance with analysis by environmental consultant, Judy Bell.
108
Appendix L2, Specialist Biodiversity assessment report, page 131, section 9.2.2 and the National list of ecosystems that are
threatened and in need of protection, GN 1002 of 9 December 2011, section 145.
109
Appendix L2, page 131, section 9.2.1
110
Above at section 9.3.
111
Above, page 143, section 11.1.
112
Above, pages 131 and 142 (fig 2).
113
Above, page 132.
114
Above, page 40.
115
Above, page 132.
107
22
Conservation Concern).116 The reasons given for the need for conveyance through wetlands, such as “the
position of the sorbent off-loading facility and the Delmas Coal mine stockpile area”, 117 contradict the
applicant’s argument for the low environmental impacts resulting from the proximity of the proposed coal
station to Delmas Coal and Ikhwezi Colliery.
It appears that the applicant has a limited understanding of the ecological surrounds of the area: ecosystems
are considered only in terms of their capacity to mitigate impacts, not to provide goods and services for society;
and there is no consideration of the importance of those few natural areas remaining - following the impacts of
mining and agriculture in the area - as important habitats for species (including a number of critically
endangered faunal species) and as vital corridors linking these remaining habitats.
The applicant proposes that nearly 12% of the wetlands in the area be lost to the proposed development. The
applicant justifies the encroachment of the proposed surface infrastructure on valuable ecosystems as of “Least
Concern” primarily because of the extant development and damage to the relevant ecosystems. This
justification negates the value of ecosystems unless they are in a pristine condition, and ignores the additional
benefits of these ecosystems following restoration or remediation. Following this rationale, a party responsible
for degradation is rewarded by the removal of the obligation to remediate the degraded area.
In addition to the loss of surface area, the impacts extend to the loss of seepage areas and wetland
functionality. The ADF will result in the loss of a large proportion (28.55ha) of the seepage areas within the
farmed fields due to the proposed ash disposal facility. These are areas of Medium to High significance, despite
the applicant’s claim that these areas are “Seriously Modified”.118 The location of the proposed coal station will
also lead to the loss of a large proportion of seep area that the applicant deems “Largely Modified”.119
The applicant glibly justifies these impacts on the biodiversity of the area by proposing the offset of these
impacts with the rehabilitation of wetland areas in alternate locations. This proposal not only entails the
remediation of damaged ecosystems in a manner contrary to the applicant’s justification of damage to the
ecosystems on the site because of pre-existing damage, but is also incorrect in the following respects:
x
The implementation of biodiversity offsets should (if ever) only be perceived as a last resort. However, the
applicant has discussed no alternatives (as required in accordance with section 6 below) to the biodiversity
offsets it proposes in order to justify the impacts of the proposed development.
x
The applicant provides no examples or illustrations as to how wetland offsets can lead to improved
environmental performance.
x
The applicant affords no consideration to the particular value of those ecosystems to be destroyed by the
proposed coal station. The location of these ecosystems within the Olifants Catchment Water Management
Area (the largest sub-catchment of the Limpopo Basin), the finding of rare, vulnerable and sensitive species
within these ecosystems, and the value of the ecosystems as ecological corridors indicate the invaluable
nature of these ecosystems. However, the applicant does not consider any setting aside of this valuable land
for biodiversity stewardship.
116
Above, page 142, section 11.1.
EIA, page 27.
118
Appendix L2, Specialist Biodiversity assessment report, page 142.
119
Above.
117
23
6.
x
The applicant relies on the rehabilitation of historical and existent ecosystem damage as mitigation for the
impacts of the proposed coal station. This pre-existing damage is separate to the further impacts affected
by the proposed development. Following the “polluter-pays” principle, those responsible for this damage
are charged with its remediation, regardless of the impacts of further projects in the area.
x
The implementation of offsets takes little account of the reduced surface water infiltration due to the
project footprint area, which will result in the reduced flow of the nearby Wilge River and lead to increased
scouring, sedimentation and erosion.
x
There is no reference to the damage (in particular coal dust impacts) resulting from the proposed coal
station, which will affect areas beyond the site and/or limit the general capacity of the natural environment
to support life.
Failure to investigate alternatives
The proper investigation of alternatives is an integral component of environmental impact assessment.
Section 23 of NEMA, which entails the general objectives of integrated environmental management, provides
that one of these general objectives is to:
“identify, predict and evaluate the actual and potential impact on the environment, socio-economic
conditions and cultural heritage, the risks and consequences and alternatives and options for
mitigation of activities, with a view to minimising negative impacts, maximising benefits, and
promoting compliance with the principles of environmental management set out in section 2 [the
NEM Principles];”120
The EIA Regulations, 2010, define “alternatives” as meaning, with regard to the proposed activity:
“different means of meeting the general purpose and requirements of the activity, which may
include alternatives to—
(a) the property on which or location where it is proposed to undertake the activity;
(b) the type of activity to be undertaken;
(c) the design or layout of the activity;
(d) the technology to be used in the activity;
(e) the operational aspects of the activity; and
(f) the option of not implementing the activity.”121
Any proper assessment of alternatives under NEMA must account for the NEM Principles as set out above,
including the ascertainment of the best practicable environmental option, respect for the public trust
doctrine, and account for the “polluter pays” principle.
In terms of NEMA section 24(4)(b)(i), procedures for the investigation, assessment and communication of the
potential consequences or impacts of activities on the environment must include, with respect to every
application for an environmental authorisation, where applicable “investigation of the potential consequences
120
121
NEMA s23(2)(b).
Reg 1.
24
or impacts of the alternatives to the activity on the environment and assessment of the significance of those
potential consequences or impacts, including the option of not implementing the activity.”
The Western Cape EIA Guideline to Alternatives, 2011 (the “Guideline to Alternatives”) is of interpretive value
when unpacking the methodology required for the true assessment of alternatives as required by NEMA and
the EIA Regulations, 2010. According to the Guideline to Alternatives, the consideration of alternatives
means the consideration of different means of meeting the general purposes of a proposed activity and is the
key consideration of EIA. The consideration of alternative design or layout is only one of such different means.
The onus is on the applicant, as the proponent of the activity requiring the EIA, to formulate such alternatives.
To allow for the proper consideration of alternatives, the purposes of the proposed activity cannot be
understood in a narrow sense. It is insufficient that the only alternatives assessed are those in the same area
and are in relation to slightly modified design and layout.
The Guideline to Alternatives provides that the “no-go” option, that is the option of no development, whilst
acting in compliance with and maintaining environmental norms and standards, must be assessed at the same
level of detail as the other feasible and reasonable alternatives. 122 The report includes no proper
consideration of alternatives nor any adequate assessment of the no-go option, due to the basis of the project
on the use of coal discard at Delmas Coal and the mopping up of the pollution incurred at Ikhwezi Colliery, as
well as the invalidated assumption that proximity to Delmas Coal and Ikhwezi Colliery are constants not to be
assessed as alternatives because of “economic reasons”. Consequently, the starting point seems to be the
generation of income for a mine that is no longer viable and the low cost rehabilitation of impacts incurred by
Kuyasa Mining, instead of the independent assessment of the most sustainable methods of power generation.
The applicant does not consider any alternatives for the generation of power, nor does it take any account
(economic or otherwise) for the possibility that the discard coal (as with other coal from Delmas Coal) could
be railed to a power station outside the HPA.
The applicant’s characterisation of the prospects of natural gas use and renewable energy electricity
generation are superficial and inaccurate.123 There is active consideration of development of an import facility
for liquefied natural gas in Richards Bay with Eskom committed to the procurement of a large combine cycle
gas-fired electricity generation plant, and strong prospects for affordable supply from the extensive new finds
of northern Mozambique.124
The most recent round of renewable energy procurement has established that renewable energy technologies
are approaching cost competitiveness with new coal-fired plants, even without taking externalised costs into
account (and this is not using the Medupi plant costs as the benchmark, as these may well be exceptionally
high). Government has clearly indicated that it will increasingly internalise the externalised costs of power
supply, through measures such as a carbon tax. The applicant’s assertion that the costs of renewable
technologies remains high125 fails to justify the superficial dismissal of renewable options without proper
analysis, particularly in the face of the national and international trends of the increasing costs from coal-fired
generation and decreasing costs of renewable energy generation. The applicant refers to the limitations of
renewable energy as a “base-load electric power source”,126 yet fails to substantiate this assertion, or to
122
Guideline to Alternatives, page 13.
EIA, page 59, sections 3.1.2 and 3.1.5.
124
In accordance with analysis by Richard Worthington.
125
Above at section 3.1.5.
126
Above.
123
25
analyse the attributes of the proposed coal power station or the extent to which the proposed project may be
tailored to meet base-load electricity demand. The applicant’s reference to the scale of the proposed coal
power station as “significantly larger that the size of typical wind or solar facilities being developed globally” 127
is also disingenuous since renewable energy capacity of thousands of megawatts is already being procured in
South Africa.128
The applicant’s assertion that a choice of coal, or of CFB, serves the objective of affordability is not justified
here and is highly contentious both nationally and internationally.129 In any event, as coal-fired power stations
are particularly polluting, there can only be a resort to such means of power generation after careful
consideration of all possible alternatives in accordance with the NEM Principles. A coal power station is not
the best practicable environmental option: coal power stations do not, as is required by NEMA, provide the
most benefit or cause the least damage to the environment as a whole, at a cost acceptable to society, in the
long term and/or the short term. Renewable energy saves costs and is a much more practicable
environmental option. As set out above, environmental legislation requires investigation and evaluation of
these alternative options.130
Over and above the applicant’s erroneous assumption that the proposed coal station must be in close
proximity to Delmas Coal and Ikhwezi Colliery, when assessing the location of the appropriate site at various
locations in the surrounding area, the applicant fails to:
x
account for atmospheric pollution as a factor in the environmental assessment and to avoid heavy
reliance on mitigation measures throughout this assessment; 131
x
consider the conclusions of the environmental assessment when accounting for the feasibility of (the
favoured) site 5 (although the environmental screening of alternatives was conducted, environmental
components are not considered as “key” criteria in the assessment of the various site locations);132
x
account for the location of the power plant to the west and the ADF to the east of the Wilge River as
factors in the assessment of alternatives, despite this necessitating the construction of two bridges
over the Wilge River (one to carry the ash conveyor, clean and dirty water pipelines and other utilities
between the power plant and ADF, and the other as a road bridge for vehicle access) with associated
environmental impacts; or to
x
afford proper consideration to the description of the site as “brown field”, in light of this resulting
from the non-compliant coal discard from Delmas Coal,133 and that the soils have not been identified
as unrecoverable.
127
Above.
In accordance with analysis by Richard Worthington.
129
Above, section 3.1.6.
130
In accordance with analysis by Richard Worthington.
131
EIA, pages 64 and 65.
132
Appendix I, Site Selection Information and EIA, page 61.
133
EIA, page 78.
128
26
7.
Non-compliance of Delmas Coal and Ikhwezi Colliery
In accordance with the “polluter pays principle”, Kuyasa Mining remains responsible for pollutants at Delmas
Coal and Ikhwezi Colliery, regardless of any further development in respect of the proposed coal power
station. However, the proposed coal power station is packaged as the only viable option purely because it is a
solution to Kuyasa Mining’s previously failed rehabilitation of Ikhwezi Colliery’s Pit H and to the surplus coal
discard from Delmas Coal. Despite underpinning the motivation for the proposed coal station with these
factors, the applicant makes no attempt to provide any insight as to the historical and existing activities on the
site, how development has taken place with time and the ownership changes regarding impacts of and liability
for existing and historical rehabilitation. The omission of an “as-built” survey of Pit H, despite its intended use
as the ADF for the proposed coal station, raises further questions as to the previous owner of the Ikhwezi
Colliery and the entity primarily responsible for the non-compliance detailed below.134 In order to assess the
responsible and valid transfer of liability for these non-compliances, in accordance with the principles of public
participation and administrative justice, it is essential that all relevant documents be provided for public
scrutiny.
The non-compliances at Ikhwezi Colliery are detailed in the Environmental Risk Assessment conducted for
Ikhwezi Colliery in respect of the closure of Pit H (or “ERA”) at Appendix D to the EIA. These include that,
despite the design of Ikhwezi Colliery’s opencast mines as “zero discharge”, water control measures were
never implemented for the operational phase of Pit H.135 The ERA relays the following:
“Ikhwezi Colliery was supposed to be closed in 2002 according to the original EMPR. As it stands, the
lack of monitoring, management and rehabilitation has left it in a degraded state. If mine
rehabilitation was to be delayed further, and Pit H was to remain in its current state, much
mitigation, management and alteration of current practices would be needed immediately to
improve the state of the area. As it currently stands, Pit H poses greater financial, social, legal,
reputational, environmental and health and safety risks than if closure were to be implemented. It is
suggested that Pit H be closed and the risks associated with it be mitigated via rehabilitation or
management. Some of these risks will be mitigated in the process of undergoing mine closure via
one of the two suggested scenarios, such as filling the unsafe void.”136
It is precisely because Ikhwezi Colliery has not been closed and rehabilitated, despite the suspension of the
mining operations and parts of the mine being due for closure and rehabilitation, that a Performance
Assessment Report (“PAR”) is still required for the colliery. The PAR identifies the key non-compliance items
at Ikhwezi Colliery as:
x
x
“Rehabilitation has not yet taken place of those areas where mining has been completed, namely Pit H.
Pit G will be used as an access point when underground mining resumes in that area again;
Stockpiles are not in line with slope, size, order and elevations specified by the EMPR. However, the
manner in which it has been done, steep slopes, have reduced the footprint impact when compared to a
situation where the gentler slopes, 1:7, would have been used;
134
EIA, page 42.
Appendix D, ERA, page 28.
136
Appendix D, ERA, page 42.
135
27
x
x
x
Clean and dirty surface water management systems have not been sufficiently maintained to prevent
contamination of river diversions and to prevent clean water run-off from entering pits. This aspect
needs to be addressed as per of the KiPower IPP project.
River diversions require some maintenance as erosion has occurred. This aspect needs to be addressed
as per of the KiPower IPP project, and
Coal discard management has not been sufficient to prevent groundwater contamination. This issue is
currently being addressed.
Ikhwezi Colliery’s mining operations ceased and many of the required rehabilitation and mitigation
measures have not yet been initiated. This is the principle area of non-compliance in terms of the EMPR
commitments. However, the rehabilitation of Pit H will commence in the near future due to the planned
KiPower IPP’s ash disposal facility being constructed partially over the rehabilitated pit. Pit G cannot be
rehabilitated yet, since this pit provides access to the underground mining reserves owned by Ikhwezi
Colliery and mining is envisaged for this area.”137
The repercussions of the above non-compliances are realised by the 26 March 2013 order served on Ikhwezi
Colliery by the DMR, in terms of section 93(1)(b)(i) of the MPRDA, requiring that the colliery immediately
rectify its failure to rehabilitate the open cast areas in accordance with its EMPR, assess its environmental
liability and increase its financial provision, and submit a performance assessment report to avoid the
suspension or termination of its mining right.138
The PAR identifies numerous environmental and safety risks related to the non-compliances at Ikhwezi
Colliery’s Pit H with the financial implications quantified as running up to R100 million.139 Those environmental
risks ranked as “high” include impacts on surface water (due to surface water turbidity, insufficient
stormwater management, acid mine drainage (“AMD”) and the effects of the Wilge River diversion), substandard groundwater quality, burning of coal discard, significant erosion of haul road bridge over Wilge River
and the running of this haul road through a wetland. Most severe of the future environmental risks post
closure of Pit H, as prescribed by the Ikhwezi Colliery EMPR, is the overflow of AMD pit water into the surface
water, notwithstanding that site visits were only conducted in the driest months of June and July.140
It is clear that Kuyasa Mining is relying on the establishment of the proposed coal station in order to avoid the
liability currently arising due to its non-compliances at Ikhwezi Colliery. In fact, the establishment of the
power station is listed in the PAR as a benefit of one of the proposed remediation plans for Pit H. 141 Such an
approach detracts from the responsibility to rehabilitate the significant environmental problems arising from
Ikhwezi Colliery regardless of any further developments. Moreover, this approach clouds the analysis of the
impacts of the proposed coal power station itself: the analysis should be governed by the NEM Principles
independently of any of the side benefits the development might have on Kuyasa Mining’s circumstantial
liabilities.
137
Appendix D, PAR, pages ii to iii.
Appendix D, PAR, appendix A.
139
Appendix D, PAR, pages 12, 14 and 22 to 31.
140
Appendix D, PAR, pages 28 to 31.
141
Appendix D, PAR, page 31 to 33.
138
28
8.
Effect on water resources142
The applicant avoids a proper analysis of the water uses necessary for the proposed coal station by inferring
that this will be conducted during the IWULA as part of the final EIA reports.143 Whilst the operational aspects
of water use may fall to be covered by the later IWULA, the EIA application in the draft EIA stage, as well as
the preceding scoping reports, are required to describe all important aspects necessary to make a decision
regarding the cumulative and integrated impacts on all environmental components, including water resources.
The EIA Regulations, 2010, require that the scoping reports include a description of the environment that may
be affected and the manner of such effects,144 and “a description of environmental issues and potential
impacts, including cumulative impacts, that have been identified”.145 The EIA report is required to include “a
description of the environment that may be affected by the activity and the manner in which the physical,
biological, social, economic and cultural aspects of the environment may be affected by the proposed
activity.”146 The additional IWULA authorisation process does not detract from the applicant’s full compliance
with these requirements.
As such, it is at least necessary at this stage that baseline information of the water environment, in so far as it
will be affected by the proposed coal station, is provided at the draft EIA stage (and even at the preliminary
scoping stage) so as to ensure the proper assessment of this information as a component of the general
environment and to ensure compliance with NEM Principles, in particular that of public participation. This
baseline information should include:
x
x
x
x
a description of the applicable water uses;
a description of the type of water use authorisation applicable to such uses;
potential impacts on the water resources; and
the mitigation measures to be employed in relation to such impacts.
The applicant’s failure to provide the above information undermines its ability to comply with the NEMA
requirements (as further outlined in the EIA Regulations, 2010) to identify real alternatives to the proposed
activity and to construct an accurate picture of the need of and desirability for the proposed coal station
whilst conducting properly informed public participation procedures (see above). The provision of this
information only during the final EIA stage - if it all – fails to afford the public sufficient opportunity for
comment in any meaningful manner.
The water-related implications for the proposed coal station must be perceived holistically - if all impacts are
not described, the full effect of the proposed coal station is distorted. We note that JaW have, in an
independent process (which is now closed for public comment and falls beyond the scope of this report),
prepared and circulated a draft basic assessment report and IWULA in respect of the proposed water supply
pipelines for the proposed coal station and Delmas Coal. The omission of such crucial information from the
draft EIA reports for the proposed coal station as a whole, clearly detracts from the applicant’s ability to relay
the full effect of this development. Furthermore, the preparation of this information in a piece-meal manner
allows for the applicant to subject itself to lesser scrutiny where possible because, if the development of the
142
In accordance with analysis by Carin Bosman, Sustainable Solutions.
See for example page 11 of the EIA.
144
Regulation 28(1)(e).
145
Regulation 28(1)(g).
146
Regulation 31(2)(d).
143
29
water supply pipelines were perceived as part of the proposed coal station as a whole, it would be subjected
to the more comprehensive scoping and environmental impact assessment procedures instead of the
simplified basic assessment process.
The need for the proper communication of the water-related impacts for the proposed coal station is
exacerbated by the implications of the development in relation to water supply and quality as set out below.
8.1
Water deficit
The applicant refers to Delmas Coal as a “water deficit mine” “unlike most other coal mines”, because it uses
an excess water supply sourced from the Rand Water supply line.147 The applicant submits that the proposed
coal station is to share the Delmas Coal water supply, the Rand Water supply line that runs south of the N17
highway between Devon and Leandra, despite this adding a demand on this strained water resource of around
3 744m3/day.148 This is a significant problem in an area where demand for water already exceeds that for
supply and the sewage systems are overwhelmed.149 There is no explanation given for why, in the face of such
unsustainability and the presentation of such a non-practicable environmental solution, it is a non-negotiable
that the proposed coal station be located so close to Delmas Coal that it shares the water supply of this water
deficit area with no real alternative water supply proposed. Nor is there any explanation of the validity of the
authorisation from Rand Water to provide the proposed coal power plant with such a significant water supply
in a water deficit area, thereby depriving the public of a scarce resource.
Despite the request from the DWA that alternative water sources be investigated, 150 the applicant confirms
no such alternative sources, and only suggests that alternative sources might include the Thaba Chueu’s
SamQuarz quarry and Brakfontein 264IR, Portion 28, (Blommeland) whilst stating that the sustainable supply
of all alternative sources is still to be confirmed.
The surface water specialist study provides little real assessment of the specific volume of water supply in
relation to the intended sources. Moreover, the rainfall data provided in relation to the area is dated only up
to 1999, taking little account of the changes in precipitation over recent years.151
Similarly, the anticipation in the Draft ground water impact assessment report that the project footprint area
is to lead to a reduced flow in the important Wilge River and its associated tributaries (due to storm-water
discharge) is assessed only in terms of the impacts on aquatic species, and not the effects of water supply and
quality on downstream users.152
147
EIA, page 71.
According to page 7 of Appendix L13, the Surface water specialist study, the peak design flow associated with the water
supply to the proposed KiPower plant was estimated to be 3744 m3/day.
149
Appendix L11, page 62.
150
EIA, page 28. Although Appendix C to the EIA (“DEA Requirements”, page 256) lists DWA Correspondence this
correspondence is not included with the EIA.
151
Appendix 6 to Appendix E, Licensing information and Appendix L13, Surface water impact assessment, pages 26- 27 and 30.
152
Appendix L3, Draft ground water impact assessment report.
148
30
8.2
Water quality implications
The site selected by the applicant for the proposed coal station is one of vital hydrological import, being within
the Olifants Catchment Water Management Area and the largest sub-catchment of the Limpopo Basin (the
Wilge River sub-catchment adjacent to the site drains a relatively small area before reaching a confluence with
the Olifants River). The Wilge and Olifants Rivers are both stressed catchments, due to the extent of coal
mining and industrial development in the region and have little or no assimilative capacity for additional
pollutants. Consequently, not only do the water volumes need to be maintained to meet reserve
requirements, as well as agricultural and domestic use needs (rendering the use of further large water
volumes in this area, as addressed above, highly inappropriate), but the existence of the facilities is reliant on
the constant full functioning of mitigation measures to prevent any pollutants flowing into the river
catchments.153 In the face of Kuyasa Mining’s previous history of non-compliance, it is extremely doubtful
that the applicant will be able to maintain such fully functioning mitigation measures. Even assuming the full
operation of these compliance measures coupled with “normal” rainfall for the region, the applicant admits
that effluent releases will occur during periods of excessive rainfall. Whilst the applicant does not predict such
excessive rainfall to happen more than once every fifty years, this prediction does not account for the recent
precipitation changes in the area (including the recent declaration of areas in Mpumalanga and Gauteng as
disaster areas following heavy and sustained “unseasonal” rains attributed to climate change).
The hydrological sensitivity of the area is evidenced by the DWA’s intention to declare the Wilge River
catchment “a Class 2 river system in order to seek to protect Mpumalanga’s water resources”, meaning that
“no new impacts will be tolerated within this catchment.”154 The applicant seems to have decided to locate its
industrial facilities and to convey ash and coal across the Wilge River within this area, regardless of its
sensitivity and import.
This sensitivity is heightened because of the nature of the primary aquifer in the area, through which the bulk
of the groundwater will be stored and transported. This aquifer extends over the entire study area with a
considerable vertical thickness of 29.43m below the ground surface. The aquifer will be highly susceptible to
surface induced impacts and activities due to its intrinsic unconfined and semi-unconfined piezometric
conditions.
The applicant’s hydrological assessment procedures in this sensitive area are faulty in a number of respects
including:
x
there is a lack of site-specific information on the ground water regime of the project area, including a
lack of:
o
o
o
153
154
information on the baseline status of existing groundwater pollution;
identification and quantification of sources responsible for the current groundwater pollution;
and
information about the acid generating potential of the material currently in the iKhwezi
Colliery pits;
EIA, page 100.
EIA, page 82.
31
x
there is no geochemical modelling to compare the current and proposed future scenarios;
x
there is an absence of key supporting documents including the hydrocensus report and maps
depicting current and predicted future impacts of groundwater drawdown and water quality- both
pre- and post-mitigation;
x
as mitigation measures fail to address existing hydrological impacts, reduction of the cumulative
impact of development is not feasible;
x
whilst water quality monitoring includes the recommendation that, if significant changes occur in
water quality, the cause must be investigated and rectified immediately, there is no account for a
significant change in water quality from 2009 to 2012;155
x
the only site assessments occurred in June/July ie the driest calendar months, despite this being an
area of extreme fluctuations in annual rainfall, as evidenced by recent flooding;
x
the water quality reports make no reference to those breaches of water quality at Ikhwezi Colliery;156
x
key reports such as the Geohydrology and the Surface Water Specialist Study are in draft format,
whilst the balance of the specialist studies are finalised;
x
there is a lack of information about the “environmentally safe water level”, including technology
selected, expected volumes to be treated, the nature of the capture and transfer infrastructure, the
necessary lifespan of the system and system construction and maintenance;
x
despite mercury being in the DWA Target Water Quality Guidelines list of criteria for aquatic
ecosystems, river water and sediments were not sampled for this pollutant;
x
excess electrical conductivity, sulphate, magnesium, chloride, aluminium and fluoride levels at the
site are downplayed. (Borehole 3, the borehole close to the Wilge River (which forms the lowest part
of the surrounding area and is the key receptor for the surrounding groundwater) showed the worst
compliance results); and
x
there is no proper consideration of the finding in the specialist biodiversity assessment that
“(t)emporal comparisons indicate a clear deterioration in the water quality at all these sites,
especially during the low flow 2012 assessment. Some of these concentrations have tripled since the
initial baseline report in 2009”.157
Criticisms concerning the methodology of the groundwater assessment include the basis of this assessment on
a once-off set of sampling results conducted by a laboratory that has “voluntarily withdrawn” its SANAS
registration,158 with sampling results of boreholes drilled showing only one set of results (not the expected
155
Appendix L2, Specialist Biodiversity assessment report, page 81.
Appendix D, PAR, pages 19 to 22.
157
Appendix L2, Specialist Biodiversity assessment report, page 81.
158
www.yankalabs.co.za as accessed on 29 March 2014.
156
32
results from deep and shallow points at each borehole). Although the SANS 241:2011 Drinking Water
Standard is the current legal reference for potable consumption (and thus used to assess the compliance of
groundwater quality in order to protect human health), the groundwater results were compared with the
2006 SANAS Standard limits. Of additional concern is that only one borehole in the proposed project site area
was sampled for water quality, apparently because this was the only “accessible” borehole.159
9.
Waste Implications160
The waste which will emanate from the proposed coal power station has severe implications unless properly
managed and maintained. The applicant proposes to dispose of the ash produced by the proposed coal power
station, and simultaneously to rehabilitate Ikhwezi Colliery’s Pit H and deal with the related non-compliances,
by implementing the ADF. The quantity of bed and fly ash to be supressed within the ADF is considerable: the
applicant estimates the ash generation to be 199 tons/hour or 5 000 tons/day. 161 The envisaged waste
disposal is potentially of significant environmental impact, including the effects of hazardous waste streams
(involving boiler ash and waste water), ash radioactivity and contaminated land.
Notwithstanding the above, the applicant’s integrated waste licence application report is characterised by
uncertainty and (the correlative) risk.162 The applicant provides insufficient information to determine whether
the rehabilitation of Ikhwezi Colliery’s Pit H by the installation of the ADF is the most sustainable and best
practicable environmental solution, instead of the previously proposed (and not followed) rehabilitation of the
pit.
The applicant provides no detailed rehabilitation plan including essential details including the adequacy of
long term water management measures at the ADF, the sustainability of these measures and whether
sufficient costs have been allocated for the rehabilitation fund.
The applicant fails to provide further fundamental information including:
x
geochemical modelling for the evaluation of the impact of the water treatment wastes disposed of with
the fly and bottom ash for the proposed coal power station;
x
a geohydrological impact assessment based on the outputs from the geochemical model for a Class C
liner;
x
the assessment of the geochemical load or concentration output for the incorporation of a clay liner
into a groundwater model;
x
the quantification and impact evaluation of the risk of ash below groundwater as result of settlement in
the ADF;
159
Appendix L3, Draft ground water impact assessment report, page 35.
In accordance with analysis by Carin Bosman, Sustainable Solutions.
161
Appendix G, page 12.
162
Appendix G, Integrated waste licence application report in fulfilment of the requirements of the National Environmental
Management: Waste Act.
160
33
x
sufficient information for the proper evaluation of the risk associated with the settlement of materials
in the ADF and liner damage;
x
a materials balance for the rehabilitation of Pit H which, together with a lack of baseline information in
respect of the pit shape, means the availability of materials to perform the pit backfill above the
expected groundwater level cannot be assessed;
x
a model of the impact of a clay liner being the only barrier beneath the lower ash layer;
x
the cost and design of the dewatering system;
x
an Integrated Waste Management Plan (“IWMP”) for construction (apparently still to be developed by
the engineering, procurement and construction contractor);163 and
x
an IWMP for the operating phase (apparently to be developed by the applicant).164
The following extract from the integrated waste licence application report exemplifies the severity of the
applicant’s uncertainty regarding key infrastructural aspects of the ADF:
“Water accumulating in Pit H, below the clay layer, will be removed in order to ensure that the poor
quality in-pit water does not decant to the Wilge River at any time. This water will be extracted by a
dewatering system to be designed once Pit H has been backfilled and the settlement issues are
resolved. The pit water will be pumped to the power plant for treatment in the waste water
treatment plant.”165
10. Air quality impact
In accordance with section 4 above, the applicant cannot rely on the proposed coal station being a new source
outside the “hot spot” areas of the HPA. The effects of the air quality impacts of the proposed coal station are
relevant, not only in terms of point source emissions, but also in so far as the cumulative nature of the air
quality in the HPA is impacted. As addressed at 4 above, the cumulative air quality is particularly pertinent, in
so far as the applicant is concerned, because many of the ambient air quality excesses in the area are due to
the operations of Delmas Coal. However, even in so far as point source emissions are concerned, the
proposed coal power station is significantly problematic.
10.1 Point source emissions
The applicant fails to acknowledge the marked dependence of CFB technology on the manner in which the
proposed coal power station is operated. The emissions will be affected by:
x
the ratio and quality of the coal and lime used;
x
the operating temperatures (the lower the operating temperatures, the lower the NOx emissions);
163
Appendix G, page 38, section 5.1.
Above.
165
Appendix G, page 25, section 3.6.2.
164
34
x
the amount, size and velocity of particulates (higher bed velocities will lead to finer particulates); and
x
the operation of the fabric filters over time (the fabric filters are only effective once there is a particle
layer trapped on the surface – clean filters may lead to high particulate emissions).166
The applicant’s failure to investigate the impact of such procedures, combined with the applicant’s admissions
of inexperience in areas relating to the proposed coal power station and the past non-compliances of Kuyasa
Mining’s Ikwhezi Colliery and Delmas Coal,167 hardly inspire confidence in the applicant’s ability to ensure the
proper operations of the CFB technology upon which it justifies much of the ability of the development to
control pollutants.
Despite the applicant’s emphasis of the point-source pollutant control abilities of the CFB technology and the
proposed ADF, it does admit certain point-source impacts of the proposed coal station on the atmosphere
such as carbon dioxide and dust impact, as well as the potential for nitrogen dioxide releases.168 However, the
applicant fails to realise and address the nature of these effects.
The applicant submits that, in lieu of NOx control, there is a potential for nitrogen dioxide releases,169 and that
“measured exceedances of the 1-hour NO2 standard occur”.170 However, there is no exploration of the global
warming potential of one kilogram of nitrogen dioxide as 298 times the same weight of carbon dioxide and
that nitrogen dioxide persists in the environment for over 100 years. It is therefore vital that nitrogen dioxide
emissions be calculated and assessed as part of climate change discussion.
The specialist biodiversity assessment quotes two conflicting sulphur dioxide emission rates: 400mg/Nm3 171
and 500mg/Nm3. 172 Moreover, the mitigation measure provided for sulphur dioxide emissions are
unsatisfactory, one being merely that the proposed coal station must comply with South Africa’s standards for
sulphur dioxide emissions of 500mg/Nm3.173 The specialist biodiversity assessment makes no mention of
dioxins, mercury and other persistent organic pollutants which can enter the food chain and affect faunal
health.174
10.2 Impact on climate change175
The only link the applicant draws between the carbon dioxide impact and the link to climate change is the subheading at page 156 of the EIA. The draft EIA reports fail to relay the high carbon footprint of the plant. In
fact, there is no mention of the carbon dioxide impact in the air quality impact assessment specialist report, 176
nor does the specialist biodiversity assessment provide any analysis of the impacts from existing, historical
166
In accordance with analysis by Suresh Ramsuroop, Department of Chemical Engineering, Durban University of Technology.
As at sections 2 and 7 above.
168
EIA, pages 157 and 158.
169
EIA, Page 90, section 4.7.3.
170
Appendix L1, Air quality impact assessment report, page 40.
171
Appendix L2, page 154.
172
Appendi L2, page 156.
173
Appendix L2, specialist biodiversity assessment, page 156.
174
In accordance with analysis by Judy Bell, environmental consultant.
175
In accordance with analysis by Richard Worthington.
176
Appendix L1 to the EIA.
167
35
and proposed developments in the area in terms of ecosystem functionality and reduction in the goods and
services the surrounding ecosystems supply to people living in the area and downstream.177 The EIA merely
reports that “no mitigation is possible”, for what is apparently 4.2 million tonnes of carbon dioxide expected
from the proposed coal station. A detailed study is required to compute the carbon footprint and to show how
this may be reduced. The typical emission factor for carbon dioxide is 0.99 kilograms of carbon dioxide per
kWhr of energy generated.
National greenhouse gas emissions continue to increase across the economy, thus any addition to national
emissions from coal-fired power plants is incompatible with the commitment to reduce emissions from a
business-as-usual trajectory by 34% by 2020 and 42% by 2025 in accordance with South Africa’s international
commitments. The imperative for the decrease in greenhouse gas emissions is exacerbated by the previouslyapproved construction and commissioning of Eskom’s Kusile and Medupi power plants, as well as Eskom’s
failure to achieve any notable reduction in its coal dependency since its pledge at the 2002 World Summit on
Sustainable Development to reduce coal dependency of its electricity supply by ten percent in ten years.
South Africa’s greenhouse gas emissions will increase quite dramatically as the Medupi and Kusile power
plants are brought into production into the next decade, while South Africa’s international commitment entail
the plateau of greenhouse gas emissions by 2025. There is no possible interpretation of this commitment that
would allow for a net increase in coal-fired power plant post Medupi, and any new coal-fired power plant
would need to be conditional upon retirement of an existing coal-fired plant. This could have a range of cobenefits, as some plants within the existing fleet have lower efficiency and significantly higher rates of all
emissions than modern plants. The necessity to control any further increase is realised by our clients’ ballpark
calculations which illustrate that the proposed coal power station is likely to increase South Africa’s greenhouse gas emissions by at least 1% if generating 600 MW power, and by 3% if the development increases to
generate the proposed 2 000 MW power.
The electricity supply industry is by far the largest contributor to South Africa’s greenhouse gas emissions,
contributing approximately 45% of national emissions. It is also a source of emissions that is more amenable
to mitigation and specifically to a reduction in the rate of emissions, or carbon intensity, than most other
sectors or sources, such that growth in electricity supply is perfectly feasible and affordable with a
simultaneous reduction in absolute emissions of the sector. This will, however, only be possible if new
electricity generation is derived from resources other than coal and if coal-fired electricity generation is
accompanied by mechanisms similar to those proposed in CCS (taking into account the criticisms concerning
the CCS procedure).
10.3 Incomplete information
We further note that potentially essential documents are missing from the air quality assessment, for example
the applicant fails to provide the “project plot plan” referred to at Appendix E of the Air quality impact
assessment report.178 This impacts negatively on our clients’ ability to comment on the draft reports.
177
178
Appendix L2 to the EIA.
Appendix L1, page 32, figure 3.
36
11. Health Impacts179
Air pollution emissions from thermal power plants contribute, inter alia, to ambient particulate matter, the
most important environmental health risk globally, as well as to emissions of mercury, a potent neurotoxin
that harms the mental development of children. A new coal-fired power plant locks in significant air pollutant
emissions for decades. However, the draft EIA reports for the proposed coal station do not include a health
impact report and omit any mention of an assessment of the human health impacts of the air pollutant
emissions.
Based on the Baker-Foley regression model,180 air pollution emissions from the proposed coal power station
are projected to cause approximately 30 premature deaths for every year of operation due to exposure to fine
particulate matter (PM2.5), thereby resulting in 1,200 deaths over a 40-year plant lifetime. This includes
approximately 100 deaths of young children. Most of these health effects are likely to occur in the
Johannesburg area.
The economic cost associated with the premature deaths, and the neurotoxic effects of mercury exposure, is
estimated at R 390 million per year, with a confidence interval of R 55 to R 1 700 million. The discounted
cumulative cost over a 40-year lifetime would be R 12 000 million rand. This cost is based on the estimated
willingness of the affected people, given their income levels, to pay to avoid the increased risk of death. It is
precisely because individual people do not have the choice of spending money to significantly reduce toxic
power plant emission that decision-makers must mandate less polluting power generation technologies than
those that are coal based (regardless of currently available techniques).181
Invariably, in health impact assessment studies, the uncertainties associated with such estimates are
significant. Regardless of these uncertainties, these results clearly indicate that the potential health impacts
and economic burden associated with the proposed coal power station would be substantial in relation to the
economic value created, as well as in relation to the costs of alternative non coal-based technologies with
significantly lower public health impacts. Consequently, the assessment of health impacts is a crucial
component in the assessment of the implications of the project and cannot merely be omitted from the EIA
process.
12. Conclusion
The above submissions are intended to highlight the primary concerns of our clients and are by no means a
comprehensive summary of the issues relating to the applicant’s draft EIA reports. Our clients have significant
concerns for the surrounding environment and human health, due to the location of the proposed coal power
station within the undeniably sensitive HPA in an area characterised by water deficiency and sensitive water
catchments. Underlying these concerns is that, whilst the applicant is proposing to undertake an operation of
potentially severe environment impact (even if the appropriate mitigation measures are undertaken in a fail179
In accordance with analysis by Lauri Myllyvirta , coal and air pollution specialist, Greenpeace International.
The Baker & Foley (2011) model is based on CAMx modeling of stack emissions of large U.S. air pollution emission sources,
and developed by U.S. Environmental Protection Agency staff. This is a more conservative model than that adopted by Zhou et
al (2006) based on CALPUFF modeling of power plants in China.
181
Using the value of life based on studies in OECD countries for cost-benefit analysis, without adjusting for lower income in
South Africa, would result in a several times higher estimate. Furthermore, the cost evaluation is conservative in that it does not
account for health impacts from particulate matter other than deaths.
180
37
safe manner), the applicant (or its holding company) has a history of significant environmental noncompliances in the area and has failed to prove any ability to uphold the requisite environmental protective
mechanisms.
The applicant is unable to conceal that the proposed coal power station has been envisaged as a means of
mitigating the significant environmental liabilities encumbering Ikhwezi Colliery. However, it is submitted that,
in opportunistically reaching for such a “get-out-of-jail-free” card, the applicant has failed to ensure that its
“solution” complies with the NEM Principles of sustainability and the best practicable environmental option.
Instead, the applicant, by ignoring iKhwezi Colliery’s invariable liabilities in accordance with the “polluter pays
principle”, has attempted to offset the potentially significant environmental repercussions of the proposed
coal power station with the argument that it should mitigate the current environmental consequences of
Ikhwezi Colliery.
Our clients do not accept the backward-looking manner in which the proposed coal power station has been
conceived, particularly in light of the potentially disastrous environmental consequences of this proposed
development and the applicant’s history of legal non-compliance. As such, our client fails to comprehend any
justification for the valid authorisation of the proposed coal power station, and it submitted that it should not
go ahead. In the circumstances, our clients submit that all relevant authorities should reject the reports
and/or refuse the relevant applications.
Should you require more information regarding any aspect of these submissions, please let us know.
Yours faithfully
CENTRE FOR ENVIRONMENTAL RIGHTS
per:
Robyn Hugo
Attorney
Direct email: [email protected]
38
Proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal
fired power plant and associated
infrastructure for KiPower near Delmas
DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.:
17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Reply sheet to receive a copy of the Draft Environmental Impact
Assessment Report (DEIR), Draft Environmental Management
Programme, Draft Waste Licence Application Report and the Draft
Atmospheric Emissions Licence Application Report and to attend
an open house and stakeholder meeting
EIA Public Participation Office
Anelle Lötter/ Sibongile Bambisa
Jones and Wagener Consulting Civil
Engineers (Pty) Ltd
P O Box 1434, Rivonia, 2128
Tel: (012) 667 4860
Fax: (012) 667 6128
Email: [email protected] or
[email protected]
Please complete by 14 February 2014 and return to the Public Participation office (as above)
Mr
Jeremy
TITLE
FIRST NAME
JP
Kirsch
INITIALS
ORGANISATION
SURNAME
Clyde Bergemann
Africa (Pty) Ltd
[email protected]
EMAIL
PO Box 374, Kya Sands, Randburg,
POSTAL
ADDRESS
TEL NO
POSTAL
CODE
FAX NO
011 704 0580
2163
086 734 0134
REGISTRATION TO RECEIVE THE DRAFT REPORTS AND TO ATTEND AN OPEN HOUSE/ STAKEHOLDER MEETING
DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT
I would like to receive a CD copy of the Draft Environmental Impact Assessment Report (DEIR)
YES
NO
DRAFT WASTE MANAGEMENT LICENCE APPLICATION REPORT
I would like to receive a CD copy of the Draft Waste Management Licence Application Report
YES
NO
DRAFT ATMOSPHERIC EMISSIONS LICENCE REPORT
I would like to receive a CD copy of the Draft Atmospheric Emissions Licence Report
YES
NO
OPEN HOUSE/ STAKEHOLDER MEETING
I would like to attend an open house / stakeholder meeting (please circle the appropriate block).
I will attend the open house / stakeholder meeting on Wednesday, 26 February 2014, at the
Delmas Agricultural Hall / Lapa (Open house is from 10:00 to 17:00 – formal meeting starts at
18:00 to 20:00)
YES
NO
COMMENTS (please use separate sheets if you wish)
Any comments you may have at this stage:
……………n/a……………………………………………………………………………………………………………………………..
………………………………………………………………………………………………………………………………………………
Please ask the following of my colleagues/friends/neighbours to register for this project:
…n/a……………………………………………………………………………………………………………………………………….
………………………………………………………………………………………………………………………………………………
THANK YOU FOR YOUR CONTRIBUTION
Proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal
fired power plant and associated
infrastructure for KiPower near Delmas
EIA Public Participation Office
ŶĞůůĞ>ƂƚƚĞƌͬ^ŝďŽŶŐŝůĞĂŵďŝƐĂ
:ŽŶĞƐΘtĂŐĞŶĞƌŶŐŝŶĞĞƌŝŶŐΘ
ŶǀŝƌŽŶŵĞŶƚĂůŽŶƐƵůƚĂŶƚƐ;WƚLJͿ>ƚĚ
WKŽdžϭϰϯϰ͕ZŝǀŽŶŝĂ͕ϮϭϮϴ
dĞů͗;ϬϭϮͿϲϲϳϰϴϲϬ
&Ădž͗;ϬϭϮͿϲϲϳϲϭϮϴ
ŵĂŝů͗ĂŶĞůůĞΛũĂǁƐ͘ĐŽ͘njĂŽƌ
ƐŝďŽŶŐŝůĞΛũĂǁƐ͘ĐŽ͘njĂ
DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.:
17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Reply sheet to receive a copy of the Draft Environmental Impact
Assessment Report (DEIR), Draft Environmental Management
Programme, Draft Waste Licence Application Report and the Draft
Atmospheric Emissions Licence Application Report and to attend
an open house and stakeholder meeting Please complete by 14 February 2014 and return to the Public Participation office (as above)
Luc and Luanne
TITLE
FIRST NAME
Mr & Mrs
Smalle
INITIALS
ORGANISATION
SURNAME
Private
EMAIL
P O Box 862, Delmas
POSTAL
ADDRESS
TEL NO
[email protected]
POSTAL
CODE
0825675166
FAX NO
2210
0866587389
REGISTRATION TO RECEIVE THE DRAFT REPORTS AND TO ATTEND AN OPEN HOUSE/ STAKEHOLDER MEETING
DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT
I would like to receive a CD copy of the Draft Environmental Impact Assessment Report (DEIR)
YES
NO X
DRAFT WASTE MANAGEMENT LICENCE APPLICATION REPORT
I would like to receive a CD copy of the Draft Waste Management Licence Application Report
YES
NO X
DRAFT ATMOSPHERIC EMISSIONS LICENCE REPORT
I would like to receive a CD copy of the Draft Atmospheric Emissions Licence Report
YES
NO X
OPEN HOUSE/ STAKEHOLDER MEETING
I would like to attend an open house / stakeholder meeting (please circle the appropriate block).
I will attend the open house / stakeholder meeting on Wednesday, 26 February 2014, at the
Delmas Agricultural Hall / Lapa (Open house is from 10:00 to 17:00 – formal meeting starts at
18:00 to 20:00)
YES X
NO
COMMENTS (please use separate sheets if you wish)
Any comments you may have at this stage:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
Please ask the following of my colleagues/friends/neighbours to register for this project:
Dianne Bath – DA Councillor e-mail [email protected]
………………………………………………………………………………………………………………………………………………
Ria van der Hoff – webmaster for the Delmas mall website
………………………………………………………………………………………………………………………………………………
THANK YOU FOR YOUR CONTRIBUTION
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<ŝŶĚZĞŐĂƌĚƐ͕
Anelle Lotter and Sibongile Bambisa
for Jones & Wagener
ª +27 76 750 9030
+27 12 667 4860
+27 12 667 6128
e-mail [email protected]
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ƚŚĞĚƌĂĨƚĚŽĐƵŵĞŶƚƐĨŽƌƚŚĞƉƌŽƉŽƐĞĚ<ŝWŽǁĞƌƉƌŽũĞĐƚ;ƐĞĞŵŽƌĞĚĞƚĂŝůƐĂďŽƵƚƚŚĞƉƌŽũĞĐƚďĞůŽǁĂŶĚĂƚƚĂĐŚĞĚͿ͘
dŚĞƌĞƋƵĞƐƚĨŽƌĞdžƚĞŶƐŝŽŶǁĂƐĐŽŶƐŝĚĞƌĞĚĂŶĚƚŚŝƐŶŽƚŝĨŝĐĂƚŝŽŶƐĞƌǀĞƐƚŽŝŶĨŽƌŵLJŽƵƚŚĂƚƚŚĞƉƵďůŝĐƌĞǀŝĞǁƉĞƌŝŽĚĨŽƌƚŚĞ
ĚƌĂĨƚĚŽĐƵŵĞŶƚƐŚĂƐďĞĞŶĞdžƚĞŶĚĞĚƚŽ&ƌŝĚĂLJ͕ϰƉƌŝůϮϬϭϰ͘
ƐĂƌĞŐŝƐƚĞƌĞĚ/ΘWLJŽƵŚĂǀĞƚŝŵĞƚŽĐŽŵŵĞŶƚŽŶƚŚĞĚƌĂĨƚĚŽĐƵŵĞŶƚƐƵŶƚŝůϰƉƌŝůϮϬϭϰʹƚŚĞƉƵďůŝĐƌĞǀŝĞǁƉĞƌŝŽĚ
ŚĂƐďĞĞŶĞdžƚĞŶĚĞĚǁŝƚŚĂŶĂĚĚŝƚŝŽŶĂůϭϮĚĂLJƐ͘
^ŚŽƵůĚLJŽƵŚĂǀĞĂŶLJƋƵĞƐƚŝŽŶƐ͕ƉůĞĂƐĞĚŽŶŽƚŚĞƐŝƚĂƚĞƚŽĐŽŶƚĂĐƚƵƐ͘
<ŝŶĚZĞŐĂƌĚƐ͕
Anelle Lotter and Sibongile Bambisa
for Jones & Wagener
ª +27 76 750 9030
+27 12 667 4860
+27 12 667 6128
e-mail [email protected]
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ĞĂƌ^ƚĂŬĞŚŽůĚĞƌƐ
dŚŝƐĞŵĂŝůƐĞƌǀĞƐƚŽŝŶĨŽƌŵLJŽƵƚŚĂƚƚŚĞƌĂĨƚƌĞƉŽƌƚƐĨŽƌ<ŝWŽǁĞƌ͛ƐƉƌŽƉŽƐĞĚĐŽŶƐƚƌƵĐƚŝŽŶŽĨĂϲϬϬDĞŐĂǁĂƚƚ;DtͿ
/ŶĚĞƉĞŶĚĞŶƚWŽǁĞƌWƌŽĚƵĐĞƌ;/WWͿĐŽĂůĨŝƌĞĚƉŽǁĞƌƉůĂŶƚǁŝůůďĞĂǀĂŝůĂďůĞĨŽƌƉƵďůŝĐƌĞǀŝĞǁĨƌŽŵϳ&ĞďƌƵĂƌLJƚŽϭϴ
DĂƌĐŚϮϬϭϰ͘dŚĞĚƌĂĨƚƌĞƉŽƌƚƐǁŝůůďĞĂǀĂŝůĂďůĞŽŶƚŚĞ:ΘtǁĞďƐŝƚĞ;ǁǁǁ͘ũĂǁƐ͘ĐŽ͘njĂͿĂŶĚĂƚƚŚĞƉƵďůŝĐƉůĂĐĞƐůŝƐƚĞĚ
ďĞůŽǁĂƐĨƌŽŵϳ&ĞďƌƵĂƌLJϮϬϭϰ͗
ŽŶƚĂĐƚ
DƐEWŽƚŐŝĞƚĞƌ
DƐEĞůŝĂEŝĞŶĂďĞƌ
DƐ>LJĚŝĂDĞŚůĂƉĞ
ZĞĐĞƉƚŝŽŶ
>ŽĐĂƚŝŽŶ
>ĞĂŶĚƌĂWƵďůŝĐ>ŝďƌĂƌLJ
ĞǀŽŶWƵďůŝĐ>ŝďƌĂƌLJ
ĞůŵĂƐWƵďůŝĐ>ŝďƌĂƌLJ
ĞůŵĂƐŽĂů
ŽŶƚĂĐƚdĞů
Ϭϭϳϲϴϯϭϭϰϴ
ϬϭϳϲϴϴϬϬϮϴ
Ϭϭϯϲϲϱϭϴϯϭ
ϬϭϯϲϲϱϳϬϬϬ
zŽƵĂƌĞĂůƐŽǁĞůĐŽŵĞƚŽĐŽŶƚĂĐƚŽƵƌŽĨĨŝĐĞƐŚŽƵůĚLJŽƵǁŝƐŚƚŽŽďƚĂŝŶĂĐŽƉLJŽĨƚŚĞƌĞƉŽƌƚƐ͘
dŚĞĨŽůůŽǁŝŶŐƌĞƉŽƌƚƐǁŝůůďĞĂǀĂŝůĂďůĞĨŽƌLJŽƵƌƌĞǀŝĞǁĂƐĨƌŽŵϳ&ĞďƌƵĂƌLJϮϬϭϰ͗
• ƌĂĨƚŶǀŝƌŽŶŵĞŶƚĂů/ŵƉĂĐƚƐƐĞƐƐŵĞŶƚ;/ͿZĞƉŽƌƚ͖
• ƌĂĨƚŶǀŝƌŽŶŵĞŶƚĂůDĂŶĂŐĞŵĞŶƚWƌŽŐƌĂŵŵĞ;DWƌͿ͖
• ƌĂĨƚtĂƐƚĞDĂŶĂŐĞŵĞŶƚ>ŝĐĞŶĐĞƉƉůŝĐĂƚŝŽŶ;tD>ͿZĞƉŽƌƚ͖ĂŶĚ
• ƌĂĨƚƚŵŽƐƉŚĞƌŝĐŵŝƐƐŝŽŶƐ>ŝĐĞŶĐĞ;>ͿƉƉůŝĐĂƚŝŽŶ͘
/ŶǀŝƚĂƚŝŽŶƚŽĂŶŽƉĞŶŚŽƵƐĞĂŶĚĂƐƚĂŬĞŚŽůĚĞƌŵĞĞƚŝŶŐ
tĞǁŽƵůĚůŝŬĞƚŽŝŶǀŝƚĞLJŽƵƚŽĂŶŽƉĞŶŚŽƵƐĞĂŶĚƐƚĂŬĞŚŽůĚĞƌŵĞĞƚŝŶŐǁŚŝĐŚǁŝůůďĞŚĞůĚŽŶϮϲ&ĞďƌƵĂƌLJϮϬϭϰ͘dŚĞ
ƉƵƌƉŽƐĞŽĨƚŚŝƐŵĞĞƚŝŶŐŝƐƚŽƉƌĞƐĞŶƚĂŶĚĚŝƐĐƵƐƐƚŚĞĐŽŶƚĞŶƚƐŽĨƚŚĞĚƌĂĨƚƌĞƉŽƌƚƐĂŶĚƚŽƉƌŽǀŝĚĞLJŽƵǁŝƚŚĂŶ
ŽƉƉŽƌƚƵŶŝƚLJƚŽƌĂŝƐĞĂŶLJĐŽŶĐĞƌŶƐLJŽƵŵĂLJŚĂǀĞƌĞŐĂƌĚŝŶŐƚŚĞƉƌŽƉŽƐĞĚƉƌŽũĞĐƚ͘
dŚĞŵĞĞƚŝŶŐĚĞƚĂŝůƐĂƌĞĂƐĨŽůůŽǁƐ͗
ĂƚĞ͗Ϯϲ&ĞďƌƵĂƌLJϮϬϭϰ
sĞŶƵĞ͗ĞůŵĂƐŐƌŝĐƵůƚƵƌĂů>ĂƉĂʹƉůĞĂƐĞĐŽŶƚĂĐƚƵƐƐŚŽƵůĚLJŽƵŶĞĞĚĚŝƌĞĐƚŝŽŶƐƚŽƚŚĞǀĞŶƵĞ
dŝŵĞͲŽƉĞŶŚŽƵƐĞŵĞĞƚŝŶŐ͗ϭϬ,ϬϬͲϭϳ,ϬϬ
dŝŵĞͲƐƚĂŬĞŚŽůĚĞƌŵĞĞƚŝŶŐ͗ϭϴ,ϬϬʹϮϬ,ϬϬ
&ŽƌŵŽƌĞŝŶĨŽƌŵĂƚŝŽŶ͕ƉůĞĂƐĞƌĞĨĞƌƚŽƚŚĞĂƚƚĂĐŚĞĚĚŽĐƵŵĞŶƚ͘
<ŝŶĚůLJĐŽŶĨŝƌŵLJŽƵƌĂƚƚĞŶĚĂŶĐĞďLJĐŽŵƉůĞƚŝŶŐƚŚĞĂƚƚĂĐŚĞĚƌĞƉůLJƐŚĞĞƚĂŶĚƌĞƚƵƌŶŝŶŐŝƚƚŽŶĞůůĞ>ƂƚƚĞƌͬ^ŝďŽŶŐŝůĞ
ĂŵďŝƐĂďĞĨŽƌĞϭϰ&ĞďƌƵĂƌLJϮϬϭϰ
^ŚŽƵůĚLJŽƵŚĂǀĞĂŶLJƋƵĞƌŝĞƐ͕ƉůĞĂƐĞĨĞĞůĨƌĞĞƚŽĐŽŶƚĂĐƚƵƐ͘
<ŝŶĚZĞŐĂƌĚƐ͕
Anelle Lotter and Sibongile Bambisa
for Jones & Wagener
ª +27 76 750 9030
+27 12 667 4860
+27 12 667 6128
e-mail [email protected]
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DƐĂŵďŝƐĂ
dZŝƐƌĞƐƉŽŶƐŝďůĞĨŽƌƚŚĞŵĂŶĂŐĞŵĞŶƚĂŶĚŽƉĞƌĂƚŝŽŶŽĨƚŚĞEϰdŽůůZŽĂĚĂŶĚƚŚƵƐǁĞĂƌĞŝŶƚĞƌĞƐƚĞĚŝŶŝƐƐƵĞƐ
;ŝŶĐůƵĚŝŶŐƉƌŽƉŽƐĞĚĚĞǀĞůŽƉŵĞŶƚƐͿĂƌŽƵŶĚŽƌĂĨĨĞĐƚŝŶŐƚŚĞEϰƌŽĂĚ͘
/ĂŵƚŚƵƐƌĞƐƉŽŶĚŝŶŐƚŽLJŽƵƌĞŵĂŝůƌĞŐĂƌĚŝŶŐƚŚĞ<ŝͲWŽǁĞƌƉƌŽƉŽƐĞĚƉŽǁĞƌƐƚĂƚŝŽŶĂƌŽƵŶĚĞůŵĂƐ͘ĂƐĞĚŽŶǁŚĂƚ/
ŚĂǀĞƌĞĂĚƐŽĨĂƌ͕ŝƚĚŽĞƐŶŽƚƐĞĞŵůŝŬĞƚŚĞƉƌŽƉŽƐĞĚĞǀĞůŽƉŵĞŶƚǁŝůůŚĂǀĞĂŶLJĞĨĨĞĐƚŽŶƚŚĞEϰŽƚŚĞƌƚŚĂŶƚŚĞĐĂƐƵĂů
ůŽĂĚƚŚĂƚǁŝůůďĞĐŽŵŝŶŐĨŽƌĚĞůŝǀĞƌLJ͘dZŝƐŚŽǁĞǀĞƌĐŽŶĐĞƌŶĞĚĂďŽƵƚĐŽŶƚŝŶƵŽƵƐĐŽĂůƐƵƉƉůLJĨŽƌƚŚĞƉŽǁĞƌƐƚĂƚŝŽŶ͘
dŚĞŝŶĨŽƌŵĂƚŝŽŶƐƵƉƉůŝĞĚĚŽĞƐŶŽƚƐŚŽǁŵƵĐŚĚĞƚĂŝůƐĂďŽƵƚƚŚĞĐŽĂůƐƵƉƉůLJƌŽƵƚĞƐ͕ĞdžĐĞƉƚƚŚĞĚĞĨŝŶŝƚĞƵƐĞŽĨƚŚĞZϱϬ͘
^ŚŽƵůĚƚŚĞƐƵƉƉůLJŽĨĐŽĂůĐŽŵĞĨƌŽŵƚŚĞŵŝŶĞƐƐŽƵƌĐĞƐƐƵĐŚƚŚĂƚƚŚĞEϰƌŽĂĚǁŝůůďĞƵƚŝůŝƐĞĚ͕dZǁŝůůďĞŝŶƚĞƌĞƐƚĞĚ
ĂŶĚƚŚƵƐƌĞƋƵĞƐƚƚŽďĞƌĞŐŝƐƚĞƌĞĚĂƐĂŶ/ΘW͘
DĂLJLJŽƵƉůĞĂƐĞĐŽŶĨŝƌŵƚŚĞĐŽĂůƐƵƉƉůLJƌŽƵƚĞƐƉƌŽƉŽƐĞĚĨŽƌƚŚĞƉƌŽƉŽƐĞĚƉŽǁĞƌƐƚĂƚŝŽŶ͘
dŚĂŶŬLJŽƵ
Reggy Nkosi
Environmental Coordinator
Trans African Concessions (Pty) Limited
«+2713 755 3316 (switchboard)
ª+2776 911 5520 (cell)
¬+2713 752 6934 (fax)
"[email protected]
à www.tracn4.co.za
&ƌŽŵ͗ĂƌůĂĂǀŝƐ
^ĞŶƚ͗Ϯϯ:ĂŶƵĂƌLJϮϬϭϰϭϭ͗ϯϰD
dŽ͗ZĞŐŐLJEŬŽƐŝ
^ƵďũĞĐƚ͗&t͗ƌĂĨƚZĞƉŽƌƚƐĂǀĂŝůĂďůĞĨŽƌ<ŝͲWŽǁĞƌ/
dŚŝƐƐĞĞŵƐƚŽďĞŶĞĂƌĞůŵĂƐ
/ĚŽŶ͛ƚƚŚŝŶŬǁĞĂƌĞĚŝƌĞĐƚůLJĂĨĨĞĐƚĞĚ͘
Carla Davis
Traffic Engineer
Trans African Concessions (Pty) Limited
«+2713 755 3316 (switchboard)
ª+2782 887 4941 (cell)
¬+2713 752 6934 (fax)
"[email protected]
à www.tracn4.co.za
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dŚŝƐĞŵĂŝůƐĞƌǀĞƐƚŽŝŶĨŽƌŵLJŽƵƚŚĂƚƚŚĞƌĂĨƚƌĞƉŽƌƚƐĨŽƌ<ŝWŽǁĞƌ͛ƐƉƌŽƉŽƐĞĚĐŽŶƐƚƌƵĐƚŝŽŶŽĨĂϲϬϬDĞŐĂǁĂƚƚ;DtͿ
/ŶĚĞƉĞŶĚĞŶƚWŽǁĞƌWƌŽĚƵĐĞƌ;/WWͿĐŽĂůĨŝƌĞĚƉŽǁĞƌƉůĂŶƚǁŝůůďĞĂǀĂŝůĂďůĞĨŽƌƉƵďůŝĐƌĞǀŝĞǁĨƌŽŵϳ&ĞďƌƵĂƌLJƚŽϭϴ
DĂƌĐŚϮϬϭϰ͘dŚĞĚƌĂĨƚƌĞƉŽƌƚƐǁŝůůďĞĂǀĂŝůĂďůĞŽŶƚŚĞ:ΘtǁĞďƐŝƚĞ;ǁǁǁ͘ũĂǁƐ͘ĐŽ͘njĂͿĂŶĚĂƚƚŚĞƉƵďůŝĐƉůĂĐĞƐůŝƐƚĞĚ
ďĞůŽǁĂƐĨƌŽŵϳ&ĞďƌƵĂƌLJϮϬϭϰ͗
ŽŶƚĂĐƚ
>ŽĐĂƚŝŽŶ
ŽŶƚĂĐƚdĞů
DƐEWŽƚŐŝĞƚĞƌ
>ĞĂŶĚƌĂWƵďůŝĐ>ŝďƌĂƌLJ
Ϭϭϳϲϴϯϭϭϰϴ
DƐEĞůŝĂEŝĞŶĂďĞƌ
ĞǀŽŶWƵďůŝĐ>ŝďƌĂƌLJ
ϬϭϳϲϴϴϬϬϮϴ
DƐ>LJĚŝĂDĞŚůĂƉĞ
ĞůŵĂƐWƵďůŝĐ>ŝďƌĂƌLJ
Ϭϭϯϲϲϱϭϴϯϭ
ZĞĐĞƉƚŝŽŶ
ĞůŵĂƐŽĂů
ϬϭϯϲϲϱϳϬϬϬ
zŽƵĂƌĞĂůƐŽǁĞůĐŽŵĞƚŽĐŽŶƚĂĐƚŽƵƌŽĨĨŝĐĞƐŚŽƵůĚLJŽƵǁŝƐŚƚŽŽďƚĂŝŶĂĐŽƉLJŽĨƚŚĞƌĞƉŽƌƚƐ͘
dŚĞĨŽůůŽǁŝŶŐƌĞƉŽƌƚƐǁŝůůďĞĂǀĂŝůĂďůĞĨŽƌLJŽƵƌƌĞǀŝĞǁĂƐĨƌŽŵϳ&ĞďƌƵĂƌLJϮϬϭϰ͗
• ƌĂĨƚŶǀŝƌŽŶŵĞŶƚĂů/ŵƉĂĐƚƐƐĞƐƐŵĞŶƚ;/ͿZĞƉŽƌƚ͖
• ƌĂĨƚŶǀŝƌŽŶŵĞŶƚĂůDĂŶĂŐĞŵĞŶƚWƌŽŐƌĂŵŵĞ;DWƌͿ͖
• ƌĂĨƚtĂƐƚĞDĂŶĂŐĞŵĞŶƚ>ŝĐĞŶĐĞƉƉůŝĐĂƚŝŽŶ;tD>ͿZĞƉŽƌƚ͖ĂŶĚ
• ƌĂĨƚƚŵŽƐƉŚĞƌŝĐŵŝƐƐŝŽŶƐ>ŝĐĞŶĐĞ;>ͿƉƉůŝĐĂƚŝŽŶ͘
/ŶǀŝƚĂƚŝŽŶƚŽĂŶŽƉĞŶŚŽƵƐĞĂŶĚĂƐƚĂŬĞŚŽůĚĞƌŵĞĞƚŝŶŐ
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<ŝŶĚZĞŐĂƌĚƐ͕
Anelle Lotter and Sibongile Bambisa
for Jones & Wagener
ª +27 76 750 9030
+27 12 667 4860
+27 12 667 6128
e-mail [email protected]
See link to Disclaimer below:
http://www.tracn4.co.za/index.php?option=com_content&view=article&id=224
Proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal
fired power plant and associated
infrastructure for KiPower near Delmas
DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.:
17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Reply sheet to receive a copy of the Draft Environmental Impact
Assessment Report (DEIR), Draft Environmental Management
Programme, Draft Waste Licence Application Report and the Draft
Atmospheric Emissions Licence Application Report and to attend
an open house and stakeholder meeting
EIA Public Participation Office
Anelle Lötter/ Sibongile Bambisa
Jones and Wagener Consulting Civil
Engineers (Pty) Ltd
P O Box 1434, Rivonia, 2128
Tel: (012) 667 4860
Fax: (012) 667 6128
Email: [email protected] or
[email protected]
Please complete by 14 February 2014 and return to the Public Participation office (as above)
TITLE
Mrs
FIRST NAME
Blanché
INITIALS
B
SURNAME
Postma
ORGANISATION
Clean Stream
Environmental
Consultants (Pty) Ltd.
PO Box 32201
Glenstantia
Pretoria
POSTAL
ADDRESS
TEL NO
[email protected]
EMAIL
012 993 5988
POSTAL
CODE
0010
FAX NO
012 993 1361
REGISTRATION TO RECEIVE THE DRAFT REPORTS AND TO ATTEND AN OPEN HOUSE/ STAKEHOLDER MEETING
DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT
I would like to receive a CD copy of the Draft Environmental Impact Assessment Report (DEIR)
YES
NO
DRAFT WASTE MANAGEMENT LICENCE APPLICATION REPORT
I would like to receive a CD copy of the Draft Waste Management Licence Application Report
YES
NO
DRAFT ATMOSPHERIC EMISSIONS LICENCE REPORT
I would like to receive a CD copy of the Draft Atmospheric Emissions Licence Report
YES
NO
OPEN HOUSE/ STAKEHOLDER MEETING
I would like to attend an open house / stakeholder meeting (please circle the appropriate block).
I will attend the open house / stakeholder meeting on Wednesday, 26 February 2014, at the
Delmas Agricultural Hall / Lapa (Open house is from 10:00 to 17:00 – formal meeting starts at
18:00 to 20:00)
YES
NO
COMMENTS (please use separate sheets if you wish)
Any comments you may have at this stage:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
Please ask the following of my colleagues/friends/neighbours to register for this project:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
THANK YOU FOR YOUR CONTRIBUTION
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Proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal
fired power plant and associated
infrastructure for KiPower near Delmas
DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.:
17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Reply sheet to receive a copy of the Draft Environmental Impact
Assessment Report (DEIR), Draft Environmental Management
Programme, Draft Waste Licence Application Report and the Draft
Atmospheric Emissions Licence Application Report and to attend
an open house and stakeholder meeting
EIA Public Participation Office
Anelle Lötter/ Sibongile Bambisa
Jones and Wagener Consulting Civil
Engineers (Pty) Ltd
P O Box 1434, Rivonia, 2128
Tel: (012) 667 4860
Fax: (012) 667 6128
Email: [email protected] or
[email protected]
Please complete by 14 February 2014 and return to the Public Participation office (as above)
TITLE
Mr
FIRST NAME
INITIALS
LJ
SURNAME
ORGANISATION
Evander Gold Mining
EMAIL
POSTAL
ADDRESS
Private bag X1012
Evander
TEL NO
(072)603 0622
Boet
Conradie
[email protected]
POSTAL
CODE
2250
FAX NO
(017) 632 4046
REGISTRATION TO RECEIVE THE DRAFT REPORTS AND TO ATTEND AN OPEN HOUSE/ STAKEHOLDER MEETING
DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT
I would like to receive a CD copy of the Draft Environmental Impact Assessment Report (DEIR)
NO
DRAFT WASTE MANAGEMENT LICENCE APPLICATION REPORT
I would like to receive a CD copy of the Draft Waste Management Licence Application Report
NO
DRAFT ATMOSPHERIC EMISSIONS LICENCE REPORT
I would like to receive a CD copy of the Draft Atmospheric Emissions Licence Report
NO
OPEN HOUSE/ STAKEHOLDER MEETING
I would like to attend an open house / stakeholder meeting (please circle the appropriate block).
I will attend the open house / stakeholder meeting on Wednesday, 26 February 2014, at the
Delmas Agricultural Hall / Lapa (Open house is from 10:00 to 17:00 – formal meeting starts at
18:00 to 20:00)
NO
COMMENTS (please use separate sheets if you wish)
Any comments you may have at this stage:
No comments at this stage
Please ask the following of my colleagues/friends/neighbours to register for this project:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
THANK YOU FOR YOUR CONTRIBUTION
Proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal
fired power plant and associated
infrastructure for KiPower near Delmas
DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.:
17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Reply sheet to receive a copy of the Draft Environmental Impact
Assessment Report (DEIR), Draft Environmental Management
Programme, Draft Waste Licence Application Report and the Draft
Atmospheric Emissions Licence Application Report and to attend
an open house and stakeholder meeting
EIA Public Participation Office
Anelle Lötter/ Sibongile Bambisa
Jones & Wagener Engineering &
Environmental Consultants (Pty) Ltd
P O Box 1434, Rivonia, 2128
Tel: (012) 667 4860
Fax: (012) 667 6128
Email: [email protected] or
[email protected]
Please complete by 14 February 2014 and return to the Public Participation office (as above)
Granny
TITLE
FIRST NAME
Mrs
kgole
INITIALS
MG
SURNAME
ORGANISATION
Shanduka coal
EMAIL
[email protected]
POSTAL
ADDRESS
TEL NO
013 244 8212
Kruger Dam road, Aerorand, Middleburg
POSTAL
1050
CODE
n/a
FAX NO
REGISTRATION TO RECEIVE THE DRAFT REPORTS AND TO ATTEND AN OPEN HOUSE/ STAKEHOLDER MEETING
DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT
I would like to receive a CD copy of the Draft Environmental Impact Assessment Report (DEIR)
x
YES
NO
DRAFT WASTE MANAGEMENT LICENCE APPLICATION REPORT
I would like to receive a CD copy of the Draft Waste Management Licence Application Report
x YES
NO
DRAFT ATMOSPHERIC EMISSIONS LICENCE REPORT
I would like to receive a CD copy of the Draft Atmospheric Emissions Licence Report
x YES
NO
OPEN HOUSE/ STAKEHOLDER MEETING
I would like to attend an open house / stakeholder meeting (please circle the appropriate block).
I will attend the open house / stakeholder meeting on Wednesday, 26 February 2014, at the
Delmas Agricultural Hall / Lapa (Open house is from 10:00 to 17:00 – formal meeting starts at
18:00 to 20:00)
x YES
NO
COMMENTS (please use separate sheets if you wish)
Any comments you may have at this stage:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
Please ask the following of my colleagues/friends/neighbours to register for this project:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
THANK YOU FOR YOUR CONTRIBUTION
Proposed construction of a 600 Megawatt
(MW) Independent Power Producer (IPP) coal
fired power plant and associated
infrastructure for KiPower near Delmas
DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.:
17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.: MP30/5/1/2/2/425MR)
Reply sheet to receive a copy of the Draft Environmental Impact
Assessment Report (DEIR), Draft Environmental Management
Programme, Draft Waste Licence Application Report and the Draft
Atmospheric Emissions Licence Application Report and to attend
an open house and stakeholder meeting
EIA Public Participation Office
Anelle Lötter/ Sibongile Bambisa
Jones and Wagener Consulting Civil
Engineers (Pty) Ltd
P O Box 1434, Rivonia, 2128
Tel: (012) 667 4860
Fax: (012) 667 6128
Email: [email protected] or
[email protected]
Please complete by 14 February 2014 and return to the Public Participation office (as above)
TITLE
Mnr
FIRST NAME
INITIALS
P.J.
SURNAME
ORGANISATION
POSTAL
ADDRESS
TEL NO
PIET SCHUTTE
BOERDERY
EMAIL
PIET (PETRUS JACOBUS)
SCHUTTE
[email protected]
POSBUS 367
DELMAS
POSTAL
CODE
2210
082 524 8328
FAX NO
N.V.T.
REGISTRATION TO RECEIVE THE DRAFT REPORTS AND TO ATTEND AN OPEN HOUSE/ STAKEHOLDER MEETING
DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT
I would like to receive a CD copy of the Draft Environmental Impact Assessment Report (DEIR)
YES
DRAFT WASTE MANAGEMENT LICENCE APPLICATION REPORT
I would like to receive a CD copy of the Draft Waste Management Licence Application Report
YES
DRAFT ATMOSPHERIC EMISSIONS LICENCE REPORT
I would like to receive a CD copy of the Draft Atmospheric Emissions Licence Report
YES
OPEN HOUSE/ STAKEHOLDER MEETING
I would like to attend an open house / stakeholder meeting (please circle the appropriate block).
I will attend the open house / stakeholder meeting on Wednesday, 26 February 2014, at the
Delmas Agricultural Hall / Lapa (Open house is from 10:00 to 17:00 – formal meeting starts at
18:00 to 20:00)
YES
COMMENTS (please use separate sheets if you wish)
Any comments you may have at this stage:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
Please ask the following of my colleagues/friends/neighbours to register for this project:
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
THANK YOU FOR YOUR CONTRIBUTION
Ms. Fiona Grimett
Tel: 012 3951793
[email protected]
Cc: Ms. Judy Beaumont
DDG: Climate Change and Air Quality Management
[email protected]
Mr. Mark Gordon
Chief Director: Integrated Environmental Authorisations
[email protected]
Dr. Thuli N. Mdluli
National Air Quality Officer
Chief Director: Air Quality Management
[email protected]
Anelle Lotter
for Jones & Wagener
[email protected]
André Joubert
Zitholele Consulting (Pty) Ltd
[email protected]
RE: NEAS Reference: DEA/EIA/0000364/2011 & DEA Reference: 12/12/20/2333
14th August 2013
Dear Fiona
groundWork is an environmental justice organisation and an interested and affected party in
relation to the proposed KiPower station near Delmas in Mpumalanga (the relevant
reference numbers appear in the subject line).I am writing to seek clarity on this DEA
approval of the draft scoping report (DSR) for the proposed KiPower power station and to
urge the DEA to reconsider this decision. From the attached correspondence which indicates
you are the contact person at the DEA, I understand that you have granted the EIA
consultants and the proponent authorisation to proceed with the EIA process for this IPP.
However, our understanding is that the National Environmental Management Air Quality
Act; the Highveld Priority Area Air Quality Management Plan, the National Framework for Air
Quality Management and the National Environmental Management Act do not permit the
DEA to authorise this development in the HPA for the reasons set out below.
A. THE AIR QUALITY ACT (AQA)
1. Section 2 of the AQA provides that its object is—
(a) to protect the environment by providing reasonable measures for—
(i)the protection and enhancement of the quality of air in the Republic;
(ii)the prevention of air pollution and ecological degradation; and
(iii)securing ecologically sustainable development while promoting
justifiable economic and social development; and
(b) generally to give effect to section 24 (b) of the Constitution in order to enhance
the quality of ambient air for the sake of securing an environment that is not
harmful to the health and well-being of people.
Ambient air quality standards (AAQS)
2. The AQA provides that the Minister, by notice in the Gazette—
(a) must identify substances or mixtures of substances in ambient air which,
through ambient concentrations, bioaccumulation, deposition or in any other
way, present a threat to health, well-being or the environment or which the
Minister reasonably believes present such a threat; and
(b) must, in respect of each of those substances or mixtures of substances, establish
national standards for ambient air quality, including the permissible amount or
concentration of each such substance or mixture of substances in ambient air.[1]
3. AAQS have been established for PM10 and PM2.5, SO2, nitrogen dioxide (NO2), ozone (O3),
and benzene (C6H6).[2]
Priority areas
4. The AQA provides for the declaration of an area as a priority area if the Minister (or
MEC) reasonably believes that —
[1]
[2]
s.9(1)(a) and (b).
GN 1210 in GG 32816 of 24 December 2009 and GN 486 in GG 35463 of 29 June 2012.
(a) AAQS are being, or may be, exceeded in the area, or any other situation exists
which is causing, or may cause, a significant negative impact on air quality in the
area; and
(b) the area requires specific air quality management action to rectify the
situation.[3]
5. A priority area air quality management plan (AQMP) must be developed to: co-ordinate
air quality management (AQM) in the area; address air quality issues; and provide for its
implementation by a committee representing relevant role-players.[4]
6. The aim of declaring priority areas is to target limited AQM resources to the areas that
require them most.[5] Once an AQMP is implemented, air quality in the area should within agreed timeframes - be brought into sustainable compliance with AAQS.[6]
7. The Minister (or MEC) may withdraw the declaration of an area as a priority area if the
area is in compliance with AAQS for a period of at least two years.[7]
8. Three priority areas have been declared – the Vaal Triangle Airshed Priority Area, the
Highveld Priority Area and the Waterberg Priority Area. AQMPs have been developed for
the Vaal Triangle Airshed and the Highveld Priority Areas.
9. KiPower is proposed within the HPA. In other words, air quality in the area in which the
proposed station is proposed is already problematic – with numerous exceedances of
AAQS - and attempts are underway to rectify the significant negative impact on air
quality.
10. It cannot be disputed that KiPower’s application, if granted, will only serve to exacerbate
the already poor air quality in this priority area. The deterioration of air quality is clearly
not what is envisaged by the declaration of priority areas and, it is submitted that this
EIA application should fail and be withdrawn by the DEA.
[3]
[4]
[5]
[6]
[7]
s.18(1).
s.19(1)-(5), (6)(b).
“Priority areas under the Air Quality Act” Engineering News Online 3 June 2011, available at
http://www.engineeringnews.co.za/print-version/priority-areas-under-the-air-quality-act-2011-0603.
“Deputy Minister of Water and Environmental Affairs launches Waterberg-Bojanala priority area”
20 July 2012, available at
http://www.info.gov.za/speech/DynamicAction?pageid=461&sid=29236&tid=77119
s.18(5).
The Highveld Priority Area (HPA)
11. This priority area was declared on 23 November 2007. Elevated concentrations of
pollutants occur in this area, many from industrial sources. 12 of Eskom’s power stations
fall within the HPA. According to the AQMP, industrial sources are by far the biggest
contributor of emissions in the HPA, accounting for 89% of PM10, 90% of NOX and 99%
of SO2. Power generation contributes an estimated 12% of PM10, 73% of NOX and 82%
of SO2 emissions. AAQS for PM10, Ozone (O3) and SO2 are exceeded in nine extensive
areas in the HPA.
12. The AQMP also highlights the concerns regarding mercury, and that, in South Africa,
power generation accounts for some 75% of the total mercury emissions, with power
generation in the Highveld making a significant contribution. Mercury has serious
health risks.
13. In relation to mercury in particular, South Africa is estimated to release approximately
30-40 tonnes of mercury emissions from the coal-fired electricity sector.1 A conservative
estimate of annual health benefits is some $39–$47 per gram of atmospheric mercury
emissions eliminated.2
14. More recently, a new study in the EU considered lost IQ costs due to mercury exposure.3
The IQ benefits from controlling mercury pollution were translated into economic
impacts based on the calculated current life-time income benefits from a higher IQ level.
The report states that there is little doubt that global benefits substantially exceed $20
billion.
15. Recognizing its serious risks to health and the environment, in January 2013, more than
140 countries agreed to limit the use and emission of mercury in terms of the Minamata
Convention on Mercury. The Convention will be signed in October 2013, and takes effect
once it has been ratified by 50 countries.
1
Pirrone, N et al. 2010, “Global mercury emissions to the atmosphere from anthropogenic and natural
sources”. Atmos. Chem. Phys., 10, 5951–5964, 2010
2
Pacyna, J et al. 2010, “An assessment of costs and benefits associated with mercury emission
reductions from major anthropogenic sources”. J Air Waste Manag Assoc 60 (3): 302-315.
3
Bellanger, M et al. 2013, “Economic benefits of methylmercury exposure control in Europe:
Monetary value of neurotoxicity prevention” Environ Health. 2013; 12:3. available at:
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3599906/
16. According to the AQMP, power station emissions are released well above the stable
surface layer through tall stacks, with the evening surface temperature inversion
preventing the plumes from reaching ground level, and dispersion occurring above the
inversion. However, during the day and especially in summer, convection can bring the
plumes to ground level when high concentrations may occur. The buoyancy of the
plumes results in maximum ground level concentrations a considerable distance from
sources. Modelled exceedances of ambient 1-hour and 24-hour SO2 AAQS from power
generation emissions occur across the central HPA – the southern parts of the
eMalahleni Local Municipality and the northern parts of the Govan Mbeki Local
Municipality and close to the individual stations of Matla, Kriel, Duvha, Kendal and
Hendrina.
17. The serious health impacts of air pollution are also addressed in the AQMP. Power
generation activities were estimated to be the primary driver of hospital admissions in
Mpumalanga, with a 51% contribution. SO2 exposure was also found to be three times
greater in Mpumalanga. SO2 emissions are generally associated with the combustion of
coal.
18. One of the seven goals of the AQMP – towards achieving the main goal of ambient air
quality in the HPA complying with all AAQS – is that, by 2020, industrial emissions are
equitably reduced to achieve compliance with AAQS and dust fallout limit values.
Industries have a number of obligations in order to meet that goal.
19. Industrial Intervention Plans are contained in Appendix 6 to the AQMP. In its plan,
Eskom promises numerous interventions to reduce atmospheric emissions from its 12
coal-fired power stations in the HPA – including: several upgrades of pollution
abatement technology; plans for raw material modification; improved fugitive emissions
management system; construction of rail infrastructure; ambient air quality monitoring;
stack emission monitoring; offset project pre-feasibility study; and energy efficiency
improvement. It is unclear to what extent Eskom has met – or is on track to meet – its
obligations, however it is evident that Eskom has recently submitted an application to
the DEA that it will not be able to meet its obligation in terms of the S21 emission limits.
This serves as a clear indication that ambient air quality is unlikely to improve in the near
term. An additional coal fired power station will only exacerbate this situation of
persistent non-compliance with the ambient air quality standards in the HPA.
20. Furthermore the HPA (by the DEA’s own admission) has over the last five years been
consistently out of compliance for the following parameters of the South Africa AAQS
(PM10; PM2.5; SO2) as indicated by the DEA graphs below (presented by the Air Quality
Management, Department of Environmental Affairs at various HPA MSRG meetings –
and in the presentation attached.
A. THE 2007 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC
OF SOUTH AFRICA
20. The Framework is published in terms of section 7 of the AQA for achieving the
objects of the AQA. The AQA’s definition of “this Act” includes the Framework. The
Framework binds all organs of state in all spheres of government; and an organ of
state must give effect to the Framework when exercising a power or performing a
duty in terms of AQA or any other legislation regulating air quality management.
There is therefore required to be compliance with the Framework in order for the
relevant decision-maker to evaluate KiPower’s application to build a coal-fired
power station.
21. Section 5.5.3 of the AQ Framework deals with Specialist Air Quality Impact
Assessment Reports. It states that “In general, all development applications
involving listed activities will be required to undergo an EIA and will require a
specialist Air Quality Impact Assessment study. Through its various requirements, the
AQA prescribes and informs the scope and content of such specialist Air Quality
Impact Assessment studies. The key elements of the AQA that are relevant to the EIA
process are summarized, followed by the establishment of norms for a specialist Air
Quality Impact Assessment report based on these requirements. Key requirements of
the AQA are as follows:
(a) Section 5.5.3.1 deals with Human health impacts: It reads “One of the objectives
of the AQA is to give effect to our constitutional right to an environment that is
not harmful to the health and well-being of people. The emphasis on human
health requires that the specialist Air Quality Impact Assessment for a proposed
listed activity includes an assessment of potential health impacts. The level of
detail required is dependent on the nature and extent of atmospheric emissions
and could range from a simple comparative assessment of predicted ambient air
quality levels with ambient air quality standards through to a full health risk
assessment”. Given the fact that a new coal-fired power station is proposed for a
priority area already out of compliance with ambient air quality standards, as
well as the serious health risks of coal-fired power stations, a full health risk
assessment is essential. The DSR is unclear whether this is planned.
(b) Section 5.5.3.2 deals with AAQS. It reads “The AQA is effects-based legislation,
with the result that activities that result in atmospheric emissions are to be
determined with the objective of achieving health-based ambient air quality
standards. Each new development proposal with potential impacts on air quality
must be assessed not only in terms of its individual contribution, but in terms of
its additive contribution to baseline ambient air quality i.e. cumulative effects
must be considered”. I have already addressed the serious non-compliance with
AAQS in the HPA. A new power station will exacerbate this.
(c) Section 5.5.3.4 deals with Mitigation measures. It states that “related to the
above, the AQA states that the Best Practicable Environmental Option (BPEO)
that would prevent, control, abate or mitigate pollution, must be used. Noncompliance with ambient air quality standards (AAQS) and priority areas”. We
submit that there has been insufficient consideration of alternatives to the
proposed KiPower station in this regard. This is elaborated on the section
below.
B. NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA)
22. The National Environmental Management (NEM) Principles contained in NEMA serve
as guidelines by reference to which any organ of state must exercise any function
when taking any decision in terms of NEMA or other laws concerning the protection
of the environment.[2] Sustainable development requires the consideration of all
relevant factors; including:
a. that pollution and degradation of the environment are avoided, or, where
they cannot be altogether avoided, are minimised and remedied;
b. that the use and exploitation of non-renewable natural resources is
responsible and equitable, and takes into account the consequences of the
depletion of the resource;
c. that the development, use and exploitation of renewable resources and the
ecosystems of which they are part do not exceed the level beyond which
their integrity is jeopardised;
d. that a risk-averse and cautious approach is applied, which takes into account
the limits of current knowledge about the consequences of decisions and
actions; and
e. 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.[3]
23. Environmental management must be integrated, acknowledging that all elements of
the environment are linked and interrelated, and it must take into account the
[2]
[3]
s.2(1)(c).
s.2(4)(a).
effects of decisions on all aspects of the environment and all people in the
environment by pursuing the selection of the best practicable environmental
option.[4] “Best practicable environmental option” is defined in NEMA as “the option
that provides the most benefit or causes the least damage to the environment as a
whole, at a cost acceptable to society, in the long term as well as in the short
term”.[5]
24. Responsibility for the environmental health and safety consequences of a policy,
programme, project, product, process, service or activity exists throughout its life
cycle.[6] The social, economic and environmental impacts of activities, including
disadvantages and benefits, must be considered, assessed and evaluated, and
decisions must be appropriate in the light of such consideration and assessment.[7]
The environment is held in public trust for the people, the beneficial use of
environmental resources must serve the public interest and the environment must
be protected as the people’s common heritage.[8] 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.[9] This is known as the “polluter pays” principle.
25. Section 23(2)(b) of NEMA provides that one of the general objectives of integrated
environmental management is to identify, predict and evaluate the actual and
potential impact on the environment, socio-economic conditions and cultural
heritage, the risks and consequences and alternatives and options for mitigation of
activities, with a view to minimising negative impacts, maximising benefits, and
promoting compliance with the NEM Principles of environmental management. In
terms of section 24(4)(b)(i) of NEMA, procedures for the investigation, assessment
and communication of the potential consequences or impacts of activities on the
environment must include, with respect to every application for an environmental
authorisation, and where applicable—investigation of the potential consequences or
impacts of the alternatives to the activity on the environment and assessment of the
significance of those potential consequences or impacts, including the option of not
implementing the activity.
[4]
[5]
[6]
[7]
[8]
[9]
s.2(4)(b).
s.1
s.2(4)(e).
s.2(4)(i).
s.2(4)(o).
s.2(4)(p).
26. The Environmental Impact Assessment Regulations, 2010 (the EIA Regulations)
define “alternatives” as follows:
“alternatives”, in relation to a proposed activity, means different means of
meeting the general purpose and requirements of the activity, which may
include alternatives to—
(a) the property on which or location where it is proposed to undertake the
activity;
(b) the type of activity to be undertaken;
(c) the design or layout of the activity;
(d) the technology to be used in the activity;
(e) the operational aspects of the activity; and
(f) the option of not implementing the activity.
27. Coal-fired power stations are particularly polluting. They are not the best practicable
environmental option: coal-fired power stations do not, as is required by NEMA,
provide the most benefit or cause the least damage to the environment as a whole,
at a cost acceptable to society, in the long term and/or the short term. Renewable
energy saves costs and is a much more practicable environmental option.
28. As argued above, environmental legislation requires investigation and evaluation of
these alternative options. This has not been properly evaluated in the KiPower
application.
29. For all of these reasons, the DSR should not have been approved.
30. I look forward to your urgent response as to the way forward. Should you require
additional information, please let me know.
Kind regards
Rico Euripidou
Anelle Lotter
Jones and Wagenaar
By e-mail: [email protected]
Our reference: gW KiPower JAW
Date: Thursday, 17th October 2013
Dear Anelle
I thought it would be best that I correspond via a letter rather than an e-mail in order that
responses are correctly documented in terms of time.
I want to confirm that the responses to my e-mail queries on the 25th September, which
followed your e-mail on the 19th September, was only received yesterday, and not on the 1st
October. Your correspondence of the 1st October only dealt with the Department of
Environmental Affairs (DEA) response, via Ms Grimett.
a) The version of the Final Scoping Report
Thanks for the clarification from the DEA.
b) Changes to scopes of work
I understand there is a scope of work for the specialist studies, as per the: ENVIRONMENTAL
IMPACT ASSESSMENT FOR THE CONSTRUCTION OF A 600MW INDEPENDENT POWER PLANT
AND ASSOCIATED INFRASTRUCTURE FOR KIPOWER (PTY) LTD NEAR DELMAS IN
MPUMLANGA FINAL SCOPING REPORT, (DEA Ref No.: 12/12/20/2333; NEAS Ref No.:
DEA/EIA/0000364/2011), Report No.: JW058/10/C182- Rev C.
However, please send groundWork the final terms of reference (TOR) for the specialist
studies. If any changes were made to the TOR for these specialist studies, even if they were
after June 2012, based upon DEA comments, please forward them as well.
While Mr Euripidou of groundWork did comment on the draft scoping document, the TOR
for the specialist studies were not made available to him, or the public in general to better
understand the specific nature of the work that Jones and Wagenaar (JAW) were requesting
from consultants and/or specialist undertaking the studies. This is a critical piece of
1
information for it would inform what is specifically requested from consultants and/or
specialist, and therefore comment on this is important. Please make these available.
c) Application forms – being updated
I think that it is important that any substantive changes in the project must be made
available to the DEA and the public formally when it occurs, in order that decision makers
and the public have sufficient time to comment on such changes, rather than leave these
changes till the Final Environmental Impact Report (FEIR) or Draft EIR (DEIR). It is not about
the forms, but rather about the content, and while the forms can be finalised later during
the process, the content and changes must be discussed at the times that they are
proposed. Leaving it till the end would result in DEA trying to ‘close the stable door after the
horse has bolted’ for the specialist studies would have already been completed based upon
a change that was not agreed upon by the decision makers.
While you indicate that the Interested and Affected Parties (IAPs) ‘will have all the specialist
studies and the DEIR report – thus the result of the TORs’, this is not the TOR. I would like to
reiterate that we would like to have sight of the final TOR and subsequent changes or
additions.
d) Public engagement
Thanks for considering too discuss alternative means of public engagement. This is
encouraging. We are considering your request on ‘proposed format of a public hearing and
any other suggestions’ and will communicate these with you early next week.
I have not seen notice of the public review period, which you indicate would occur within
two weeks from the 1st October. Please forward any of such notices to myself
([email protected]) and Rico Euripidou ([email protected]).
Thanks for considering the request for an extended public review period.
Kind regards,
S. (Bobby) Peek
Director
2
KiPower
Our Ref: 9/2/219/0001
Enquiries: Phillip Hine
Tel: 021 462 4502
Email: [email protected]
CaseID: 174
Date: Wednesday February 06, 2013
Page No: 1
Interim Comment
In terms of Section 38(8) of the National Heritage Resources Act (Act 25 of 1999)
Attention: Mr Ayanda Bam
Kuyasa Mining (Pty)Ltd
Private Bag X 7250
Witbank
Mpumalanga
1035
ENVIRONMENTAL IMPACT ASSESSMENT FOR THE CONSTRUCTION OF A 600MW INDEPENDENT
POWER PLANT AND ASSOCIATED INFRASTRUCTURE FOR KIPOWER (PTY) LTD NEAR DELMAS IN
MPUMLANGA
Pistorius, July 2012. A Phase I Heritage Impact Assessment (Hia) Study For A Proposed 600mw Power Plant
And Associated Infrastructure For Kipower (Pty) Ltd Near Delmas On The Eastern Highveld In The
Mpumalanga Province Of South Africa
KiPower (Pty) Ltd. proposes the development of a 600MW power plant on the farms Haverglen 269IR and
Haverklip 265IR, 20km southeast of Delmas, Mpumalanga Province. SAHRA APM commented on the
Heritage Scoping Report for this project and recommended the following:
-Since the project will be situated within an area already heavily affected by previous mining activities SAHRA
has no objection to the proposed development. However, the recommendations listed below must be
implemented:
-A Palaeontological Impact Assessment must be undertaken before mining and construction may proceed.
The report must be submitted to SAHRA for further recommendations. If the specialist deems it sufficient, a
letter of exemption from further palaeontological studies may submitted to the heritage authority.
-The cemetery on the farm Haverklip will be affected by the proposed ash stock pile and will need to be
relocated. If the graves are older than 60 years the developer must ensure that the mandatory 60 day
consultation is done and a permit in terms of section 36 of the NHRA (Act no 25 of 1999) must be obtained
from SAHRA Burial Grounds and Graves Unit.
-The author recommended that the Homestead Ruin on the farm Haverklip will need to be recorded in detail
before it can be demolished. The Homestead Ruin on the farm Haverglen is younger than 60 years so no
further action is required. Please note that Decisions in terms of Built Environment must be sought from the
Mpumalanga Provincial Heritage Authority (Mr Benjamin Moduka, [email protected]).
KiPower
Our Ref: 9/2/219/0001
Enquiries: Phillip Hine
Tel: 021 462 4502
Email: [email protected]
CaseID: 174
Date: Wednesday February 06, 2013
Page No: 2
-Although the homestead and associated cemetery that is located north of stockpile area close to the R50 falls
outside the footprint of the development, SAHRA strongly advises that the developer must ensure that no
impact occur on them. These features must be mapped on construction maps and all contractors must be
made aware of the legal status of heritage resources. To avoid secondary impacts that may result from the
development, SAHRA recommends that the cemetery be fenced and access gates installed to allow visits for
relatives and friends.
-It is not clear from the heritage report if the proposed coal conveyor and sorbent conveyor routes were
surveyed. Please note that these routes must be surveyed by a specialist and the results submitted in a report
to SAHRA before development proceeds.
The new report submitted to SAHRA identified a further two cemeteries, however, it is only Graveyard 4 that
will be affected by the proposed Ash Stockpile Area. This cemetery contains two graves. The cemetery is
fenced, although it is overgrown with vegetation.
Decision
1) Since Graveyard 4 falls within the stockpile area the two graves related to this cemetery will need to
be relocated. SAHRA BGG Unit will only support relocation dependent on the results of the 60-day public
participation process. A Permit will be required in terms of section 36 of the National Heritage Resources
Agency (Act no. 25 of 1999). Graveyards 1, 2, and 3 must be retained in situ. For this purpose all graves must
be cleaned and restored where and a proper fence must be installed with access gates to allow visits from
relatives and friends. No development is allowed within 15-20 meters of the graveyards.
2) SAHRA APM Unit specifically requested that the alignment for the coal conveyor be surveyed. The report
submitted does not mention the coal conveyor so it is unclear from SAHRA’s perspective if this was
undertaken. SAHRA APM Unit therefore recommends that before construction starts on the conveyor route, an
archaeologist must provide a walk down report to SAHRA APM Unit.
3) SAHRA APM Unit specifically requested a palaeontological impact assessment, which has not been
submitted yet. Please note that a PIA must be undertaken or at least a letter of exemption will be required from
a professional palaeontologist indicating that such a study is unnecessary. SAHRA will not be able to issue the
final comment for this project until the PIA is received.
4) The heritage scoping report undertaken by Dr R. De Jongh recommended that the Homestead Ruin on the
farm Haverklip will need to be recorded in full detail. This has not been done during the current study.
Decisions regarding the built environment must be sought from the Mpumalanga Provincial Heritage Authority
(Mr Benjamin Moduka, [email protected]).
Should you have any further queries, please contact the designated official using the case number quoted
above in the case header.
KiPower
Our Ref: 9/2/219/0001
Enquiries: Phillip Hine
Tel: 021 462 4502
Email: [email protected]
CaseID: 174
Date: Wednesday February 06, 2013
Page No: 3
Yours faithfully
________________________________________
Phillip Hine
Heritage Officer
________________________________________
Colette Scheermeyer
SAHRA Head Archaeologist
South African Heritage Resources Agency
ADMIN:
(DEA, Ref: 12/12/20/2333)
Terms & Conditions:
1. This approval does not exonerate the applicant from obtaining local authority approval or any other necessary approval for
proposed work.
2. If any heritage resources, including graves or human remains, are encountered they must be reported to SAHRA immediately.
3. SAHRA reserves the right to request additional information as required.
Ms Anelle Lotter
JONES & WAGENER
P.O. BOX 1434
RIVONIA
2128
Date:
20 November 2013
Enquiries: Milton Moloko
Tel +27 13 693 4440
Dear Ms. Lotter
NOTIFICATION: ENVIRONMENTAL AUTHORIZATION AND LICENSING FOR THE
PROPOSED REHABILITATION OF A DISCARD DUMP FACILITY AND THE
RECONSTRUCTION OF THE EXISTING POLLUTION CONTROL DAMS AT DELMAS COAL
MINE IN MPUMALANGA.
Our ref: LD/W/MM/098/2013
MDEDET ref: 17/2/3N-300
This notification affects the existing Eskom Distribution’s Delmas Coll – Brakfontein 22
kV, Delmas Coll – Haverglen 22Kv, Delmas Coll – Devon 22Kv, and Brakfontein – Delmas
Collery 88kV overhead power lines.
Eskom Distribution will raise no objection to the proposed rehabilitation project, provided Eskom’s
rights and services are acknowledged and respected at all times.
Further to the above the following conditions must be adhered to and accepted in writing;
1. There is a 9 metres and 15.5metres building and tree restriction either side of the centre lines
of the 22kV and 88kV power lines, which must be adhered to in all future development. The
rights for the 22kV power lines are not registered against the property, but are secured under
a Wayleave Agreement. No construction work may be executed closer than 11 metres from
any of Eskom’s structure and or supporting mechanisms.
2. All work within Eskom Distribution reserve area and servitudes must be done in accordance
with the requirements of the Occupational Health and Safety Act No.85 of 1993 as amended.
Special attention must be given to the clearances between Eskom’s conductors, structures,
cables and electrical apparatus and the proposed work as stipulated by Regulation R15 of the
Electrical Installations Regulations of the aforementioned Act or any other legal requirements.
3. Eskom cannot guarantee the exact position of the underground electrical cables and
therefore the applicant’s site representatives must expose the cables by hand, in order to
establish their location.
4. Eskom Distribution shall not be liable for the death of or injury to any person or for the loss of or
damage to any property whether as a result of the encroachment or of the use of the area
where Eskom Distribution has its services, by the applicant, his/her agent, contractors,
employees, successors in title and assigns. The applicant indemnifies Eskom against loss,
claims or damages including claims pertaining to consequential damages by third parties and
whether as a result of damage to or interruption of or interference with Eskom Distribution
services or apparatus or otherwise. The applicant’s attention is drawn to section 27(3) of the
Electricity Act 1987, (Act 41 of 1987, as amended in 1994), Section 27(3), which stipulates that
the applicant can be fined and/or imprisoned as a result of damage to Eskom’s apparatus.
Mpumalanga Operating Unit
Asset Creation
Cnr Watermeyer and Jelicoe Street
P O Box 223 Witbank 1035 SA
Tel +27 13 693 3263 Fax +2786 574 1734 www.eskom.co.za
Eskom Holdings SOC Limited Reg No 2002/01527/06
5. Eskom Distribution shall at all times have unobstructed access to and egress from its services.
6. No mechanical equipment, including mechanical excavators, high lifting machinery and drilling
equipment shall be used within Eskom’s reserve area, or within close proximity of Eskom’s
services and equipment, without prior written permission having been granted by Eskom. If
such permission is granted the applicant must give at least ten working days prior notice of the
commencement of any work. This allows time for arrangements to be made for supervision
and/or precautionary instructions to be issued.
7. No work shall commence unless Eskom has received the applicant’s written acceptance of the
conditions specified in the final letter of consent.
8. Eskom’s rights and duties in the servitude shall be accepted as having prior right at all times
and shall not be obstructed or interfered with. Please note: Where an electrical outage is
required, at least fourteen working days is required for arrangement.
9. Any third party servitudes encroaching on Eskom servitudes shall have to be registered against
the property at the applicant’s own cost. Eskom is not the landowner thus Eskom’s consent
doesn’t relieve the applicant from obtaining the necessary statutory, landowner’s and or
municipal approvals.
10. If and where applicable: Wherever any pipe crosses the Eskom services, the edge of the
excavation shall not come within 10 metres of the Eskom services and structures. Any angles
crossing should preferably be from 45º degrees to 90º. Cathodic protection must be installed to
prevent corrosion of the pipe. Pipeline markers to be situated at 30 metre intervals and where
the pipeline is crossing Eskom’s servitude, the pipeline must be clearly marked.
11. The effective management and handling of waste is of crucial importance. No dumping shall be
allowed within Eskom Distribution Servitudes. All unwanted waste (gaseous, liquid or solids)
should be disposed of at a registered waste disposal site as stipulated under Section 20 of the
Environmental Conservation Act (Act 73 of 1989). The applicant will adhere to all relevant
environmental legislation. Any cost incurred by Eskom as a result of non-compliance will be
charged to the applicant.
12. The use of explosives of any type within 500 metres of Eskom’s services shall only occur with
Eskom’s previous written permission. If such permission is granted the applicant must give at
least fourteen working days prior notice of the commencement of blasting. This allows time for
arrangements to be made for supervision and/or precautionary instructions to be issued in
terms of the blasting process.
13. Any development, which necessitates the relocation of our services, will be to the account of
the developer. If you decide on the option of relocation of the existing power lines, the
Customer Services, Regional Key Customer Executive (08600 37566) should be contacted in
connection with costs.
14. Eskom will recover costs from the applicant where any damages of Eskom assets and or any
penalties suffered by Eskom occur. The Applicant accepts costs if:
• Eskom pylons subside or are damaged as a result of blasting activities.
• Eskom has to incur any costs to comply with statutory requirements because of the
applicants or applicant’s contractor work or the presence of the equipment or plant in the
reserve area. Such proven costs shall be refunded on demand.
Should the applicant or his contractor damage any of Eskom services during commencement of any
work whatsoever, then Eskom’s 24 hour Contact Centre Tel: 086 000 1414/08600 37566 must be
dialled immediately to report the incident.
We thank you and hope you find the above in order.
Yours sincerely
For LOUISE HUMAN
LAND DEVELOPMENT MANAGER
EXHUMATION OF GRAVES AT KIPOWER
Our Ref:
Enquiries: Itumeleng Masiteng
Tel: 012 320 8490
Email: [email protected]
CaseID: 1961
Date: Thursday June 27, 2013
Page No: 1
Letter
In terms of Section 36(3) of the National Heritage Resources Act (Act 25 of 1999)
Attention: KiPower Pty LtdI
EXHUMATION AND REINTERNMENT OF GRAVES AT KIPOWER ON THE FARM HAVERKLIP 265 IR
I hereby like to acknowledge that a report about the the Archeaological investigation of a grave yard at Delmas
Coal(KiPower) was received by SAHRA during the first week of June this year.The mining area is located on
the farm Haverklip 265 IR near Delmas in Mpumalanga.The report that was submitted by Archaetnos, was
informative about the graves that were exhumed and relocated.The report is accepted as a record of all the
processes taken by Archaetnos in this particular case and that all the processes were done in accordance with
NHRA legislation. Hence, in the future mining activities can continue in this particular area without any
reservations.
The SAHRA BGG Unit wishes you success in your future projects.
Should you have any further queries, please contact the designated official using the case number quoted
above in the case header.
Yours faithfully
________________________________________
Itumeleng Masiteng
Heritage Officer: BBG Permitting
South African Heritage Resources Agency
EXHUMATION OF GRAVES AT KIPOWER
Our Ref:
Enquiries: Itumeleng Masiteng
Tel: 012 320 8490
Email: [email protected]
CaseID: 1961
Date: Thursday June 27, 2013
Page No: 2
________________________________________
Mimi Seetelo
Manager:Burial Grounds & Graves Unit
South African Heritage Resources Agency
ADMIN:
Direct URL to case: http://www.sahra.org.za/node/116898
Terms & Conditions:
1. This approval does not exonerate the applicant from obtaining local authority approval or any other necessary approval for
proposed work.
2. If any heritage resources, including graves or human remains, are encountered they must be reported to SAHRA immediately.
3. SAHRA reserves the right to request additional information as required.
NEW POWER PLANT AND
DISPOSAL OF ASH
KIPOWER IPP PROJECT
– Delmas Coal,
– Ikhwezi Colliery
and
– KiPower
• Kuyasa Mining
group owns:
PROJECT BACKGROUND
• KiPower is a new subsidiary for power
generation from coal supplied by Delmas Coal
• Initial plant of 600MW expandable to
2000MW
• Delmas Coal has sufficient reserves to supply
coal for well over 30 years
PROJECT BACKGROUND
– Coal reserves
– Undermined areas
– Surface water
resources
– Biodiversity
sensitivities
• 10km radius around
Delmas Coal
• Excluded areas:
SITE SELECTION PROCESS
POWER PLANT & ASH
Owned by BHP-B
• Shortlisted sites
Owned by Farmers
Owned by Kuyasa
SITE SELECTION PROCESS POWER PLANT & ASH
– Can fit 30 years of ash on site 3 if we rehabilitate
existing opencast pit
– Power plant can fit on Site 5
• Private owned land quite expensive – to be
avoided if possible
• New information on Site 5 undermining (lower
seam) – only power plant can fit on Site 5.
• Final outcome
SITE SELECTION
SORBENT
CONVEYOR
MINE ACCESS ROAD
COAL CONVEYOR
POWER
PLANT
R50
ASH DISPOSAL FACILITY
PROPOSED LAYOUT OF POWER PLANT, ASH DISPOSAL
FACILITY & ASSOCIATED INFRASTRUCTURE
• Plant will consist of four 150MW units
• Plant requires 2.8 million tonnes of coal per
year; 84 million tonnes over 30 years
• 600 MW Plant + construction laydown area: 40
+ 100 hectares = 140 hectares
• Ash disposal facility (600 MW, 30 years): 200250 ha
POWER PLANT CONCEPT
– Fuel flexibility (allows for changes in coal quality)
– Suitable for poor coal quality (low calorific value, low
volatility and high ash content)
– Uses sorbent to absorb sulphur from coal during
combustion of the coal
– Sorbent (Dolomite and limestone) available
– Works at lower operating temp: results in lower NOx
emissions
– Evidence that mercury emissions are mitigated by
sorbent addition
• Plant based on Circulating Fluidised Bed (CFB)
technology:
POWER PLANT CONCEPT
• Scoping phase concluded July 2012
• Specialist assessments almost complete (end
January 2012)
• EIA-EMPr public review (April 2013), incl WULA,
IWWMP, WLA and AEL application
• Submission July 2013
– 20 January 2011 (MDEDET, DEA, DWA)
– Public meeting 19 April 2012 (DEA)
– 15 November 2012 (DWA)
• Commenced EIA in 2011-application to DEA for
NEMA and NEM:WA.
• Meetings involving authorities:
STATUS OF PERMITTING PROCESSES
– Ground water (incl leachate, seepage modelling)
– Surface water
– Air quality
– Biodiversity
– Traffic, noise, visual, social
• SPECIALIST ASSESSMENTS
STATUS OF PERMITTING PROCESSES
WASTE LICENSE APPLICATION
It is expected that more than 100m3 of general waste will be stored on site,
especially during the construction phase of the station
It is expected that more than 35m3 of hazardous waste will be stored on site,
especially during the construction phase.
At the waste recycling plant/salvage yard more than 1 ton of general waste will
be sorted for recycling purposes per day.
Should a garden waste composting plant be constructed it may have the
capacity to treat more than 10m3 of garden waste per day.
More than 2000m3, but less than 15 000m3 of sewage water will be treated at
the onsite sewage works per annum.
During the construction and operational phase, it is likely that diesel and oil
spills will be treated in situ.
The construction of any of the above activities will trigger this activity
This activity is triggered by the disposal of the boiler ash onto a waste disposal
facility if the boiler ash classifies as hazardous waste.
This activity is triggered by the disposal of the boiler ash onto a waste disposal
facility if the boiler ash classifies as general waste.
The construction of any of the above facilities triggers this activity.
Category A 3(1)
Category A 3(2)
Category A 3(5)
Category A 3(9)
Category A 3(11)
Category A 3(12)
Category B 4(9)
Category B 4(10)
Category B4(11)
Category A 3(18)
DESCRIBE EACH LISTED ACTIVITY (and not as per the wording of the
relevant Government Notice):
* To be updated and submitted with final reports
ACTIVITY NUMBERS (AS LISTED IN THE
WASTE MANAGEMENT ACTIVITY LIST) :
ACTIVITIES (JULY 2009)*
• Waste license application report will be
compiled covering all waste related activities
• EIA and specialist studies will support the
application
• Submission to MDEDET, DWA for comment
• Submission to DEA for authorisation
WASTE LICENSE APPLICATION
– Class C proposed
• Liner design:
– 4 ash samples classify as Type 3 waste.
• Draft waste classification system:
WASTE CLASSIFICATION FOR ASH
ASH LINER DESIGN
• Pit already a source of polluted water that
must be managed.
– What is the impact on water make and quality?
– What are the alternatives?
• Construction of the ash dump liner over the pit
is problematic due to settlement of spoils
• Should the ash dump be constructed over the
mined pit?
CONSTRUCT ASH DUMP OVER PIT OR NOT
Area = 42.7ha
Vol spoils = 1.7m m3
Deficit = 2.1m m3
Pit H
PIT WITHOUT DUMP
Rehabilitated pit:
• Assumed shaped and free-draining.
• Closure water balance of 56 700 m3/a.
• Ground water component :
10 830 m3/a for 1525 mamsl.
• River basin elevation at 1531 mamsl.
• Recommend active in-pit water
balance management at elevation of
1525 mamsl.
• Requires borehole curtain with 4-6
active boreholes.
PIT WITHOUT ASH
Ground
Water
30 m3/day
PIT H1
Infiltration
125 m3/day
PIT WITHOUT ASH – WATER BALANCE
Decant
155 m3/day
PIT WITH ASH
PIT WITH ASH
Ground
water
30 m3/day
TREATMENT PLANT
PIT H1
Seepage
75 m3/day
Treatment
132 m3/day
Decant
57 m3/day
Infiltration
27 m3/day
ASH DUMP OVER PIT
PIT WITH ASH – WATER BALANCE FINAL
• A reduction in pit water make when ash is
disposed over pit - 132 m3/day vs 155 m3/day
• A reduction in overall water make if compared
with the construction of the portion of ash on
different site
• No additional long term water management
liability
• Preservation of arable land
CONSIDERATIONS
• The liner serves to separate ash seepage from
pit H ground water ingress.
• Both streams need treatment
• DWA has indicated a liner must be used.
CONSTRUCT ASH DUMP WITH LINER OR NO LINER
ASH DUMP WITH LINER
PIT H1
TREATMENT PLANT
Ground
water
30 m3/day
Treatment
71 m3/day
Decant
57 m3/day
Infiltration
27 m3/day
Seepage
14 m3/day
Treatment
61 m3/day
Leachate
61 m3/day
ASH DUMP OVER PIT
ASH DUMP WITH LINER – WATER BALANCE CLOSURE
–
–
–
–
Prepare pit as for no liner
Fill “hole” with ash to achieve free-draining surface
Construct liner on free draining surface
Manage water make from ash facility collected
separately
– Actively manage water level in pit to ensure no decant
• Proposed optimised liner solution:
– Preservation of agricultural land
– Reduction in overall impacted footprint
– Reduced overall water make
• Significant advantages to construct dump over
mined area, including
RECOMMENDATION
OPTIMISED LINER SOLUTION
ATMOSPHERIC EMISSIONS LICENSE
• Air quality assessment – Airshed Planning
Professionals
• Draft report currently under review by Black &
Veatch
• Updated report will be included in EIA review
process
• AEL application document, together with EIA
and specialist report to be submitted to
MDEDET for authorisation
ATMOSPHERIC EMISSIONS LICENSE
– Delmas Coal current emissions as part of the
baseline
– Dust, SO2, NOx from power plant, conveyors, ash
handling and ash disposal
– Recommended mitigation measures
– Monitoring plan (baseline and operational)
• Will include:
ATMOSPHERIC EMISSIONS LICENSE
THANK YOU
QUESTIONS?
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KUYASA MINING
KIPOWER IPP POWER PLANT
Distribution Date:
Job No:
Our Ref:
31 January, 2013
C182
c182-00_min01_rev1_gm_ps_mv
z_aelmeeting_2013
0131
Next meeting:
To be confirmed
DEA REF: 12/12/20/2333
NEAS REFERENCE: DEA/EIA/0000364/2011
MINUTES WASTE AND AIR EMISSIONS
LICENCES MEETING
Held at DEA, Pretoria on 30 January 2013
PRESENT:
Name:
Company:
Cell
Email
Prav Sewmohan (PS)
Marius Van Zyl (MvZ)
Gina Martin (GM)
Lucian Burger (LB)
Thandi Magagula (TM)
L. Moja (LM)
J&W
J&W
J&W
Airshed Planning Professionals
Delmas Coal (Kuyasa Mining)
Dept of Environmental Affairs
(DEA)
DEA
Mpumalanga DEDET
Mpumalanga DEDET
Nkangala District Municipality
083 629 8825
082 880 1250
072 997 8935
082 491 0385
072 540 7628
082 265 9344
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
083 781 0900
076 965 8415
079 189 5599
082 414 2905
[email protected]
[email protected]
[email protected]
[email protected]
Name:
Company:
Cell
Email
Gerrit Kornelius
Airshed Planning Professionals
Greg Scott (GS)
M. Mahlalela (MM)
Fikile Theledi (FT)
Vusi Mahlangu (VM)
APOLOGIES:
[email protected]
ADDITIONAL DISTRIBUTION:
Name:
Company:
Tariq Aziz
Tony Compaan
Ayanda Bam
Pierre van der Berg
Fiona Grimmett
Black & Veatch
Black & Veatch
Kuyasa Mining
J&W
DEA
Cell
Email
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
MINUTES OF MEETING
Action
1.
1.1.
INTRODUCTION
FT thanked everyone present for being able to attend the meeting.
1.2.
It was indicated that this meeting is concerning the proposed IPP by
KiPower near Delmas.
1.3.
FT added that the focus of the meeting should be air quality and that
waste management should be touched on briefly.
DATE
2
Action
DATE
1.4.
All present at the meeting introduced themselves and described their
interest in the project.
2.
PROJECT BACKGROUND
2.1.
PS made a presentation providing an overview of the project and
touching briefly on the waste licence and air quality aspects
associated with the proposed project.
2.2.
Refer to the attached PowerPoint presentation.
3.
STATUS OF PERMITTING PROCESSES
3.1.
Refer to the attached PowerPoint presentation. The scoping phase of
the EIA has been completed and the specialist assessments are in the
process of being finalised.
4.
WASTE LICENCE APPLICATION (WLA)
4.1.
Refer to the attached Power Point presentation. The waste application
(WLA) will be submitted to DEA for authorisation, and for comment to
DEDET and DWA.
4.2.
PS to include Nkangala District Municipality in the circulation list when
submitting the WLA report.
5.
EMISSIONS LICENCE APPLICATION (AEL)
5.1.
Refer to the attached Power Point presentation. The emission license
will be submitted to DEDET for authorisation, and for comment to DEA
and Nkangala District Municipality.
5.2.
GS and FT stated that this meeting was called regarding an omission
in terms of legal process requirements. The AEL application document
was overlooked by J&W.
5.3.
GS clarified that the AEL application form needed to be submitted with
the EIA application and is an upfront form to be lodged with DEDET.
There is a parallel process with EIA and AEL in the National
Framework. A reference number is then issued for the application and
must be used in the EIA process.
5.4.
PS asked whether it is sufficient to submit all outstanding documents
immediately or if the process should be halted.
5.5.
FT said that the information required may already be included in the
current Scoping Report. PS to send the completed AEL application
form as soon as possible to DEDET.
PS
06/02/2013
Hard copies of the final Scoping Report to be forwarded immediately
to DEDET (3 copies), Nkangala District Municipality (1 copy) and
DEA’s GS (1 copy).
PS
1/02/2013
BMS: Minutes of Meeting
c182-00_min-01_rev1_gm_ps_mvz_aelmeeting_20130131
PS
3
Action
CT
5.6.
DEDET will read the Scoping Report and inform PS of any
amendments or additions to be made within the timeframes allowed
for (30 days). A second meeting can then be held to discuss any
additional requirements that DEDET may have.
5.7.
PS further committed to submit updated AEL forms with the final
submission, if all information is not available at this stage of the EIA.
However, given that specialist work is being finalised, all information
required should be available.
PS
5.8.
It will take 14 days from the submission of the AEL application form for
J&W to be issued with a registration number by DEDET.
CT
DATE
20/02/2013
This number should to be included in all future advertisements and
documents as good practice.
5.9.
MvZ stated that there is a cement factory in Delmas, whose air quality
should also be looked at. GK/LB to consider this development in the
baseline for the project.
GK/LB
5.10.
GS stated that there will be a Highveld Priority Area meeting on 15
February 2013 in Witbank. He suggested that J&W should attend this
meeting and give a presentation regarding CFB technology, air quality
and the challenges of mitigating impacts in a priority area. A multistakeholder reference group will be present and therefore the
presentation should focus on a description of the project and possibly
on the baseline constraints.
GS
31/01/2013
LB
31/01/2013
GS to forward the invitation to MvZ.
5.11.
GS expressed his concern regarding the potential impact of windblown dust from the proposed ash disposal facility on the R50 stretch
of road adjacent to the proposed ash disposal facility.
LB to ensure this issue is covered in the specialist report.
6.
GENERAL
6.1.
FT suggested DEDET offices in Witbank or Nkangala District
Municipality offices in Middelburg to be used for the follow up meeting.
To be confirmed.
6.2.
MvZ thanked FT for updating J&W on the AEL procedure required.
6.3.
PS apologised for the omission and thanked FT for accommodating
J&W given the advanced stage of the EIA.
Next meeting: To be confirmed
Minuted by: Gina Martin
for Jones & Wagener
BMS: Minutes of Meeting
c182-00_min-01_rev1_gm_ps_mvz_aelmeeting_20130131
CT/PS
4
Document source: C:\Alljobs\C182_KiPowerIPP\Minutes\C182-00_MIN-01_Rev1_GM_PS_AELMeeting_20130131.docx
Document template: corMinutes_12r0
BMS: Minutes of Meeting
c182-00_min-01_rev1_gm_ps_mvz_aelmeeting_20130131
Jones & Wagener
Consulting Civil Engineers
59 Bevan Road PO Box 1434 Rivonia 2128 South Africa
Tel: 00 27 (0)11 519 0200 Fax: 00 27 (0)11 519 0201 email: [email protected]
KUYASA MINING
KIPOWER IPP POWER PLANT
Distribution Date:
Job No:
Our Ref:
27 February, 2013
C182
c182-00_min01_dmr_revc_gm_
mvz_20130227
Next meeting:
None
DEA REF: 12/12/20/2333
NEAS REFERENCE: DEA/EIA/0000364/2011
MINUTES DEPARTMENT OF MINERAL
RESOURCES MEETING
Held at Department of Minerals (DMR) (eMalahleni)
on 25 February 2013
PRESENT:
NAME:
COMPANY:
CELL
EMAIL
Martha Mokonyane (MM)
Samuel Mathavhela (SM)
Marius van Zyl (MvZ)
Prav Sewmohan (PS)
Gina Martin (GM)
Department of Mineral Resources (DMR)
DMR
Jones & Wagener (J&W)
J&W
J&W
082 447 2400
071 456 8349
082 880 1250
083 629 8825
072 997 8935
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
NAME:
COMPANY:
CELL
EMAIL
Ayanda Bam (AB)
Kuyasa
082 457 0197
[email protected]
APOLOGIES:
ADDITIONAL DISTRIBUTION:
NAME:
COMPANY:
CELL
EMAIL
Mpumelelo Saliwa
Kenneth Cameron
Tariq Aziz
Peter Dacomb
Delmas Coal
071 681 0661
082 78 7873
[email protected]
Black & Veatch
The Practice Group
082 457 3746
[email protected]
[email protected]
MINUTES OF MEETING
Action
1.
INTRODUCTION
1.1.
It was indicated that this meeting is concerning the proposed
Independent Power Producer (IPP) power plant project by KiPower
near Delmas.
1.2.
PS explained that this meeting is aimed at informing DMR of the
proposed project, jointly identifying issues/concerns and identifying
legal requirements associated therewith.
DATE
2
Action
2.
PROJECT BACKGROUND
2.1.
PS presented an overview of the project, touching briefly on the waste
licence and air quality aspects associated with the proposed project,
the site selection process undertaken, power plant technology, and
waste classification of the ash from the power plant
Note: The PowerPoint presentation is attached to these minutes.
3.
AUTHORISATION PROCESSES
3.1.
The scoping phase of the EIA has been completed and the specialist
assessments are in the process of being finalised.
3.2.
It is expected for the draft EIA/EMPr to be available in April/May 2013
and for the Final EIA/EMPr to be submitted by July 2013.
4.
PROPOSED ASH PIT
4.1.
The proposed disposal of ash from the power station into a
rehabilitated opencast pit at Ikhwezi Colliery was described.
4.2.
PS explained that the purpose of the project is to add power to the
Eskom grid. There is an abundance of coal at Delmas Coal and there
has recently been a call for IPPs to contribute in satisfying South
Africa’s energy requirements.
4.3.
MvZ added that this project is advantageous in that the proposed
power plant would be a mouth of mine power plant, situated 2.5km
from the mine and that no external transport of coal is needed.
4.4.
The proposed power plant site is excluded from any mining rights
area. The power plant will, however, need to be rezoned from
agricultural/mining to industrial land.
Legally, the pit would have to be rezoned as well, as ash classifies as
industrial waste.
4.5.
SM asked whether the mine or the IPP would be liable for any
environmental responsibilities.
4.6.
MvZ stated that Ikhwezi Colliery has the responsibility to rehabilitate
the pit area and address the decant water from the pit. The decant
water and rehabilitated pit would have been Ikhwezi’s responsibility
anyway, regardless of the proposed ash disposal.
4.7.
MM said that if a partial closure were to be applied for, there would
still be residual permanent impacts (e.g. the decant) which would have
to be taken care of.
MvZ said that pit G and H are under one mining right. If one were to
be closed, the other would have to close as well to obtain closure for
the mine.
MM added that partial closure is not an option, as closure implies that
every impact has been managed.
BMS: Minutes of Meeting
c182-00_min-01_dmr_revc_gm_mvz_20130227
DATE
3
4.8.
Action
DATE
PS/MvZ
2013/02/27
MvZ added that the rehabilitated pit would have an acidic water quality
and the ash seepage an alkaline quality. DWA has requested that
these two streams be kept separate.
PS said that if active water management for the decant were to be
stopped in the future, acidic pit water could mix with the ash therefore
DWA requested that the ash is kept isolated from the pit. MM
indicated that even if the power station will be removing pit water
through boreholes and treating it, the mine will remain liable forever
for this impact.
4.9.
PS suggested a formal agreement between Ikhwezi and KiPower
regarding the pit water management liability.
4.10.
MM said that if the responsibility of the decant water gets transferred
to KiPower, closure for Pit H is possible.
4.11.
An agreement as follows was proposed:
x Ikhwezi rehabilitates the opencast pit;
x Liability of the pit and its decant is transferred to KiPower (a
closure certificate and transfer of liability is applied for);
x KiPower hold all further liability for the pit and the decant water
and
x Update of the Ikhwezi EMPR to exclude Pit H on its closure.
MvZ and PS to discuss the proposed agreement with Kenneth
Cameron and Ayanda Bam.
4.12.
MPRDA Regulation 59 specifies the requirements for transfer of
liability.
4.13.
If a transfer of liability is applied for, an EMPR amendment is needed
as noted above.
4.14.
PS to update and submit entire EIA/EMPr (for NEMA) to DMR, in
addition to a transfer of liability application. This will suffice as an
EMPR amendment to the DMR. The EIA must include all the
requirements of the DMR that may not be covered by the NEMA
requirements, such as an environmental awareness plan, financial
provision, etc.
PS
July 2013
4.15.
PS to include a list of commenting authorities in the submission of the
EIA/EMPR to the DMR so that the department can be aware which
state departments would have received the document for review and
comment.
PS
July 2013
MM/SM
July 2013
At least 4 copies of the EIA/EMPR are needed for the DMR EMPR
Amendment application.
4.16.
MM indicated that the DMR will consult with National Department of
Agriculture, Forestry and Fisheries and the Mpumalanga Tourism and
Parks Agency externally and the Principal Inspector of Mines
internally.
BMS: Minutes of Meeting
c182-00_min-01_dmr_revc_gm_mvz_20130227
4
4.19.
PS will ensure Department of Water Affairs (DWA), Department of
Environmental Affairs (DEA) and Mpumalanga Department of
Economic Development, Environment and Tourism (DEDET) are
included in the submission of the final reports. MvZ stated that the
district and local authorities will also have to be included.
4.18.
To be included/amended in the EIA/EMPR:
x Closure plan and closure design of pit H;
x Financial provisioning and
x Environmental awareness procedure (employees).
Action
PS
DATE
July 2013
PS
July 2013
AB/PS
July 2013
The EIA needs to meet the DMR requirements but the NEMA format
may be used.
5.
GENERAL
5.1.
KiPower IPP would need to prove that they have experience with
environmental management if they are to have liability transferred to
them. The DMR will require this information.
Next meeting: None.
Minuted by: Gina Martin
for Jones & Wagener
Document source: C:\Alljobs\C182_KiPowerIPP\Minutes\DMRMeeting\C182-00_MIN-01_DMR_RevC_GM_MvZ_20130227.docx
Document template: corMinutes_12r0
BMS: Minutes of Meeting
c182-00_min-01_dmr_revc_gm_mvz_20130227
1
A Water Use Licence in terms of the National Water Act (NWA), No 36 of 1998 from the Department of Water Affairs (DWA). The application is supported by an
Integrated Water and Waste Management Plan (IWWMP);
An Atmospheric Emissions Licence Application (AEL) in terms of the National Environmental Management Air Quality Act (NEM:AQA), No 39 of 2004 from the
Nkangala District Municipality;
An Environmental Management Programme Report (EMPR) Amendment and Closure application for the Pit H area of Ikhwezi Colliery in terms of the Mineral and
Petroleum Resources Development Act (MPRDA), No 28 of 2002 from the Department of Mineral Resources (DMR) in Mpumalanga;
An application for rezoning of Portions 3, 4 and 5 of Haverklip 265 IR was submitted to the Victor Khanye Local Municipality in April 2013. On 23 August 2013 the
rezoning of these portions of land was approved for use as a residue facility. An application for rezoning of the power plant footprint has not yet been submitted to
the municipality. This land is still in the process of being transferred to Kuyasa Mining from BHP Billiton Energy Coal South Africa (BECSA). Once the transfer
agreement is finalised, the rezoning application will be submitted.




Version 1 of the CRR was made available with the Draft Scoping Report (DSR) which was available for public review from 22 March to 11 May 2012.
The EIA process for the above project began in 2007 with site screening and the selection of alternative sites for the project. The EIA application was submitted in the second
half of 2011 and the scoping phase was completed in 2012 when the DEA approved the Final Scoping Report on 7 November 2012.
A Waste Management Licence in terms of the National Environmental Management: Waste Act (NEM:WA), No 59 of 2008 from the DEA;

In addition to the application under NEMA for environmental authorisation, KiPower is also applying for:
An integrated process for the Environmental Impact Assessment (EIA) and the other licence applications listed below is being undertaken for the proposed construction of a
600MW Independent Power Producer (IPP) coal fired power plant and associated infrastructure for KiPower (Pty) Ltd near Delmas in Mpumalanga. The proposed project and
associated infrastructure requires a Scoping and Environmental Impact Reporting (S&EIR) process in terms of the National Environmental Management Act (NEMA), No 107
of 1998 and the EIA regulations (Government Notice Regulation R.543 to 546, published in June 2010). An environmental authorisation from the Department of
Environmental Affairs (DEA) is therefore required in order to construct and operate the proposed power plant.
Version 4
Comments and Responses Report
(DEA Ref No: 12/12/20/2333; NEAS Ref No: DEA/EIA/0000364/2011; AEL Ref No.: 17/4/AEL/MP311/13/01, Ikhwezi Colliery DMR Ref No.:
MP30/5/1/2/2/425MR)
for KiPower (Pty) Ltd near Delmas in Mpumalanga
Construction of a 600 MW Independent Power Producer (IPP) coal fired power plant and associated infrastructure
Comments and Responses Report (Version 4)
2
3.
2.
1.
Requested specialist studies regarding natural
resources e.g. soils, geo-tech, land capability, etc.
and any spatial information indicating the structures
spatially together with the associated symbology
(Shape-Files, ArcGIS 10).
TRAC is responsible for the management and
operation of the N4 Toll Road and thus we are
interested in issues (including proposed
developments) around or affecting the N4 road.
TRAC is concerned about continuous coal supply
and the transport thereof for the power station.
Sasol Gas’ pipelines will not be affected by the
proposed project; therefore Sasol has no objection
against the proposed project.
Requested to be furnished with an electronic copy
of the draft report, as well as the documents which
will be available on 7 February 2014.
COMMENTS, QUESTIONS AND ISSUES
F. ISSUES NOT RELATED TO THIS STUDY
D. SOCIAL ISSUES
E. ECONOMIC ISSUES
B. LEGISLATION AND PROCESS ISSUES
C. BIOPHYSICAL ISSUES
SOURCE
Mr Reggy Nkosi,
Trans African
Concessions (Pty)
Limited
(Environmental Coordinator)
Mr B. Heuvel, Sasol
Gas Limited
Mr Jan Venter,
Department of
Agriculture, Fisheries
and Forestry (DAFF)
Email
Correspondence
24 Jan 2014 and 18
February 2014
Email
Correspondence,
23 January 2014
Email
Correspondence,
21 January 2014
RESPONSE
Noted.
Coal will be transported via overland conveyor from Delmas
Coal to the power station without crossing any roads. The N4
will not be affected by the conveyor. See Section 2.3.4 and
Figure 2-2 of EIR.
A CD with copies of the report was sent to Mr Jan Venter on 14
February 2014.
A CD of the soils shape files was provided to Mr Jan Venter on
25 February 2014.
A. COMMENTS RECEIVED ON THE DEIR
COMMENTATOR
A. COMMENTS RECEIVED ON THE DRAFT EIR
The CRR is categorised as follows:
This report (Version 4 of the Comment and Response Report (CRR)) captures the issues raised by stakeholders since the commencement of the Environmental Impact
Assessment (EIA).
Version 2 of the CRR was made available with the Final Scoping Report (FSR) which was made available for public review from 27 June to 20 July 2012.
Version 3 of the CRR was made available with the Draft Environmental Impact Report (DEIR) which is available from 7 February to 4 April 2014 for public review.
Version 4 of the CRR is currently made available with the Final Environmental Impact Report (FEIR) for public review and comments.
Comments and Responses Report (Version 4)
How much soil will be required for rehabilitating the
ash disposal facility (ADF)?
Asked how long will the topsoil be stockpiled?
How will the ADF be rehabilitated?
How will KiPower ensure that depositing on the
ADF will not create high heaps of ash?
Asked if KiPower has considered redirecting ash
for other market use?
Ash handling facilities, if these fail can cause a
backlog. It was asked if the conveyor has enough
capacity/redundancy.
7.
8.
9.
10.
11.
Requested to be provided with page numbers of
the Draft EIR regarding the following statements:
An environmental impact statement which
contains—
(i) a summary of the key findings of the
environmental impact assessment; and
(ii) a comparative assessment of the positive and
negative implications of the proposed activity and
identified alternatives.
Requested an extension of 12 additional days to
review the draft reports. Mr Hugo provided reasons
as to why they require an extended public review
period, these have been appended to the CRR.
6.
5.
4.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Mandlenkosi
Mahlalela, DEDET
Mr Mandlenkosi
Mahlalela,
Mpumalanga
Department of
Economic
Development,
Environment,
Environment and
Tourism (DEDET)
Mr Mandlenkosi
Mahlalela, DEDET
Mr Frans Mashabela,
DAFF
Mr Frans Mashabela,
DAFF
Mr R Hugo,
Centre for
Environmental Rights.
(Acts on behalf of
Ground Work
Mr Frans Mashabela,
Department of
Agriculture, Fisheries
and Forestry (DAFF)
Dr. Koos Pretorius;
Federation for
Sustainable
Environment
COMMENTATOR
3
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Email
Correspondence,
19 February 2014
Email
Correspondence,
10 February 2014
SOURCE
It is known that ash can be used for cement and brick making. It
is also know that there is an ash overstock especially in
Mpumalanga. The ADF design is based on the worst case
scenario-all the ash needs to be disposed of. Investigations to
use the ash can be pursued by KiPower during operations.
The ash conveyor design allows for spare capacity. There is
also an option of using trucks. Redundancies of blowers and
piping systems in the plant will be utilised to prevent backlog of
Topsoil will be cleared during construction and will be stockpiled
and used for rehabilitating the ADF. Each phase will be
rehabilitated as it reaches a maximum height. It is planned to
use 40cm of soil cover on the ADF – see Section 8.8 of the
Design Report in Appendix H, Volume 2 of the EIR.
Each stockpile will be stored for approximately 5 years.
Depending on the rehabilitation schedule, topsoil may be stored
for much shorter periods.
The ADF will be rehabilitated in phases. The ADF will have a
liner (barrier system), then ash and lastly topsoil. Thereafter the
ADF will be vegetated. See Section 2.4 of the EIR.
Since the ADF will be a licensed waste facility, it will need to
comply with the approved design for the facility and will be
monitored in terms of the approved monitoring programme. It is
therefore highly unlikely that uncontrolled heaps of ash can be
created without meeting the design conditions. See Section 2.4
of the EIR and Section 8 of the Design Report.
The request was considered and accepted. The public review
period was extended until 4 April 2014. A notification was sent to
all registered I&APs on 20 February 2014. See Section 5 and
Appendix K in Volume 2 of the EIR.
Section 12 provides an overall summary of the project as
required of the environmental impact statement. The referencing
to the detailed alternatives assessment given in Section 3 has
been omitted in Section 12 and this cross reference is included
in the Final EIR.
A CD copy of the draft documents was sent to Dr Pretorius on
14 February 2014.
RESPONSE
The project team needs to take into consideration
that when topsoil stockpiles are left out for too long
the soil is sterilised.
Indicated that as authorities they are often
requested to provide comments on various mining
applications on which there is not enough
information regarding the extent and the exact
location of the proposed development.
Requested Jones & Wagener to send Draft reports
to DARDLA for review and comment.
Air quality issues and climate change are linked to
coal fired power stations, and as such these two
aspects need to be considered.
Will the proposed IPP use discard at any stage?
14.
15.
17.
16.
13.
Why did KiPower opt for a 600 Mega Watt IPP coal
fired power plant made up of four 150MW units
instead of two 300 units?
As part of the process to rehabilitate for land use,
the soil has to be replaced by 600 mm for optimum
agricultural use. Mr Venter suggested that thicker
layers of topsoil be used during the rehabilitation
process.
12.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Mandlenkosi
Mahlalela, DEDET
Mr Mandlenkosi
Mahlalela, DEDET
Mr Jan Venter ,
Department of
Agriculture, Rural
Development and
Land Administration
(DARDLA)
Mr Jan Venter ,
Department of
Agriculture, Rural
Development and
Land Administration
(DARDLA)
Ms Ntombifutsi
Mathebula, DARDLA
Mr Mandlenkosi
Mahlalela, DEDET
COMMENTATOR
4
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
SOURCE
An air impact assessment has been included as Appendix L1 of
the EIR. This assessment considers particulate, NOx and SO2
emissions from the power plant, taking into consideration
background levels.
The soci-economic assessment included in Appendix L11 of the
EIR considers the cost of greenhouse gas emissions from the
plant in comparison to other energy technologies. The
Department of Energy and eskom have nevertheless forecast
continued expansion in coal fired power generation in order to
meet medium term demand – see Section 2.10 of the EIR.
The coal supply from Delmas Coal will be low-grade coal not
suitable for other power stations. This low-grade coal would
mostly become discard if the KiPower plant is not built. Kuyasa
The exact location (GPS coordinates) is provided in Section 2.1
of the Final EIR.
Draft Reports were submitted to Mr Oneday Magagula at
DARDLA for comment. A CD with a copy of the reports was
provided to DARDLA at the meeting of 25 February 2014.
The owner and rehabilitation contractor will be bound by a
performance based contract and any augmentation that is
required for the topsoil to yield grasslands will need to be done,
such as the addition of fertilizers both organic and chemical.
ash.
There will be a temporary storage area within the power plant.
The temporary storage area will have sufficient capacity to store
ash for approximately three days. There is a temporary
offloading platform at the ADF that can also provide limited
storage during emergency conditions. See Design Report in
Volume 2 of the EIR.
600 MW is the maximum fit for the site. The design is based on
four 150 MW units instead of two 300 MW units to allow for
better reliability.
The ADF cannot be re-used for agricultural purposes as the side
slopes are too steep and any activity on the slopes will result in
disruption of the storm water canals, pipes and culverts. The
rehabilitation is not meant to meet agricultural land use
requirements but simply to allow for adequate rehabilitation.
RESPONSE
There are two types of rehabilitation, (viz) land use
and land capability. DARDLA prefers land to be
rehabilitated to land capability.
What kinds of issues have I&APs raised regarding
the proposed project. He further explained that he
is interested in knowing what kind of issues have
been raised by I&APs as DARDLA is involved in
multi-stakeholder group meetings that are being
held with authorities, local businesses and local
residents. The purpose of these meetings is to get
an understanding of issues that local communities
are experiencing.
The EIA team asked if Mr Mahlalela is aware of
any issues that were raised by I&APs at the Multistakeholder groups.
20.
21.
Recommended that the next public meeting should
be held during the weekend and in close proximity
to the Sub-highway Community. Some residents
wanted to attend the meeting but did not attend
due to constraints in terms of transport.
Concerned that the proposed IPP coal fired power
plant will affect their health as they live in close
proximity to the proposed site.
23.
24.
22.
19.
The Mpumalanga Parks and Tourism Agency
(MPTA) must be kept updated regarding the
proposed project since there are red data species
within the proposed site
Which land uses have been identified as part of the
EIA study?
18.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Vidalis Mokoni,
Resident: Subhighway Community
Ms Nomcebo
Makhubelo, MYCC
Mr Vidalis Mokoni,
Resident: Subhighway Community
Ms Anelle Lötter
Mr Mandlenkosi
Mahlalela, DEDET
Mr Jan Venter,
DARDLA
Mr Comfort Nxumalo
DARDLA
Mr Frans Mashabela,
DAFF
COMMENTATOR
5
Open day session,
26 February 2014
Open day session,
26 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
Authorities Meeting,
25 February 2014
SOURCE
Mr Mahlalela indicated that I&APs have raised concerns
regarding socio- economic issues and the previous
government’s moratorium on new coal-fired power generation
projects in Mpumalanga. These issues were also raised in this
EIA and are addressed in this Comments and Response Report.
The public participation team visited the Sub-highway
Community, distributed information about the project and spoke
to local residents to obtain their issues and concerns. Delmas
Coal also provided transport for representatives of the Subhighway Community to the public meeting held on 26 February
2014.
Specialist studies were conducted to determine the potential
impacts that the proposed development may have on I&APs. In
summary, potential impacts can be mitigated in such a way that
it will be within the standards set by government. These
standards are based on acceptable health limits. See Section 8
and 9 of the EIR.
The identified land uses are mining and agriculture. Brownfields
areas will be used as far as possible in order to minimise the
impact of the proposed project on agriculture. See Section 4.3 of
the EIR.
The ADF will not be rehabilitated back to land capability since it
cannot be used for agriculture in future. Other disturbed areas
that will not be used during operations will be rehabilitated to its
original land use capability.
The EIA team indicated that all authorities are welcome to attend
the stakeholders’ meeting in order to get a better understanding
of I&APs issues regarding the proposed project.
This CRR reflects all issues raised by I&APs.
Mining is investigating the use of existing discard at Delmas
Coal in this power plant. A long term benefit would be
investigating the use of discards from other mines in the region
in this power plant.
The Mpumalanga Parks and Tourism Agency has been
registered as an I&AP for the proposed project.
RESPONSE
It will be wise if KiPower relocates residents from
the Sub-highway Community to a place where they
will not be affected by the proposed IPP coal fired
power plant.
Residents in the Sub-highway Community currently
live in shacks, and are concerned that the
emissions from the proposed IPP plant will easily
permeate into their houses. Requested that
KiPower build houses for them which will protect
them from the emissions produced by the IPP.
How will the proposed project benefit people from
the Sub-highway Community?
26.
32.
31.
There are many untrained people in Delmas.
People from outside Delmas are employed by the
mines. For this project local people should be
trained and then employed by the contractors.
In the past years mines took unskilled people and
equipped them with skills that enabled them to
work for mines. Nowadays mines only employ
people with the relevant skills.
Requested clarity on the proposed project site.
Concerned that her property might be affected by
the proposed project.
What about impacts on the groundwater from the
power plant and ADF.
29.
30.
We live close to a coal mine but we do not have
electricity.
28.
27.
It is not true that there will be job opportunities as
indicated in the non-technical executive summary
document. Local people are hardly considered for
job opportunities at the mines.
25.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Doctor Mofokeng
Resident from
Extension 2, Delmas
Doctor Mofokeng,
Resident from
Extension 2, Delmas
Ms Louise Korb
Estate Agent: Delmas
Ms Louise Korb,
Dewtar properties
Many participants at
the meeting voiced
this concern
Mr Vidalis Mokoni,
Resident: Subhighway Community
Mr Vidalis Mokoni,
Resident: Subhighway Community
Mr Vidalis Mokoni,
Resident: Subhighway Community
COMMENTATOR
6
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
SOURCE
People currently employed by Delmas Coal will have greater job
security once the IPP plant is constructed. Many people staying
in the Sub-highway Community either work for Delmas Coal or
for contractors of the mine. The community may benefit from the
secondary economic benefits and some people may benefit from
direct work opportunities.
The delivery of electricity to residents is facilitated though the
local municipality and is not the responsibility of independent
power producers. The electricity that will be generated by the
KiPower plant feed directly into the Eskom grid.
The proposed site for the KiPower IPP and its associated
infrastructure was shown on a map to Ms Korb and it was
established that her property would not be directly affected.
All storage dams, materials storage areas, tanks and the ADF
will be lined in accordance with the Department of Water and
Environmental Affairs’ requirements. See the Design Report in
Vol 2.
Kuyasa Mining trains a certain number of people annually in a
variety of technical skills. For this project, contractors will be
required to recruit local people wherever possible. See Section 9
of the EIR.
Kuyasa Mining trains a certain number of people annually in a
variety of technical skills. Their programme of training will
continue, however for the proposed power plant to be
constructed and operated, different skills are required.
A socio-economic study was conducted to estimate the number
of jobs (temporary and permanent) that may be created with the
proposed development. Please see Section 2.7 as well as
Appendix L11 of the EIR. Specific skills will be required and
Kuyasa Mine has undertaken to employ local people if they meet
the skills criteria.
KiPower is not proposing to relocate anyone since the potential
impact of the development will not have a significant negative
impact outside the boundaries of the power plant and ADF. The
emissions produced by the IPP plant will be within the standards
set by government. A programme to continuously monitor the
emissions and regularly monitor ambient levels of particulates,
SO2 and NOx will also be followed to ensure that KiPower will
maintain these standards.
RESPONSE
Why are companies allowed to continue with coal
fired power stations when there was a moratorium
on coal fired power generation in this area?
At what stage of the EIA is this project?
Will the electricity generated from the proposed IPP
be used for Kuyasa mine?
Indicated that Anglo Thermal Coal has received
and Environmental Authorisation for a 450 MW
CFB plant.
Mr Saliwa mentioned that Delmas Coal intends to
develop people, Ms Makhubelo asked which
people will be developed by Delmas Coal?
Students who studied commercial subjects seem to
be excluded by Delmas Coal. What is the
motivation behind funding a Maths and Science
School?
36.
37.
38.
39.
42.
41.
40.
Is Mr Saliwa representing KiPower or Kuyasa
Mine?
Will Non-Governmental Organisations have access
to monitoring data during the operational phase?
35.
34.
Indicated that there was a company that provided
skills in brick laying, however it did not provide job
opportunities for local people.
Will the proposed project supply the community
with clean water and electricity?
Concerned that they will not benefit from the
proposed project although they will be the ones
exposed to all negative impacts posed by the
proposed project.
33.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Ms Lydia Ngwenya
Ms Nomcebo
Makhubelo, MYCC
Ms Nomcebo
Makhubelo, MYCC
Mr Julian Eslait,
Anglo Thermal Coal
Mr Julian Eslait,
Anglo Thermal Coal
Mr Julian Eslait,
Anglo Thermal Coal
Ms Lydia Ngwenya,
Witbank
Ms Lydia Ngwenya,
Witbank
Mr Doctor Mofokeng,
Resident from
Extension 2, Delmas
Ms Nomasonto
Dumo, Delmas
Location
COMMENTATOR
7
Stakeholder
meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
Open day session,
26 February 2014
SOURCE
Delmas Coal has several in-house training programmes for their
staff and the mine plans on opening a center where students
with mathematics and science can further their learning.
There is a shortage of skills in the Mathematics and Science
fields and therefore Delmas Coal wishes to focus on these
subjects. Mathematics and science are key subjects required to
acquire further technical skills and training that will be useful for
the mine and the power station. There are limited commercerelated job opportunities at mines and in industry.
Mr Saliwa is the General Manager for Delmas Coal. Delmas
Coal is one of the subsidiaries of Kuyasa Mining. KiPower will
only have personnel if the proposed power plant is approved to
continue.
Noted.
The proposed project will not supply clean water or electricity to
communities. It is intended to utilize the existing coal from
Delmas Coal to provide electricity into the national electricity
grid.
The proposed development is designed and constructed to stay
within legislated standards thereby limiting negative impacts on
communities.
Monitoring data can be made available on request. Monitoring
data will be provided to the mandated authorities as part of the
license requirements which may be released to NGOs.
The moratorium was lifted in order to allow Eskom to develop
Kusile. The Department of Energy and Eskom have called for
the development of coal-fired IPPs to supplement existing
supply. Thus, government is allowing the development of coalfired power stations. See Section 2.10 of the EIR.
At the time of comment, the specialist studies have been
completed and the Draft Environmental Impact Report was
available for public review. This CRR is attached to the final EIR
that is being submitted to the DEA.
No, the electricity generated will be supplied into the national
electricity grid.
Noted.
RESPONSE
How many local people has Delmas Coal
employed?
Who did Delmas Coal consult with regarding their
intention to establish a Mathematics and Science
school?
How does the Maths and Science school fit into
Victor Khanye Local Municipality’s Integrated
Development Plan?
44.
45.
51.
50.
The information presented is vague and
inadequate.
Asked why local people are not part of the decision
makers. Local people will be negatively affected by
the proposed project; therefore it is only reasonable
to have them as decision makers for the proposed
process.
Delmas Coal needs to take into consideration that
there are people in Delmas who suffer from
silicosis, and it is a concern that the proposed
project will pose additional health impacts to local
people.
Concerned that the proposed project will create a
lot of air pollution.
48.
49.
Was a Social and Labour Plan undertaken as part
of the proposed project?
47.
46.
From which areas do Delmas Coal source their
employees from?
43.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Bongani Nyakalo
Mr Dan Molapo
Mr Siboniso Dlamini
Mr Siboniso Dlamini
Mr Mduduzi Mabena
Mr Mduduzi Mabena
Mr Mduduzi Mabena
Mr Ivan Rakoena
Mr Ivan Rakoena
COMMENTATOR
8
Stakeholder
meeting, 26
February 2014
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meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
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meeting, 26
February 2014
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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SOURCE
Coal fired power stations are historically associated with air
pollution, however new technology is proposed for this project to
ensure significantly reduced emissions. This project will not
exceed the national emission standards. See Section 9.1 and
Appendix L1 of the EIR.
The following information was available on the day of the
stakeholder meeting at the venue:
- Posters providing a summary of the specialist findings
and the integrated authorisation process being followed
and information about the proposed design of the IPP.
- Non-technical summaries of the project were available
in English, Afrikaans and isiZulu – this document
provided and overview of the study and a summary of
the Draft EIR.
The potential emissions from the proposed IPP will comply with
emission standards set by government. The KiPower plant will
not impact on Delmas town. See Section 9.1 and Appendix L1 of
the EIR.
According to Kuyasa Mining, it has made Victor Khanye LM
aware of its intention and has requested land from the
municipality for this initiative.
According to Kuyasa Mining, this has not been explored with the
municipality as yet. Kuyasa Mining wants to educate students
with potential and ability from Grade 8 or so through to university
at their cost. They wish to produce scientists who will contribute
to the development of our country.
Delmas Coal has a Social and Labour Plan (SLP) in place. A
SLP is not required for the proposed IPP because it is not a
mine.
Communities have input via the EIA public participation process
(issues are reflected in this CRR). The authorities will take into
consideration the issues raised by I&APs when they make their
final decision. See also Appendix K in Volume 2 of the EIR.
Opportunities at Delmas Coal are advertised and people are
recruited through advertising that takes places locally and
nationally. It is noted that Delmas Coal is a separate entity to
KiPower.
According to Delmas Coal, 97 of their employees are from the
Delmas Municipal area.
RESPONSE
Mr Saliwa mentioned that Delmas Coal provides a
training programme for about 30 people every year.
Where does Delmas Coal source these candidates
for their training programme?
Has KiPower consulted with residents from the
Sub-highway Community?
57.
59.
If KiPower relocates residents from the Subhighway Community they need to realise that they
are taking away their livelihoods.
The proposed project poses potential negative
health impacts, therefore KiPower must ensure that
the health of residents from the Sub-highway
What will happen to residents from the Subhighway Community? Are they going to be
relocated?
56.
58.
It’s a gimmick that local people will be employed.
No mine has ever created job opportunities. Mines
have taken people for granted.
In another project, Black & Veatch borrowed
money from an international bank in order to
finance the construction of Kusile power station.
The project did not benefit local people. What
guarantee do they have that local people will be
considered for employment opportunities once the
proposed IPP is operational.
The proposed project is funded by tax payers’
money, therefore local people should also benefit
from this IPP project.
The project team needs to take into account that
people in Delmas are familiar with the legislation
and their rights. It is therefore essential that the
project team communicates accurate information
which is aligned with the needs of the community.
55.
54.
53.
52.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Doctor Manana,
ANC
Mr Doctor Manana,
ANC
Mr Doctor Manana
ANC
Mr Bongani Nyakalo
Mr Bongani Nyakalo
Mr Bongani Nyakalo
Mr Bongani Nyakalo
Mr Bongani Nyakalo
COMMENTATOR
9
Stakeholder
meeting, 26
February 2014
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meeting, 26
February 2014
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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SOURCE
The public participation practitioner visited the community,
ensured distribution of the non-technical summary of the EIR,
and representatives of the community were transported to the
public meeting by Delmas Coal.
No residents will be relocated. The project footprint does not
encroach on the Sub-highway Community.
The design for the proposed KiPower IPP was done in such a
way that it will meet national standards for all aspects (e.g. air,
water). Current impacts at the Sub-highway Community are
All information is available for any member of the community to
scrutinize. The information provided is accurate, based on
science and interpreted by an independent Environmental
Assessment Practitioner (EAP). One of the purposes of
arranging a stakeholder meeting is to assist people with any
questions..
It is proposed that a number of people will be employed during
construction of the IPP and later on for the operation of the
facility. Section 2.7 of the EIR indicates the number of
employment opportunities that will be created.
The IPP project location is on property belonging to BHP Billiton
SA. No residents will be relocated. There are no houses or
residents on the proposed footprint for the project. See Section
2.1 and Figure 2-2 of the EIR.
Kuyasa Mining indicates that it sources people with ability and
potential locally and nationally.
CDs with copies of all available draft reports and the
specialist reports.
- Presentations by KiPower, Black & Veatch and the EAP.
Despite requesting more information, I&APs prevented the EAP
from showing its presentation at the public meeting.
For construction, contractors will be requested to recruit locally
wherever possible. Contractors will advertise job and contracting
opportunities in the local media. People with the necessary skills
and required attributes will be considered for the available
openings and opportunities. This aspect is included in the EMPr
(Section 9 of the EIR) which is enforceable through the
Environmental Authorisation.
The proposed project is not funded by tax payers’ money. The
KiPower project is a privately funded initiative.
-
RESPONSE
Indicated that the majority of people do not
understand the information presented in the
reports. Do people understand the potential
impacts posed by the proposed project?
Suggested that the project team must educate local
people about the impacts, both positive and
negative, relating to the project.
The EIA process commenced about three years
ago. He asked if the residents from the Subhighway Community have been consulted.
GroundWork is concerned about the impacts posed
by this type of development.
Requested the project team not to present an
overload of information to an uninformed audience.
Concerned that the Department of Environmental
Affairs has spoken in favour of the proposed
62.
64.
65.
66.
63.
61.
Where will they be relocated too? Indicated that
she does not want to be relocated to the township
as there is a high crime rate. She still prefers
staying on a farm.
It is not clear if local people will benefit from the
proposed project. It seems that the proposed
project is not well planned.
60.
Community is not adversely affected by the
proposed project.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Bobby Peek;
GroundWork
Mr Bobby Peek;
GroundWork
Mr Bobby Peek;
GroundWork
Mr Thomas Mnguni
GMRA
Mr Thomas Mnguni
GMRA
Unknown participant
Ms MaStory Sibeko
Subhighway
Community resident
COMMENTATOR
10
Stakeholder
meeting, 26 Feb
Stakeholder
meeting, 26
February 2014
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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SOURCE
Since the announcement of the project in 2011 advertisements
were placed in the local newspapers and BIDs were delivered at
the Sub-highway Community to inform them of the process and
to invite 64.them to become involved. The community was
visited by the public participation practitioner and
representatives of the community were transported to the
stakeholder meeting by Delmas Coal.
The potential impacts that the proposed development may pose
during its construction and operation have been investigated,
listed and mitigation measures have been recommended. Refer
to the Sections 8 and 9 of the EIR.
Information about the proposed project has since the beginning
of the EIA been provided in different formats, languages and
methods. Stakeholders had the opportunity at meetings to listen
to information and to ask the questions that they had. Posters
were produced for stakeholders to visually receive information
and to ask questions to the project team. Non-technical
summaries of documents in various languages were produced
for those who required an overview of the progress made with
the applications. Full versions of the reports were made
available for stakeholders to receive information.
Comment noted.
related to dust from coal trucks that are offloading at the
Transnet offloading point, adjacent agricultural activities and
possibly operations at Delmas Coal.
No residents will be relocated. The power plant does not
encroach on the community. See Figure 2-2 in the EIR. Impacts
will be within acceptable levels and therefore no-one needs to
be relocated.
The EIR indicates the various measures that will be
implemented during planning and design, construction,
operations and closure. See Section 8 and 9 of the EIR. Benefits
to the local community are detailed in the socio-economic impact
assessment – Appendix L11 of the EIR.
The stakeholder meeting was arranged for stakeholders to
receive more information and to clarify any information that is
difficult to understand. Stakeholders could contact the EAP at
any time to have information explained to them. The information
in the EIR was also presented in a non-technical summary which
was produced in English, Afrikaans and isiZulu.
RESPONSE
The information presented at this public meeting
will not solve problems that they are currently
experiencing.
The project team needs to reconsider a way
forward.
69.
74.
Some community members cannot understand
English. Requested the project team to be
accommodative in terms of language. All
information materials which are being distributed to
the community need to be compiled in relevant
local languages.
It is essential that the decision makers are present
at public meetings. This will make them realise the
type of issues that the affected communities have
regarding the proposed project.
Suggested that the project team must organise
another meeting which will empower people to
have a better understanding of the proposed
project.
72.
73.
One public meeting is not sufficient for this type of
project.
71.
70.
We need energy that will not pose negative
impacts on people’s health.
project prior to receiving the EIR.
The specialist studies undertaken as part of the
EIA process do not address issues that have been
raised by I&APs.
68.
67.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Thomas Mnguni
GMRA
Mr Thomas Mnguni
GMRA, Mr Ivan
Rakoena and Mr
Bobby Peek
Unknown participant
Unknown participant
Unknown participant
Unknown participant
Mr Bobby Peek;
GroundWork
Mr Bobby Peek;
GroundWork
COMMENTATOR
11
Stakeholder
meeting, 26
February 2014
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meeting, 26
February 2014
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meeting, 26
February 2014
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meeting, 26
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meeting, 26
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meeting, 26
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meeting, 26
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2014
Stakeholder
meeting, 26
February 2014
SOURCE
Stakeholders were invited to liaise with the EAP and the project
team if any further information or explanations of the information
was required. The extended comment period has provided
sufficient time for I&APs to make their submissions.
The decision makers were notified of the meeting. All comments
made at the meeting are captured in this CRR which is part of
the submission of final documents to the competent and
commenting authorities.
Stakeholders have the right to information. Information was
presented and made available through different methods during
the open day and the stakeholder meeting. Anyone with
questions, or needing clarification, could contact the EAP.
Another meeting was not held since the EAP was satisfied that
I&APs had sufficient opportunity and time to comment on the
EIR.
The non-technical summary of the draft reports were made
available in isiZulu, Afrikaans and English. The main reports are
only available in English, however anyone can contact the EAP
and the project team for clarifications. The project team has
members on board that can assist stakeholders in most spoken
languages in the country. At the stakeholder meeting, facilitators
were able to accommodate other languages such as Sotho,
Xhosa, Afrikaans and isiZulu.
Those who attended the meeting were invited to liaise with the
EAP with regards to any problems relevant to the proposed
development.
Comment noted.
I&APs are invited to comment on the specialist studies and if
they note any gaps to bring that to the attention of the EAP. The
purpose of making available draft reports is for stakeholders to
verify that their comments in the scoping phase have been
addressed. The CRR included in the Draft EIR indicated how
stakeholder issues were addressed. This CRR indicates how
comments and issues raised during the public review of the
Draft EIR are addressed.
Comment noted. The project team is following the regulatory
process stipulated by government.
RESPONSE
KiPower must organise another meeting to discuss
the proposed project. They must ensure that their
management team is present at the next meeting
since they are the decision makers.
Indicated that based on their (stakeholders’)
background, they are not well resourced people.
Therefore, they cannot afford to make copies of the
Draft reports. Requested to be provided with a hard
copy of the draft reports.
We are being taken for granted by mines and
corporate companies. Mines are not prepared to
communicate with the affected communities.
Requested information regarding the exact location
of the proposed power station (GPS co-ordinates)
81.
84.
83.
82.
80.
Almost 50% of the land is infested with mines.
Consultants do not have resolution in terms of
decisions to be taken by mines.
Has KiPower consulted with communities in Devon
and Leandra?
KiPower needs to empower and consult with local
people. Poor people need to be consulted prior to
decisions being taken.
The extent of the impacts should be discussed with
I&APs
People who live in Brakfontein are equally affected
by the proposed project, Brakfontein is not an
island.
The public review period is not enough to review all
the reports. The reports are too technical, is it not
possible to translate the reports to IsiZulu?
79.
78.
77.
76.
75.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Rico Euripidou
GroundWork
Mr Bongani Nyakalo
Mr Mduduzi Mabena
Unknown participant
Lwandle
Mr Dikgetsi
Sepenyana
Mr Thomas Mnguni
GMRA
Ms Lydia Ngwenya
Ms Lydia Ngwenya
Mr Bongani Nyakalo
COMMENTATOR
12
Stakeholder
meeting, 26
February 2014
Email
Correspondence, 27
February 2014
Stakeholder
meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
Stakeholder
meeting, 26
February 2014
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meeting, 26
February 2014
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meeting, 26
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Stakeholder
meeting, 26
February 2014
SOURCE
The EIA and related applications were advertised in the Springs
Advertiser and the Streeknuus newspapers that do cover the
Devon and Leandra areas. Copies of all draft reports were also
placed in libraries at Leandra and Devon.
The management of the proponent was available at the
stakeholder meeting on 26 February 2014. The EAP does not
believe another meeting is required. At this stage, the decision
rests with the regulatory authorities.
CD copies of the report were available at the meeting. Of the 55
copies, 53 were taken by I&APs who attended the meeting. Hard
copies of the reports are available at the public places of which
the availability was advertised. An electronic copy of the report
was also available on the web site as advertised.
The open house and public meeting on 26 February 2014 were
arranged for any interested and affected party to meet with the
EIA project team and Kuyasa Mining.
AEL application form provides WGS84 LO29 coordinates of the
site’s centre point, location of stacks and auxiliary boiler stack
and SW corner of ADF, plant area, stockpile areas, etc. See
Table 5.4.1 and Table 5.4.5. The form is provided in Appendix
E2 of the EIR. The stack height is 150 metres above ground
level.
The Brakfontein community has had opportunity to comment on
the Draft EIR. The impact assessment indicates there will be no
impacts at Brakfontein.
The public review period was extended on request for another
12 days until 4 April 2014. The reports are technical and will not
be less technical if these are translated. Stakeholders were
invited to contact the project team if any information has to be
clarified. The open house and stakeholder meeting provided the
opportunity for I&APs to liaise with the project team and obtain
first hand explanations on the technical issues.
The public participation process for this project goes beyond the
requirements of the EIA regulations in order to ensure I&APs
were properly involved.
The posters and presentations were specifically designed to
ensure all potential impacts could and would be discussed. On
26 February 2014, posters were used to explain the project,
potential impacts and proposed mitigation.
Opinion noted.
RESPONSE
What is the exact height of the stacks of the
proposed IPP?
What will the annual emissions of all parameters
that will be regulated under the Air Quality Act and
associated regulations (S21 MES) be?
Requested information regarding emission rates
and the projected load factor
What are the exact stack emission concentrations
for the proposed power station
What is the thermal efficiency of this proposed
power station
What will the load factor of the proposed power
station be?
Requested information on all available information
on the coal quality including the calorific value, the
thermal efficiency, heavy metals analysis (including
for mercury, and cadmium) for the proposed
KiPower power station.
I would like to register as I&AP for the
environmental authorisation processes for this
power station project. Could you please forward me
any relevant information regarding the different
authorisations being applied for as well as the
status and progress thereof?
85.
86.
87.
88.
89.
90.
91.
92.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Riaan Fourie
Environmental
Analyst
Green Fund
Environmental
Finance Unit,
Development Bank
South Africa (DBSA)
Mr Rico Euripidou
GroundWork
Mr Rico Euripidou
GroundWork
Mr Rico Euripidou
GroundWork
Mr Rico Euripidou
GroundWork
Mr Rico Euripidou
GroundWork
Mr Rico Euripidou
GroundWork
Mr Rico Euripidou
GroundWork
COMMENTATOR
13
Email
Correspondence, 6
March 2014
Email
Correspondence, 27
February 2014
Email
Correspondence, 27
February 2014
Email
Correspondence, 27
February 2014
Email
Correspondence, 27
February 2014
Email
Correspondence, 27
February 2014
Email
Correspondence, 27
February 2014
Email
Correspondence, 27
February 2014
SOURCE
Coal analysis conducted by Eskom is given in Table 1 of the
Eskom Coal Testing Report – Appendix J of the EIR.
The mercury content is discussed in Section 2.2.6 of the Air
Quality Impact Assessment – Appendix L1. The original analysis
was made available to Mr Euripidou.
Cadmium analysis was not carried out on coal but on the ash as
part of the waste classification process. See Appendix G of the
EIR.
Mr Fourie was registered as an I&AP and all relevant information
was forwarded to him via email.
AEL application form provides this information. See Table 5.4.1.
The form is provided in Appendix E2 of the EIR. The stack
height is 150 metres above ground level.
AEL application form provides regulated emissions as requested
by MDEDET (competent authority for the issuing of AELs) under
Section 5.4. Table 5.4.6 provides maximum release rate per
annum for regulated emissions. The form is provided in
Appendix E2 of the EIR.
AEL application form provides regulated emissions as requested
by MDEDET (competent authority for the issuing of AELs) under
Section 5.4. Table 5.4.6 provides maximum release rate per
annum for regulated emissions. The form is provided in
Appendix E2 of the EIR.
AEL application form provides regulated emissions as requested
by MDEDET (competent authority for the issuing of AELs) under
Section 5.4. Table 5.4.6 provides maximum release rate per
annum for regulated emissions. The form is provided in
Appendix E2 of the EIR.
Table 2.1 of the EIR indicates boiler efficiency. The Eskom Coal
Testing Report indicated efficiencies for various combinations of
coal and sorbent – see Appendix J of the EIR.
It is not clear what “load factor” means. The design basis for the
IPP is given in Table 2.1.
RESPONSE
94.
93.
3. In summary, the NEMA principles must be
integrated into decision making including the
authorization of activities listed under section
24. Actual and potential socio-economic
impacts, risks and consequences, and
alternatives and options for mitigation must be
2. Our second submission is that application is
also not compliant in that it has failed to
properly assess the costs and benefits of the
proposed plant as required by the Department
of Water and Environmental Affairs.
1. The authorisation should not be granted as it
fails to comply with the regulatory scheme for
impact assessment and environmental
authorization under NEMA. We base this
submission on the following points:
a) NEMA requires an assessment of the socio
economic impacts of the activity applying for
authorisation in terms of section 24 of NEMA.
b) This assessment requires the application of the
NEMA principles including the choice of the
best practicable environmental option (BPEO).
c) The best practicable environmental option
requires a cost benefit analysis of the
alternatives to the plant as well as the plant
itself. The regulation for EIA’s set out the
requirements for the consideration of
alternatives.
d) This was not done and hence the application is
not complaint.
Please send me all the slides that you guys had
hung up around the room and the lapa that day (26
February 2014).
The submission from the Legal Resource
Centre is a document of 16 pages and is
attached to the CRR. Below is an overview of
the main points. Please refer to the attachment
for a complete version of the comments made
by the LRC.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Legal Resource
Centre on behalf of
the Federation of
Sustainable
Environment (FSE)
Mr Bobby Peak,
GroundWork
COMMENTATOR
14
Email
Correspondence, 6
March 2014
Submission in
response to the
DEIR, 4 April 2014
SOURCE
4. A detailed consideration of alternatives, including estimated
3. Internal and external costs are discussed in depth in the
socio-economic assessment that is included in Appendix
L11. External costs related to air quality are addressed in
the socio-economic assessment in Appendix L11. Water is
seen as an operating cost since the water supply does not
negatively impact on the communities (external costs would
apply, for example, to ground water usage, which is not
envisaged for this project).
2. Refer response 1c above.
1. Compliance with regulatory requirements:
a) A socio-economic assessment is included in the Social
Impact Assessment (Appendix L11 of the EIR), and was
summarised in the EIR.
b) The selection of alternatives detailed in the EIR indicates
that the most appropriate site and technology was chosen
for this project.
c) The BPEO needs to consider a cost that is acceptable to
society – this does not mean a cost-benefit analysis is
required. The selection of the preferred site included an
analysis of capital and operating cost. The preferred
technology was based on ensuring limited environmental
impact and therefore costs were not considered, based on
the requirement that the project would be coal fired. Kuyasa
Mining is a coal mining company wishing to establish a coalfired power plant to utilize its low grade coal. The socioeconomic assessment indicates the external costs of the
project. Lastly, the Department of Energy and Eskom have
both indicated that new coal fired power stations are still
required to meet medium term demand projections.
d) Given the above, the EAP wishes to note that the NEMA
application is indeed compliant with the legislated
requirements.
A CD with posters that were displayed at the stakeholder
meeting was sent via Speed Services to the postal address of
GroundWork.
This response is based on the submission from the LRC, under
each of the numerically summarized issues in the first column.
RESPONSE
7. The cost benefit analysis for the plant is
deficient in the following respects:
a) The report fails to assign any meaningful cost
estimates to the impacts associated with the
project;
b) For most externalities, the report fails to assign
any value;
c) The report leaves out important impacts that
6. Before the decision-maker can exercise
discretion whether to authorize the plant, it
must have sufficient information on
alternatives, their costs and benefits to
determine whether the plant is in fact the
BPEO. It cannot rely on broad policy
considerations about future energy to exclude
consideration of alternatives, and which are
under review and not cast in stone. The EIA
has failed to follow this approach redering any
decision to the authorize the plant as noncompliant with NEMA and PAJA.
5. The scoping report confines the assessment to
the plant only, avoiding a consideration of the
BPEO and of possible impacts and costs of
alternatives. This has rendered the process
flawed.
4. It is submitted that the EIA requires a
consideration of alternatives in order to
determine the BPEO, at the very least a cost
benefit analysis, given that the BPEO requires
the benefit as well as the potential damage to
be assessed and the acceptable cost to society
to be determined.
considered, with a view to their minimization.
Socio economic impacts are not defined in
NEMA. It is submitted that these must at
minimum include the actual as well as the
externalized costs of the KIPOWER plant, on
water, and air quality.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
COMMENTATOR
15
SOURCE
9. External cost related to the loss of land is discussed in Table
3.10. Mining raw materials were not discussed since these
materials would be mined irrespective of whether the
KiPower project goes ahead or not. The advantage of
KiPower potentially using discards that are current
8. The emissions were estimated and then subject to
dispersion modeling to predict worst case ambient levels in
order to assess whether the plant could exceed ambient
standards. These are included in the air impact assessment
in Appendix L1.
7. The economic section of the social report includes the
following:
a) Table 3.10 which assigns values to benefits and impacts.
b) Climate change is discussed in Table 4.2 Impact
Assessment.
c) Human health externalized costs are provided in Table 3.10.
6. The consideration of alternatives is based on the technical,
environmental and economic aspects of the project: sites,
technology, services and utilities. The site selection does not
only look at the plant, but also at the ADF and modes of
transport (Section 3). The energy policy considerations were
not part of the consideration of alternatives but part of the
motivation for the project given in Section 2.10. This policy
indicates that new coal-fired power stations will be required
to meet medium term demand projections. Kuyasa Mining
wishes to exploit the availability of low grade coal to meet
part of the medium term need. Therefore other sources of
energy were not considered as reasonable and feasible
alternatives due to an existing energy source.
5. See above responses. The consideration of alternatives
covered sites and technology options (Section 3).
costing for different options was carried out and is included
in Section 3 of the EIR. A cost benefit analysis of the
preferred option would indicate the cost to society, and the
EIR details the benefits and potential negative impacts of the
project on the local environment in Sections 8 and 9, and in
the Socio-economic Impact Assessment in Appendix L11.
RESPONSE
Who will be receiving the power that is generated
by the proposed IPP facility?
Where do you propose to abstract your water from
for the planned facility?
What will be done with the sewerage generated at
the proposed facility?
Why was a mine stability assessment undertaken?
97.
98.
99.
100.
96.
95.
should have costs assigned to them, such as
the impact on climate change and potential
impact on human health.
8. The assessment of external costs does not
include values for SO2, NOx, particulates,
VOC’s and NH3.Although the EIA indicates
these emissions will be lower than
conventional, these emissions have not been
estimated for the EIA which is a glaring
omission.
9. The additional external costs for the ADF,
mining raw materials and water consumption
needs to be quantified.
10. Other energy sources were not considered.
A meeting was requested by the Executive Mayor
of Victor Khanye Local Municipality to be briefed
about the proposed project.
How many job opportunities will be created during
construction and once the proposed IPP project is
operational?
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Fiona Grimett
Environmental
Officer: Integrated
Permitting System,
DEA
Mr Floyd Mashele,
Executive Director
Technical Services
Victor Khanye LM
Mr Floyd Mashele,
Executive Director
Technical Services
Victor Khanye LM
Ms Eva Makhabane
Executive Mayor
Victor Khanye LM
Ms Eva Makhabane
Executive Mayor
Victor Khanye LM
Ms Eva Makhabane
Executive Mayor
Victor Khanye LM
COMMENTATOR
16
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Email in response to
the DEIR, 17 March
2014
Meeting on 8 April
2014
SOURCE
A new bulk water pipeline will be constructed to supply KiPower
from the existing Rand Water supply. A Basic Assessment is
being conducted for this purpose. Water will also be sourced
from a local quarry, viz. Sam Quarz. See Section 3.5 of the EIR.
The proposed IPP design includes a sewage treatment plant
and during construction chemical facilities will be used. The
treated sewage effluent will be re-used in the plant. See Section
2.3 of the EIR.
A mine stability assessment was undertaken to ensure that the
IPP facility is not located on unstable, undermined land. This
assessment is required by the DMR.
A meeting and site visit was held on 8 April 2014, involving Ms
Eva Makhabane and Mr Floyd Mashele of the Victor Khanye
Local Municipality.
Construction of the IPP is planned for over a three year period.
At its peak in this period it is estimated that some 3000 people
will be employed. Between 160 and 200 long term jobs will be
available during the operation of the facility. Limited job
opportunities such as for the rehabilitation of the wetlands will
also be created. Labour requirements are summarised in
Section 2.7 of the EIR.
This plant will feed directly into the Eskom grid.
10. Kuyasa Mining did not consider other energy sources since
it is in the coal mining sector and wishes to exploit the low
grade coal currently mined at Delmas Coal. Therefore other
sources of energy were not considered to be reasonable
and feasible alternatives due to an existing energy source.
environmental liabilities is also not included although such
consideration would favour the project. Costs for water
consumption were not included since this is seen as an
operational cost and the use of Rand Water by this project
will not result in an increased cost for potable water in the
region.
RESPONSE
Is the proposed wetland offset strategies part of the
DEIR documents?
How long will the proposed construction of the IPP
project be?
The traffic on the R50 is increasing and it is
suggested that warning lights be placed ahead of
the crossing to the entrance of the proposed IPP
road.
We would like to suggest that the developer
maximize on local labour and that the larger
component of the work force be from Delmas.
Often after the construction of such large projects,
there is a community that has settled themselves
on or close to the construction site that cannot
sustain themselves. This often becomes the
problem of the local municipality since people just
settle on available land and should be serviced. It
is suggested that the construction activities be ringfenced to make it impossible for people to stay
close by or on the premises where construction is
taking place.
Are there any graves that have to be relocated?
What are the incentives for Delmas Coal in
implementing the proposed project?
102.
103.
104.
108.
107.
106.
105.
What would the impact of air pollution from the IPP
be?
101.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Mr Floyd Mashele,
Executive Director
Technical Services
Victor Khanye LM
Ms Eva Makhabane
Executive Mayor
Victor Khanye LM
Fiona Grimett
Environmental
Officer: Integrated
Permitting System,
DEA
Ms Eva Makhabane
Executive Mayor
Delmas
Mr Floyd Mashele,
Executive Director
Technical Services
Victor Khanye LM
Ms Eva Makhabane
Executive Mayor
Victor Khanye LM
Mr Floyd Mashele,
Executive Director
Technical Services
Victor Khanye LM
Ms Eva Makhabane
Executive Mayor
Victor Khanye LM
COMMENTATOR
17
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
Meeting on 8 April
2014
SOURCE
In addition to Delmas Coal selling its high grade coal to Eskom,
it will utilize its low grade coal to generate electricity that can be
sold to Eskom.
The graves that were located in the proposed project’s footprint
have already been exhumed and relocated. See Section 4.8.3 of
the EIR.
The Environmental Management Programme recommends that
the contractor should implement a detailed and approved
accommodation plan to avoid such a problem. The contractor
should also establish a control committee with adjacent
landowners to ensure a multi-level approach to avoid such
challenges.
Contractors will be required to maximize the use of local labour
as far as possible.
This has been included in the EMPr of the EIR. See Section 9.
It is proposed for three years. See Section 2.7.1 and 2.9 of the
EIR.
Dust (particulates), NOx and SOx are the key emissions of
concern – these are addressed through a number of design
measures such as a 150metre high stack (minimum height),
addition of sorbent, CFB technology and regular monitoring of
emissions and local ambient air quality. The IPP will be operated
within the national standards for air emissions. Meeting these
standards will ensure that human health is protected at an
acceptable level. See Section 8 and Appendix L1.
Yes, the report is included in the suite of documents. There are
five wetland rehabilitation strategies, all of which will take place
on Kuyasa Mining’s property. See Appendix L16.
RESPONSE
The submission from the Centre for
Environmental Rights is a document of 38
pages and is attached to the CRR. Below is an
overview of the main points. Please note every
point below is substantiated in the submission
– please refer to that for more detail.
The applicant submits that the proposed coal
station will entail circulating fluidised bed (“CFB”)
technology to burn coal and produce electricity so
as to make use of Delmas Coal’s lower grade
discard coal and to control the emissions
emanating from the station. This submission does
not address whether any additional coal power
generation projects - and the emissions these
entail - should be considered at all within the
Highveld Priority Area (“HPA”), why such
technology cannot be employed elsewhere outside
the HPA, or why an alternative use for the discard
coal and pit rehabilitation - which does not entail
the use of non-renewable energy and greenhouse
gas emissions – cannot be considered.
An air quality management plan for the HPA was
promulgated in 2012 (the “HPA Management
Plan”). The HPA Management Plan applies to the
entire priority area, including that in which the
proposed coal station, Delmas Coal and Ikhwezi
Colliery are located, in light of the “total estimated
emissions” of the HPA and so as to “achieve and
maintain compliance with the ambient air quality
standards across the HPA, using the Constitutional
principle of progressive realisation of air quality
movements.” As further detailed below, our clients
submit that there is no basis for the applicant’s
nonsensical and opportunistic suggestion that the
HPA Management Plan applies only to previously
established point source emissions and does not
include the cumulative emission contributions from
future point sources in the HPA. In fact, the
applicant itself submits that the focus of air
110.
112.
111.
What is the proposed lifespan of the Delmas Coal
mine?
109.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Ms Eva Makhabane
Executive Mayor
Delmas
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
COMMENTATOR
18
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
Meeting on 8 April
2014
SOURCE
Future emitters must comply with the national emission
standards at commencement of operations.
Neither the EAP nor the applicant suggested that only current
emitters need to comply with the HPA management plan.
It was simply pointed out that measures in the HPA
management plan are aimed at current emitters only, and does
not provide guidance to future emitters.
It is noted that the HPA management plan does not indicate that
future emitters will not be allowed to develop in the area.
It is not for a single entity such as KiPower to consider whether
additional coal power generation should be considered in the
HPA. This issue is addressed by the Department of Energy in its
energy forecast and by Eskom in its recent IRP, which indicates
that the country will continue to be reliant on coal power
generation (see Section 2.10 of the EIR). The development of
Kusile is an indication that additional coal power generation has
been accepted in Mpumalanga. It is also not for the applicant to
determine if CFB cannot be employed outside the HPA – this is
a potential strategy government could apply to address the
energy demand. The alternatives for coal discard and for pit
rehabilitation would need to be considered by Kuyasa Mining in
their update of their EMPRs since the liability belongs to the
respective mines and not to KiPower. KiPower has simply
provided an alternative for these existing liabilities.
The project is based on compliance with the national standards
for emissions and ambient air quality, which would ensure
compliance with the HPA management plan.
This response is based on the submission from the CER, under
each of the summarized issues in the first column.
30 years. See Section 1.1 of the EIR.
RESPONSE
119.
118.
117.
116.
115.
114.
113.
Discrepancies in the procedure underlying these
reports (DEIR and its appendices) in that the
applicant fails to:
a. submit considerations independent of the
submission that ultimately the proposed coal
power station is to generate 2 000 MW, and not
the 600 MW apparently subject to the current
EIA process;
b. comply with the requirements for public
participation, so as to ensure transparency and
accountability;
c. prove the required experience in environmental
management, so as to ensure the pollutant
control and mitigation of the proposed coal
power station;
d. ensure the undertaking of the specialist expert
reports in a comprehensive, transparent and
accountable manner;
e. ensure that all relevant information is
considered and that irrelevant considerations
are not taken into account (specific relevant
information is given in the CER submission);
f. recognise the integral requirement that the
cumulative impacts of environmental
consequences be assessed.
pollution control is on the receiving environment
and not the source.
We note the applicant’s submission that no building
plans are to be submitted regarding change of land
use.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
COMMENTATOR
19
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
SOURCE
a) The project is based on a 600MW plant only. The plant
layout, sizing and utilities are based on a 600MW plant. Any
proposed expansion to 2000MW would be subject to a new
authorization process.
b) The public participation process meets all the legislated
requirements and includes best practice procedures and
methodologies.
c) KiPower IPP plant will have its own environmental
management team, based on the organogram presented in
Appendix G of the EIR.
d) The approved TOR’s for the specialist studies were adhered
to, and any deviations were highlighted in the EIR. See
Section 6.2 of the EIR.
e) Delmas Coal’s current operations and commitments for
supply of coal were not provided since it is a licensed
operation. The transmission connection is still being
investigated by Eskom. Supply agreements still need to be
negotiated with respect to limestone. Flooding potential is
discussed in the Surface Water Impact Assessment
(Appendix L2 of the EIR). Financial information regarding
Delmas Coal and Ikhwezi Colliery is considered confidential
by these entities. Capital and operating costs for the power
plant are provided in the Socio-economic Impact
Assessment (appendix L11). Macro-economic benefits and
social funds are also given in Appendix L11.
f) Cumulative impacts are discussed in the EIR – see Section
9.4 of the EIR. Quantification is not possible without a
structured source of information for the municipality, province
and country on air quality, water, soils, biodiversity, etc.
The rezoning process for the ADF met the requirements of
Victor Khanye LM. The same process will be followed for the
power plant site. However, should the Victor Khanye LM require
building plans these will be submitted during the detailed design
phase of the project.
RESPONSE
The applicant’s failure to establish the need and
desirability of the proposed coal power station in
that it:
a. refers to the need for coal-based electricity
in a misleading and outdated manner that
confuses the increasing demand for
electricity with the imperative that this
electricity be coal-based, conflates the
need for new coal-based electricity
(particularly that from domestic sources)
and attempts to detract from the
requirements for rigorous assessment of
the project and available alternatives;
b. elevates the benefits of CFB technology, if
properly employed, above that which is to
become a standard requirement for all new
coal-based power generation and in
disregard for the need for carbon capture
and storage (CCS) mechanisms so as to
control climatic impacts;
c. places a high value on the use of low
grade coal discard by the proposed coal
power station in disregard for the
abundance of South African coal, Kuyasa
Mining’s obligations to manage its coal
discard (regardless of the establishment of
the proposed coal power station), the
prerogative of new coal-based power
generation to use CFB technology so as to
use lower grade coal, and the national
policy and obligations to diversify energy
supply sources and control climate change;
d. over-emphasises and misconstrues the
creation of downstream opportunities.
The applicant’s failure to investigate alternatives in
any real sense, in its basis of the project on the use
of coal discard at Delmas Coal and the cleaning up
of the pollution incurred at Ikhwezi Colliery, as well
as its assumption that proximity to Delmas Coal
and Ikhwezi Colliery are non-negotiable factors due
to “economic reasons”, despite the related
environmental impacts.
120.
121.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
COMMENTATOR
20
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
SOURCE
The consideration of alternatives is comprehensive and was
accepted by the authorities when the scoping report was
approved.
The project is based on the use of low grade coal from Delmas,
and the feasibility of using coal discard is still being investigated.
Delmas Coal and Ikhwezi Colliery are governed by their own
permits and licenses and cannot be governed by any licenses
issued to KiPower.
a) The need and desirability of the project is given in the EIR –
see Section 2.10 of the EIR. This need is also addressed in
by the Department of Energy in its energy forecast and by
Eskom in its recent IRP (2013), which indicate that SA will
continue to be reliant on coal fired power generation for the
foreseeable future – see Section 2.10 of the EIR.
b) The advantages of CFB technology and of using low grade
coal are factually presented and are not elevated.
c) The emphasis on low grade coal is an opportunity to use this
natural resource to assist in meeting the energy need SA is
facing.
d) The methodology for estimating downstream opportunities is
based on standard economic practice – see Appendix L11 of
the EIR.
RESPONSE
The applicant’s failure to recognise the legal and
factual importance of the location of the proposed
coal station within the HPA and, concurrently, the
importance of the cumulative effect of emissions
within this area. The applicant’s attempts to
undermine the importance of the definition of the
HPA by focussing on the proposed coal power
station being a future project outside the air
emission “hot spots” (despite the clear application
of cumulative air quality and the dispersive nature
of air impacts and the forward-looking nature of the
HPA Management Plan) is, our clients submit,
nonsensical and opportunistic, and is contrary to
the focus of the air pollution control on the
receiving environment as opposed to the source.
The problematic nature of the applicant’s point
source emissions, including the applicant’s failure
to consider the impact of the proposed coal power
station on climate change, both in terms of its real
effects and its violation of South Africa’s
international obligations to reduce greenhouse gas
124.
125.
123.
The premise of the project on the failure of Delmas
Coal to manage its discard coal and the failure of
Ikhwezi Colliery to comply with the required
rehabilitation and closure schemes with the
concurrent environmental liabilities. As such, the
applicant overlooks the responsibilities of Delmas
Coal and Ikhwezi Colliery in accordance with the
“polluter pays principle”, regardless of any further
developments in respect of the proposed coal
station, and assumes the faith of the decisionmaker in its abilities to mitigate the environmental
impacts of the proposed coal power station, despite
these past environmental transgressions.
The applicant’s failure to prioritise the location of
the proposed coal power station within a sensitive
wetland area bordering on the sensitive Wilge
River, catchment and tributaries.
122.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
COMMENTATOR
21
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
SOURCE
The CO2 emissions cannot be mitigated, as highlighted in the
EIR. It is therefore up to the mandated authorities to decide if
this project should go ahead or not, taking into account SA’s
international obligations in terms of GHGs and taking into
consideration the energy needs of SA.
As indicated in the EIR, wetlands were avoided as far as
possible. A wetland offset strategy has been developed to
improve current and future impacts, and there will be no
discharges to the Wilge River due to its sensitivities – see
Appendix L16. All dirty water systems have been sized in
compliance with GN704, which requires that spillages may not
occur more than once in a 50-year period – see Appendix L2 of
the EIR.
The HPA is highlighted as a concern in the report. CFB
technology is considered the most appropriate coal fired
technology due to its reduced emissions, which will ensure the
power plant meets the national emission standards, as is
required of new emitters in the HPA.
The project is not based on Delmas Coal or Ikhwezi Collieries
management.
Through the site selection process, it was determined that the pit
could be used and it would be a beneficial to the environment if
it is used. The location of the power plant and ADF on
brownfields sites is beneficial for the environment since
greenfields sites are not impacted on. The project does not in
any way assist Delmas with its current environmental
management liabilities.
The project will use low grade coal. The possibility to use
discard is being investigated.
RESPONSE
128.
127.
126.
The effect of the proposed coal power station on
the vital water sources in area in that:
a. the large scale water need of coal-based
power generation will be drawn from an
overburdened source in a water deficit
area, with no proper investigation of
alternatives, despite the request from the
DWA that alternate sources be identified;
b. the proposed location of the development
in an area of such significant hydrological
sensitivity that the DWA has made public
its intention to declare the Wilge River
catchment “a Class 2 river system in order
to seek to protect Mpumalanga’s water
resources” meaning that “no new impacts
will be tolerated within this catchment”36this sensitivity is exacerbated because the
primary aquifer in the area is highly
susceptible to surface-induced impacts and
activities due to its intrinsic unconfined and
semi-unconfined piezometric conditions;
and
c. the significant discrepancies in the
applicant’s hydrological assessment
procedures, together with Kuyasa Mining’s
history of environmental non-compliances,
raise concerns about the applicant’s ability
emissions.
The applicant’s wholly inadequate assessment of
the waste implications of and procedures for the
proposed coal power station with the associated
ADF, despite the potentially severe environmental
implication of the development including the effects
of hazardous waste streams (involving boiler ash
and waste water), ash radioactivity and
contaminated land;
The applicant’s avoidance of a proper analysis of
the water uses necessary for the proposed coal
station, as required at the draft EIA stage, by
inferring that this will be conducted during the
IWULA as part of the final EIA reports.
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
COMMENTATOR
22
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
SOURCE
a) The water demand, water supply and alternatives to water
supply are discussed in the EIR (see Section 3.5).
b) The sensitivity of the location is highlighted and it is ensured
in the design that the Wilge River will be protected. All dirty
water systems have been sized in compliance with GN704,
which requires that spillages may not occur more than once
in a 50-year period – see Appendix L2 of the EIR. A wetland
offset strategy is also proposed (see Appendix L16).
c) The Surface Water Impact Assessment is in line with best
practice methodology for hydrological assessments. The
KiPower plant will be governed under current legal
requirements. Kuyasa Mining’s other entities operate under
older legal requirements and therefore projects to bring
these operations in line with current legal requirements were
presented by Mr Saliwa at the public meeting of 26 February
2014
All areas and activities that would require a water use license
are discussed in the project description in Section 2 of the EIR.
The IWULA will simply structure these into the water use
categories required by DWA.
A waste licence report is included in the EIR and addresses all
waste related issues. The waste classification concluded that the
waste has a low hazardous rating (Type 3) – see Appendix G of
the EIR.
RESPONSE
The LRC clients do not accept the backwardlooking manner in which the proposed coal power
station has been conceived, particularly in light of
the potentially disastrous environmental
consequences of this proposed development and
the applicant’s history of legal non-compliance. As
such, our client fails to comprehend any
justification for the valid authorisation of the
proposed coal power station, and it submitted that
it should not go ahead. In the circumstances, our
clients submit that all relevant authorities should
reject the reports and/or refuse the relevant
applications.
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
Centre for
Environmental Rights
representing
GroundWork and
several community
groups
to ensure the containment of all
contaminants and, thereby, to validate the
proposed mitigation measures.
The applicant’s failure to consider the health
impacts of the proposed coal power station,
regardless of the indications that the potential
health impacts and economic burden associated
with the project would be substantial in relation to
the economic value created, as well as in relation
to the costs of alternative non coal-based
technologies with significantly lower public health
impacts.
Written submission
in response to the
DEIR, 4 April 2014
Written submission
in response to the
DEIR, 4 April 2014
SOURCE
The health related impacts are taken into consideration through
the various specialist assessments, by ensuring the project
complies with national standards for emissions, air quality, water
quality and waste management. By complying with national
standards, potential health impacts are negated since these
standards are based on acceptable levels of pollutants to ensure
health related impacts do not occur (acceptable levels of
pollutants are normally based on a conservative approach).
Existing health impacts in the HPA are due to non-compliance
with national standards of Eskom and other industrial
installations in Mpumalanga as detailed in the HPA management
plan.
Opinion noted.
RESPONSE
All the comments, questions and issues following from B. onwards have been included as an appendix in the DEIR and was previously presented as Version 3 of
the Comments and Response Report
130.
129.
COMMENTATOR
23
COMMENTS, QUESTIONS AND ISSUES
Comments and Responses Report (Version 4)
Failure to place the following considerations
in front of the decision maker:
 The process of weighting the criteria
skews the findings
 Specialist site visits are required to
confirm assumptions in the report
therefore the report is incomplete and
inconclusive.
 The scoping report was required to
place a higher weight on considering
the socio-economic and cultural
impacts of the proposed project.
(The complete comments have been
4
3
2
KiPower (Pty) Ltd is a separate entity to
Kuyasa Mining, and it is an industrial
company and not a mining company.
The core function of the power plant is an
industrial activity which is isolated from the
mining activity. The power plant must be
dealt with as an industry that it is not
sufficiently linked with mining. All the power
plant would use is coal from a mine.
If the project falls on mining land, then
Delmas Coal would need to amend their
Environmental Management Programme to
incorporate rehabilitation aspects. Each
entity (Delmas Coal and KiPower) would
have their own authorisations and legal
operations,
We do not want people entering our
properties without permission.
1
COMMENTS, QUESTIONS AND
ISSUES
Comments and Responses Report (Version 4)
SOURCE(S)
Ms Nerisha Baldevu
Sustainable Energy &
Climate Change Project (A
project of Earthlife Africa
JHB)
Mr Johan Claassens,
Haverklip / Vangatfontein
and Mr Johan van Dyk,
Haverklip.
Mr Kenneth Cameron,
Cameron Cross
Incorporated
Mr Kenneth Cameron,
Cameron Cross
Incorporated
Email on 11 May 2012
Meeting on 11 August
2011 with potentially
directly affected
landowners at Delmas
Coal.
Authorities meeting, 21
January 2011
Authorities meeting, 21
January 2011
RESPONSE(S)
It was agreed upon that all scientists doing specialist studies
during the impact assessment phase will liaise through the
public participation office (Andre Joubert) at least a week
before a visit who will then contact the specific landowner to
ask permission to enter his/her property. Follow up visits can
be dealt with directly between the landowner and scientist.
The site selection report provides the detail on the site
selection process. This has been supplemented with a
separate pair wise comparison to provide better
understanding on how the sites compared with each other.
Specialist input was obtained in the site selection process as
outlined in Appendix B1 of the Site selection report
(Appendix H of the EIR).
Noted.
Noted.
B. LEGISLATION AND PROCESS ISSUES
COMMENTATOR(S)
25
5
appended to this document)
My client objects to the project with the
following issues and concerns:
The applicant disregards environmental
laws on other projects so there is no
guarantee that will not happen in this
project.
The applicant disregards the rights of
property owners adjacent to its current
operations.
The applicant should indicate the volume of
process coal that will be fed from the
crusher by way of conveyor belts into the
power plant, and whether or not the current
coal crusher plant situated at Delmas
Colliery will be upgraded and enlarge.
The applicant should indicate if additional
land will be taken up by the crusher plant,
and should identify such land. The
environmental studies should include this
site.
Environmental specialist studies should
also be undertaken concerning the access
and maintenance roads of the conveyor
routes and the access roads to the plant
and ash facilities to determine the effect on
the environment concerning coal spillage
and coal dust.
The health hazards should be investigated
for people and livestock due to emission of
toxic fumes from the ash dumps and
contamination of water sources. A chemical
analysis should be undertaken.
Specialist studies should be undertaken to
determine the effect that excessive and
abnormal rainfall will have on the stability of
the ash dumps and the possible run- off of
ash water and/or the collapse of the ash
dump and the subsequent flooding of the
nearby properties with ash.
Comments and Responses Report (Version 4)
Mr. Johann Minnaar on
behalf of Mr. Johan
Claassens from
Vanggatfontein Beleggings
(Proprietary) Limited
Email on 11 May 2012
26
The 100 – year floodlines were determined to ensure
infrastructure is positioned outside of this floodline. The
surface water impact assessment in Volume 3 details the
floodlines for the power plant and ash disposal facility.
Various specialist assessments were carried out and are
included in Volume 3 of the EIR. This includes the air impact
assessment, which assessed the dust impact zone for the
project.
The Eskom servitudes are shown in Figure 2-2 of the EIR as
well as the drawings of the ash facility in Section 2 of the
EIR.
This application is for the initial 600MW plant. If KiPower is
granted authorisation and wish to expand the plant, it would
require a new application process for its expansion. For this
reason, only the 600MW is being considered in this
application.
KiPower will be a separate entity and will be subject to
several licenses that, if issued by government, will be based
on the current best practice expected of such plants. Kuyasa
wishes to note that Delmas Coal is an old colliery, and many
of the issues are legacy issues which are being addressed.
8
7
6
Hydrological studies should include the
determining of the various 100, 50, 20 and
10 years flood lines within the areas that
will be taken up by the ash dumps.
The Scoping Report is vague concerning
the proposed expansion of the power plant
to a 1200MW plant. The specialist studies
should include in detail the expansion and
the areas that the enlarge plant and ash
dumps will take up. My client’s properties
are adjacent to the ash dump and any
enlargement to the ash dump site will have
a detrimental effect on my client’s farming
business, and it is fair to state that should
any enlargement of the ash dump area be
planned in future that my client should be
aware of it before the proposed first power
plant becomes operational.
The route of the proposed power lines of
Eskom that will convey electricity to the
national grid should be indicated on a plan
and the size of the pylons and the grouping
of the lines should be indicated.
Scientific agricultural studies should be
undertaken to study the effect that the ash
dust and the coal dust will have on the crop
production and grazing potential of the
adjacent and nearby agricultural lands.
(The complete comments have been
appended to this document)
The construction phase must be
incorporated into the studies since most
professionals do not account for impacts
during the construction phase.
Power generated from the power plant
would be fed into the Eskom grid. The EIA
for the line from the substation to the
Eskom grid would be the responsibility of
Eskom. This is Eskom’s requirement.
The water balance at the mine would
Comments and Responses Report (Version 4)
Mr Stanford Macevele,
Ms Praveshni Sewmohan,
Jones & Wagener
Mr Stanford Macevele,
Department of Water
Affairs
Authorities meeting, 21
Authorities meeting, 21
January 2011
Authorities meeting, 21
January 2011
27
Jones & Wagener is assisting Kuyasa Mining with its water
Noted.
The construction related impacts of the project are assessed
in Section 10.1 of the EIR.
Once the EIA is completed, the EAP
disappears and there is no-one to protect
the landowners.
Mr Gregory Scott expressed his concern
regarding the potential impact of windblown
dust from the proposed ash disposal facility
on the R50 stretch of the road adjacent to
the proposed ash disposal facility. The
specialists are to ensure this issue is
covered in the air quality specialist report.
See minutes of meeting held attached.
The minutes of the meeting held on 15
November 2012 accurately reflect the
discussion (see minutes attached). The
principles of avoiding impacts and where
unavoidable minimising and mitigating as
well as the precautionary approach were
noted (see NEMA Section 2). Similarly the
matter of mixing ground water streams was
considered with respect to avoiding or
minimising the risk of pollution, and
conserving energy and management risk.
The performance of clay only liners such as
11
13
12
Transnet Pipelines will not be affected by
your proposed development.
10
9
change with time and this needs to be
taken into account. He further indicated that
separate water licenses could result in a
disjoint between the plant and mine water
balances.
The impact of the proposed development
on water and farming, especially sheep
must be investigated.
Comments and Responses Report (Version 4)
Mr Kelvin Legge, Chief
Engineer: Integrated
Environmental Engineering,
Department of Water
Affairs
Mr Gregory Scott,
Department of
Environmental Affairs
Mr MT Hadebe, Servitude
Management, Transnet
Pipelines
Mr. Hannes van Zyl,
Brakfontein
Mr Pieter Combrink,
Saamwerk Boerdery,
Delmas.
Department of Water
Affairs
Meeting held on 30
January 2013 with the
Department of
Environmental Affairs
(DEA), Mpumalanga
Department of
Economic
Development,
Environment and
Tourism (MDEDET)
and Nkangala District
Municipality.
Meeting held on 15
November 2012 at the
Department of Water
Affairs.
I&AP Public Meeting
held on 19May 2012
Email on 27 July 2011.
Fax on 18 July in
response to the
announcement.
January 2011
28
Noted.
The impact on the R50 is included in the air impact
assessment report in Volume 3.
Noted.
The impact of dust and spillages were assessed in the air
quality and surface water impact assessments (Volume 3 of
the EIR). Impact on individual species was not investigated;
instead, predicted levels were compared to the national
ambient standard.
Noted.
use license application (WULA) and will also assist KiPower
with its WULA. The water balances will, therefore, be
properly integrated. However the different business entities
need to hold their own water use licences,
15
14
It was stated that even if the power station
The design proposal was thus amended to
minimise the waste disposal on agricultural
land and optimise the use of the existing pit
for ash disposal, despite its challenges, by
the short term use of ash (two years) as fill
material on a lined area. This ash fill will be
undertaken to form a free draining area
over which another liner (Class C
performance) will be placed effectively
acting as a cap to the underlying waste and
piggyback barrier to the overlying ash. The
same form of liner would be required over
the new area of footprint development.
Temperature of barrier must be considered
in the service life design and it was noted
that the pit shaping would be undertaken in
such a way that the foundation is above
ground water level. In accordance with the
minutes it is recommended that the
amended conceptual design and layout be
taken to tender stage design, singed of by a
PrEng and submitted upon which it should
be given favourable consideration for
approval.
It was asked whether the mine or the IPP
would be liable for any environmental
responsibilities. See minutes of meeting
held attached.
GLB+ being far inferior to composite liners
such as Class C with respect to restricting
pollution migration (seepage), and with
respect to differential settlement, was
noted.
Comments and Responses Report (Version 4)
Ms Martha Mokonyane,
Mr Samuel Mathavhela,
DMR
Meeting held on 25
Meeting held on 25
February 2013 at the
Department of Mineral
Resources, Emahlaleni
29
Ikhwezi Colliery has the responsibility to rehabilitate the pit
area and address the decant water from the pit. The
rehabilitated pit would have an acidic water quality and the
ash seepage an alkaline quality. The DWA has requested
that these two streams be kept separate, and this has been
included in the ADF design. The DMR indicated that it would
consider a transfer of liability for the pit from Ikhwezi Colliery
to KiPower in order to allow for on-going management of pit
H water.
It was suggested that a formal agreement between Ikhwezi
The DMR will consult with the National
Department of Agriculture, Forestry and
Fisheries and the Mpumalanga Tourism
and Parks Agency externally and the
Principal Inspector of Mines internally. See
minutes of meeting held attached.
KiPower IPP would need to prove that they
have experience with environmental
management if they are to have liability
transferred to them. The DMR will require
this information with the submission of the
transfer of liabilities. See minutes of
meeting held attached.
The Final Scoping Report was accepted by
the DEA in terms of regulation 30 (1) (a) of
the EIA Regulations, 2010.
17
18
19
MPRDA Regulation 59 specifies the
requirements for transfer of liability. If a
transfer of liability is applied for, an EMPR
amendment is required. See minutes of
meeting held attached.
16
will be removing pit water through
boreholes and treating it, the mine will
remain liable forever for the potential
impact. If the responsibility of the decant
water gets transferred to KiPower, closure
for Pit H is possible. See minutes of
meeting held attached.
Comments and Responses Report (Version 4)
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Ms Martha Mokonyane,
DMR
Ms Martha Mokonyane,
DMR
Ms Martha Mokonyane,
DMR
DMR
Letter from the DEA
dated 7 November
2012.
Meeting held on 25
February 2013 at the
Department of Mineral
Resources, Emahlaleni
Meeting held on 25
February 2013 at the
Department of Mineral
Resources, Emahlaleni
Meeting held on 25
February 2013 at the
Department of Mineral
Resources, Emahlaleni
February 2013 at the
Department of Mineral
Resources, Emahlaleni
30
Noted.
The EIA/EMPr (for NEMA) will be submitted to DMR, in
addition to a transfer of liability application. This will suffice
as an EMPR amendment to the DMR. The EIA must include
all the requirements of the DMR that may not be covered by
the NEMA requirements, such as an environmental
awareness plan, financial provision, etc. A list of
commenting authorities in the submission of the EIA/EMPR
to the DMR is required so that the department can be aware
which state departments would have received the document
for review and comment. At least 4 copies of the EIA/EMPR
are needed for the DMR EMPR
Amendment application.
J&W will ensure that the Department of Water Affairs
(DWA), Department of
Environmental Affairs (DEA) and Mpumalanga Department
of
Economic Development, Environment and Tourism
(DEDET) are included in the submission of the final reports,
as well as the relevant district and local authorities.
The transfer of liability documents will be submitted to the
DMR and will include these requirements.
It is noted that after approval KiPower will be allowed to
operate within the license and authorisation conditions..
and KiPower be drafted regarding the pit water management
liability. An agreement as follows was proposed:
o
Ikhwezi rehabilitates the opencast pit;
o
Liability of the pit and its decant is transferred to
KiPower (a closure certificate and transfer of liability is
applied for);
o
KiPower hold all further liability for the pit and the
decant water; and
o
Update of the Ikhwezi EMPR to exclude Pit H on its
closure.
24
23
22
21
20
f)
Quantity of waste to be stored and
the period of storing on site must
be stated.
e) Facility illustration of the waste
storage facility must be included.
The following amendments and additional
information are required for the EIR:
d) The wastewater treatment works
process must be discussed in detail
i.e. also use sketches.
The following amendments and additional
information are required for the EIR:
c) Technology alternatives for the
wastewater treatment works should
be considered.
The following amendments and additional
information are required for the EIR:
b) The total footprint of the proposed
development should be indicated. A
layout map of the power plant, ash
disposal facility and associated
infrastructure must be provided.
The following amendments and additional
information are required for the EIR:
a) Details of the future plans for the
site and infrastructure after
decommissioning in 30 years and
the possibility of upgrading /
expanding the facility.
The following amendments and additional
information are required for the EIR:
The following amendments and additional
information are required for the EIR:
Comments and Responses Report (Version 4)
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
31
This is included in Section 2.3.9 of the EIR and in the Waste
License Report.
The ash disposal facility is described in Section 2.4 of the
EIR and in the Design Report in Volume 2.
The waste water works is described in Section 2.3.7 of the
EIR and in the Design Report in Volume 2.
Whilst the preliminary design includes a reverse osmosis
design for the waste water treatment works, the detail
design by the EPCM may consider alternatives provided the
effluent quality and recovery of the plant meets the
preliminary design requirements.
This is provided in Figure 2-2 of the EIR.
A concept closure plan is included in the EIR (Section 10.3).
A detailed closure plan will be required if the site is
decommissioned in future,
31
30
29
28
27
26
25
Should a Water Use License be
required, proof of application for a
license needs to be submitted.
The following amendments and additional
information are required for the EIR:
l)
k) The EAP must classify the waste to
be disposed of in terms of the
Minimum Requirements.
The following amendments and additional
information are required for the EIR:
The maintenance plan and disposal
methods of the boiler ash into an
authorised disposal facility must be
included in the EIR.
The following amendments and additional
information are required for the EIR:
j)
Frequency of removal of the
various waste types.
The following amendments and additional
information are required for the EIR:
i)
h) Details pertaining to the sorting,
handling, storage and collection
procedures for the respective types
of waste.
The following amendments and additional
information are required for the EIR:
g) Details on the type of waste
materials that will be taken for
recycling.
The following amendments and additional
information are required for the EIR:
The following amendments and additional
information are required for the EIR:
Comments and Responses Report (Version 4)
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
32
This is included in Appendix C of the EIR.
The proof of submission for a water use license will be
included in the Final EIR.
This is included in the Waste Classification Report in
Volume 3 of the EIR.
This is included in the Design Report in Volume 2.
This is included in Section 2.3.9 of the EIR and in the Waste
License Report.
This is included in Section 2.3.9 of the EIR and in the Waste
License Report.
This is included in Section 2.3.9 of the EIR and in the Waste
License Report.
38
37
36
35
34
33
32
n) Possible impacts and effects of the
development on health and
agricultural activities must be
indicated.
The following amendments and additional
information are required for the EIR:
o) Possible impacts and effects of the
development on the surrounding
area.
The following amendments and additional
information are required for the EIR:
p) Environmental costs versus
benefits of the facility and economic
viability of the facility and how the
local community will benefit.
The following amendments and additional
information are required for the EIR:
q) Information on services required on
the site, e.g. sewage, refuse
removal, water and electricity. Who
will supply these services and has
an agreement and confirmation of
capacity been obtained?
The following amendments and additional
information are required for the EIR:
r) A construction and operational
phase EMP to include mitigation
and monitoring measures.
The following amendments and additional
information are required for the EIR:
s) Should blasting be required,
appropriate mitigation measures
should be provided.
An amended application form with the EIR,
m) Proof of application for an Air
Emissions Licence must be
provided.
The following amendments and additional
information are required for the EIR:
Comments and Responses Report (Version 4)
Ms Fatima Rawjee, Acting
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Authorisations
Letter from the DEA
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
33
The amended application form will be included in the Final
Section 11 outlines measures should blasting be required
during construction.
This is included in Section 11 of the EIR.
This is included in Section 2 of the EIR and in the Design
Report as far as possible based on the preliminary design
information.
This is included in the impact assessment in Section 10 of
the EIR and in the various specialist reports in Volume 3,
This is included in the impact assessment in Section 10 of
the EIR and in the various specialist reports in Volume 3.
This is included in the impact assessment in Section 10 of
the EIR and in the various specialist reports in Volume 3.
42
41
40
39
Since the project will be situated within an
area already heavily affected by previous
mining activities SAHRA has no objection to
the proposed development. However, the
recommendations listed below must be
including only those sub-activities which are
applicable to the project (e.g. Activity 11
(x1) of GN R 544) and remove Activity 20 of
GN R 544 which has not yet been enacted
which states that the provision relating to
prospecting, mining exploration and
production and related activities will only
come into operation 18 mkonths after the
date of commencement of the MPRDA
Amendment Act.
Ensure that the EIR includes at least one
A3 map of the area and that locality maps
include the different proposed alignments
and above ground storage of fuel. The
maps should at least have the following
attributes:
 Maps are relatable to one another
 Cardinal points
 Co-ordinates
 Legible legends
 Indicated alternatives
 Latest land cover
 Vegetation types of the study area
Should the application for environmental
authorisation be subject to the provisions of
the National Heritage Resources Act, the
DEA will not be able to make nor issue a
decision pending a letter from the pertinent
heritage authority categorically stating that
the application fulfils the requirements of
the relevant heritage resources authority.
No activities may commence prior to an
environmental authorisation being granted
by the DEA as per Section 24 F of NEMA.
Comments and Responses Report (Version 4)
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Mr Phillip Hine, Heritage
Officer, South African
Heritage Resources
Agency
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Ms Fatima Rawjee, Acting
Director: Integrated
Environmental
Authorisations
Director: Integrated
Environmental
Authorisations
Letter from SAHRA
dated 6 February 2013
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
Letter from the DEA
dated 7 November
2012.
dated 7 November
2012.
34
A palaeontological study was undertaken and submitted to
SAHRA. See Volume 3 for the specialist study.
Noted.
Noted. The necessary applications have been lodged with
SAHRA. See Appendix C.
This is provided in the EIR.
EIR.
44
43
implemented:
a) A Palaeontological Impact
Assessment must be undertaken
before mining and construction may
proceed. The report must be
submitted to SAHRA for further
recommendations. If the specialist
deems it sufficient, a letter of
exemption from further
palaeontological studies may
submitted to the heritage authority.
Since the project will be situated within an
area already heavily affected by previous
mining activities SAHRA has no objection to
the proposed development. However, the
recommendations listed below must be
implemented:
b) The cemetery on the farm
Haverklip will be affected by the
proposed ash stock pile and will
need to be relocated. If the graves
are older than 60 years the
developer must ensure that the
mandatory 60 day consultation is
done and a permit in terms of
section 36 of the NHRA (Act no 25
of 1999) must be obtained from
SAHRA Burial Grounds and Graves
Unit.
Since the project will be situated within an
area already heavily affected by previous
mining activities SAHRA has no objection to
the proposed development. However, the
recommendations listed below must be
implemented:
c) The author recommended that the
Homestead Ruin on the farm
Haverklip will need to be recorded
in detail before it can be
demolished. The Homestead Ruin
Comments and Responses Report (Version 4)
Mr Phillip Hine, Heritage
Officer, South African
Heritage Resources
Agency
Mr Phillip Hine, Heritage
Officer, South African
Heritage Resources
Agency
Letter from SAHRA
dated 6 February 2013
Letter from SAHRA
dated 6 February 2013
35
Please see Volume 3 where the documentation of the old
homestead has been included.
Please see Appendix C for documentation regarding the
exhumation of the graves.
46
45
on the farm Haverglen is younger
than 60 years so no further action
is required. Please note that
Decisions in terms of Built
Environment must be sought from
the Mpumalanga Provincial
Heritage Authority (Mr Benjamin
Moduka, [email protected]).
Since the project will be situated within an
area already heavily affected by previous
mining activities SAHRA has no objection to
the proposed development. However, the
recommendations listed below must be
implemented:
d) Although the homestead and
associated cemetery that is located
north of stockpile area close to the
R50 falls outside the footprint of the
development, SAHRA strongly
advises that the developer must
ensure that no impact occur on
them. These features must be
mapped on construction maps and
all contractors must be made aware
of the legal status of heritage
resources. To avoid secondary
impacts that may result from the
development, SAHRA recommends
that the cemetery be fenced and
access gates installed to allow
visits for relatives and friends.
Since the project will be situated within an
area already heavily affected by previous
mining activities SAHRA has no objection to
the proposed development. However, the
recommendations listed below must be
implemented:
e) It is not clear from the heritage
report submitted if the proposed
coal conveyor and sorbent
Comments and Responses Report (Version 4)
Mr Phillip Hine, Heritage
Officer, South African
Heritage Resources
Agency
Mr Phillip Hine, Heritage
Officer, South African
Heritage Resources
Agency
Letter from SAHRA
dated 6 February 2013
Letter from SAHRA
dated 6 February 2013
36
These areas were included in the heritage assessment
submitted to SAHRA and included in Volume 3 of the EIR.
These measures were included in the EMP in Section 11 of
the EIR.
47
2) SAHRA APM Unit specifically requested
that the alignment for the coal conveyor be
surveyed. The report submitted does not
mention the coal conveyor so it is unclear
from SAHRA’s perspective if this was
undertaken. SAHRA APM Unit therefore
recommends that before construction starts
on the conveyor route, an archaeologist
1) Since Graveyard 4 falls within the
stockpile area the two graves related to this
cemetery will need to be relocated. SAHRA
BGG Unit will only support relocation
dependent on the results of the 60-day
public participation process. A Permit will
be required in terms of section 36 of the
National Heritage Resources Agency (Act
no. 25 of 1999). Graveyards 1, 2, and 3
must be retained in situ. For this purpose all
graves must be cleaned and restored
where and a proper fence must be installed
with access gates to allow visits from
relatives and friends. No development is
allowed within 15-20 meters of the
graveyards.
conveyor routes were surveyed.
Please note that these routes must
be surveyed by a specialist and the
results submitted in a report to
SAHRA before development
proceeds.
The new report submitted to SAHRA
identified a further two cemeteries,
however, it is only Graveyard 4 that will be
affected by the proposed Ash Stockpile
Area. This cemetery contains two graves.
The cemetery is fenced, although it is
overgrown with vegetation. Please note the
following:
Comments and Responses Report (Version 4)
Mr Phillip Hine, Heritage
Officer, South African
Heritage Resources
Agency
Letter from SAHRA
dated 6 February 2013
37
The fencing and protection of the other graves is included in
the EMP requirements in Section 11 of the EIR.
The relocation of the graves in Graveyard 4 is documented
in Appendix C of the EIR.
49
48
4) The heritage scoping report undertaken
by Dr R. De Jongh recommended that the
Homestead Ruin on the farm Haverklip will
need to be recorded in full detail. This has
not been done during the current study.
Decisions regarding the built environment
must be sought from the Mpumalanga
Provincial Heritage Authority (Mr Benjamin
Moduka, [email protected]).
I hereby like to acknowledge that a report
about the Archeaological investigation of a
grave yard at Delmas Coal (KiPower) was
received by SAHRA during the first week of
June this year. The mining area is located
on the farm Haverklip 265 IR near Delmas
in Mpumalanga. The report that was
submitted by Archaetnos, was informative
about the graves that were exhumed and
relocated. The report is accepted as a
record of all the processes taken by
Archaetnos in this particular case and that
all the processes were done in accordance
with NHRA legislation. Hence, in the future
mining activities can continue in this
particular area without any reservations.
The traffic impact study for Springboklaagte
3) SAHRA APM Unit specifically requested
a palaeontological impact assessment,
which has not been submitted yet. Please
note that a PIA must be undertaken or at
least a letter of exemption will be required
from a professional palaeontologist
indicating that such a study is unnecessary.
SAHRA will not be able to issue the final
comment for this project until the PIA is
received.
must provide a walk down report to SAHRA
APM Unit.
Comments and Responses Report (Version 4)
Erica van Zyl, Traffic
Itumeleng Masiteng
Heritage Officer: BBG
Permitting
South African Heritage
Resources Agency
Email correspondence,
Letter from SAHRA,
dated 27 June 2013
38
The traffic impact assessment considered a worst-case
Noted.
The old residence has been documented and submitted to
MPHRA – see Appendix C.
The conveyors were included in the original assessment. It
is noted that the bulk of the conveyor route runs within an
existing haul road between Ikhwezi Colliery and Delmas
coal.
I am writing to seek clarity on this DEA
approval of the draft scoping report (DSR)
for the proposed KiPower power station and
to urge the DEA to reconsider this decision.
53
52
Can I also please have copies of the terms
of reference for the specialist studies that
have been commissioned as part of this
EIA. I would also like to have copies of any
other studies additional to those in the Final
Scoping Report (FSR). Additionally can I
please have the names of the experts who
will conduct the specialist reports, as well
as proof that they comply with Regulation
17(a) and (b) of EIA Regulations – i.e. that
they are independent; and have expertise in
conducting environmental impact
assessments, including knowledge of the
Act, the EIA Regulations and any guidelines
that have relevance to the proposed
activity.
Please also indicate who the competent
authority of this EIA is – is it national or
provincial government? Please provide me
with the details of the relevant contact
persons. Finally please indicate the time
period for EIR comments as set out in the
EIR.
51
50
mine was submitted to the authorities for
approval. Please note that this is an update
of a previously approved study. Your
studies will thus have to take
Springboklaagte mine into account, as well
as the Moabsvelden mine, which was also
approved.
Please give me an update of where this
process is? Has there been any progress
since the Draft Scoping Report was
submitted to the DEA.
Comments and Responses Report (Version 4)
Rico Euripidou,
groundWork - Friends of
the Earth South Africa
Rico Euripidou,
groundWork - Friends of
the Earth South Africa
Rico Euripidou,
groundWork - Friends of
the Earth South Africa
Rico Euripidou,
groundWork - Friends of
the Earth South Africa
Engineer
Letter dated, 14 August
2014
Email correspondence,
dated 30 July 2013
Email correspondence,
dated 30 July 2013
Email correspondence,
dated 23 July 2013
dated 17 July 2013
39
National government is the competent authority in terms of
NEMA and NEM:WA, whilst provincial government is the
competent authority in terms of NEM:AQA. The specific
case officer at DEA: Ms Fiona Grimmett; MDEDET: Mandla
Mahlalela. It was proposed to make the EIR available during
September 2013, however the schedule was changed.
Stakeholders were made aware of the proposal that the
DEIR will be made available early in 2014.
Ms Fiona Grimett, Environmental Officer: Integrated
Permitting System at the Department of Environmental
Affairs has acknowledge receipt of the submission from
groundWork on 14 August 2013.
Mr Euripidou was reminded that the DEA accepted the Final
Scoping Report (FSR) and that a notification with the
acceptance letter from DEA was sent to all stakeholders on
20 November 2012. The information was again sent to the
stakeholder.
The FSR and its appendices are available on our web site –
(welcome
to
follow
the
direct
link:
http://www.jaws.co.za/public-reviewdocuments/services/kipower-ipp-project). Should you have
challenges downloading the document – just let us know
and we can cut a CD and put that in the mail for you. The
FSR and appendices are too big to email. The TORs for the
specialists are part of the FSR. The reports will be included
in the Draft EIR when it is available for public review and will
include the specialists names and their individual declaration
of independence.
growth in traffic to allow for future developments such the
Springboklaagte mine. See Volume 3 of the EIR.
55
54
Please provide me with a copy of the Final
Scoping Report that was submitted to the
DEA. It seems that the version submitted to
the DEA is different from the version that
was available for public review.
I understand that DEA has granted the EIA
consultants and the proponent authorisation
to proceed with the EIA process for this
IPP. However, our understanding is that the
National Environmental Management Air
Quality Act; the Highveld Priority Area Air
Quality Management Plan, the National
Framework for Air Quality Management and
the National Environmental Management
Act do not permit the DEA to authorise this
development in the HPA for the reasons set
out in the letter – please see letter attached
to this report.
I am still not quite clear where the TOR’s
are for each of the specialists who are
undertaking the specialist studies. Also
please explain to me if the specialist studies
have already started? GroundWork want to
have the opportunity to comment on the
TOR’s for the specialist studies BEFORE
they are started.
Comments and Responses Report (Version 4)
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
Rico Euripidou,
groundWork - Friends of
the Earth South Africa
Email correspondence
and telephonic
discussion, 19
September 2013
Email correspondence,
17 September 2013
40
“I can confirm that the Final Scoping Report which you have
just sent through is indeed the same Final Scoping Report
As you may be aware, this EIA process started some time
back. I&APs had an opportunity to comment on the Draft
Scoping Report from Thursday, 22 March 2012 to Friday, 11
May 2012. Advertisements were placed in The Springs
Advertiser and Streeknuus newspaper to advertise the
availability of the DSR for comment in the week of 19 March
2012 in addition to letters and emails sent to registered
I&APs. I&APs had an opportunity to comment on the Final
Scoping Report from Wednesday, 27 June to Friday, 20 July
2012. The Final Scoping Report was approved by the DEA
on 7 November 2012. We have since completed the
specialist studies and are in the process of finalising the
Draft EIR for public review. The TOR’s for specialist studies
were included in the Draft Scoping Report and in the Final
Scoping Report. We welcome any comments on the TORs
even at this late stage and will welcome your comments on
the specialists studies and Draft EIR when these become
available early in 2014.
The version of the Final Scoping Report that Mr Peek sent
to the EAP’s office was the most final version and the
version that was submitted to DEA. The web link is:
http://jaws.co.za/public-review-documents/ki-power-ippproject/. The DEA subsequently responded as follows when
they were requested to rectify their reference to the report:
57
56
You indicated that there is a delay in the
design specialist study. Are the others
delayed or are they completed? It is likely
that the specialist studies will only come out
late in the year or early next year. It would
be good if these studies, as well as the next
round of EIA documents, do not come in
December or November, for it will be
impossible for groundWork and the
community people to make meaningful
comment over the festive season.
We would like to obtain a copy of the final
terms of reference for the specialist studies.
Comments and Responses Report (Version 4)
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
Email correspondence
and telephonic
discussion, 19
September 2013 and
further correspondence
dated 17 October
2013.
Email correspondence
and telephonic
discussion, 19
September 2013
41
Chapter 6 as from page 41 of the Final Scoping Report
describes the TOR for the specialist studies. There were
changes to the scope of works for the specialists but these
can be seen as enhancements and extensions. Some of the
scopes were changed several times and all of this is not on
paper – some were discussed at meetings. All studies are
described in the scoping report except for the
paleontological study that was commissioned when it was
requested by SAHRA. This will be included in the Draft EIR.
The specialists provided scopes of work when Jones and
Wagener put together its proposal for the project. The
project scope has been adjusted over time as more
technical detail became available from the engineering team
(Black and Veatch) and more clarity was developed by the
project team. The terms of reference included in the Final
Scoping Report represents the latest TORs based on which
specialist work was completed.
(FSR) that was reviewed and approved by the Department. I
have scanned and attached the cover page of the
Department's copy of the report - you can see that it is the
same version. Our copy of the report was stamped by our
Admin department as being received on 3 July 2012, hence
the reference to that date in the Department's letter. I must
however apologise for incorrectly stating that the document
was dated July 2012. In drafting the letter, I mistakenly
referenced the wrong date contained on the FSR cover
page (i.e. the deadline date for which comments should be
received by). The Department's letter should have read that
the FSR was dated "June 2012" and not "July 2012".
It is proposed to have the DEIR available for public review
from mid-October to end November 2013. It is proposed to
have the FEIR available early next year. Documents for
public review will most certainly not be made available for
public comments in the Dec/Jan holiday period.
Stakeholders were subsequently notified that there is a
delay with the finalisation of the EIR and that the document
will only be available for public review early in 2014.
59
58
I think that some of these changes could be
important to the process and I would
suggest that these changes are discussed
with the DEA in a formal minuted meeting
and the minutes made public, in order that
people are kept abreast and can make
input and are not informed only when the
FEIR come out, and thus have limited time
to comment. Please ensure that updated
application forms are made available with
the draft environmental impact report
Ideally groundWork would have liked to
formally make input into the drawing up of
the TORs, but we were not granted this
opportunity. We would like to do this now,
even more so considering changes were
made as you indicated for enhancements
and extensions. groundWork would like to
have their input urgently considered for the
specialist studies because of the potential
impact of this proposal to the receiving
environment and peoples health. Please let
us have these urgently with all the
amendments! If amendments were not
made, but were agreed to in meetings,
please send us the meeting notes.
It is unlikely that there is a deviation from
the original plan of scoping submitted to the
DEA at the commencement of this project,
but you will check and get back to us.
Comments and Responses Report (Version 4)
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
Email correspondence
and telephonic
discussion, 19
September 2013 and
further correspondence
dated 17 October
2013.
Email correspondence
and telephonic
discussion, 19
September 2013 and
further correspondence
dated 17 October
2013.
42
The application form will have to be updated with some
activities. It was clarified with the DEA that this will be done
when the FEIR is submitted. The DEIR will already include
the assessment of these additional activities. An amended
application form will be included with the FEIR to ensure
project changes are brought into the forms. There have
been project changes either due to new thinking on the part
of the project team or to address issues highlighted by
specialists, such as fixing the stack height for the boilers,
including additional effluent treatment capacity in the plant,
using a rehabilitated open pit for ash disposal, etc.
The TORs still stand and if changes were made it happened
after June
2012 and based on the comments received from DEA in
their approval letter of the FSR. As mentioned an additional
study - palaeontology – was added. The approval letter of
the DEA was circulated to all stakeholders so that they could
have been informed of the recommendations of the DEA.
Since the DEIR will be available in due course, you will have
the result and the outcome of any changes to the TORs.
According to our records that were kept by the public
participation practitioner, Andre Joubert, Rico Euripidou of
groundWorks was kept informed during the scoping process
and a submission to us in May 2012 in response to the Draft
Scoping Report. The outcome and results of the enhanced
TORs and, as mentioned earlier an additional palaeontology
study as requested by DEA, will be available as part of the
Draft EIR. With the Draft EIR in hand you will have the
result to comment on and make suggestions thereto.
63
62
61
60
(DEIR) - instead of the FEIR.
Any substantive changes to the scope of
study or TORs should ideally be subject to
an open participative process that updates
stakeholders at the time of the changes - in
this regard we suggest that the proponents
arrange for a public participation meeting to
update all the stakeholders of the changes
and progress in this EIA process.
It is critical to understand that the
population in the area who will be impacted
upon and are IAPs are might be unable to
participate in the process due to language
barriers, illiteracy, disability or any other
disadvantage. This can be attained from
census data in the area. So JAWS need to
find creative ways of getting peoples’
comments. I would suggest that there is a
form of public hearing in the process, in
order that people can make known their
concerns, and that they can hear of the
concerns of other people. People in the
area also need to be given notice of the
eminent DEIR and development via
alternative means, rather than just written
medium. I would suggest local radio
stations etc.
The documentation that will be made public
for comment will be extensive when all the
specialist reports are finalised. IAPs will
have to consult technical experts to better
understand the process, and considering
the limited resources even NGOs such as
gW have, doing this is going to be a
challenge if the period for comment is very
restrictive.
Ideally all reports should be made available
in the local language, but understand that
this is a challenge, so it is hoped that there
is consideration of making the executive
Comments and Responses Report (Version 4)
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
S. (Bobby) Peek, Director
groundWork, Friends of the
Earth
Email correspondence
and telephonic
discussion, 19
September 2013 and
Email correspondence
and telephonic
discussion, 19
September 2013 and
further correspondence
dated 17 October
2013.
Email correspondence
and telephonic
discussion, 19
September 2013 and
further correspondence
dated 17 October
2013.
Email correspondence
and telephonic
discussion, 19
September 2013, also
in letter dated 17
October
43
A non-technical summary of the Draft EIR was translated
and distributed.
I&APs are more than welcome to request an extension to
the proposed 40 day public review period. Any reasonable
requests will be considered.
The public participation conducted thus far has gone beyond
the regulatory requirements and we plan on providing
sufficient opportunity in reviewing the DEIR. We support and
aim for meaningful participation and will consider any
suggestions from your side – that is why Groundwork and
other NGOs have been included on this project’s database
from the start. Please provide some more information with
regards to the proposed format of a public hearing and any
other suggestions in this regard. It is proposed to provide
notice of the public review period and we will host
stakeholder interaction events during the public review
period – the format has not yet been finalised.
Stakeholders will have the opportunity to comment on the
TORs for specialist studies as well as the findings of the
specialists when the DEIR is made available for public
comment early in 2014.
64
Mr Stanley Mndaweni a former Delmas
Coal mine contractor indicated that there
was a community meeting which was held
“last Sunday” with community members
from Sub Highway and Brakie
(Brakfontein). The community meeting was
organised by Earth Life Africa, Sustainable
Energy and Climate Change project
(SECCP) and groundWork. Although the
meeting was organised for 150 people, only
78 people attended the meeting. According
to Mr Mndaweni representatives from
Delmas Coal mine were also in attendance.
The purpose of the community meeting was
to discuss the KiPower’s proposed 600 MW
power plant and the implications that the
proposed project will have on their health
as a community that stays close to the
proposed project site. Mr Mndaweni also
indicated that they were told that there is a
proposed open cast mine that will be
constructed which will be very close to their
community. They were told that the
proposed open cast mine will also affect
them and their houses may be damaged
when blasting from the open cast mine is
being undertaken. Mr Mndaweni said that
with all the information that was presented
at this meeting he does not want a coal
fired power station close to his community.
He stated that should the proposed power
plant be constructed, then Ki Power must
relocate them or compensate them for the
health effects they will be experiencing as a
result of the proposed power plant.
Mr Mndaweni also indicated that it will also
be worthwhile for the project team to
summaries of all reports available in local
languages.
Comments and Responses Report (Version 4)
Mr Stanley Mndaweni,
Subway community
further correspondence
dated 17 October
2013.
Visit to the subway
community, November
2013
44
68
67
66
65
Is it proposed that power generated by the
proposed IPP will be sold to Eskom?
organise a community meeting similar to
the one that groundWork has organised.
Community members from Brakie
(Brakfontein) must also be invited to such a
meeting as they also have similar issues.
Ms Sibeko indicated that she is aware of
the proposed power plant as she has been
informed at community meeting that was
recently held with all community members
from the Sub Highway community. She
enquired if they will be relocated once the
proposed power plant is being constructed
and where will they be relocated to. She
also enquired about how the proposed
project will assist them as a community as
some of them do not have Identity Books
and they are currently unemployed. She
requested that documentation that is
distributed to the community must be
translated in Southern Sotho so that they
can also understand what the proposed
project entails. During discussions with Ms
Sibeko she indicated that she does not trust
mines and as such she is uncomfortable to
give us her contact details.
Ms Ntuku stated that she is bothered by all
the proposed developments that will be
undertaken in their community, none of the
proposed projects provide employment
opportunities.
When is it planned for the proposed IPP to
be operational?
Comments and Responses Report (Version 4)
Elise Tempelhoff – Beeld
environmental journalist
Elise Tempelhoff – Beeld
environmental journalist
Ms Palesa Ntuku, Subway
community
Ms Mastrong Sibeko
Mndaweni, Subway
community
Email correspondence,
6 November 2013
Email correspondence,
6 November 2013
Visit to the subway
community, November
2013
Visit to the subway
community, November
2013
45
All environmental authorisations and licenses have to be in
place before construction can commence. If another 12
months are allowed for that, construction may commence in
2015. It is anticipated that construction and related
preparations will take another four years. The IPP will not be
operational before 2019/2020.
It is public knowledge that Eskom will solicit bids to assist
with supplying the required base load power. Kipower will
take part I that process to make bids in this regard to
Eskom. Kipower will also approach major power consumers
Employment opportunities are discussed in Section 2 of the
EIR and measures to maximise local employment are
included in Section 11.
The IPP project will not require relocation of people. The
summary document has been translated to Afrikaans and
Zulu – the predominant languages in the region. However,
translators will be available at the public meeting to assist in
other languages.
Do you perhaps know of any objections to
this project? I know there were
people/residents who are worried about the
cumulative impact of another coal power
station in this already polluted area.
Should we inform the community?
Please supply this office with the farm
descriptions of the proposed 600MW coal
power station. And in future please use
descriptions of the farm portions. Our
records is strictly working on erf/ farm
portions descriptions for filing of
documents.
69
70
71
Comments and Responses Report (Version 4)
Jan Steenekamp
Deputy Manager Technical
Services
Victor Khanye Local
Municipality
Unidentified interested and
affected party
Elise Tempelhoff – Beeld
environmental journalist
Email correspondence,
11 November 2013
Email correspondence
from community
member
Email correspondence,
6 November 2013
46
If we can assist you to make additional copies of the letter
and send that to you for easier distribution, please let us
know and we can do that.
Delmas Coal and Ikhwezi Colliery are located approximately
20km as the crow flies south-east of Delmas town. The
proposed power plant will be a mine – mouth coal-fired
power generation facility and it will be located within 5km of
the mine’s North Shaft. The power plant will be located on
the farm Haverglen 269 IR, which is currently owned by
BHP Billiton South Africa. The ash disposal facility will be
located on the farm Haverklip 265 IR, which is owned by
Ikhwezi Colliery, a subsidiary of Kuyasa Mining. The ash
disposal facility will also utilise part of an existing opencast
pit, Pit H, on this farm.
At this stage and in terms of comments received thus far,
some stakeholders have concerns. We hope to address
these concerns in the DEIR and through the findings of the
specialists. Some stakeholders are against the generation of
power through coal fire power plants as they support only
renewable energy sources.
The information that we have sent to you is public
knowledge and you are most certainly welcome to share the
information with anyone.
As part of the public review period we will provide the
opportunity for stakeholders to meet with the team to
discuss the findings as per the DEIR.
in future.
The specialist studies have been completed and are being
integrated into the Draft Environmental Impact Report
(DEIR). Once the DEIR is made public, the potential impacts
will be known and available for public review and comment.
As per the letter sent to all stakeholders, we plan on making
the DEIR, Environmental Management Programme and the
specialist studies available early next year – hopefully
towards the end of January 2013. Stakeholders will
personally be notified of the availability of the documents
and the associated review period.
Could a copy of the geological report be
sent to the department?
What is the status with regards to the
rezoning of the land that is proposed for the
project?
75
76
74
The proposed project affects the existing
Eskom Distribution’s Delmas Coal –
Brakfontein 22kV, Delmas Coal –
Haverglen 22Kv, Delmas Coal – Devon
22Kv, and Brakfontein – Delmas Collery
88kV overhead power lines.
73
Eskom Distribution will raise no objection to
the proposed rehabilitation project, provided
Eskom’s rights and services are
acknowledged and respected at all times.
Further to the above certain conditions
must be adhered to and accepted in writing.
Why are there no notification signs on the
premises where the proposed construction
of the power station is planned?
Sasol Gas Pipelines will not be affected by
the proposed project
72
Comments and Responses Report (Version 4)
Mr Jan Venter,
Mpumalanga Department
of Agriculture, rural
Development and Land
Administration (DARDLA)
Mr Jan Venter,
Mpumalanga Department
of Agriculture, rural
Development and Land
Administration (DARDLA)
Mr Jan Venter,
Mpumalanga Department
of Agriculture, rural
Development and Land
Administration (DARDLA)
B van den Heuvel, Service
Coordination, Sasol Gas
Limited
Milton Moloko
Mpumalanga Land & Rights
Telephone
conversation, 29
November 2013
Telephone
conversation, 29
November 2013
Telephone
conversation, 29
November 2013
Letter, dated 6
November 2013
47
An application for the amendment of the Victor Khanye Land
Use Management Scheme as it pertains to Portions 3, 4 and
5 of the farm Haverklip number 265, Registration Division IR
(Mpumalanga) was approved by the Victor Khanye Local
Municipality in August 2013. The application sought to
amend the zoning of the land to allow for a residue disposal
facility.
In as far as the remaining land is concerned on which it is
proposed to develop a power plant, an application for the
amendment of the town planning scheme on a similar basis
The specialist reports, including the soils report and
geohydrological report, are provided in Volume 3 of the EIR.
Site notices are placed when the EIA for the proposed
project is announced. Site notices were placed on 21 July
2011 (see Volume 2 of the EIR for proof of placement).
Noted
Haverglen 269 IR remainder of 269. Owned by BHP Billiton.
Land and minerals rights transfer in process.
Haverklip 265 IR portions 3, 4, 5. Owned by Ikhwezi
Investments (part of Kuyasa Mining).
Noted
The power station would need water from
Rand Water, and this pipeline to the
nearest Rand Water pipeline at Devon
would require a separate EIA. The pipeline
application will be done by Delmas Coal
(mining subsidiary of Kuyasa Mining) since
water will be supplied to the mine.
Would the power plant and ash disposal
facility be outside the mining footprint? If it
is on mining land, then the mine will also
need to provide financially for rehabilitation.
How far are the alternative sites from
streams and river systems?
Why will low grade coal be used in the
power plant? South Africa has a lot of good
quality coal which is usually exported.
I live near the proposed development and
am concerned about the proposed discard
dump, because it will be built in a wetland.
In the rainy season this area gets very wet
and with the water flow from south to north,
any hazardous waste will contaminate the
wetland.
1
4
5
3
2
Has the National Department of Agriculture
been consulted with regards to the rezoning
process as they are the custodians of the
land and have the authority under Act 70?
77
Comments and Responses Report (Version 4)
Mr Hendrik Cloete, Delmas
Mr Stanford Macevele,
Department of Water
Affairs
Mr Stanford Macevele,
Department of Water
Affairs
Mr Stanford Macevele,
Department of Water
Affairs
Mr Marius van Zyl, Jones &
Wagener
Email on 2 August
2011.
Authorities meeting, 21
January 2011
Authorities meeting, 21
January 2011
Authorities meeting, 21
January 2011
Authorities meeting, 21
January 2011
C. BIOPHYSICAL ISSUES
48
The site selection report is included in Appendix H of the
EIR. The proximity to rivers was taken into consideration in
the site selection process.
Mr Mpumelelo Saliwa, Delmas Coal Manager said Delmas
Coal owns the coal reserves and only low grade coal is
available. The design of the power plant would
accommodate the use of the available low grade coal. The
use of low grade coal in this project will actually help
eliminate/reduce the accumulation of low grade coal, which
can cause an environmental concern if not utilized.
The design of the ash disposal facility includes water
management infrastructure, lining of the facility and
treatment of any leachate. Please see Section 2 of the EIR
and the surface and ground water impact assessments in
Volume 3 of the EIR.
The DMR has indicated that a transfer of liability for Pit H
can be considered. The footprints are being rezoned to
allow for industrial development.
Mr Stanford Macevele, Department of Water Affairs said he
is concerned about using water from Rand Water as this is
mainly domestic water and there is already pressure on
water resources in the area. Therefore alternatives are
being investigated as indicated in Section 3 of the EIR.
will commence once land ownership has reverted to the
mining company for such purpose.
The land use scheme of the Victor Khanye Local
Municipality incorporates the land in question and controls
its use via zoning and land use provisions contained in the
scheme. The provisions of the Subdivision of Agricultural
Land Act 70 of 1970 do not apply to areas under control of a
proclaimed town planning or land use scheme as may be
contemplated in the provisions of the Town Planning and
Townships Ordinance, 1986 (Ordinance 15 of 1986).”
Will impacts of the ash be looked at?
Will only wetlands and pans be looked at?
Can the sites be expanded?
14
Are there any sensitive areas on the sites
and are these integrated into the site
selection process.
Will water be stored on site? Will this be
recycled water and why not use mine
water?
I live near the proposed development my
biggest concern is the impact on our health
and the health of our animals. I am also
concerned about the impact on our
groundwater and soils as well as the effects
of air pollution.
I need more information on the discard
dump. Exactly where will the power station
be built and when will Alternative 9 be
affected?
I protest against the planned crushing
facility (vergruisaanleg) at South Shaft. I
farm with cattle next to South Shaft and the
additional dust will affect my cattle and
meadows. The planned overland conveyor
belt will also add to the pollution.
How will this development keep carbon
emissions to a minimum and as not to
contribute to greenhouse gasses?
There is a huge dam (1,7 million cubic
metres) on my property. What would the
impact be of a power station and an ash
disposal facility on this dam?
Where will water be sourced from for the
project?
13
12
11
10
9
8
7
6
Comments and Responses Report (Version 4)
Department of
Environmental Affairs
Mr. Robbie van Bulderen
Transnet
Department of Water
Affairs
Mr. Robbie van Bulderen
Transnet
Mr Thomas Mnguni,
Greater Middelburg
Residents Association.
Mr Adriaan Nel, Haverklip
Mr Jacobus Francois
(Koos) Liebenberg, Farm:
EnkeldeboschDelmas
Mr Tienie Schalekamp,
Landowner Haverklip
Ms Hannelie Cloete,
Delmas
Authorities Meeting
held on 19 April 2012
Authorities Meeting
held on 19 April 2012
Authorities Meeting
held on 19 April 2012
Meeting on 11 August
with potentially directly
affected landowners at
Delmas Coal.
Authorities Meeting
held on 19 April 2012
Email on 19 August
2011
Email on 9 August
2011
Fax received on 2
August 2011
Email on 2 August
2011.
49
Full terrestrial, aquatic and wetland surveys were done –
see Volume 3 of the EIR.
Not in the current scope due to high land price, but the land
is there and can be relooked at in years ahead when the
Rand Water bulk line parallel to N17 will have a tap off from
this line at Devon and bring the pipeline to the mine and the
power plant. Other alternatives to the Rand Water option are
being investigated as indicated in Section 3 of the EIR.
Delmas Coal does not have excess water. The plan is to
supplement and replace the RW source with dirty sources.
Sensitive areas were considered in the site selection
process – see Section 3 of the EIR.
The ash disposal facility is included in all the specialist
assessments – see Section 2 and Section 10 of the EIR.
The dam falls outside the zone of impact of the project – see
Section 10 of the EIR.
The project will contribute to greenhouse gas emissions due
to the combustion of coal.
This crushing facility is not related to this project and has
been sent to Kuyasa Mining.
The overland conveyor will be covered with dog sheeting to
minimise pollution.
Alternative 9 will not be used. The finalised location is on on
Sites 3 and 5 – see Section 3 of the EIR.
The impact of air pollution is addressed in Section 10 of the
EIR and in the air impact assessment in Volume 3 of the
EIR.
Will the coal be washed crushed and
screened before it goes to the power
station? Will it be ROM coal?
Will there be a crushing facility or will the
existing facility be used?
18
21
20
19
Farmer has raised a concern about his
300,000 chickens on the neighbouring farm.
17
How many tonnes coal was mined at
Delmas Coal last year?
Will EIA studies only be based on the
footprint of the development only?
Is it an opencast mine?
Is the coal only from this mine for the power
plant?
How much will the power station cost?
Who is owner of coal around Devon?
Does Eskom not want the coal?
If plant is extended then will ash also be
extended?
Does NEMA authorisation cover all listed
activities?
Is Solomon shaft closed and where is new
mining going to happen?
The issue of grass owls has been raised.
What ablution facilities will be on site?
How will the power plant work with Eskom?
16
15
Comments and Responses Report (Version 4)
Mr. Ernst de Jager,
Haverklip
Ms. Elise Tempelhoff,
Beeld
Mr. Johan Gericke,
Brakfontein
Mr. Johann Minnaar,
Vanggatfontein
Mr. Robbie van Bulderen
Transnet
Mr Jan Moolman
Department of Water
Affairs
I&AP Public Meeting
held on 19 May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
Authorities Meeting
held on 19 April 2012
I&AP Public Meeting
held on 19 May 2012
Authorities Meeting
held on 19 April 2012
50
There are different models for building the power plant – this
will be an IPP. Investment will come from Kuyasa and its
other investors. Power will be sold to different buyers to
recover their costs. It will be private sector money.
No, it will be based on a zone of influence.
1.8 Million tonnes were mined at Delmas Coal the previous
year. Delmas Coal owns approximately 200 million tonnes in
Yes, it covers all listed activities, not just the power plant
and ash facility.
Solomon Shaft is closed. Current mining will continue from
South Shaft and North Shaft.
Ingwe/BHB Billiton.
Yes, some of the coal is good for Eskom but some patches
are not good for Eskom.
No, it is an underground mine.
Yes.
need arises.
The initial concept is for Eskom to buy the electricity, but
options to find additional customers and sell the power via
the Eskom grid are also investigated.
Sewerage Treatment Plant will be provided for the 200
people, but most likely chemical toilets will be used during
construction with an agreement with the municipality with
the contractor for the disposal of waste during construction.
Grass owls were considered in the biodiversity assessmentsee Volume 3 of the EIR.
Noted. The traffic impact assessment, air quality impact
assessment and noise impact assessment are provided in
Volume 3 of the EIR.
The coal will be low grade directly from the mine.
The coal will be crushed but not washed.
A new crusher will be erected in the vicinity of the existing
North plant.
Yes it would need an extension and would be considered as
part of the application for any expansion of the plant.
25
24
23
22
So it means the mine will be short, and the
current stockpiles are already a mess. The
mine is still 900 000 tonnes short so where
will this come from?
So how will the new mine be licensed? How
will this additional coal supply be
addressed?
The Wilge River runs through my farm.
Delmas Coal and another mine are both
upstream of my farm and these two mines
have polluted the river to such an extent
that my animals cannot drink the water.
Traffic needs to be considered at a regional
level. Currently there is no data available
from a regional perspective. Need to
approach the Provincial department to do a
regional assessment. Traffic studies for
other projects here are really poorly done,
with traffic counts taken at inappropriate
times and without consideration for the
other mining development that is to happen
in the area.
Where will Eskom power line connection
work? Please add route and size of lines to
the report so that landowners are known.
There is a problem with Eskom’s
management process and therefore the
likely route should be shown in the EIA so
landowners are aware of the potential for
transmission lines.
Value of land, proximity to ash.
Rehabilitation of the pit could cost R50 to
R60 mil. But, they don’t want to buy land
that would be cheaper than that value.
There was a valuer used to assess the
farms, its assets, soil type, etc. The R42mil
4 years ago was for the entire mine, not just
the one pit.
If the power plant does not come, those pits
will lie there for another ten years before
Comments and Responses Report (Version 4)
Johann Minnaar:
Vanggatfontein
Johann Minnaar:
Vanggatfontein
Mr. Jan Boshoff,
Kromdraai
Mr. Peet Bezuidenhout,
Welgelegen
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
51
There is still some coal so those pits north of the plant will
not be rehabilitated soon to allow access to the remaining
coal.
The rehabilitation has to happen whether the power plant
occurs or not. Thus outside land will be a cost to the project
over and above the rehabilitation.
Eskom is currently investigating the power line connection.
Three alternatives are being considered by Eskom.
Therefore a final route is not yet known.
Noted. The Mpumalanga Traffic Department did not have
new projections for use in this study, however, the
department advised that a growth rate of 2% would
represent a worst-case scenario for the area. The traffic
impact assessment considered a growth rate of 2% as well
as looked at the impact of the project should the growth rate
be as high as 5%. See Volume 3 of the EIR.
coal reserves that will sufficiently support the proposed 600
MW Power Plant. Delmas Coal will supply unwashed coal to
the Kuyasa Power Plant from its No. 4 upper and No. 2
lower coal seams via an overland conveyor, which will be
sized to cater for the full coal demand of the power plant,
thus providing sufficient back-up for planned and emergency
maintenance on this supply system.”
The plant and ADF will contain all polluted water, which will
be treated for re-use. Please see Section 2 of the EIR and
the surface water impact assessment in Volume 3 of the
EIR.
27
32
31
30
29
Kendal Power Station which belongs to a
parastatal (Eskom) cannot control the dust
on its ash facility. How will KiPower control
the dust on its ash facility with a much
smaller budget than Eskom?
Our farm will be next door to the ash facility.
Will you monitor the dust on our farm as
well?
How will animal studies be done? Because
these studies are very complex and take a
lot of time. We cannot just extrapolate what
is done overseas. Umsebo mine indicated
there is not enough research on pigs and
chickens to determine any impact on
animals.
Please ensure a comparative analysis of
the complete cost of the power station is
made with other forms of energy. This
should include the full cost of water
treatment of the area where the coal is
mined, as well as the cost of coal
combustion. I am attaching a document
relating to the cost of coal combustion for
your perusal.
The cumulative impact – especially relating
to air pollution should also be investigated
in detail – taking into account the impact of
Kusile.
(The complete comments have been
appended to this document)
The DSR and application for this EIA
How will coal be moved to power station?
Will the ash facility be lined?
26
28
rehab. At least now it will be rehabilitated.
What about the rehab of the pits north of
the power plant.
Noise level – what radius will be looked at?
Comments and Responses Report (Version 4)
Mr. Rico Euripidou,
Dr Koos Pretorius,
FSE
Ms. Magda Kleyn,
Straffontein
Mr. Johan van Dyk,
Haverklip.
Ms. Elise Tempelhoff,
Beeld
Mr. Peet Bezuidenhout,
Welgelegen
Mr. Ernst de Jager,
Haverklip
Email on the 18 May
Email on the 20 April
2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
52
This is included in the social impact assessment in Volume
3 of the EIR.
The impact assessment did not consider individual species
but rather used national ambient standards to compare the
predicted ambient levels of dust and pollutants to. Where
the ambient standards would be exceeded, additional
mitigation has been specified in the EMP.
There is no defined zone of impact. Basically the impact
must have an acceptable zone based on the closest
receptor.
By conveyor belt.
Yes, according to new waste classification, ash is also
classified.
KiPower will be subject to several licenses that, if issued by
government, will be based on the current best practice
expected of such plants. The Eskom power stations are
likely dealing with legacy issues due to a lack of
environmental legislation when these were built.
Yes, a monitoring station has been recommended on your
farm – see Section 11 of the EIR.
1
Delmas is the most polluted area in the
region, but there is a shortage of power.
Local landowners have to live with the
pollution to supply the nation with power.
We cannot say that because we need
should be put aside based on the following
issues:
Air Quality:
 The power station cannot meet
stringent emission standards in its
design and operation.
 The report does not state whether
background PM measurements
were carried out on site.
Health Impacts:
 Coal pollutants contribute to four of
the five leading causes of mortality
in the USA.
 Each step of the coal lifecycle
impacts human health.
 Respiratory and nervous effects of
coal pollution.
Ash Disposal Facility:
 Coal ash contains toxic metals.
 The DSR does not do enough to
recognize that mercury is a global
priority in the power generation
sector and that some actions to
address mercury emissions in the
HPA need to be addressed.
The DSR has an incorrect interpretation of
our regulatory scheme regarding control of
air, water and land pollution.
Refer to the attached Groundwork
comments for more details on the above
comments.
(The complete comments have been
appended to this document)
Comments and Responses Report (Version 4)
Mr.Peet Bezuidenhout,
Welgelegen
Groundwork.
I&AP Public Meeting
held on 19May 2012
D. SOCIAL ISSUES
2012
53
Comment noted.
The one will be rehabilitated. The other may continue to be
mined by Ikhwezi in the future.
Metals, such as mercury, are included in the air impact
assessment in Volume 3.
Comparison of predicted pollutant levels were compared to
the national ambient standard and where these could be
exceeded, additional mitigation measures are included in
the EMP.
Background PM measurements were not available and were
extrapolated from regional data. Baselne monitoring is
proposed prior to construction.
CFB technology is able to meet the national emission
standards.
Is there anybody present today who has a
problem selling their land for the
development of this proposed project?
If we do not look carefully at these issues,
the pollution will impact on the nation,
through the food we eat from these farms. It
happens slowly but it happens.
1
2
2
power, that we must build power stations
without considering the impacts properly
and with sensitivity to the local people.
Will the two open pits be re-opened?
Socio-economic: Delmas coal started in
Dieplaagte and the Brakfontein informal
settlement remains today. Eskom power
has been uncoupled and there’s no
rehabilitation, etc. They don’t have work
and they steal and deal in crime. You
cannot go there at night. 3000 people here:
many will filter into the local environment
resulting in a big mess on the environment.
So this construction would result in other
informal settlements with similar problems.
The old compound needs to be addressed
because it is a social ill.
Comments and Responses Report (Version 4)
Mr.Peet Bezuidenhout,
Welgelegen
Mr Andre Joubert,
Facilitator, Zitholele
Consulting.
I&AP Public Meeting
held on 19May 2012
I&AP Public Meeting
held on 19May 2012
Meeting on 11 August
with potentially directly
affected landowners at
Delmas Coal.
E. ECONOMIC ISSUES
Mr. Jan Boshoff, Kromdraai
54
Radioactivity tests on trial ash indicate that the levels are
well below acceptable norm standards.
Nobody had any objection to selling property to Kuyasa
Mining for the proposed development, should an offer be
made. Potentially directly affected landowners present at the
meeting were:
Mr Johan van Dyk – Haverklip;
Mr TienieSchalekamp – Haverklip;
Ms Isabel Knox – Haverklip;
Mr Johan Claassens – Haverklip/ Vanggatfontein;
Mr Piet Combrink – Haverklip;
Mr GerritBorman – Haverklip;
Mr AdriaanNel – Haverklip;
Mr Wessel Venter – Steenkoolspruit/ Haverklip. (Mr Venter
also presented his father-in-law, Dr George Prinsloo, also a
potentially affected landowner.)
Kuyasa Mining will deal directly with landowners regarding
the possible purchasing of land as it falls outside the scope
of this environmental process.
Noted.
The EIR includes measures to minimise the formation of
new informal settlements or the increase of existing ones in
the EMP.
Kuyasa undertook to liaise with the municipality about the
existing information settlement.
How would Kuyasa handle a power station
if they cannot deal with the environmental
issues on the mine right now? Mine was
served with a Section 50 notice in terms of
MHS but nothing was done with regards to
dust suppression. Failure to comply with
environmental law has resulted in impacts
on neighbouring lands.
J&W was present at a meeting with the
previous mine manager and Head: DEA –
Mr Altus Lotter, and J&W wrote an action
plan which was attached in the enquiry to
DEA and DWA. Nothing has been done in
this regard. How sure are landowners that if
the ash facility is on/neighbouring their
property, that it will not encroach on their
land as on Mr Schalekamp’s land from the
mine. Where is the new crusher and how
could this further impact on Mr
Schalekamp’s property? The EMPR will
need to be amended for the crusher plant.
The mine has refused to provide a copy of
3
2
My client has the following concerns:
The product dumps encroach onto his
property even after the erection of a
concrete boundary fence.
Not effective dust suppressions which leave
coal dust on the agricultural land as far as
500m from the boundary fence.
Coal dust is ever present over my client’s
property and on structures and immovable
assets at the homestead.
Is the R50 mine shaft closed?
1
The dust from the ash facility is sometimes
radioactive and this needs to be
considered.
Comments and Responses Report (Version 4)
Mr. Martin Schalekamp,
Haverklip
(Mr. Johann Minnaar)
Mr. Johan van Dyk,
Haverklip.
Mr. Johann Minnaar on
behalf of Mr. M. A
Schalekamp,
Matjiesgoedkuil 266 IR
I&AP Public Meeting
held on 19May 2012,
(Email on 11 May
2012)
I&AP Public Meeting
held on 19May 2012
Email on 11 May 2012
The power plant will be regulated in terms of the latest
legislation. The design includes many measures to minimise
impacts as indicated in Section 2 and Section 10 of the EIR.
The mine is considering options to solve the problem. It is a
challenge.
The mine does not want to make false promises. There are
issues of space and engineering constraints.
It will not be opened again. The open pit across the road will
not be re-mined. In fact it is the site for the ash facility in
future.
Comments noted.
KiPower will be a separate entity and will be subject to
several licenses that, if issued by government, will be based
on the current best practice expected of such plants. Kuyasa
wishes to note that Delmas Coal is an old colliery, and many
of the issues are legacy issues which are being addressed.
F. ISSUES NOT RELATED TO THIS STUDY
55
6
5
4
The underground fire is smouldering on
both sides and most probably beneath the
Wilge River as well.
the EMPR to the farmers. Maize had to be
replaced with grass and the cattle don’t
want to eat the grass there. The retaining
wall has been broken and they fix it and
then it breaks again. The land is covered in
coal dust and cannot be used anymore.
The coal chute runs right against the fence
line – there is no space for the coal to slope
away – therefore it falls over the fence.
Why must government grant a RoD if this
applicant cannot comply with environmental
laws of this country as evidenced on
Delmas Coal? Delmas Coal is engaging
with the farmer. How can this be taken
further?
The mine is obviously too slow and they are
losing patience. There is an appeal to take
this issue forward.
(The complete comments have been
appended to this document)
(Photos attached to this report)
Discard dumps that are burning. When you
call their office, they say it is Eskom’s
problem. They do not talk to the farmers.
There was a notice issued to them by Mike
Poultney, DMR. If there are problems in
the future, the environmental consultants
are no longer involved and the farmers sit
with the problems. The mine just does not
care.
I have photos showing that the discard
dump is burning and that nothing is being
done to solve this problem.
(Photos attached to this report)
Comments and Responses Report (Version 4)
Mr Izak de Lange,
Steenkoolspruit
Mr.Johan Gericke,
Brakfontein
Mr.Peet Bezuidenhout,
Welgelegen
Telephonic
conversation on 9
November 2012
I&AP Public Meeting
held on 19 May 2012
I&AP Public Meeting
held on 19May 2012
56
KiPower will be a separate entity and will be subject to
several licenses that, if issued by government, will be based
on the current best practice expected of such plants. Kuyasa
wishes to note that Delmas Coal is an old colliery, and many
of the issues are legacy issues which are being addressed.
Noted.
KiPower will be subject to several licenses that, if issued by
government, will be based on the current best practice
expected of such plants.
The Highveld Priority Area Air Management Plan aims to
improve government’s capacity to address the current air
quality issues in the area.

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