Response on the DRS
Comments on DSR Transmission Lines
NMA Effective Social Strategists ATTENTION: Theo Hansford
Fax: 086 601 0381
E-mail: theoh@nma.org.za
Dear Sir
COMMENT: DRAFT SCOPING REPORT, PROPOSED ESKOM
BANTAMSKLIP TRANSMISSION LINES & ASSOCIATED
INFRASTRUCTURE (DEAT EIA Ref.NoS 12/12/20/1223 & 12/12/20/1224)
The Overstrand Conservation Foundation (OCF) wishes to make the following
comments regarding the Draft Scoping Report for the above referenced EIA’s.
The comments relate to the following observations:
- Obligation to find data
- Western Cape Provincial Spatial Development Framework Objectives, Policies, Strategies as Criteria for EIA Decision-making
- Establishing World Best-Practice for Electrical Power Transmission through a Biodiversity Hot-Spot
- Underground Cabling Option
- Detailed Specialist Study on Tourism Impact
- Integration of Conclusions & Recommendations of the Transmission Line and Bantamsklip EIA’s
Obligation to find data
The Draft Scoping Report assigns sensitivities to areas through which the proposed alternative transmission line routes pass on the basis of data / information available at the time that the alternative routes were mapped out. Areas along the routes for which incomplete or no information was available have been classified as having “low sensitivity.” This association of low sensitivity with areas for which there is a lack of data is not acceptable. The obligation in environmental law for the use of the “precautionary principle” requires that a lack of data should be associated with high sensitivity until such time as data has shown that this is not the case.
There is an obligation on the developer to acquire data that demonstrates that the activity proposed will not compromise biodiversity. There should similarly be the same obligation in relation to aesthetics, tourism and other socio-economic sensitivities.
The scoping report must contain a specification of the precautionary principle and require that all specialists rigorously apply it.
Western Cape Provincial Spatial Development Framework Objectives, Policies, Strategies as Criteria for EIA Decision-making
The Western Cape Provincial Spatial Development Framework (WCPSDF) sets out the objectives, policies, strategies and guidelines that are to be used for the planning of developments across the Western Cape. This WCPSDF was drawn up with full public participation and is the only document that has had wide public input that can be used as a reference in matters relating to the planning of development.
Specialist studies must all draw their conclusions and make their recommendations in terms of the contents of the WCPSDF and this document must form the basis upon which the Department of Environment and Tourism makes its decisions about the impact upon the environment and sustainability in the area.
Specialist studies must all draw their conclusions and make their recommendations in terms of the contents of the WCPSDF and this document must form the basis upon which the Department of Environment and Tourism makes its decisions about the impact upon the environment and sustainability in the area.
Specialist studies must all draw their conclusions and make their recommendations in terms of the contents of the WCPSDF and this document must form the basis upon which the Department of Environment and Tourism makes its decisions about the impact upon the environment and sustainability in the area.
Specialist studies must all draw their conclusions and make their recommendations in terms of the contents of the WCPSDF and this document must form the basis upon which the Department of Environment and Tourism makes its decisions about the impact upon the environment and sustainability in the area.
The area through which the proposed transmission lines are to pass form a key part of the Cape Floristic Kingdom, internationally recognised as a biodiversity hot spot that is under threat.
The area through which the proposed transmission lines are to pass form a key part of the Cape Floristic Kingdom, internationally recognised as a biodiversity hot spot that is under threat.
The Scoping Report needs to specify that a study must be performed to determine international best practice for transmitting electrical power through biodiversity hot spots of similar sensitivity to the Cape Floral Kingdom.
Underground Cabling Option
The Scoping Report makes no provision for any part of the transmission line to be underground and the specialist studies will ignore this possibility. Lack of any study will rule out underground cabling as a possible solution to serious visual sensitivity or other problems. While underground cabling may not be a preferred alternative to overhead transmission lines, it must be a possible solution for certain portions of the proposed routes and must be included as a potential recommendation that specialists may make.
The scoping report must require underground cabling as a potential option for sections or all of the route.
Detailed Specialist Study on Tourism Impact
Tourism is the lifeblood of the Overstrand economy, present and future. The potentially significant damage that is likely to occur to tourism development as a result of the combination of a nuclear plant at Bantamsklip and the associated transmission lines needs to be specifically studied in detailed. The study needs to look at the cumulative effect of the power station and the transmission lines and all the associated construction and operational activities. The separation of the impacts is unlikely to give a true reflection and is therefore not acceptable.
The Scoping Report must specify a study of the potential impact on future tourism development of the combined power station and transmission lines.
Integration of Conclusions & Recommendations of the Transmission Line and Bantamsklip EIA’s
This may not be relevant to the Scoping Report, but has a bearing on the plan for conducting the EIA’s and developing the EIR’s. To their credit, Acrus Gibb use a peer review process to integrate the specialist report findings and to prepare the EIR’s for each EIA. Since there are multiple EIA’s covering parts of the proposed transmission line and the proposed Bantamsklip power station, a similar peer review process is necessary to draw the conclusions and recommendations of the separate EIR’s together. This final summation of the EIR’s should be subject to public comment before DEAT make their decision.
Summary
Obligation to find data
The scoping report must require all specialist studies to apply the precautionary principle and to assume high sensitivity in the absence of data to show a lower sensitivity rating.
Western Cape Provincial Spatial Development Framework Objectives, Policies, Strategies as Criteria for EIA Decisionmaking
The Specialist studies must use the WCPSDF as the basis for drawing conclusions and making recommendations about the impact of the proposed transmission lines. If any other basis is used for decision-making criteria, this must be subjected to public comment.
Establishing World Best-Practice for Electrical Power Transmission through a Biodiversity Hot-Spot
The scoping report must include a specialist study to establish what world best-practice is for transmission of electrical power across biodiversity hot spots of similar sensitivity to the Cape Floristic Kingdom.
Underground Cabling Option
The lack of any specialist study into the use of underground cabling as a possible solution to visual or other problem over portions of the proposed cable route rules this out. The Scoping Report must include the study of underground cabling as an alternative for highly sensitive portions or all of the route.
Detailed Specialist Study on Tourism Impact
The Scoping Report must include a study of the cumulative effect on future tourism development of the proposed Bantamsklip power station and the associated transmission lines.
Integration of Conclusions & Recommendations of the Transmission Line and Bantamsklip EIA’s
The same approach as is used to integrate the specialist report conclusions and recommendations into an EIR for each EAI must be applied to the integration of the EIR’s for the separate EIA’s into a single recommendation to DEAT relating to the proposal to build the Bantamsklip Power Station and the associated transmission lines. This integrated EIR must be subject to public comment before DEAT makes the final decision.
Please acknowledge receipt of this document.
Yours faithfully
Rob Fryer
Manager
Cc: OCF members.
