J27344-Sani Pass Draft Scoping Report

Transcription

Environmental Impact Assessment for the Proposed
Upgrade of the Sani Pass Road (P318): Phase 2
Draft Scoping Report
Project No.: J27344
DEAT Ref. No.: 12/12/20/1184
December 2008
PURPOSE OF THIS REPORT
The Department of Transport (DOT) proposes to continue with the upgrading of the existing
Sani Pass Road (P318), which transects the uKhahlamba Drakensberg Park World Heritage
Site (UDP WHS) near Himeville, KwaZulu-Natal (KZN). This is the second phase of a twophase project. Phase 1 has been granted environmental authorisation and construction has
commenced. The second phase, for which this EIA is being conducted, extends from km 14
at the old Good Hope Trading Post, which is also the eastern boundary of the UDP WHS, to
km 33, the summit of the Sani Pass at the Lesotho Border post, a total distance of 19kms.
In order to undertake the proposed upgrade, DOT is required to conduct an Environmental
Impact Assessment (EIA) process and compile an EMP in terms of the National
Environmental Management Act (NEMA), 1998 (Act 107 of 1998). Arcus GIBB (Pty), an
independent company has been appointed to conduct the EIA for the Upgrading of the Sani
Pass Road.
This environmental authorisation process commences with an Environmental Scoping Phase
(hereafter referred to as the ‘Scoping Phase’). Following submission of a Scoping Report and
associated Plan of Study for the Impact Assessment Phase, to and approval by the DEAT,
the Impact Assessment Phase will be initiated. A prescribed Public Participation Process
runs concurrently with the Scoping and Impact Assessment Phases.
The objectives of the Scoping Phase are to:
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Investigate and gather information on the proposed site to establish an understanding
of the area
Establish how the proposed development activities will potentially impact on the
environment
Identify Interested and Affected parties (I&APs) and relevant authorities by conducting
a public participation process
Identify potential environmental impacts and issues through investigation and those
raised through public participation
Describe proposed and potential alternatives
Define the scope of the Impact Assessment Phase.
This Draft Environmental Scoping Report will be distributed to I&APs and placed at
numerous public places for public review and comment from 03 December 2008 for a period
of 52 days (comment period ending 23 January 2009). Registered I&APs will be informed of
the availability of the DSR for review. Any comments received on the Report will be recorded
in the comments register and will be appended to, and addressed in the Final Scoping
Report (FSR). The FSR will then be submitted to the DEAT for authorisation. I&APs will be
informed of the submission with electronic copies distributed to those who wish to review the
FSR.
This Draft Environmental Scoping Report consists of:
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An overview of background description of the proposed project
Identified alternatives to the proposed project
A description of the existing environment of the project area
An overview of the EIA process, including public participation followed to date
The potential environmental issues and impacts which have been identified to date
A Plan of Study (POS) detailing the tasks and specialist studies that will be
undertaken during the Impact Assessment Phase
J27344-Sani Pass Draft Scoping Report.doc
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YOUR COMMENT ON THE DRAFT SCOPING REPORT
This Draft Scoping Report is available for public comment from Wednesday 03 December
2008 until 23 January 2009. The DSR is available in both hard and soft copy. Hard copies
of the DSR are available at the following places:
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Underberg Library
Kwa Sani Municipal Offices
Southern Drakensberg Tourist and Accommodation Centre
Arcus GIBB office (Durban)
NOTE: Hard copies are not to be removed from the venues.
Soft copies of the report are available on a CD. Please contact the undersigned to request
your copy. Alternatively, the Report can be downloaded from the Arcus GIBB website:
www.gibb.co.za
You may comment on this Draft Scoping Report by:
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Submitting a written letter or email (with any additional supporting material)
Attending the Public Meeting (see below)
Public Meeting and Open Day
An open day and public meeting will be held, for those who wish to attend, on 06 December
2008 at the Underberg Primary School Hostel. The open day will start at 10h00 and the
public meeting at 14h00 during which time you will have the opportunity to interact with
project team and discuss any issues and concerns you may have on the project.
The due date for comments on this Draft Scoping Report is 23 January 2009. Written and
electronic comments can be addressed to:
Sanusha Govender
Arcus GIBB (Pty) Ltd
P.O. Box 1365
Westville, 3630
Tel: (031) 267 8560
Fax: (031) 266 3310
Email: sgovender@gibb.co.za
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EXECUTIVE SUMMARY
The Department of Transport (DOT) proposes to continue with the upgrading of the existing
Sani Pass Road (P318), which transects the uKhahlamba Drakensberg Park World Heritage
Site (UDP WHS) near Himeville, KwaZulu-Natal (KZN). This project originally consisted of
three phases, of which Phase 1 has been granted environmental authorisation and
construction has commenced. Phases 2 and 3 have been combined into one phase, now
referred to as Phase 2. Phase 2 extends from km 14 at the old Good Hope Trading Post,
which is also the eastern boundary of the UDP WHS, to km 33, the summit of the Sani Pass
at the Lesotho Border post, a total distance of 19kms.
The motivation for the upgrading of the Sani Pass Road includes the following
considerations:
•
The existing road drainage system is unable to cope with the high intensity runoff of
water on steep gradients, which results in excessive scour and gravel loss. Gravel roads
constructed in steep gradients are generally more difficult to maintain which leads to
frequent closures of the road due to significant erosion and environmental damage.
•
Gravel is a non-renewable resource and good quality gravels are particularly difficult to
source in the Drakensberg areas of KwaZulu-Natal. The excessive loss of gravel from the
Sani Pass is therefore of serious concern, particularly as the opening of new borrow pits
has a high visual impact and is not permitted in the World Heritage Site. The haul
distance for gravels from outside borrow pits makes it difficult to maintain the Pass.
•
Furthermore a co-operation agreement was signed in 2005 between Lesotho and South
Africa to improve access between the two countries via Sani Pass. This is part of an
initiative to improve accessibility between SADC countries. The intention is for South
Africa to surface the P318 from Himeville to the Lesotho border and Lesotho to surface
the section from the SA border to Mokhotlong approximately 60kms away. The ultimate
goal is to have a hard-surfaced road all the way to Maseru.
•
The Sani Pass Road currently provides access to, and passes through, the UDP, which
is a proclaimed World Heritage Site. Sustainable access to the Park needs to be
developed and carefully managed and Main Road P318 forms an integral part of this
initiative. Furthermore, a co-operation agreement was signed in 2005 between Lesotho
and South Africa to improve access between the two countries via the Sani Pass. This
project is thus part of an initiative to improve accessibility between SADC countries.
Aside from being an access road into Lesotho, the Sani Pass Road is used by local
residents, landowners, tour operators and tourists to access private properties located
along the first section of the road, the UDP and the top of the Pass itself. The Sani Pass
also represents an important international trade, service and tourism link between
Lesotho and KwaZulu-Natal with many of the Basuto people from the Mokhotlong district
travel into South Africa to make use of the facilities in Underberg and Himeville.
It is predicted that the provision of an all-weather road through the Sani Pass will have a
number of anticipated economic benefits, namely:
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It will provide access to the UDP from both sides of the escarpment and incorporate the
border and park access controls
The distance between the eastern Free State, Maseru through to Durban will be reduced
by up to 150 km
The Eastern Lesotho Highlands will be opened up to tourism development
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Business and trade links between the Mokhotlong area and the businesses in Underberg
and Pietermaritzburg will be strengthened and extended
Transportation and accessibility to Lesotho for locals from both sides will improve
A new scenic tourism route will be opened up between the eastern Free State and
KwaZulu-Natal via Lesotho.
Environmental Authorisation
In terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998)
(NEMA), the upgrading of the Sani pass Road is listed as an activity that may be detrimental
to the environment and thus, requires authorisation from the Department of Environmental
Affairs and Tourism (DEAT) before it can proceed. The DOT has appointed Arcus GIBB as
the Environmental Assessment Practitioner (EAPs) to undertake the Environmental Impact
Assessment (EIA) for the project.
This report represents the Draft Environmental Scoping Report (DSR) for the proposed
project and has been prepared in accordance with the EIA Regulations published in
Government Notice No. R385 of 2006. These Regulations were published by the national
Department of Environmental Affairs and Tourism under Section 24(5) read with Section 44
of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) to
control activities which may have a detrimental effect on the environment.
Public Participation Process
The public participation for this project has been undertaken in accordance with Regulation
56 of the EIA Regulations (GNR 385) and associated guidelines. As part of the prescribed
process, the following tasks were undertaken:
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Identification and registration of stakeholders and interested and affected parties (I&APs)
on a database. Existing databases from Phase 1 and the Border Post Relocation Project
were integrated into the project database
Notification of Key Stakeholders through letters, email and telephonic discussions
Media notices detailing the project and the EIA process that is currently in progress, as
well as an invitation for the registration and participation of I&APs, was placed in the
Sunday Times, the Mercury and the Mountain Echo newspapers
Notice boards detailing information about the project and the Scoping and EIA Process,
as well as invitation to register as I&APs, were strategically fixed at various conspicuous
points along the Sani Pass route, as well as in public places in Himeville and Underberg
A Background Information Document (BID) was compiled in English, Sotho and Zulu and
distributed to all registered I&APs in South Africa and Lesotho and to various venues in
the Underberg and Himeville. The BID which contains information on the proposed
project, the proponent, consultants and the proposed Scoping and EIA process and
associated PPP to be followed.
Twelve (12) Key Stakeholder meetings were held with different public sectors,
organisations and individuals. The purpose of these meetings was to offer key
stakeholders an opportunity to raise issues, concerns with regard to the proposed
development.
An Open Day and Public Information Sharing Meeting have been scheduled for Saturday
06 December at the Underberg Primary School Hostel. The purpose of the open day is to
provide an informal opportunity for I&APs to interact one-on-one with members of the
project team and discuss their issues and concerns.
All I&AP and Stakeholder comments and issues recorded during the various meetings
and all written comments received have been documented in the Issues and Concerns
Report which is included in the Draft Scoping Report.
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•
The Draft Scoping Report has been released for public review for a period of 52 days
from 03 December 2008 to 23 January 2009 (inclusive).
Project Description
The proposed Phase 2 upgrade entails a complete re-grading and resurfacing of the Sani
Pass from a gravel to a hardened surface, all-weather road. The upgrade will include road
widening, re-alignment of sections, new bridges, stormwater control and attenuation
systems, bank and slope stabilisation and road servitude rehabilitation.
Alternatives
The project engineers have identified that the degradation of the Sani Pass Road is caused
by a number of factors. The main contributor is the poor stormwater drainage system which
is unable to cope with the excessive water flows and the run-off which are eroding the
surface of the road and the slopes of the Pass. In order to rectify these problems and prevent
further degradation, the project team has considered a number of road upgrade alternatives
which range from making minor improvements to the drainage to reconstructing the entire
road structure. Each alternative considers a variety of aspects, such as the impact on the
environment, tourism, community, road safety and political links.
The Alternatives are described in order of increasing scale of upgrade from no modification
(Alternative 1) to complete upgrade (Alternative 6). In the subsequent sections the
Alternatives are grouped and compared by aspect. Of the options, Alternative 5 is considered
by the project team to be the preferred option as it most effectively meets the design
specifications and objectives of the proposed project. Of the road surfaces, preliminary
studies indicate that a Granular Base and Continuously Reinforced Concrete Pavement
(CRCP) may be the preferred pavement types for the lower and upper sections of the route
respectively, but investigations are still on-going this stage.
Potential Environmental Impact and Issues
The environmental impacts and issues identified during Scoping to date have been
summarised into the following categories:
•
Biophysical
- Soil erosion and sedimentation
- Potential water and soil pollution
- Alteration of hydrological functioning and change on habitat
•
Ecological Impacts
- Destruction of Rare Species Habitats
- Sedimentation of local water sources and rivers
- Disturbance of avi-faunal species
- Disturbance of faunal species
•
Socio-Economic
- Change to sense of place and experience
- Sani Pass tourism
- Changes for commercial and private road users
- Local economic development and job creation
- Changes in human movement and trade patterns
- Safety and security of local residents
- Disruption to road users
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Economic
- Impact on employment, tourism and trade
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Visual/Aesthetic
- Construction camps and associated activities
- Construction of the road
- Road design
- Improper rehabilitation
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Cultural Heritage
- Impact on geological and fossil material
- The loss of a historical 4x4 road
- Impact on cultural heritage resources
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Road Structure and Construction
- Road Surface
- Road Maintenance
- Construction
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Safety Impacts
- Safety of workers
- Safety of travellers
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Technical Design Issues
- Engineering constraints
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Cumulative Impacts
Way Forward
The DSR will be made available in hard copy at the public places listed below from 03
December 2008 until 23 January 2009 (52 days) for public review. Registered I&APs will be
informed of the availability of the DSR for review. Electronic versions of the report are also
available on CD for those who wish to receive a copy or it can be downloaded from the Arcus
GIBB website.
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Underberg Library
Arcus GIBB website (www.gibb.co.za)
Any comments received on the Draft Scoping Report or any new comments or issues raised
during, or as a result of the Public Information Sharing Meeting, will be recorded in the ICR
which will be revised and incorporated into the Final Scoping Report (FSR). Following a
period of revision after expiration of the comment period, the FSR will be submitted to the
DEAT for review and authorisation. On receiving approval from the DEAT, the Impact
Assessment Phase of the EIA will be initiated.
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Environmental Impact Assessment for the Proposed Upgrade
of the Sani Pass Road (P318): Phase 2
CONTENTS
Chapter
Description
Page
1
OVERVIEW AND BACKGROUND
1
1.1
Background
1.1.1 Upgrading of the Sani Pass Road
1.1.2 Relocation of the Border Post
1
1
2
1.2
2
1.3
Responsible Parties
1.3.1 Arcus GIBB EIA Team
1.3.2 Specialists
1.4
1.4.1
1.4.2
1.4.3
1.4.4
1.4.5
1.4.6
2
3
4
5
6
Relevant Environmental Legislation
The Constitution of South Africa
The National Environmental Management Act
The Environment Conservation Act
Legislation for the Conservation of Natural Resources
Legislation for Cultural Resources
Local and Regional Integrated Development Plans
6
6
7
8
8
9
10
DESCRIPTION OF THE PROPOSED DEVELOPMENT
13
2.1
13
Proposed Development
2.2
Motivation for the Project
2.2.1 Department of Transport Motivation
13
13
2.3
2.3.1
2.3.2
2.3.3
2.3.4
2.3.5
2.3.6
2.3.7
2.3.8
14
14
15
15
16
16
17
17
18
Road Design and Construction Specifications
Department of Transport Terms of Reference
Horizontal and Vertical Alignment
Geo-Environmental Aspects of the Design/Construction
Material Sources
Structures
Drainage
Pavement
Construction
ALTERNATIVES
20
3.1
Description of Alternatives
20
3.2
Alternative Impacts on Department of Transport
21
3.3
Alternative Impacts on the Environment
22
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4
5
3.4
Alternative Impacts on Tourism
24
3.5
Alternative Impacts on the Local Communities
25
3.6
Alternative Impacts on Road Safety
26
3.7
Alternative Impacts on the KZN – Lesotho Links
27
3.8
Road Surface Alternatives
31
DESCRIPTION OF THE PROJECT ENVIRONMENT
33
4.1
General Description of the Region
33
4.2
4.2.1
4.2.2
4.2.3
4.2.4
4.2.5
Biophysical Environment
Topography
Climate
Geology and Soils
Geomorphology
Hydrology and Drainage
34
34
34
34
34
35
4.3
Botanical
4.3.1 General
4.3.2 Invasive Alien Plants
35
35
36
4.4
Fauna
4.4.1 General
4.4.2 Avi-Faunal
37
37
38
4.5
Aquatic Environment
4.5.1 Aquatic Herpetofauna – Amphibians
4.5.2 Icthyofauna – Fish
38
39
39
4.6
Socio-economic Environment
4.6.1 Social Context
4.6.2 Economic Context
40
40
41
4.7
Tourism
43
4.8
4.8.1
4.8.2
4.8.3
4.8.4
4.8.5
Aesthetics
Topography
Vegetation Cover
Landscape Diversity
Landscape Character
Visibility
44
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45
45
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46
4.9
Cultural Heritage Environment
4.9.1 History
4.9.2 Archaeology
46
46
48
SCOPING PHASE APPROACH AND METHODOLOGY
50
5.1
50
EIA Process
5.2
Scoping Phase
5.2.1 Objectives
52
52
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5.2.2 Scoping Report Requirements
52
5.3
Pre-application Consultation
53
5.4
EIA Application
53
5.5
Specialist Investigations
53
5.6
5.6.1
5.6.2
5.6.3
5.6.4
5.6.5
5.6.6
5.6.7
5.6.8
5.6.9
5.6.10
5.6.11
Identification and Involvement of Stakeholders and I&APs
Register of I&APs
Notification of Key Stakeholders
Registered I&APs from the Sani Pass Phase 1 Project
Landowner Notification
Media Notices
Notice Boards
Background Information Document
Stakeholder Meetings
Open Day and Public Information Sharing Meeting
Interested and Affected Parties and Stakeholder Comments
54
54
55
55
55
55
56
56
57
57
58
58
5.7
Compilation of the Draft Scoping Report and Public Review
59
5.8
Compilation of the Final Scoping Report
59
5.9
Comments Register
5.9.1 WESSA Tourism Survey
59
59
POTENTIAL ENVIRONMENTAL IMPACTS AND ISSUES
61
6.1
Introduction
61
6.2
Project Need and Desirability
62
6.3
6.3.1
6.3.2
6.3.3
Biophysical
Soil Erosion and Sedimentation
Potential Water and Soil Pollution
Alteration of Hydrological Functioning and Change in Habitat
63
63
63
63
6.4
6.4.1
6.4.2
6.4.3
6.4.4
Ecological Impacts
Destruction of Rare Species Habitats
Sedimentation of the Mkomazana River
Disturbance of Avi-faunal Species
Disturbance of Faunal Species
63
63
64
64
64
6.5
6.5.1
6.5.2
6.5.3
6.5.4
6.5.5
6.5.6
6.5.7
6.5.8
6.5.9
6.5.10
Socio-Economic
Change to Sense of Place
Sani Pass Tourism
Changes for Commercial and Private Road Users
Local Economic Development and Job Creation
Changes in Human Movement and Trade Patterns
Safety and Security Risk
Impacts on Road Safety and Travelling Conditions
Sporting Events
Safety and Security of Local Residents
Disruption to Road Users
65
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66
66
66
67
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67
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8
6.6
6.6.1
6.6.2
6.6.3
6.6.4
Economic
Economic Benefits
Economic Disbenefits
Employment
Economic Impacts on Tourism
67
67
68
68
69
6.7
6.7.1
6.7.2
6.7.3
6.7.4
Visual / Aesthetic
Construction Camps and Associated Activities
Construction of the Road
Slopes and Vegetation
Rehabilitation
69
70
70
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70
6.8
6.8.1
6.8.2
6.8.3
Cultural Heritage
Impact on Geological and Fossil Material
The Loss of a Historical 4x4 Road
Cultural Heritage Resources
70
70
71
71
6.9
6.9.1
6.9.2
6.9.3
Road Surface
Road Maintenance
Construction
71
71
72
72
6.10
Safety Impacts
73
6.11
73
6.12
Cumulative Impacts
74
PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT
ASSESSMENT
75
7.1
Impact Assessment Phase Tasks
75
7.2
Competent Authority Consultation
76
7.3
Environmental Impacts and Issues
76
7.4
7.4.1
7.4.2
7.4.3
7.4.4
7.4.5
Terms of Reference for Specialist Studies
Riverine and Aquatic Impact Assessment
Social Impact Assessment
Economic Impact Assessment
Visual Impact Assessment
Heritage Impact Assessment
76
77
78
78
79
79
7.5
Methodology for Impact Significance Scoring
80
7.6
Environmental Management Plan
81
7.7
7.7.1
7.7.2
7.7.3
7.7.4
Public Involvement
Announcement of the Availability of the Draft EIR and Draft EMP
Public Review of Draft EIR and Draft EMP
Announcement the Availability of the Final EIR and Draft EMP
Announcement of Authorities’ Decision
82
82
82
82
82
CONCLUSION AND WAY FORWARD
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8.1
Conclusion
83
8.2
Way Forward
83
REFERENCES
84
REVIEW STATEMENT
2
TABLES
Table 1: Identified Listed Activities
Table 2: Responsible Parties in EIA
Table 3: Arcus GIBB EIA Team Members
Table 4: Specialists Involved in the Scoping Phase
Table 5: Engineering Specialists involved in the Scoping Phase
Table 6: Road Upgrade Alternatives 1 and 2
Table 9: Resident Employment by Sector, Sani Pass Impact Area, KZN, 2001
Table 10: Media Notice Newspaper Details
Table 11: Notice Board Details
Table 12: List of Background Information Document Distribution Points
Table 13: Chronological List of Meetings
Table 14: Summary Table of Potential Impacts and Issues
3
4
5
6
6
28
29
30
42
56
56
57
58
61
FIGURES
Figure 1:
1: 50 000 Map
Figure 2:
Road Cross-Section Sketch of the Proposed Road Design
Figure 3:
River Structure line Drawing
Figure 4:
Botanical Species Map
Figure 5:
EIA Process Flow
Layout 1 sht 1-2
Design Plan for km 14 – km 16
Layout 2 sht 3-4
Design Plan for km 16 – km 18.6
Layout 3 sht 5-6
Design Plan for km 18.6 – km 20.7
Layout 4 sht 7-8
Design Plan for km 20.7 – km 23
Layout 5 sht 9-10
Design Plan for km 22.8 – km 25.1
Layout 6 sht 11-12 Design Plan for km 25.1 – km 27.3
PLATES
Plates 1-8: Scenic Photographs
Plates 9-16: Public Participation Notices
Plates 17-27: Environmental Impacts Related to and/or Resulting from the Sani Pass Road
APPENDICES
Appendix A: Curriculum Vitae for Arcus GIBB
Appendix B: List of Botanical Species
Appendix C: Curriculum Vitae for Specialists
Appendix D: Declaration of Independence
Appendix E: Interested and Affected Parties Database
Appendix F: Media Notices
Appendix G: Background Information Document
Appendix H: Meeting Minutes
Appendix I: Issues and Concerns Report
Appendix J: Authority Comments
Appendix K: I&AP Comments Received
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ACRONYMS & ABBREVIATIONS
ACER:
AMAFA:
a.s.l:
BCOCC:
BID:
DAEA:
DEAT:
DEIR:
DM:
DMA:
DME:
DOT:
DSR:
DWAF:
ECO:
EA:
EIA:
EKZNW:
EMP:
FEIR:
FSR:
HIA:
I&AP:
IDP:
IMP:
IRP:
KZN:
LM:
MDG:
MDTP:
NEMA
NEPAD:
PLC:
PPP:
PGDS:
PSEDS:
RISP:
ROD:
SADC:
SCAP:
TFCA:
UDP WHS:
ACER (Africa) Environmental Management Consultants
AMAFA aKwaZulu-Natali
above sea level
Border Control Operational Co-ordinating Committee
Background Information Document
KZN Department of Agriculture and Environmental Affairs
Department of Environmental Affairs and Tourism
Draft Environmental Impact Report
District Municipality
Demarcated Management Area
Department of Minerals and Energy
National Department of Transport
Department of Water Affairs and Forestry
Environmental Control Officer
Environmental Impact Assessment
Ezemvelo KZN Wildlife
Final Environmental Impact Report
Final Scoping Report
Interested and Affected Party
Integrated Development Plan
Integrated Management Plan
Issues and Response Report
KwaZulu-Natal
Local Municipality
Millennium Development Goals
Maloti Drakensberg Transfrontier Project
National Environmental Management Act, 1998 (Act No 107 of 1998)
New Partnership for Africa’s Development
Project Liaison Committee
Public Participation Programme
Provincial Growth and Development Strategy
Provincial Spatial Economic Development Strategy
Regional Indicative Strategic Development Plan
Record of Decision
Southern African Development Community
Special Case Area Plan
Transfrontier Conservation Areas
uKhahlamba Drakensberg Park World Heritage Site
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1
OVERVIEW AND BACKGROUND
The Department of Transport (DOT) proposes to continue with the upgrading of the
existing Sani Pass Road (P318), which transects the uKhahlamba Drakensberg Park
World Heritage Site (UDP WHS) near Himeville, KwaZulu-Natal (KZN). This project
originally consisted of three phases, of which Phase 1 has been granted
environmental authorisation and construction has commenced. Phases 2 and 3 have
been combined into one phase, now referred to as Phase 2. Phase 2 extends from
km 14 at the old Good Hope Trading Post, which is also the boundary of the WHS, to
km 33, the summit of the Sani Pass at the Lesotho Border post, a total distance of 19
kilometres.
The study area is approximately 23 kms north of the town of Underberg, KwaZuluNatal and falls within the jurisdiction of Kwa Sani Local Municipality and Sisonke
District Municipality (See Figure 1).
The DOT, as the project proponent, has appointed Arcus GIBB (Pty) Ltd (Arcus GIBB)
as the Independent Environmental Assessment Practitioner (EAP) to undertake the
Environmental Impact Assessment (EIA) for the proposed upgrading of the Sani Pass
Road (P318): Phase 2 (hereafter referred to as the ‘proposed project’ or ‘Road’).
This report constitutes the Scoping Phase of the EIA, which places the project in
context, describes the proposed project and alternatives, and identifies the potential
impacts related to the proposed project through public involvement and technical
investigations.
The following chapter provides a background to the proposed project and associated
EIA process, outlines the purpose and structure of the Scoping Report, and details of
the EIA application and the project team.
1.1
Background
1.1.1 Upgrading of the Sani Pass Road
Initially, the proposed upgrading of the Sani Pass Road was to occur in three phases:
•
•
•
Phase 1 – km 0 (junction with the Main Road 126 from Himeville) to km 14
(Good Hope Trading Post)
Phase 2 – km 14 (Good Hope Trading Post) to km 25 (current SA border post)
Phase 3 – km 25 to km 33 (summit at Lesotho border post)
The EIA for Phase 1 was undertaken by ACER (Africa) Environmental Management
Consultants during 2006 and was conducted in terms of the Environment
Conservation Act (Act No. 73 of 1989). Environmental authorisation was issued by
the KZN Department of Agriculture and Environmental Affairs (DAEA) on 02 October
2006. Construction of Phase 1 commenced in October 2006 with earthworks
currently still underway.
Phase 1 entailed the upgrading of the first 14kms of the P318 from a gravel road to
an 8.5m wide two-lane blacktop (asphalt) road (type 3 road cross-section). The road
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was designed to allow a speed of 80km/hr for the first 7.5km and 60km/hr for the
remaining 6.5km. The Phase 1 was designed to carry all vehicle types, including
articulated vehicles that are currently used in the area.
In addition, the Phase 1 upgrade also included the improvement of road geometrics
(e.g. improving the radius of sharp corners requiring localized re-alignments) and the
construction of a number of bridges or box culverts for improved stormwater control
and drainage as the road crosses a number of stream crossings and drainage lines.
The motivation for the Phase 1 upgrade was to:
•
•
•
Improve access in the area for farming and forestry operations, local residents,
tourism facilities, taxis, tourists and deliveries
Improve access to the South African border post, which is planned for
relocation to the Good Hope trading store ruins located at the end of the
Phase 1 upgrade at km 14
Provide an upgraded link from the Main Road 126 (km 0) near Himeville to the
start of Phase 2 (provided Phase 2 receives environmental authorisation).
The initial intention had been to upgrade of the remaining portion of the Road in two
(2) phases as noted above. The DOT has since revised the project and combined the
initial Phase 2 and 3 into Phase 2 and has initiated the planning and engineering
design phase of the road which includes the EIA for Phase 2.
1.1.2 Relocation of the Border Post
The Sani Pass Road passes through the South African Sani Border Post at km 25.
Ezemvelo KZN Wildlife (EKZNW), in conjunction with DEAT, the Department of Public
Works and the Border Control Operational Co-ordinating Committee (BCOCC), are
proposing to relocate the Sani Border Post. This includes an entrance gate and
interpretation centre for the UDP WHS, to the site of the Good Hope trading store
ruins at km 14. The Basic Assessment for the proposed relocation is currently in
progress under the direction of ACER (Africa).
Although both the proposed Border Post Relocation Project and the upgrading of the
Sani Pass Road Project are invariably linked by the fact the Border Post is located on
the Road and controls access to the Road, the EIAs for the projects are not related,
nor are their environmental authorisation applications dependent on the outcome of
the other.
1.2
This report represents the Draft Environmental Scoping Report (DSR) for the
proposed project and has been prepared in accordance with the EIA Regulations
published in Government Notice No. R385 of 2006. These Regulations were
published by the DEAT under Section 24(5) read with Section 44 of the National
Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) to control
activities which may have a detrimental effect on the environment.
Accordingly, certain “listed activities” require environmental authorisation by way of an
EIA process as described in Chapter 4.1 below.
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The following activities, as listed in Government Notice No. R386 and 387 (July 2006
EIA Regulations) have relevance to the proposed project:Table 1: Identified Listed Activities
Number and
date of the
relevant notice
GNR 386
Listing Notice 1
Activity
No
1 (d)
1 (m)
1 (p)
1 (k)
GNR 386
Listing Notice 1
12
GNR 386
Listing Notice 1
15
GNR 387
Listing Notice 2
2
GNR 387
Listing Notice 2
5
Listed activity
The construction of facilities or infrastructure, including
associated structures or infrastructure, for resorts, lodges, hotels or other tourism and hospitality
facilities in a protected area contemplated in the National
Environmental Management: Protected Areas Act, 2003
(Act No. 57 of 2003)
Any purpose in the one in ten year flood line of a river or
stream, or within 32 metres from the bank of a river or
stream where the flood line is unknown, excluding
purposes associated with existing residential use, but
including – canals; channels; bridges; dams; and weirs
The temporary storage of hazardous waste
The bulk transportation of sewage and water, including
stormwater pipelines with –
i) an internal diameter of 0.36 meters or more; or a peak
throughput of 120 litres per second or more
The transformation or removal of indigenous vegetation of
3 hectares or more or of any size where the
transformation or removal would occur within a critically
endangered or an endangered ecosystem listed in terms
of section 52 of the National Environmental Management:
Biodiversity Act, 2004 (Act No. 10 of 2004)
The construction of a road that is wider than 4 metres or
that has a reserve wider than 6 metres, excluding roads
that fall within the ambit of another listed activity or which
are access roads of less than 30 metres long
Any development activity, including associated structures
or infrastructure, where the total area of the development
area is, or is intended, 20 hectares or more
The route determination of roads and design of associated
physical infrastructure, including roads that have not yet
been built for which routes have been determined before
the publication of this notice and which has not been
authorised by a competent authority in terms of the
Environmental Impact Assessment Regulations, 2006
made under section 24(5) of the Act and published in
Government Notice No. R. 385 of 2006, where:
i) it is a national road as defined in section 40 of the
South African National Roads Agency Limited and
National Roads Act, 1998 (Act No. 7 of 1998);
ii) it is a road administered by a provincial authority;
iii) the road reserve is wider than 30 metres; or
iv) the road will cater for more than one lane of traffic in
both directions.
The proposed project constitutes activities under both GNR386 requiring a Basic
Assessment and GNR387, a full Scoping and Environmental Impact Assessment
Process. However, the EIA Regulations (GNR385) stipulate that where any activity
associated with a proposed development is listed within GNR387, a full Scoping and
EIA Process must be followed, regardless of whether additional activities are
identified in GNR 386 for Basic Assessments. Therefore a full Scoping and EIA
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Process is required for the proposed upgrade of the Sani Pass Road (P318): Phase
2.
1.3
Responsible Parties
Table 2: Responsible Parties in EIA
DEAT CASE OFFICER
PROPONENT
DEAT Environmental Impact Evaluation Unit
Mr. Chuckeka Tivani
Principal Environmental Officer
Department of Transport (DOT)
Mr. Siboniso Mbhele
P.O. Box 9043
Pietermaritzburg
3200
Department of Environmental Affairs and
Tourism
Private Bag X447, Pretoria 0001
Tel: 031 355 8704
Fax: 031 355 8090
siboniso.mbhele@knztransport.co.za
Tel: 012 310 3533
Fax: 012 320 7539
e-mail: ctivani@deat.gov.za
PROJECT ENGINEERS
ENVIRONMENTAL ASSESSMENT
PRACTITIONER
Mr. Russell Stow
Associate Environmental Scientist
Joint Venture between SSI, Semenye
Furumele Transportation Engineers and
Ndizani Civilworks
SSI
Mr. Eddy Gademan
Project Engineer
P.O. Box 1365, Westville, 3630
Tel: 031 267 8560
Fax: 031 266 3310
email: rstow@gibb.co.za
P.O. Box 1066, Pietermaritzburg, 3200
Tel: 033 345 3211
Fax: 033 386 3635
e-mail: eddyg@ssi.co.za
Semenya Furumele Transportation Engineers
Mr. Sello Semenya
Project Engineer
Suite 6, Hillcrest Office Park, 2 Old Main Road,
Hillcrest, 3650
Tel: 031 765 3079
Fax: 031 765 6525
e-mail: Raymond.reynolds@sfte.co.za
Ndizani Civilworks
Mr. Obakeng Pienaar
Project Engineer
32 Churchill Road, Windermere,Durban, 4001
Tel: 031 303 7622
e-mail: pienaaro@nizanicivilworks.co.za
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1.3.1 Arcus GIBB EIA Team
The EIA team comprises the following members from Arcus GIBB:
Table 3: Arcus GIBB EIA Team Members
NAME
ROLE
Jaana Maria Ball
Project Director and Reviewer
Russell Stow
Project Leader and Senior Environmental Scientist
Gisela Fechter
Project Leader and Senior Environmental Engineer
Tarryn Henstra
Project Environmental Scientist
Sanusha Govender
Project Environmental Scientist PPP coordinator
Rashieda Thomas
Project Environmental Scientist
Arcus GIBB is a multi-disciplinary engineering and environmental consultancy
organisation whose environmental division comprises over 50 highly qualified and
experienced environmental professionals. Arcus GIBB’s Environmental Division has
a proven track record in the planning, co-ordination, management and execution of a
wide range of environmental projects (CV’s are attached in Appendix A). Key areas
of expertise include:
Environmental Sciences:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Environmental advisory services
Environmental policy and corporate reporting
Sustainability assessments
Environmental management systems
Environmental liability and risk assessment
Integrated development planning
Strategic environmental assessments
Environmental impact assessments
Public consultation
Environmental management programmes
Environmental training, monitoring and auditing
Environmental permit and regulatory compliance management
Coastal zone management
Planning and botanical and rehabilitation assessments
Environmental Engineering:
•
•
•
•
•
•
•
•
•
•
•
Environmental monitoring protocols
Hazardous waste management
Integrated waste management plans
Landfill management and operation plans
Landfill planning, development, design, construction and closure
Leachate treatment and landfill gas management
Monitoring and environmental permit and regulatory compliance management
Permitting of landfill sites
Pollution prevention
Risk assessment
Site remediation
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•
Waste minimisation and recycling
1.3.2 Specialists
It was recognised early in the technical component of the Scoping Phase that there
was insufficient information available (inadequate, out-dated or unavailable
information) on certain aspects of the local and regional environment in order to make
an accurate contextualisation of the study area and identify potential environmental
impacts. Specialists were, therefore, appointed to research and describe the various
aspects and, base d on their investigations, identify and describe related potential
environmental issues and impacts that could occur as a result of the upgrade. The
specialist studies and details of the appointed specialists are provided below:
Table 4: Specialists Involved in the Scoping Phase
Aspects
Visual and Aesthetics
Botanical
Archaeology and Heritage
Social and Tourism
Economic and Tourism
Aquatic
Avi-Fauna
Specialist
Bapela Cave and Klapwijk
Mr. Menno Clapwijk
Elsa Pooley Indigenous Landscaping
Dr. Elsa Pooley
Nzumbululo Heritage Solutions
Dr. McEdward Murimbika
Institute of Natural Resources (INR)
Ms. Fonda Lewis
African Development Economic Consultants (ADEC)
Mr. Randall Gross
Ground Truth
Dr. Mark Graham
Pied Piper Expeditions
Prof. Steven Piper
In addition to these investigations, the following technical studies were undertaken as
part of the engineering component which have relevance to the EIA:
Table 5: Engineering Specialists involved in the Scoping Phase
Aspects
Geotechnical Investigation
Traffic Impact Assessment
Hydrological Assessment
1.4
Specialist
Arq Consulting Engineers
Mr. Alan Parrock
Mr. Stan Walden
SSI / Semenye Furumele / Ndizani Civilworks
Relevant Environmental Legislation
This chapter details applicable legal provisions and aims to provide a review of
relevant national and provincial legislation and regulations, and policy documents,
which are applicable to (or have implications for) the proposed upgrade of the Sani
Pass Road.
1.4.1 The Constitution of South Africa
The legal reference source for environmental law in South Africa is found in the
Constitution of the Republic of South Africa (Act No.108 of 1996) and as such, all
environmental aspects should be interpreted within the context of the Constitution.
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The Constitution has enhanced the status of the environment by virtue of the fact that
environmental rights have been established (Section 24) and other rights created in
the Bill of Rights which impact on environmental management. An objective of local
government is to provide a safe and healthy environment (Section 152) and public
administration must be accountable, transparent and encourage participation (Section
195(1)(e) to (g)).
1.4.2 The National Environmental Management Act
The National Environmental Management Act (Act No. 107 of 1998) (NEMA) is South
Africa’s overarching framework for environmental legislation. The objective of NEMA
is to provide for operative environmental governance by establishing principles for
decision-making on matters affecting the environment, institutions that will promote
co-operative governance, and procedures for co-ordinating environmental functions
exercised by organs of state.
NEMA sets out a number of principles that aim to implement the environmental policy
of South Africa. These principles are designed, amongst other purposes, to serve as
a general framework for environmental planning, as guidelines by reference to which
organs of state must exercise their functions and to guide other law concerned with
the protection or management of the environment.
The principles include a number of internationally recognised environmental law
norms and some principles specific to South Africa, namely, the:
•
•
•
•
Preventive Principle
Precautionary Principle
Polluter pays Principle
Equitable access for the previously disadvantaged to ensure human wellbeing.
Chapter 5 of NEMA is designed to promote integrated environmental management.
Environmental management must place people and their needs at the forefront of its
concerns, and serve their physical, psychological, developmental, cultural and social
interests equitably. Development must be socially, environmentally and economically
sustainable. Sustainable development therefore requires the consideration of all
relevant factors including the following:
•
•
•
•
•
•
•
•
The disturbance of ecosystems and loss of biological diversity is avoided, or,
minimised and remedied
The pollution and degradation of the environment are avoided, or, minimised
and remedied
The disturbance of landscapes and sites that constitute the nation’s cultural
heritage is avoided, or, minimised and remedied
That waste is avoided, or, minimised and re-used or recycled where possible
and otherwise disposed of in a responsible manner
The use and exploitation of non-renewable natural resources should be
utilised responsibly and equitably
The development, use and exploitation of renewable resources and the
ecosystem of which they are part of, do not exceed the level beyond which
their integrity is jeopardised
A risk-averse and cautious approach is applied
Negative impacts on the environment and on the people’s environmental
rights be anticipated and prevented, and where they cannot be altogether
prevented, are minimised and remedied.
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Regulations promulgated under NEMA include the EIA Regulations published under
GNR 385, and the associate Listing Notices GNR 386 and 387. Section 24(5) of
NEMA stipulates that certain “listed activities” require environmental authorisation by
way of either a Basic Assessment (BA) or a full Scoping and Environmental Impact
Assessment as defined in the EIA Regulations Listing Notices (July 2006 EIA
Regulations). As identified in Chapter 1.2 above, the proposed project constitutes
listed activities in both Listing Notices. However, GNR 387 supersedes GNR 386 and,
as such, a full Scoping and Environmental Impact Assessment must be undertaken.
This report represents the Draft Environmental Scoping Report (DSR) and has been
prepared in accordance with the EIA Regulations published in GNR 385.
1.4.3 The Environment Conservation Act
The objectives of the Environment Conservation Act (Act No. 73 of 1989) (ECA) are
to provide for the effective protection and controlled utilisation of the environment.
Following the enactment of NEMA, a number of the powers of the Act have either
been repealed from or assigned to the provinces. These include the EIA Regulations
for activities that were regarded as detrimental on the environment and were
published under Government Notice Regulation 1182 of 05 September 1997, as
amended. New EIA Regulations have been promulgated under Section 24(5) of
NEMA and are published under GNR 385, 386 and 387 of June 2006 and as such,
replace those promulgated under ECA.
Waste management is still coordinated and controlled under Section 20 of ECA. The
National Waste Management Act, currently in draft form, will replace this section of
the Act.
1.4.4 Legislation for the Conservation of Natural Resources
(a) National Water Act
The National Water Act (Act No. 36 of 1998) (NWA) is the fundamental law for
managing South Africa’s water resources. The purpose of the Act is to ensure that
water resources of the nation are protected, used, developed, conserved and
controlled. It is concerned with the allocation of equitable access and the
conservation of water resources within South Africa. The NWA repeals many of the
powers and functions of the Water Act (Act No. 54 of 1956).
Key Aspects of the NWA include:
•
•
•
Catchment Areas - Any disturbance to a watercourse such as the construction
of a dam or weir type facility requires authorization from the DWAF
Water Supply - Under the NWA, a developer is required to obtain the
necessary permits for water usage and the disposal of wastewater from the
DWAF
Wastewater – the NWA is the principal piece of South African legislation
governing wastewater management. Under the Act there are several important
issues relating to wastewater to note:
- It is an offence to wilfully or negligently pollute surface water or groundwater
- In the event of a pollution incident, the offending party is obliged to report the
incident to the regulatory authority
- The regulatory authority can take the necessary steps to prevent the pollution
of water resources and can recover the costs of clean up from the polluter.
(b) National Environmental Management: Biodiversity Act
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The National Environmental Management: Biodiversity Act (Act No. 10 of 2004)
(NEMBA) provides for the management and conservation of South Africa’s
biodiversity within the framework of the NEMA. This Act allows for the protection of
species and ecosystems that warrant national protection, the sustainable use of
indigenous biological resources, the fair and equitable sharing of benefits arising from
bio-prospecting involving indigenous biological resources and the establishment and
functions of the South African National Biodiversity Institute.
Key elements of the NEMBA are:
•
•
•
•
•
The identification, protection and management of species of high conservation
value
The identification, protection and management of ecosystems and areas of
high biodiversity value
Biodiversity Initiatives such as the STEP (Subtropical Thicket Ecosystem Plan)
and CAPE (Cape Action Plan for People and Environment) may become
accepted as bioregional plans and are thus implemented as legislation
Alien invasive species control of which the management responsibility is
directed to the landowner
Section 53 of the Act identifies that any process or activity that is regarded as
a threatening process in terms of a threatened ecosystem, requires
environmental authorization via a full Environmental Impact Assessment
(GNR387).
(c) National Forest Act
Under the National Forest Act (Act No. 84 of 1998), listed trees and forests are
protected and no person may cut, disturb, damage or destroy a protected tree or
forest without prior approval via a permit from the Minister of the DWAF.
•
Vegetation is further protected from disturbance in terms of NEMA, (EIA
Regulation GNR386) where environmental authorisation is required for the
transformation or removal of indigenous vegetation of 3 ha or more.
1.4.5 Legislation for Cultural Resources
(a) National Heritage Resources Act
The National Heritage Resources Act (Act 25 of 1999) (NHRA) aims to promote the
protection and good management of the national estate of South Africa. In terms of
Section 38 of the Act, the South African Heritage Resources Agency (SAHRA) must
be notified during the early planning phases of a project for any development that
includes any of the following activities:
•
•
•
•
The construction of a road, wall, powerline, pipeline, canal or other similar
form of linear development or barrier exceeding 300m in length
Any development or other activity which will change the character of a site
exceeding 5 000 m² in extent
The costs of which will exceed a sum set in terms of regulations by SAHRA or
a provincial heritage resources authority
Any other category of development provided for in regulations by SAHRA or a
provincial heritage resources authority.
If a project is listed under the NHRA Regulations, then a permit application must be
made to the SAHRA before the project can commence. For projects in KwaZulu-Natal
permit applications must be made to AMAFA in terms of KwaZulu-Natal Heritage Act
(Act No. 10 of 1997) see below.
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(b) The KwaZulu-Natal Heritage Act, 1997 (Act No. 10 of 1997)
The aim of the KwaZulu-Natal Heritage Act (Act No. 10 of 1997) is to provide for the
establishment of a statutory body to administer heritage conservation on behalf of the
provincial government of KwaZulu-Natal, namely AMAFA aKwaZulu-Natali (AMAFA).
Section 27 of the Act states that the developer must notify AMAFA if he is wishing to
undertake a proposed development in terms of the following categories:
•
•
•
•
•
•
•
Developments (roads, walls, powerlines, pipelines) greater than 300m Linear
in length
Bridges greater than 50 m in length
Proposed developments exceeding 10000m²
Proposed developments exceeding three or more erven
Proposed developments exceeding three or more existing erven consolidated
within past five years
Proposed development will exceed a cost set in terms of regulations
Any other category provided for in regulations.
AMAFA has been notified of the proposed upgrade of Sani Pass and have requested
that a Heritage Impact Assessment (HIA) be undertaken. Heritage issues had already
been identified during the Scoping as requiring further investigation. Nzumbululo
Heritage Solutions has been appointed to investigate heritage and cultural issues as
part of the Scoping Phase and undertake the required HIA which will form part of the
Impact Assessment Phase of the EIA.
1.4.6 Local and Regional Integrated Development Plans
There are numerous planning frameworks, initiatives and documents that have been
devised for the uKhahlamba Drakensberg Region and Lesotho which are relevant to
the Sani Pass area and/or the upgrading of the Sani Pass Road:
(a) Southern African Development Community (SADC): Regional Indicative Strategic
Development Plan (RISDP) and other protocols and agreements
The RISDP is the SADC region’s blueprint for integration. The RISDP has broad
targets and priorities, of which five have been identified for immediate
implementation. Infrastructure and Services Development is one of these five and
is identified as the core area for integration, with programmes that promote
access to transport, communications, energy, water and tourism by the rural
disadvantaged and that promote community participation in mainstream business
as a vehicle for poverty reduction. The SADC Transfrontier Conservation Areas
(TFCAs) are seen as a major attraction for the international tourists (DFA, 2006)
(ACER Africa, 2006).
Furthermore, South Africa and Lesotho have signed a Declaration of Intent to
promote technical cooperation and activities in the area of transport, including
roads, rail and air transportation, and includes the upgrade of the Sani Pass. This
agreement is part of regional cooperation and agreement in terms of the SADC
Protocol on Transport, Telecommunication and Meteorology. It is in fulfilment of
the vision of the New Partnership for Africa’s Development (NEPAD), and
commitment to the Almaty Declaration on Landlocked Countries and fulfilment of
SADC’s Millennium Development Goals (MDG) (Radebe, 2006) (ACER Africa,
2006).
(b) Maloti Drakensberg Transfrontier Project (MDTP): Bioregional Planning
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The MDTP is currently undertaking bioregional planning processes for both South
Africa and Lesotho. Once complete, the plans will be brought together, and the
common issues will be extracted into one coherent Transfrontier Strategy and
Action Plan (TFCA). The MDTP is also in the process of developing a tourism
strategy for the region. This is consistent with SADC initiatives and specific
agreements between Lesotho and South Africa (ACER Africa, 2006).
The MDTP is in support of the Sani Pass upgrade as it is seen to meet both of its
objectives, viz. the conservation of globally significant biodiversity and cultural
heritage, and its contribution to socio-economic growth through sustainable
livelihood opportunities.
(c) Special Case Area Plan for the Drakensberg (SCAP)
The Special Case Area Plan for the Drakensberg (SCAP) report was produced by
the KZN Town and Regional Planning Commission in 2001 to provide a balance
between conservation requirements and development needs to ensure
sustainable development within the SCA. It contains planning principles, regional
zonation and recommendations. The UDP WHS is the core conservation area
and an integral part of the plan. Although the SCAP for the Drakensberg has not
been formally announced, it is a widely accepted document and is adopted in
both the Sisonke and KwaSani Municipal Integrated Development Plans (IDPs). It
is also being used as the basis for EKZNW’s planning of the UDP WHS’s buffer
zone. (SCAP, METROPLAN, 2001; EKZNW, 2005; KSM, 2005) (ACER Africa,
2006).
(d) uKhahlamba Drakensberg Park World Heritage Site Integrated Management Plan
(IMP)
Although not yet formally adopted, a draft Integrated Management Plan (IMP) has
been prepared for the UDP WHS in terms of the World Heritage Convention Act
(Act No. 49 of 1999) and the National Environmental Management: Protected
Areas Act (Act No. 57 of 2003). This plan is the primary and overarching
management document for the Park for the period 2006 to 2011. It forms the
framework within which the Park will be managed and developed towards the
achievement of its management objectives derived in collaboration with the
Park’s stakeholders in October 2003 (EKZNW, 2005).
Although the Sani Pass is not specifically mentioned, the fact that the Road
transects the WHS requires the project take cognisance of and align itself with
the UDP WHS IMP. Of particular relevance to the proposed project is Section
6.11.3 which specifically deals roads within the WHS:
“Park Management must ensure that the existing access network is effectively
maintained to the appropriate standards to support relevant use and to avoid soil
erosion as well as other negative impacts on the environment.
Proposed development of new or the closure of roads, tracks and paths must
follow the set procedures for authorisation.
Roads and tracks that are heavily used by vehicles should either be tarred, paved
or all-weather gravel roads that have been treated with a dust repellent (sealer).
Hiking trail paths, of which there are an estimated 1 550 km in the Park, are
generally in a poor condition.
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These paths need to be more accurately mapped, marked for maintenance
purposes, assessed and maintained on an annual basis.”
(e) Sisonke District and KwaSani Local Municipal Integrated Development Plans
(IDPs)
In terms of the Local Government: Municipal Systems Act (Act No. 32 of 2000),
Sisonke District Municipality and KwaSani Local Municipality have IDPs in place
which is a principle strategic 5-year planning document guiding all planning,
budgeting, management and decision-making in a municipality (KSM, 2002;
SDM, 2002).
The vision of SDM is to “uplift the quality of life of its residents by providing
sustainable infrastructure, water, health services, sanitation and social amenities
through intergovernmental collaboration by 2010. There will be equitable
distribution of land for residential, farming, investors and sports and recreation.
Sisonke will be one of the Province’s viable tourist destinations characterized by
sustainable natural, social and economic environment. Men, women, the elderly,
disabled, youth and children will equally enjoy living in a safe and healthy
environment.” (Sisonke IDP, 2008).
In order to achieve this vision, Sisonke has identified the Infrastructure and
Services as a key performance area (KPA) noting improvement of road
infrastructure as a priority issue. Under the KPA of socio-economic development,
promoting environmental integrity was identified as a priority issue as was
promotion of agriculture and tourism. Although there is no specific mention of the
Sani Pass or plan to promote it as a tourism destination, all three of priority
issues mentioned have relevance to the proposed development in that the
upgrading of the Pass Road, in whatever form, will be an improvement to road
infrastructure within the District, while the consideration of environmental issues
in the planning and design phases of the proposed project demonstrates the
promotion of environmental integrity.
In addition, the proposed project could assist in making Sisonke a viable tourism
destination as it could improve access to the tourism assets of the District such
as the UDP although there is much evidence and belief that the contrary will
happen. The potential impact of this is still to be investigated in the Impact
Assessment Phase.
The vision of the Kwa Sani Municipality is “to provide essential services to our
community in order to meet their basic needs and promote economic
development. Our standards are effectiveness, affordability and sustainability”.
Part of its strategic framework is also relevant to both phases of the Sani Pass
Road (P318) Upgrade. This includes a local economic development strategy to
develop and improve the services offered by the tourism sector of the local
economy to capitalize on the UDP WHS. By upgrading the Sani Pass Road, the
project meets this objective to improve services to the tourism sector and expand
the tourism diversity by making the UDP WHS more accessible to a broader
range of tourists. In terms of economic development of the local region, is it
anticipated that the upgrade road will provide an improved and more accessible
trade route between South Africa and Lesotho which could equate to economic
growth and development on both sides of the border.
In terms of management of the environmental aspects of the Kwa Sani municipal
area, the IDP identifies EKZNW as the main organisation responsible for
ensuring all environmental matters and issues are identified and managed.
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2
DESCRIPTION OF THE PROPOSED DEVELOPMENT
2.1
Proposed Development
The proposed Phase 2 upgrade entails a complete re-grading and resurfacing of the
Sani Pass from a gravel to a hardened surface, all-weather road. The upgrade will
include road widening, re-alignment of sections, new bridges, stormwater control and
attenuation systems, bank and slope stabilisation and road servitude rehabilitation.
The Sani Pass Road currently provides access to, and passes through the UDP,
which is a proclaimed World Heritage Site. Sustainable access to the Park needs to
be developed and carefully managed and Main Road P318 forms an integral part of
this initiative. Furthermore, a co-operation agreement was signed in 2005 between
Lesotho and South Africa to improve access between the two countries via Sani
Pass. This project is thus part of an initiative to improve accessibility between SADC
countries. The intention is for South Africa to surface the P318 from Himeville to the
Lesotho border and Lesotho would surface the section from the border to Mokhotlong
approximately 60 kms away. The ultimate goal is to have a hard-surfaced road all the
way to Maseru.
2.2
Motivation for the Project
2.2.1 Department of Transport Motivation
•
Main Road P318 provides access to and passes through the uKhahlamba
Drakensberg Park, which is a proclaimed World Heritage Site. Sustainable
access to the Park needs to be developed and carefully managed and Main
Road P318 forms an integral part of this initiative.
Furthermore a co-operation agreement was signed in 2005 between Lesotho
and South Africa to improve access between the two countries via Sani Pass.
This is part of an initiative to improve accessibility between SADC countries.
The intention is for South Africa to surface the pass to Mokhotlong. The
ultimate goal is to have a surfaced road all the way to Maseru.
•
It is predicted that the provision of an all-weather road through the Sani Pass
will have a number of economic benefits, namely:
-
It will provide access to the UDP from both sides of the escarpment and
incorporate the border and park access controls
The distance between the eastern Free State, Maseru through to Durban will
be reduced by up to 150 km
The Eastern Lesotho Highlands will be opened up to tourism development
Business and trade links between the Mokhotlong area and the businesses in
Underberg and Pietermaritzburg will be strengthened and extended
Transportation and accessibility to Lesotho for locals from both sides will
improve
A new scenic tourism route will be opened up between the eastern Free State
and KwaZulu-Natal via Lesotho.
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The reason for proposing that the Pass be upgraded and surfaced is attributable to
the following:
•
•
•
2.3
The existing road drainage system is unable to cope with the high intensity
runoff of water on steep gradients, which results in excessive scour and gravel
loss. Gravel roads constructed in steep gradients are generally more difficult to
maintain which leads to frequent closures of the road due to significant erosion
and environmental damage.
Gravel is a non-renewable resource and good quality gravels are particularly
difficult to source in the Drakensberg areas of KwaZulu-Natal. The excessive
loss of gravel from the Sani Pass is therefore of serious concern, particularly
as the opening of new borrow pits has a high visual impact and is not
permitted in the World Heritage Site. The haul distance for gravels from
outside borrow pits makes it difficult to maintain the Pass.
The eroded gravel eventually deposits in the local streams and rivers,
particularly the Mkhomazana River which flows down the Sani Valley, resulting
in sedimentation and pollution of the lower reaches of the river when the
velocities slow down. The silt carrying capacity of water is related to the
square of the velocity. Thus, if the flow velocity is reduced by a half, the silt
carrying capacity is reduced four fold. The very steep terrain, therefore, has an
inordinate silt carrying capacity which aggravates the situation. To prevent this
problem from occurring:
- It is better to retain the existing gravel on the road by surfacing the road
- Closures of the Pass result in unnecessary hardship for the impoverished
communities of the Mokhotlong District and in a loss of revenue to the tourism
industry
- Gravel roads result in dust being deposited on the adjacent vegetation, which
in turn leads to a decline in the quality of adjacent vegetation and impacts on
the biodiversity.
Road Design and Construction Specifications
2.3.1 Department of Transport Terms of Reference
DOT provided the engineering consortium with the following Terms of Reference
(TOR) for the proposed design of the Road upgrade:
•
•
•
•
•
•
Provide an all-weather, hardened surface road
Provide a two-way road, thus one lane in each direction with road surface
width of:
- 7 m between km 14 and km 25 (lower section)
- 6 m between km 25 and km 33 (upper section)
Allow for a safe traffic speed for a short-wheel-based truck or bus of:
- 50 km per hour (km/h) between km 14 and km 25 (lower section)
- 30 km/h between km 25 and km 33 (upper section)
Remain within the existing DOT road servitude and retain the current road
alignment where possible, but adjust the alignment where necessary to
achieve the abovementioned design specifications
Widen the road where necessary, through appropriate cut, fill, retainment and
bridge structures
Make use of the approved borrow pit from the Phase 1 project for road
construction materials.
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2.3.2 Horizontal and Vertical Alignment
The DOT stipulated in their request for proposals that the road width between km 14,
at Good Hope and km 25, at the current border post, be seven (7) metres wide with a
design speed of 50 km/h. This means that a driver must be able to travel along this
section of road comfortably at 50 km/h.
Between km 25 and km 33 at the top of the Pass, the road width is to be reduced to
six (6) metres with a design speed of 30 km/h. This means that a driver must be able
to travel along this section of the road comfortably at 30 km/h.
During the design process, areas may be identified where the required design speeds
and widths cannot be achieved without major environmental impact. In each case,
this will be discussed with the client and, if agreed, changes will be made to the
design in order to accommodate the existing terrain and minimise the environmental
impact.
Each proposed cutting and fill will be assessed in terms of the in situ material and
decisions will be taken on how best to position the road. These design options will
more than likely be reviewed a number of times before the optimum alignment has
been determined.
There will be certain predetermined locations where the construction traffic will need
to turn. These areas will be formalised into view sites and/or new picnic sites. Where
possible, the turning locations will utilise existing view points and historical borrow pits
and spoil areas.
2.3.3 Geo-Environmental Aspects of the Design/Construction
Environmental damage due to gravel loss has already been mentioned. This is
particularly severe at the Sani Pass due to the severe gradient where silt loads
increase with the square of the water velocity. During periods of high, short-duration
rainfall, the road acts as a conduit for water until a convenient low point is reached
where concentrated outflow takes place. This concentrated, high-velocity flow,
contains a significant silt load gathered in the flow over and along the un-protected
cuttings and un-surfaced road. At this point of discharge, the velocity is thus high and
scour occurs adding to the silt load. This silt laden stream flow eventually reaches the
shallower slopes of the river due to the velocity drop and deposits the silt in the river
which has a significant impact of aquatic biodiversity and river system health and
hydraulics.
In order to alleviate this condition, it is first necessary to protect the cuttings using soil
nails and shotcrete which will render the cuttings stable and less prone to erosion.
The shotcrete (concrete slurry) used to cover the cuttings will be randomly shaped
and weathered with a naturally occurring organic compound “Permeon” which can be
sprayed on in various concentrations to create various hues of brown, replicating the
Tarkastad, Molteno, Elliot, Clarens and Drakensberg formation rocks which occur
along the Pass.
The installation of soil nails will necessitate that only limited-height benches are
excavated at one a time due to the risk of. Necessary removal of rock material, will in
all likelihood, require blasting over most areas, but due to the small vertical drop at
each point, only small charges will be used. This in turn will limit the “throw” of the
blast and practically eliminate the large rock-blast rubble which typically occurs on the
down slope in these types of projects.
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The cross section of the road is designed so that nearly all flow would initially take
place from the road towards the cutting side. After being intercepted by regularlyspaced drainage holes through the purpose-designed hand-labour constructed
arrestor walls, the flow would be filtered in an arrestor bed, which has dual-purpose.
Not only is it designed as the initial phase of the filter system, but it also acts as the
rock arrestor layer for boulders which may come off the slope above. (See Figure 2
for cross section). This arrestor area is designed such that it has sufficient width to
facilitate both hand and machine clearing during the life of the structure; handclearing to provide a labour-input source for locals and machine-clearing where the
mass of material is too great for hand removal.
Further attenuation of velocity and filtration would take place when flows traverse the
“in situ treatment by blasting” area located beneath the pavement layers. Water would
thus exit the road area at low-velocity, with no silt load, over the full length of the road,
substantially reducing the possibility the high-velocity, high-silt content flows at
concentrated points, which has been the norm in the past.
2.3.4 Material Sources
The construction of a road requires various quality materials for the various pavement
layers and appurtenant structures (arrestor walls, head walls for drainage structure
etc). To develop a large borrow area that is remote from road is environmentally
unacceptable. The initial aerial photograph interpretation and in situ inspections have
indicated some promising areas along the route which may be further exploited. It is
envisaged that they be incorporated into the cuttings possibly generating view points
and picnic areas which are aesthetically pleasing and provide recreation points along
the route. Field testing and evaluation will be necessary to validate this in conjunction
with material requirements and road section geometry both in the long- and crossdirection.
Borrow Pits and Quarries identified and utilised in Phase 1 of the full project will
provide adequate road building materials for Phase 2. As such, no additional borrow
pits and quarries or permits are required.
2.3.5 Structures
The design of road works and associated structures in mountainous terrain of rugged
natural beauty, poses special challenges to the designer to achieve an acceptable
balance between the traditional civil engineering goals of safety, durability,
constructability and economy, with the more philosophical objectives of preserving the
aesthetic, ecological and other important attributes of the particular environment.
This is especially true in the case of a project such as the upgrading of the unique
Sani Pass between Himeville in KwaZulu-Natal and the eastern highlands of Lesotho.
This pass is the only vehicular route across the Drakensberg Mountains from
KwaZulu-Natal and is situated within the uKhahlamba Drakensberg Park, which is a
proclaimed World Heritage Site.
In this instance, the challenge is compounded by advocates of the status quo, who
assert that technical improvement to the pass will diminish tourists’ enjoyment of the
“Sani Experience”, in which overcoming the obstacles of dangerous hair-pin curves
and steep gradient on loose road surfaces, inundated stream crossings and so on,
either on foot or as a four-wheel drive vehicle passenger, are deemed important
elements of a sense of achievement in reaching the top of the Pass, which is said to
enhance appreciation of the spectacle in so doing.
Unfortunately, the aforementioned civil engineering goals are the very antithesis of
the rudimentary nature of the existing pass, which is deemed to be worthy of
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preservation by the opponents of upgrading, notwithstanding the dangerous and
intermittently impassable conditions and the cost of maintenance and repair.
Design of the upgrade must, therefore, respect the views of the proponents and
opponents of the scheme alike, whilst meeting the standards of best practice in the
particular circumstances.
With respect to the structures (river bridges, retaining walls, energy dissipation works
and the like) every effort will be made to harmonise these with the natural
environment in terms of form, composition and the use of natural materials. In the
case of the river or stream crossings, original waterways will be preserved or
reinstated to allow the passage of flow, including boulders, unobstructed by piers or
walls. Preference will be given to structures with single span decks with an arched
form, along the lines of the attached diagram, final details of which will be dependent
on foundation conditions. In particular the abutments will be spaced so as to minimize
any impact on the natural flow width for floods of 20 years frequency, or less (See
Figure 3).
In all cases it is proposed that external reinforced concrete faces should be tastefully
clad with grouted and dressed local rock to match the surrounding terrain as far as is
practical. Likewise, parapets along the edges of bridge decks should be constructed
from local rock, with concealed reinforced concrete cores, along the lines of the
parapets adopted for Chapman’s Peak Pass in Cape Town.
Reference will be made to the treatment of structures in the successful development
of similar projects elsewhere in the world.
2.3.6 Drainage
The Department of Transport has requested that all the cross-drainage be
accommodated through structures, such as pipes, box culverts or bridges, under the
road. The drainage on this road is of vital importance to the success of the proposed
project and will be assessed as follows:
•
•
•
•
A hydrological study will be undertaken along the Mkhomazana River in order
to determine the 1:25 year, 1:50 year and the 1:100 year flood levels so as to
determine the required level of the road where the two meet
Each catchment will be looked at individually in order to determine the runoff
and the conduit under the road will be sized accordingly
Where pipes are required they will be placed with enough cover over the pipe
so as to prevent cracking. The velocity of the water is to be managed in order
to prevent erosion at the outlet
The larger catchments will require either a box culvert or a bridge. The
proposal is to clad these structures with stone from the immediate area so as
to blend in with the environment.
2.3.7 Pavement
The layer works, that is the various layers of soil under the road surface, will be
designed to accommodate an eight (8) ton vehicle and the extreme winter conditions
experienced at the top of the Pass.
The design team has access to expertise both in Europe and Canada who have
constructed numerous roads in the same extreme conditions and their expertise will
be drawn from, and included, in the design.
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The pavement options that the design team is currently investigating for the project
include ten (10) different base types including:
•
•
•
•
•
•
•
•
•
•
Remain Gravel Road
Hyson Cells
Pavement Blocks
Precast Concrete Sections
Cemented Granular base
Continuously Reinforced Concrete Pavement (CRCP)
Penetration Macadam
Waterbound Macadam
Foam Bitumen
Granular Base
Each type has its own particular strengths and weaknesses and the final design may
comprise two or more different pavement types along the length of the project. The
investigation of the most suitable pavement is still in its preliminary stages, however,
initial results suggest that either a Granular Base or Foam Bitumen may be the most
suitable option for Phase A and CRCP for Phase B (as detailed below).
2.3.8 Construction
The intention is to undertake the construction into two sections which will be
constructed simultaneously:
a)
b)
Phase A - km 14 to km 25
Phase B - km 25 to km 33
In terms of the location of the construction camps, Phase A would use the
construction camp currently being used by the Phase 1 Upgrade project. The most
suitable location for a construction camp for Phase B, which starts at the current SA
border post, would be at the border post as all the facilities already exist. No new
construction camp would need to be constructed and hence the impact on the
environment is significantly reduced. This is, however, very dependent on the Border
Post Relocation Project going ahead and that by the time the construction of the Sani
Pass Phase 2 Upgrade (this project) is initiated, if approved, that the existing Border
Post has been vacated. Once construction is completed, the Border Post will be
deconstructed and the site rehabilitated for inclusion back into the WHS, which is the
intention of EKZNW.
Issues highlighted to date that will need to be managed during the construction phase
include:
•
•
•
•
•
•
•
Occupational Health and Safety (OHSA)
Oil and diesel spillages,
Traffic Management
Recovery of any vehicles and/or equipment which may fall into the valley
Proposed site camps and their management
Stockpiling of hazardous materials
Blasting of rock.
The above and other related issues will be highlighted in the project specification and
Environmental Management Plan (EMP) compiled for the construction phase. The
contractor will be required to complete risk assessments for every phase of work
carried out and submit method statements for approval before construction can
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commence. All environmental issues will be managed by the Environmental Control
Officer (ECO) appointed for the duration of the construction.
The on-site geotechnical engineer will manage every cut and fill on the project to
ensure that the contractor conforms to the design. Should the in-situ material in the
cuttings vary in any way from the geotechnical report, it will be the responsibility of the
geotechnical engineer to alter the design in order to manage the variance.
The reinstatement of all the cuttings and fill embankments will be done in
conformance with the recommended procedures as laid out in the EMP. The EMP will
be compiled as part of the Impact Assessment Phase Draft Environmental Impact
Report (DEIR), and will be made available to I&AP’s for review and comment.
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3
ALTERNATIVES
The project engineers have identified that the degradation of the Sani Pass Road is
caused by a number of factors. The main contributor is the poor stormwater drainage
system which is unable to cope with the excessive water flows and the run-off which
are eroding the surface of the road and the slopes of the Pass. In order to rectify
these problems and prevent further degradation, the EIA team has considered a
number of Road upgrade alternatives, which range from making minor improvements
to the drainage to reconstructing the entire road structure. Each alternative has been
assessed based on a variety of aspects, such as the impact on the environment,
tourism, community, road safety and political links.
The alternatives are described in order of increasing scale of upgrade from
Alternative 1 (the ‘no-go alternative or the status quo remains) to Alternative 6
(complete upgrade). In the subsequent sections the Alternatives are grouped and
compared by aspect. The tables below then summarise the aspects for each
Alternative.
3.1
Description of Alternatives
Alternative 1: No upgrade
The condition of the road is deteriorating to such a degree that if measures are not
taken to rectify the problems the road will be unsafe for public use and will continue to
cause significant environmental damage. If no action is taken the road will have to be
closed, decommissioned and handed over to EKZNW for rehabilitation and
integration into the UDP. This alternative will not meet any of the objectives of the
proposed project.
Alternative 2: Re-gravel, minor drainage improvements and maintain
The second option is make minor improvements to the drainage system. Although
this will not address the water problem per se, it may slow down the flow of water.
The road will remain a gravel surface and be maintained regularly. Degradation of the
road will continue as the cause of the erosion has not been corrected. This alternative
will not meet the objectives of the proposed project.
Alternative 3: Improve geometrics, upgrade drainage, retain splash-throughs,
construct retaining walls and re-gravel
The third alternative is to improve the structure of the road, upgrade the drainage
system so that the splash-throughs are still retained, and construct retaining walls.
The construction will allow the road to retain its original state but the factors which are
causing the degradation will be addressed. The road surfaced will be graded, regravelled and maintained on a regular basis. This alternative will not meet all of the
objectives of the proposed project.
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Alternative 4: Improve geometrics, upgrade drainage, construct bridges,
retaining walls, hard surface up to km 25, gravel to km 33
Alternative 4 will address the same issues as Alternative 3 regarding improving the
geometrics of the road to control the drainage and erosion. A hard surface will be
constructed for the first portion of the road, up to km 25, and the remaining section, to
km 33, will remain as a gravel surface and be maintained on a regular basis. The
most appropriate type of hard surface has not been resolved as yet. This alternative
will meet most of the objectives of the proposed project.
Alternative 5: Improve geometrics, upgrade drainage, construct bridges and
retaining walls, hard surface from km 14 to km 33
Alternative 5 has been expressed as the preferred alternative for the project by the
proponent. This option involves improving and re-constructing all the geometrics of
the road as in Alternatives 3 and 4 but includes hard surfacing the entire road. The
hard surface will either be a concrete surface, asphalt or chip and spray, or a
combination of the three depending on the section of Road. This alternative will meet
all the objectives of the proposed project.
retaining walls, hard surface from km 14 to km 31 and tunnel (3km)
Alternative 6 involves improving and reconstructing the geometrics of the road to
control water run-off and erosion and constructing a hard top surface from km 14 to
km 31. A tunnel will then be constructed through the mountain from km 31 and will
exit 3 kms into Lesotho. This alternative will not meet all the objectives of the
proposed project.
As mentioned above the preferred alternative is Alternative 5. The impacts of each
alternative have been briefly discussed below. The alternatives will be further
investigated and discussed in the Impact Assessment Phase.
3.2
Alternative Impacts on Department of Transport
If the road is closed there will no longer be any upgrade expenses, however the road
will have to be rehabilitated (as per regulations) and these costs are likely to be high.
The rehabilitation of the road will more than likely be DOT’s responsibility.
If the road remains a gravel surface the initial construction cost will be fairly low, but
the maintenance costs high. Maintenance costs associated with a gravel road are
higher than that of a hard surfaced road. Materials will have to be transported to the
site on a regular basis and a permanent maintenance team will have to be set up
which adds to the costs.
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The construction costs for Alternative 3 will higher than Alternative 2 as the
geometrics of the road will be reconstructed and rectified. The maintenance costs
thereafter may be slightly lower the Alternative 2. The improved condition of the road
will be safer for motorists and will reduce the impact on the environment.
The construction costs for Alternative 4 will be high but the maintenance costs
thereafter considerably lower than the previous alternatives. This alternative is seen
as a compromise for all parties.
The preferred alternative of hard surfacing the entire road surface will involve very
high construction costs but the maintenance costs thereafter are reduced. As
mentioned above the maintenance costs of a hard surface road are lower than a
gravel road.
The overall costs (construction and maintenance) associated with the construction of
a tunnel are extremely high and not within DOT’s budget. In addition, electricity and
water will have to be supplied to the top of the Pass from South Africa, which will add
to the overall project cost.
3.3
Alternative Impacts on the Environment
The closure and rehabilitation of the road will allow the road servitude to return to its
natural wilderness state again and be integrated into the World Heritage Site. Soil
erosion will reduce significantly resulting in less sedimentation of the rivers. River and
the riverine environment conditions will improve and the impact by 4x4 vehicles on
sensitive vegetation on the plateau will be reduced.
To allow the road to remain as a gravel surface, with maintenance, is not sustainable
as the source of issues such as slope stability, gravel depletion and road surface
scour is not addressed. The existing problem of sediment run-off from the road into
nearby rivers is not corrected and river systems will continue to degrade. Road verge
vegetation remains.
In order to maintain a gravel surface, specific grades of road material need to be
used. As there is already a shortage of suitable gravels in the Drakensberg region
and no mining is allowed in the WHS gravel, road material needs to be sourced and
brought in from borrow pits far away. Through this there is the risk that alien invasive
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species may be brought into the UDP. In addition, mining of borrow pits could
potentially cause significant environmental impacts at the source.
Controlling the drainage on the road will reduce the environmental impacts caused by
run-off and erosion, on all sections particularly the switchbacks and water crossings.
However, as stated above maintaining a gravel road is not sustainable in the long
term in terms of sourcing the gravel and transporting it to the site and the potential
environmental impacts at the source and on the Pass. Impact on the road verge
vegetation is limited.
Controlling the drainage on the road will reduce the environmental impacts, caused
by run-off and erosion, on all sections particularly the switchbacks and water
crossings. A hard surface road for the lower section of the Pass from km 14 – km 25
will reduce the amount of sediment run-off and erosion and as such, rivers will be
protected to some degree from siltation. However, the outstanding environmental
impacts occurring at the top of the Pass where the highest levels of degradation are
taking place, are not mitigated or resolved. Road verge vegetation is removed in the
lower section to allow for the increased road width.
If the entire road is hard surfaced and a stormwater control system is installed, the
major causes of the environmental impacts will be addressed. Drainage will be
improved and erosion of the Road and the adjacent environment will be significantly
reduced. Furthermore, with reduced erosion, sedimentation of the rivers will
decreased dramatically and the health of the river system will improve. Dust will also
no longer be a problem for vegetation along the road although current road verge
vegetation has been removed to widen the road. Visual and noise impacts will
increase as the amount of traffic and people on the Pass increase. In addition, the
higher volume of people and vehicles may impact on the biodiversity of the area and
increase erosion on the top of the Pass, which may lead to secondary erosion
occurring further down the Pass.
As with Alternative 5, hard-surfacing the entire road and installing a stormwater
control system will substantially reduce the amount of uncontrolled water flow and
reduce erosion both on the Road and the adjacent slopes. Alternative 6 will have all
the benefits and problems of Alternative 5 but with the additional impacts of
constructing a tunnel through the top of the mountain. The construction of the tunnel
through the top of the mountain may reduce the current environmental impacts
occurring on the switchbacks but could also create a whole new set of impacts. In
addition, the actual construction would be a potentially huge engineering feat and
would have significant environmental impacts.
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3.4
Alternative Impacts on Tourism
All existing tourism activities associated with driving the Pass would be totally lost as
the Road would be closed. The supporting hospitality industry would also be
significantly affected due to the immediate reduction in tourists to the area.
Opportunities for alternate tourism activities in the region are limited but possible.
Tourism status quo would be retained. The tour operators and current tourism
activities would not be impacted in any way as the state of the road would remain a
gravel surface and only accessible by 4x4 vehicles.
The tour operators and current tourism activities would not be impacted in any way as
the Pass would remain a gravel surface with access still limited to 4x4 vehicles. The
general public and locals are still unable to fully utilise and benefit from the Road.
As the upper section of the Pass would still be a gravel surface, and the existing
tourism structure could be retained and the tour operators would still be able to offer
the experience of the Pass to tourists. The Road would still not be entirely accessible
to the general public and locals. Alternative tourism opportunities could be created.
A full upgrade of the road would allow significantly impact on the existing tourism
structure, particularly the 4x4 Sani tour industry as 4x4 vehicles would no longer be
required to access the Pass. The off road experience so strongly tied to the Sani
Pass could be lost and could lose its status as an international tourism destination.
However, new, alternative tourism opportunities could be developed in both Lesotho
and South Africa.
A full upgrade of the road would allow significantly impact on the existing tourism
structure, particularly the 4x4 Sani tour industry as 4x4 vehicles would no longer be
required to access the Pass. The off road experience so strongly tied to the Sani
Pass could be lost and could lose its status as an international tourism destination.
However, new, alternative tourism opportunities could be developed in both Lesotho
and South Africa.
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3.5
Alternative Impacts on the Local Communities
Closure of the Road would have a detrimental impact on the communities in the entire
region extending from Underberg to Mokhotlong as the Sani Pass is the only access
route between Mokhotlong in Lesotho and KZN. Many of the local community rely on
the Pass for trade and travel between home and work.
The current state of the road does not benefit the greater community as it is only
accessible to those with 4x4 vehicles (mainly tour operators, taxis and recreational
users eg: mountain walkers and climbers) and is often closed during bad weather
conditions, restricting movement up and down the Pass. For those locals who do use
the Pass (e.g. passengers), cost of travel is higher than normal due to the high
maintenance cost of 4x4 vehicles (e.g. taxis).
This alternative still restricts the type of vehicles that can use the Pass and hence
does not benefit the greater community. Trading and movement of people would still
be restricted both by cost and access to the Pass (closure due to bad condition of the
road or weather).
A partially hard surfaced road would have an increased benefit to the greater
community as travel along the Pass will become easier and cheaper as wear and tear
on 4x4 vehicles would be reduced. Access, travel and trade between SA and Lesotho
are still limited by the upper section of the Pass which would still be gravel and only
accessible by 4x4 vehicles.
The benefit to the community will increase with a hard surfaced road as it will be
accessible to the general public and not exclusive to 4x4 vehicles. Access would be
dramatically improved and travel opportunities more freely available i.e. ease and
convenience of travel would improve. Costs of travel would also decrease as 4x4
vehicles would no longer be needed. Travel times would also be substantially
reduced. The Pass would be subject to Road closures during bad weather.
The scenario for Alternative 5 above applies for Alternative 6.
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3.6
Alternative Impacts on Road Safety
If the road is closed and decommissioned all aspects associated with road safety will
be irrelevant.
The current state of the road forces motorists to drive slowly and cautiously thus
reducing the amount of accidents that has occurred on the road. However, the poor
state of the road also jeopardises the safety of those using it.
The current state of the road forces drivers to travel slowly and cautiously thus
reducing the amount of accidents that has occurred on the road. However the poor
state of the road also jeopardises the safety of those using it.
Hard surfacing the lower portion of the road could in one respect reduce the risk of
accidents due to improved road conditions. On the other hand improved conditions
and increase speeds on the upgraded road could increase the risk of accidents. In
addition the allowance of inexperienced drivers on the pass could also increase the
number of accidents. The dangers associated with gravel roads would still be relevant
to the top section of the road.
retaining walls, hard surface from km 14 to km 33)
Upgrading the road could in one respect reduce the risk of accidents due to improved
road conditions. On the other hand improved conditions and increase speeds on the
upgraded road could increase the risk of accidents. In addition the allowance of
inexperienced drivers on the pass could also increase the number of accidents. The
build up of ice on the hard surface during snowfalls also increases the risks of
accidents.
The issues associated with Alternative 5 above apply for Alternative 6. The
construction of a tunnel on the pass will increase the risk of accidents.
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3.7
Alternative Impacts on the KZN – Lesotho Links
Closure of the Road would sever all links between KZN and Lesotho as the Sani Pass
is the only access route between Mokhotlong in Lesotho and KZN. This in turn does
not allow for trade and development between Lesotho and KZN.
The current state of the road does not facilitate cross-border interaction as it is only
accessible to those with 4x4 vehicles (mainly tour operators and taxis) and is often
closed during bad weather conditions. For those locals who do use the Pass (e.g.
passengers), cost of travel is higher than normal due to the high maintenance cost of
4x4 vehicles (e.g. taxis). Opportunities of growth and development between the two
countries are not maximised.
This alternative still restricts the type of vehicles that can use the Pass and hence
does not promote cross border interaction. Trading and movement of people would
still be restricted both by cost and access to the Pass (closure due to bad condition of
the road or weather).
A partially hard surfaced road would have an increased benefit to the greater
community as travel along the Pass will become easier and cheaper as wear and tear
on 4x4 vehicles would be reduced. Access, travel and trade between SA and Lesotho
are still limited by the upper section of the Pass which would still be gravel and only
accessible by 4x4 vehicles, thus opportunities of growth and development between
the two countries are not maximised.
retaining walls, hard surface from km 14 to km 33)
Cross border interaction will increase with a hard surfaced road as it will be
accessible to the general public and not exclusive to 4x4 vehicles. Access would be
dramatically improved and travel opportunities more freely available i.e. ease and
convenience of travel would improve. Costs of travel would also decrease, as 4x4
vehicles would no longer necessarily be needed. Travel times would also be
substantially reduced. The Pass is still subject to Road closures during bad weather.
The scenario for Alternative 5 above applies for Alternative 6. Across border tunnel
operation and maintenance agreement will have to be agreed with Lesotho and South
Africa as the border post will have to be relocated.
27
Rev 0 / Dec 2008
ALTERNATIVE
NUMBER
DESCRIPTION
1
Close Pass: De-declare Road and Hand over to
KZN Wildlife
PROS
Alternative Impact on • Less Pressure on
DOT
KZN DOT Budget
2
Re-gravel, minor drainage improvements and
maintain
CONS
PROS
• Large savings in initial
• KZN DOT could be
required to rehabilitate
capital layout
the road back to natural
state (if EKZNW do not
want it).
• Will result in major lobby
against KZN DOT
Alternative Impact on • Could become a
Environment
wilderness area
again and integrated
into World Heritage
Park
• Difficult to maintain,
permanent labour team
required
• Not sustainable (slope
stability, gravel
depletion, road surface
scour)
• Ongoing environmental
damage (World Heritage
Site, borrow pits,
haulage, introduce
invader species through
importation of gravel)
• No growth in tourism.
Alternative Impact on • Alternative tourism
Tourism
opportunities e.g.
hiking trails
• Loss of tourism
opportunities
Alternative Impact on
Community
• Major impact on the
greater community
• Does not benefit the
greater community (high
maintenance costs on
vehicles)
• Lengthy pass closures
due to bad weather
Alternative Impact on • Irrelevant
Road Safety
• Irrelevant
• Road Safety is a
concern
Alternative mpact on
KZN Lesotho Links
• Sever social and
economic ties
between KZN and
Lesotho
• Sever only link road
between KZN and
Lesotho
• Conflicts with SA /
Lesotho Declaration
of Intent dated 2005
• Retains socio economic
links with Lesotho
through KZN
• Only semi accessible to
all people
• Growth and
development are
restricted
Lesotho Declaration of
Intent dated 2005
• All vehicles MUST be
4X4
Vehicle Type to be
Used
• Satisfied tour operators
and tourism industry
CONS
• High maintenance costs
28
Rev 0 / Dec 2008
ALTERNATIVE
NUMBER
DESCRIPTION
3
4
Improve geometrics, upgrade drainage, retain
splash-throughs, construct retaining walls and
re-gravel
Improve geometrics, upgrade drainage, construct
bridges, retaining walls, hard surface up to km 25,
gravel to km 33.
PROS
Alternative Impact
on DOT
Alternative Impact
on Environment
Alternative Impact
on Tourism
CONS
• Moderate maintenance • Increased construction
cost
costs.
• Safer road
permanent labour
• Improved
team required
environmental
protection
• Reduced
• Outstanding
environmental
environmental
impacts on all
issues and impact
sections particularly
causes at the top of
the switchbacks and
the pass are not
water crossings
dealt with
• Factors causing
potential impacts are
controlled and
impacts are mitigated
• The ideal option for
• Not completely
the tour operators
accessible to all
and tourism industry
tourists.
Alternative Impact
on Community
PROS
• Increased construction
costs
permanent labour team
required
• Reduced environmental
impact (less erosion of
gravel surface into the
streams)
• Factors causing
potential impacts are
controlled and mitigated
• No growth in tourism
• Compromise with tour
operators and tourism
industry
• Does not benefit the
greater community
(high maintenance
costs on vehicles,)
• Lengthy pass closures
due to bad weather
• Road Safety is a
concern
• Slightly reduced
Pass closures due to
bad weather
• Increased benefit to the
greater community
(lower maintenance
costs on vehicles)
• Improved trading
• Cheaper travel
Alternative Impact
on Road Safety
• Safer road than
option 2
• Attraction of less
experienced drivers
which could result in
more accidents
• Safer road than option
3
Alternative Impact
on KZN Lesotho
Links
• Retains socioeconomic links with
Lesotho through KZN
• Not maximising
socio economic links
with Lesotho through
KZN
• Retains socio-economic
links with Lesotho
through KZN
• All vehicles MUST
be 4X4
•
Vehicle Type To Be
Used (through
traffic)
29
CONS
• Reduced road
maintenance costs
• Less opposition
• Compromise option
• Only semi accessible
to all people
• Growth and
development are
restricted
Lesotho Declaration of
Intent dated 2005
• All vehicles MUST be
4x4
Rev 0 / Dec 2008
ALTERNATIVE
NUMBER
DESCRIPTION
5
6
Improve geometrics, upgrade drainage,
construct bridges and retaining walls, hard
surface from km 14 to km 33.
Improve geometrics, upgrade drainage, construct
bridges and retaining walls, hard surface from km
14 to km 31 and tunnel (3km)
PROS
Alternative Impact on • Minimised
DOT
maintenance costs
CONS
• Increased construction
costs
Alternative Impact on • If the entire road is
Environment
hard surfaced and
the drainage is
controlled all
environmental
impacts will be
addressed. Gravel
will no longer erode
and wash into the
streams, and dust
will no longer be a
problem for
vegetation along the
road
• Environmental
issues such as noise
and visual still to be
dealt with
• More traffic, more
people, more direct
impact on the
environment. e.g:
litter, vandalism etc.
• Need to manage the
environment
• Closing the switch
backs would be an
environmental benefit
• Reduced
environmental impact
(No erosion of gravel
surface into the
streams, no dust
pollution on adjacent
vegetation)
Alternative Impact on • Open other tourism
Tourism
opportunities in KZN
and Lesotho
• "Experience of Sani"
is opened to all
• Unhappy tour
operators and
tourism industry
• Sani drops off the list
of international
tourism destinations
• Decreased tourism
(Specific to
experiencing the
existing rough Sani
Pass Road)
• Open other tourism
opportunities in KZN
and Lesotho
• Attraction of less
experienced drivers
which could result in
more accidents
• All weather road
• Serious safety
concerns regarding
the tunnel
• Will grow socioeconomic links with
Lesotho through KZN
• Need to establish
cross border tunnel
operation and
maintenance
agreement with
Lesotho
• Need to relocate the
Lesotho border post
• Vehicles up to 8 ton
max can be used
Alternative Impact on • Increased benefit to
Community
the greater
community (lower
maintenance costs
on vehicles)
• Reduced pass
closures due to bad
weather
• Increased tourism in
general
Alternative Impact on • Improved access to
Road Safety
the top of pass and
Lesotho
Alternative Impact on • Will grow socioKZN Lesotho Links
economic links with
Lesotho through
KZN
Vehicle Type To Be
• Accessible to all the
Used (through traffic)
public and not only
4X4
• Only fully laden
trucks (8 ton max)
MUST be 4X4
30
PROS
CONS
• High construction costs
• Electricity and water
required to the top of
Sani for tunnel
• High maintenance costs
• Major environmental
impact, huge spoil
volumes (approx. 100
000m³)
• Significant
construction impact
• More traffic, more
people, more direct
impact on the
environment. e.g. litter,
vandalism etc
• Major environmental
impact
• Need to manage the
environment
• Loss of income for
tourism
• Sani drops off the list
of international tourism
destinations
• Considerable
reduction in pass
closures due to bad
weather
• Accessible to all the
public and not only
4X4
Rev 0 / Dec 2008
3.8
Road Surface Alternatives
As with the road upgrade alternatives, ten (10) possible pavement or surface
alternatives are currently under investigation by the project engineers. To date a
preliminary assessment has been undertaken, the findings of which are summarised
below. Each of the pavement alternatives was evaluated using the following criteria:
•
•
•
•
•
•
•
•
Cost – How does the pavement cost compare with other options
Community – Is the proposed pavement appropriate in terms of labour
intensity, the community, the purpose it will serve and the life-cycle of the
project?
Materials – Are the necessary materials available and are the transportation
implications acceptable?
Constructability – Is the proposed method practical in terms of constructability
with regard to the terrain and design intent?
Maintenance – How much future maintenance be necessary?
Socio-economic impact – will people benefit economically and skills
transferred?
Environmental impact – Will the environment and heritage be negatively
impacted and is the pavement structure sustainable?
Risk – Is risk of failures high due to construction or maintenance deficiencies?
The first four criteria are more concerned with construction and the associated issues,
while the other criteria considers the longer term effects of the initial decisions.
The various options have been evaluated according to the following rating system:
0-2
3-4
5
6-7
8-9
10
very poor
poor
average/fair
good
very good
excellent
Based on the multi criteria analysis and the other considerations, the pavement
engineers recommended that the following pavement structures be further
investigated during the preliminary design process for possible use on each of the
sections:
a)
Lower section (km 14 -25)
- Granular base
- Foam bitumen base
b)
Upper section (km 25 -33)
- Continuously reinforced concrete pavement
31
Rev 0 / Dec 2008
Sani Pass Pavement Alternatives: Multi Criteria Analysis
a) Lower Section (km 14 - 25)
Multi-Criteria (with weights per criteria)
Pavement Type
Cost
Weight
Remain Gravel Road
Hyson Cells
Pavement Blocks
Cemented Granular Base
CRCP
Penetration Macadam
Waterbound Macadam
Foam Bitumen
Granular Base
20
8
3
3
2
8
2
6
6
7
8
Community Materials
10
2
6
5
5
5
6
7
7
5
4
10
2
7
5
7
8
7
7
6
8
7
Constructability
10
8
6
4
3
9
5
5
5
8
9
Maintenance
15
3
3
5
7
2
9
5
5
5
5
SocioEconomic
10
2
6
6
6
3
6
8
8
4
3
Environment
15
1
5
7
7
5
7
5
6
6
6
Risk
Total
10
4
3
2
3
5
8
7
7
7
8
100
400
460
460
490
565
600
610
615
625
635
Environment
15
1
5
7
5
7
6
5
5
6
7
Risk
Total
20
2
5
2
3
3
5
5
5
5
9
100
255
440
450
455
495
500
520
525
540
740
b) Upper Section
Multi-Criteria (with weights per criteria)
Pavement Type
Weight
Remain Gravel Road
Cemented Granular Base
Pavement Blocks
Hyson Cells
Granular Base
Foam Bitumen
Penetration Macadam
Waterbound Macadam
CRCP
Cost
10
8
8
4
4
2
8
7
6
6
4
Community Materials
5
2
5
5
6
5
4
5
7
7
6
10
2
8
5
7
7
7
8
7
7
7
Constructability
15
4
3
4
6
3
3
5
4
4
7
32
Maintenance
20
1
1
5
3
7
4
4
4
4
9
SocioEconomic
5
2
3
6
6
6
3
3
9
9
6
Rev 0 / Dec 2008
4
DESCRIPTION OF THE PROJECT ENVIRONMENT
4.1
General Description of the Region
The Sani Pass is a mountain pass located within the UDP in the southern half of the
Drakensberg mountain range in the province of KwaZulu-Natal, South Africa (See
Plates Scenic Photographs 1-8). The top of the escarpment of the mountain range
also forms the international boundary between South Africa and Lesotho. The Sani
Pass is the northern-most and highest pass over the Drakensberg escarpment into
Lesotho from KwaZulu-Natal. Most other Drakensberg Passes further north are only
passable on foot and those accessible to vehicles are much further south in the
Eastern Cape Province, where the escarpment is less steep and at a lower altitude.
Due to the extreme gradient and current condition of the road, it is only accessible by
4x4 vehicles.
The UDP WHS, encompassing the Drakensberg Mountain Range, is a listed world
heritage site and managed by EKZNW. The UDP WHS forms part of the Maloti
Drakensberg Transfrontier Project (MDTP), which lies along the eastern border of
South Africa and Lesotho and addresses conservation and community development
issues in both countries jointly (MDTP, 2006). The Polela Biosphere Reserve is
located along the P318 and the Oribi Conservancy is located to the east of MR126.
The Sani Pass valley is located on the western edge of the Sisonke District
Municipality and KwaSani Local Municipality boundary with the two nearest towns
being Himeville and Underberg. The region is characterised by commercial agriculture
and forestry, tourism and small commercial businesses. The towns of Himeville and
Underberg are the main service centres and provide basic essential goods and
services, accommodation and basic health amenities to the surrounding population as
well as to tourists.
The entire P318 is a KZNDOT road within a formally proclaimed road servitude of
30 m under the jurisdiction of the Sisonke District Municipality. The first 13 kms falls
within the boundaries of Kwa Sani Local Municipality with the remaining 20 kms of the
road, through the UDP WHS to the Lesotho border, a formally protected area, falling
within a Demarcated Management Area (DMA) i.e. the WHS.
The study area is rural in nature and has a relatively low population density. The tribal
areas in the vicinity of the UDP and Lesotho border are farmed on a communal
subsistence basis (livestock and crops). The Phase 1 road upgrade runs through
privately owned farmlands (beef and diary cattle, pigs, sheep and maize farming). A
number of tourism facilities such as the Sani Pass Hotel, B&Bs and backpackers
accommodation, trout fishing and quad biking are also located along the first 14 km of
the road.
Aside from being an access road into Lesotho, the Sani Pass Road is used by local
residents, landowners, tour operators and tourists to access private properties located
along the first section of the road, the UDP and the top of the Pass itself. The Sani
Pass represents an important international trade, service and tourism link between
Lesotho and KwaZulu-Natal with many of the Basuto people from the Mokhotlong
district travel into South Africa to make use of these facilities in Underberg and
Himeville.
33
Rev 0 / Dec 2008
A number of development planning documents (covering international and national
through to local issues) are of relevance to the area, and focus particularly on issues
relating to delivery and implementation of services and infrastructure (including
transport) and promotion of tourism as well as conservation.
4.2
Biophysical Environment
4.2.1 Topography
The Drakensberg has two main topographical features: The High Berg and the Little
Berg. The former is at a higher altitude and is characterised by the summit plateau
adjacent to the escarpment edge, the peaks and rock faces of the main escarpment,
and the steep slopes beneath them. The Little Berg comprises a grass covered
plateau below the slopes of the High Berg. It extends eastward into KZN in the form
of spurs and ridges, which end in prominent sandstone cliffs ranging in height from
1 900m a.s.l. in the northern Drakensberg to over 2 200m a.s.l. in the south (EKZNW,
2005).
4.2.2 Climate
The climate of the area is characterised by high rainfalls (annual rainfall of 1,800 mm)
and heavy downpours in the summer months. Cold temperatures and snowfalls occur
in winter and the upper sections of the Sani Pass often ice up. Temperatures in the
Drakensberg range from 35oC to -20oC while the annual mean temperature is 16oC.
The maximum temperatures occur on north facing slopes in summer at lower
altitudes, while the minimum temperatures occur on the summit plateau during winter
nights. The area is characterised by strong westerly winds, especially during August
and September with the escarpment receiving the maximum force of these winds.
4.2.3 Geology and Soils
The Drakensberg consists of two parallel escarpments stepping up from the lowlands
to the Lesotho plateau. This comprises four rock formations of the Stormberg Series,
underlain in turn by the Upper Beaufort Beds of the Beaufort Series. The lower
escarpment, or "Little Berg" as it is commonly known, is capped by prominent Clarens
Sandstone cliffs. Underlying this formation are three formations of sedimentary rocks.
Above the Clarens Sandstone lies stratified basaltic lavas, with a vertical thickness of
nearly 1 400 m. The cliffs of the main escarpment are dark coloured, bare and form
spectacular sheer cliff faces locally, some of which are almost 500 m in height (UDP
WHS).
The Sani Pass follows the valley of the Drakensberg foothills; first through the
mud/sand-stone of the Beaufort Group, then through several beds of course Molteno
‘glittering’ sandstone (high quartz content) and muddy shale, to the red mudstone
beds (Elliot formation) and fine grained white Cave Sandstone (Clarens Formation).
Cliffs of white Cave Sandstone straddle the road and remnants of the early Cenozoic
planation can be seen on the spurs to either side of the valley (King, 1982; Meth et
al., undated). Basaltic lava layers dominate the higher altitudes and the skyline
(above 2800m) shows the Gondwana land surface. The head of the pass is a
Cretacic landscape truncating the basaltic layers irregularly (King, 1982).
4.2.4 Geomorphology
The geomorphology of the Drakensberg Park is varied owing to the considerable
geological and climatological differences between the lower altitude sandstone
regions and higher altitude basalt outcrops. Substantial climatological contrasts play
an important role in establishing site-specific geomorphologic processes. Areas
34
Rev 0 / Dec 2008
above 2800m host landscape components that are typical to ‘alpine’ or ‘periglacial’
environments, where cold temperatures, ice and snow are important controlling
factors. The steep slopes and deep valleys to the east of the Great Escarpment,
combined with a high annual precipitation, produce substantial hydraulic gradients
along fluvial channels and on slopes, thus providing for a diverse landscape which
hosts a wide assortment of erosional and depositional features. Some features that
are no longer actively forming are referred to as ‘fossil-’, ‘relict-’ or ‘palaeo-‘ landforms.
Such landforms may have developed under a different climate than that of today,
reflecting a constantly adjusting landscape. The Drakensberg Park has landforms that
are both Holocene (last 10 000 years) and Pleistocene (last 2 million years) in age
(Grab, 2004).
4.2.5 Hydrology and Drainage
Within a broader context, the Drakensberg serves as a catchment for the Orange,
Thukela, Mkhomazi, and Mzimkhulu Rivers (EKZNW, 2005). In the Drakensberg, as
much as half of the annual rainfall (roughly 600 mm) can leave the area in the form of
runoff due to shallow soils and steep inclines. Although large rainstorms are common,
indigenous vegetation generally absorbs surface flow ensuring a gradual and
sustained water yield throughout the year rather than erratic flooding and subsequent
dryness. Water reaching streams under these conditions is usually sediment free and
of a high quality (EKZNW, 2005).
The P318 is located in the Mkhomazi River catchment with one of its tributaries, the
Mkhomazana River, running adjacent to the road for the majority of its length from
Lesotho, although it veers northeast from the pass after the Good Hope ruins. Small
wetlands can be found near the road and the only significant stream crossed by the
Phase 1 road is the Gxalingenwa, a tributary of the Mkhomazana River.
The sub-catchments (catchment areas which cross the road) are generally smaller
than 5 km². The catchment areas are very steep with average slopes varying between
15% up to 60%. With the catchments being relatively small and the steep slopes,
stormwater runoff peaks for a short period but high velocities are generated, which
increases the potential for erosion. Measures will be put in place to reduce the
velocities at the drainage structures.
The flows for the Mkomazana River from near the top of Sani Pass (km33) to just past
the new proposed border post site (km 14) is also being modelled in order to establish
flood levels along the road.
4.3
Botanical
4.3.1 General
Within the Maloti-Drakensberg region, the vegetation of Sani Pass is unique. No other
valley has such a diversity of plant life. Because of its exceptional diversity the
vegetation of Sani Pass has an international reputation.
The flora of these high mountains has recently been recognized as one of the world’s
‘hot spots’, a centre of plant diversity of global botanical importance. The dramatic
broken landscape of the escarpment and the harsh climatic conditions on the
highlands of Lesotho account for the remarkably diverse plant life with about 2,200
species and almost 400 endemics (plants found only in this area and nowhere else in
the world). 1
35
Rev 0 / Dec 2008
It is known as the Eastern Mountain Region (EMR) or the Drakensberg Alpine Centre
(DAC). For the purposes of this document it will be referred to as the EMR.
The vegetation is broadly defined as follows:
•
•
•
Alpine.
± 2800-3500 m
Sub-alpine ± 1800-2800 m
Montane below 1800 m
According to Low and Rebelo3 the vegetation along Sani Pass fits the following
categories:
•
•
•
•
•
Alti Mountain Grassland (46), found in the sub-alpine belt.
Afro Mountain Grassland (45), found mostly in Lesotho.
Wet Cold Highveld Grassland (41), found on the rocky slopes of the
Drakensberg and includes a shrub layer.
Moist Upland Grassland (42), includes shrublands and some Protea savanna.
North-eastern Mountain Grassland (43), includes trees and shrubs.
The dominant vegetation physiognomy of the Maloti-Drakensberg region is high
altitude grasslands and dwarf scrub and scattered patches of afromontane forest in
fire-protected valleys. Wetland communities are scattered along drainage lines and
moister slopes, but are concentrated in the alpine region1. These high altitude wetland
systems support several endemic species2.
Altitude, climate, aspect, latitude and geology are important determinants of species
composition and physiognomic patterns in the region.3
(a) Rare, endangered and endemic species
The Red Data List is currently being fully revised and as such plant species on Sani
Pass were classified according to the last published list. The list of vulnerable species
is available in Appendix B.
(b) EMR Endemic Plants found on Sani Pass
The population of endemic species found on Sani Pass is fairly large. It is important to
list endemic species because, although they might be locally common, they are found
nowhere else in the world. Some might have a very restricted distribution in the EMR
and this is not yet properly understood. In the absence of data, construction damage
should be kept as low as possible.
EMR endemic species recorded on Sani Pass in January 2007 and 2008 are listed in
Appendix B.
4.3.2 Invasive Alien Plants
Disturbed ground is quickly colonised by invasive alien plants. This is apparent on the
lower reaches of the Pass where there is heavy infestation of wattle and Cotoneaster
berry bushes as well as American bramble in particular. This is due to past practices
of heavy grazing from stock and from the mule trains from Lesotho before the road
1
Pooley, E S 2003
. Rutherford, MC and Westfall, R H, 1986.
3
. Low and Rebelo 1966
4
. Nősser 1999
5
Ambrose and Talukdar 1999
6
Klug et al.1991
2
36
Rev 0 / Dec 2008
was constructed up the pass. Some of it is also due to garden escapes from farm
houses, trading stores etc.
The upper reaches of the Pass are relatively free of alien plants. The more extreme
climatic conditions make it inhospitable for the extremely invasive species found on
the lower reaches. However, high altitude weeds, particularly from the northern
hemisphere are moving in from the Lesotho side of the border along the road, and
others, from the base of the Pass in South Africa. Hilliard and Burtt have listed a large
number of alien species found up Sani Pass, considered to have followed the road.
Any disturbed ground is a potential problem area with negative effects on the
biodiversity of the area. The list of alien invasive species that are found on Sani Pass
are also listed in Appendix B.
Maps of the indicated species and sensitive areas are presented in Figure 4.
4.4
Fauna
4.4.1 General
The fauna along the Sani Pass Road itself is scarce as the existing road has been in
place for many years. Many animal species were hunted to extinction in the past and
the modified environment within the road servitude is not a hospitable habitat to many
species. There are a number of reedbuck that inhabit the lower sections of the Pass.
Eland (the largest antelope in Africa) are predominantly found in the wilderness areas
of the mountains, although they do occasionally wander further down the Pass.
Klipspringer also inhabit the more inaccessible parts of the mountains although they
also frequent farmland. The most common antelope is the Vaal rhybok or Grey
Rhebuck, which is often seen near troops of baboons, and Oribi and Mountain
Reedbuck are also evident (Clark, 2001; EKZNW, 2005).
Within the foothills of the Drakensberg predators such as the Jackal (e.g. the black
backed jackal) and the lynx or caracal are present. Serval and sundry wild cats are
also established in the area although leopards are absent. Mongoose, skunks, as well
as baboons are common and colonies of voles (small rodent of the gerbil family)
known as ‘ice rats’ are found around the top of the mountain. Along the rivers, otters
such as the Cape Clawless may be seen (Clark, 2001).
Snakes found near the pass are generally grass snakes, of which the Skaapsteker is
the most common. The most dangerous snake to be found is the Puff Adder while the
Herald snake or the Natal Green snake is found near water. Many lizard species also
inhabit the area (Clark, 2001).
Although reportedly out of date, the KZN Systematic Conservation Plan identifies four
animal species of conservation significance that are potentially found in the project
area:
•
•
•
•
Wattled Crane (Bugeranus carunculatus) (bird).
White-winged Flufftail (Sarothura ayresi) (bird).
Midlands Dwarf Chameleon (Bradypodion thamnobates) (reptile).
Three-coloured Red Millipede (Centrobolus tricolor) (invertebrate).
37
Rev 0 / Dec 2008
4.4.2 Avi-Faunal
Sani Pass is a very popular birding route and rated by birders as an easy place to see
the full complement of montane specials: Mountain Pipit, Drakensberg Rockjumper,
Drakensberg Siskin and Lammergeier being the "big four". Other bird species along
this route include Brown-backed Honeybird, Bush Blackcap, Swee Waxbill, Gurney's
Sugarbird, Ground Woodpecker, Buff-streaked Chat, Barratt's Warbler, Drakensberg
Prinia, Fairy Flycatcher, Grey Tit, Layard's Tit-Babbler, Southern Bald Ibis, Sicklewinged Chat, Large-billed Lark, Sentinel Rock-Thrush, Cape Vulture, Verreaux's
Eagle, Jackal Buzzard, Black Harrier, Southern Pale Chanting Goshawk and African
Rock Pipit. (E Marais, http://www.birdlife.org.za/news/news, 2005).
Other species include Green malachite sunbirds and canaries and the Grey Wing
Francolin has been seen on the road and in the sagebrush higher up on the Pass.
Blue Cranes are presently nesting on farmland adjacent to the Sani Pass. The
Redwing Francolin is found in open grassland while the Long Crested Eagle has
appeared with forestry on farmland. The Gymnogene is quite common and the Martial
Eagle can be seen in the surrounding area (Clark, 2001; EKZNW, 2005). Although
seen in the area at the beginning of 2006, Wattled Cranes have not nested this year
as per previous years in the wetland area south of the road between km 0 and km 1.
Of the 98 endemic species to South Africa, 44 are to be found in the Sani Pass ¼° by
¼° grid-cell and these constitute 44% of the all th e species endemic to southern
Africa. Four of these endemics are particularly common: Sentinel Rock-thrush, Jackal
Buzzard, Cape Vulture and the Gurney’s Sugarbird, all charismatic species much
sought after by bird watchers and also of concern to conservationists. Of the 62
species found in southern Africa which are considered to be ‘near-endemic’ a total of
seven (11%) may be found in the Sani Pass grid-cell.
Birds are classified depending on their conservation level. Five (5) species of Critically
Endangered species are found in South Africa of which 1 is found on Sani Pass, the
wattled crane. 11 endangered species are found in South Africa of which 1 is found
on Sani Pass, the bearded vulture. 8 out of 43 vulnerable species of which 8 are
found on the Sani Pass and 21 near threatened species.
4.5
Aquatic Environment
The Sani Pass area has various aquatic habitats, mostly in the form of wetland and
riverine ecosystems. As previously indicated, the Pass traverses the UDP, is a World
Heritage site, and is in the List of Wetlands of International Importance (under the
Ramsar Convention).
The principle aquatic system, the Mkomazana River, has its source in alpine
environments from where it drains the Sani Pass valley whilst gaining flow from
numerous tributaries. The river flows perennially with strong flows being experienced
typically during the wet season. Typically, the rivers and stream of the Mkomazana
Catchment are driven by landscape features and therefore fall steeply at the
headwaters, cascading over a repeating sequence of rocky pools and riffle/rapid
habitats. In some reaches large bedrock shelves are present, but otherwise the river
bed consists of large boulders and cobbles. In the lower reaches the Mkomazana
River is defined by long riffle sections interspersed with deep pools. From the variety
of habitat templates alone, for the Mkomazana River, the Sani Pass area is host to an
array of aquatic biota.
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4.5.1 Aquatic Herpetofauna – Amphibians
The Sani Pass area is known to support at least eighteen species of frog, with
additional species recorded in the surrounding area also likely to occur (Minter et al.
2004). The vast majority of these frog species have life histories strongly tied to
aquatic ecosystems. A large component of the local frog fauna consists of highaltitude endemics, many with fairly restricted global distributions. Furthermore, several
of these are habitat specialists with a number of species having experienced a
decline in population numbers across their ranges.
(a)
Red Data (RD) species
There are a number of frog species that have been recorded from the Sani Pass area
and its surroundings, some of which are classified as Red Data species and include:
•
•
•
The Plain Stream Frog Strongylopus wageri (RD status - Near Threatened)
Long-toed Tree Frog Leptopelis xenodactylus (RD status - Endangered)
Natal Leaf-folding Frog Afrixalus spinifrons intermedius (RD status Vulnerable)
(b) Other notable species
In addition to the Red Data frogs, a number of other species have historically been
recorded from the area. These frogs are considered notable on the basis that they
are habitat specialists, localised endemics and/or under threat in parts of their range:
•
•
•
•
•
Natal Ghost Frog Hadromophryne natalensis
Drakensberg River Frog Amietia dracomontana
Aquatic River Frog Amietia vertebralis
Berg Stream Frog Strongylopus hymenopus
Karoo Toad (Drakensberg population) Vandjikophrynus gariepensis nubicolus
(c)
Aquatic Herpetofauna – Reptiles
One species of reptile that utilises aquatic habitats (wetlands and streams), is the
Cream-spotted Mountain Snake Montaspis gilvomaculata, is considered a sensitive
species. This is a poorly known species, with only five individuals found so far, two of
which are from Sani Pass. Currently, the Cream-spotted Mountain Snake is not Red
Data listed, as it was only discovered after the publication of the current evaluation
(Branch 1988), but will be listed as RD - Data Deficient in the upcoming Red Data
evaluation (South African Reptile Red Data Book, In prep.).
4.5.2 Icthyofauna – Fish
The Mkomazana River is an important system that potentially supports various fish
species. However, deficient fish surveys and/or presence of trout suggest the river
has a reasonably poor diversity of fish species.
(a) Sensitive species
The Mkomozana River is considered significant from an icthyological perspective in
that it is the river from which the Maluti Minnow (Pseudobarbus quathlambae) type
specimens4 originated. Subsequent to this original collection of this species from the
Mkomozana River in 1938 no further records of these minnows were made until 1970
when specimens were found in the Tsoelikana River in the Sehlabathebe National
Park, Lesotho during a rivers survey conducted by Messrs. A. Tedder, of Lesotho
Fisheries, and T. Pike, a fisheries biologist from the then Natal Parks Board.
4
The specimen on which a species is described and named
39
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Further investigations of rivers in Lesotho revealed the presence of these minnows in
approximately 17 other rivers, all situated in the Maluti Mountains of Lesotho (i.e. the
highland mountains of Lesotho). However, no further records of Maluti Minnows were
reported from their “species type locality” (i.e. the Mkomazana River) despite efforts
from a very brief investigation carried out in 1991 on a small section (approximately
1km) of the Mkomazana River, in the vicinity of the described locality where the
original specimens were collected. This investigation was done by Messrs. T. Pike
and R. Karssing (Natal Parks Board). No thorough investigation of the presence of
fish, particularly Maluti Minnows, has been carried out in the Mkomazana River (Pike,
2008).
The Maluti Minnow is classified as Critically Endangered (with only 6 small
populations known). According to Skelton (2001) the Maluti Minnow is threatened by
the building of dams and roads, siltation and the introduction of trout. Examples from
rivers in Lesotho have attributed overgrazing and poor cultivation methods as
additional causes to heavy siltation of rivers and the subsequent pressure on this
species.
4.6
Socio-economic Environment
4.6.1 Social Context
The social environment in the Sani Pass area can be described as follows:
The Sani Pass is located in the Sisonke District Municipality and the Kwa Sani Local
Municipality. The area is largely rural with few small towns (Himeville and Underberg)
and is characterised mainly by conservation areas, agricultural farms and tourism.
(a) Sisonke District Municipality
Sisonke District Municipality (DM) is located in the south west of KwaZulu-Natal and
is comprised of five local municipalities, namely KwaSani, Ubuhlebzwe, Ingwe,
Greater Kokstad and uMzimkhulu. Sisonke DM recognises the need to align its
Integrated Development Plan (IDP) with both the Provincial Growth and Development
Strategy (PGDS) and the Provincial Spatial Economic Development Strategy
(PSEDS). In accordance with these provincial strategies, Sisonke DM has identified
tourism as a key sector to facilitate economic development, generate employment
opportunities and alleviate poverty. Sisonke DM recognises that KwaSani Local
Municipality currently attracts the most tourists visiting the DM, and this is attributed to
its location as the gateway of the uKhahlamba Drakensburg Park (Sisonke District
Municipality IDP 2008-2009).
(b) KwaSani Local Municipality
KwaSani Local Municipality (LM) is located at the foothills of the southern
Drakensburg. The economy of the KwaSani LM is based primarily on tourism and
commercial agriculture (KwaSani Municipality, 2006). Himeville and Underberg are
the main service centres, providing a range of wholesale and retail trade facilities, as
well as basic essential services, accommodation and some health care services to
the surrounding population and to tourists. In addition to these two small towns, there
are a number of rural community settlements including KwaPitela, Stepmore,
Mqatsheni, Enhlanhleni, Ntwasahlobo, Netherby, Ridge, and KwaThunzi.
KwaSani LM and has a population of approximately 17 453 with relatively low
population densities (Sisonke District Municipality 2008-2009). The population is
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Rev 0 / Dec 2008
characterised by low levels of education and high levels of unemployment (KwaSani
IDP 2006-2007).
Local and district roads are not a very good condition and this is recognised as
hindering the full potential of tourism, agricultural and forestry, which are key
economic sectors in this area (KwaSani 2006-2007).
(c) Lesotho and the Mokhotlong District
Mokhotlong District is one of 10 districts in Lesotho, and is the district immediately
adjoining the Sani Pass. The Mokhotlong District is the largest and least populated of
all the districts in Lesotho (ACER Africa 2006). According to the 1996 census there
were 74 496 Basotho living in Mokhotlong District (Ministry of Economic Planning
1996). The District is largely rural with very limited infrastructure and economic
activity. There is also very little tourism infrastructure on the Lesotho side of the Sani
Pass, with the notable exception being the Sani Top Chalets.
May et al. (2002) report that districts in the mountainous areas of Lesotho are three
times poorer than the Lesotho national poverty average. Agriculture forms an integral
part of household food production and livestock forms an integral part of the culture
and livelihoods of the Basotho people (Serage, no date). The Sani flats (immediately
after the Sani Pass and before Black Mountain Pass) have historically been used as a
summer grazing area for livestock by people from the lower areas of the Mokhotlong
District. Grazing of goats and sheep in this area has led to the establishment of a
number of sheering sheds with the wool and mohair exported directly to South Africa
via the Sani Pass.
The Sani Pass has historically been an important transport link for the people of
Mokhotlong and South Africa. Because Sani Pass is the only road providing access
for motor vehicles into South Africa from Mokhotlong, it is used extensively by local
residents, traders and business people wanting to access goods and services in
South Africa. Many Basotho people from the Mokhotlong district rely on the Sani Pass
to access a range of trade, health care and education facilities, which are lacking in
the Mokhotlong District. There are also strong cultural and family links between local
households in KwaSani and Mokhotlong, with many families split between the areas5.
The Sani Pass is therefore an important social, trading and logistical link between
Lesotho and KwaZulu-Natal.
4.6.2 Economic Context
The household and local business impact area is tentatively defined to comprise three
main places in Kwa Sani Local Municipality: Himeville, Underberg (roughly 6 km’s
south of Himeville), and Sani Pass. The Cobham State Forest, also known as
Mkhomazi Wilderness Area, includes the Sani Pass Road corridor. This 1 180km2
area had a total population of 15 308 in 2001, up by 5.0% or 734 from 1996. The
area’s small population base is expanding, but at only one-half the rate of the nation
as a whole. KwaSani remains sparsely populated, with just 13 residents per km2 (as
compared with a national average of 37 persons per km2), and within the lowest third
of South African municipalities in population density.
In 2001, residents of this impact area held about 3 600 jobs. The largest share of
these jobs was in the agricultural sector, accounting for roughly 27% of all jobs held
Before the establishment of the international border post at Sani Pass, there was free movement of local people in the area and marriages between
members of households in South Africa and the Mokhotlong District of Lesotho are reported to have been common. There are currently still strong family
ties between these households split between South Africa and Lesotho with family members frequently travelling between the two areas for social and
cultural events.
5
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by impact-area residents. The other important employers were private households
(22%), community services (17%), and trade (16%).
Within the impact area, there are some local differences in terms of the jobs held by
residents. Residents of Himeville, located on the Phase 1 portion of the road that is
already under construction, were employed primarily in private households (40%),
trade (18%), and community services (14%). These are the most “dependent”
sectors, in that residents were the most dependent on informal sectors and
government employment. Residents of Kwa Sani, in the rural part of Underberg, were
overwhelmingly employed in the agriculture sector (50%), followed by households
(20%). Thus, a large share of residents had productive employment in a primary
industry.
Within Underberg, resident employment patterns were similar to those of Himeville,
although there appeared to be somewhat less dependence on jobs in private
households. People living within the Cobham State Forest area (including the Phase
2 project corridor), were primarily employed in community services (40%) such as in
Government (possibly working in State Forest jobs). About 19% were employed in
private households, 15% in trade, and 13% in agriculture. All areas had a low level of
residents employed in utilities, finance, transport, manufacturing, construction, and
mining. In fact, only three residents listed employment in the mining sector in 2001.
Table 9: Resident Employment by Sector, Sani Pass Impact Area, KZN, 2001
Sector
Himeville
KwaSani
#
#
%
Underberg
%
#
%
CS Forest
#
%
AREA
Plus MWA
Subtotal
TOTAL
%
18
6%
738
50%
87
9%
54
13%
897
966
Mining
-
N/A
-
N/A
0
N/A
-
N/A
-
3
0%
Manufacturing
6
2%
135
9%
27
3%
6
1%
174
193
5%
Agriculture
27%
3
1%
3
0%
30
3%
-
0%
36
36
1%
27
9%
25
2%
105
11%
27
6%
184
200
6%
Wholesale & retail
57
18%
136
9%
231
23%
63
15%
487
569
16%
Transport services
18
6%
9
1%
45
5%
3
1%
75
69
2%
FIRE
15
5%
36
2%
51
5%
18
4%
120
170
5%
Community services
45
14%
99
7%
222
22%
166
40%
532
627
17%
Private households
126
40%
289
20%
195
20%
80
19%
690
776
22%
TOTAL
315
100%
1,470
100%
993
100%
417
100%
3,195
3,609
100%
Utilities
Construction
Notes:
Agriculture includes forestry & fishing. Utilities are electricity, gas, & water.
FIRE is Financial, Insurance, Real Estate & Business services.
Transport includes storage and communications services.
Community services include social & personal services.
CS is Cobham State Forest. KwaSani Underberg is non urban.
Impact Area comprise KwaSani Local Municipality.
MWA is Mkhomazi Wilderness Area.
N/A is Not Applicable.
Sources:
Statistics South Africa and African Development
Economic Consultants (Pty) Ltd.
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4.7
Tourism
Tourism is becoming increasingly important in the area. KwaSani LM has identified
tourism as one of its key economic sectors, with the Sani Pass, Bushman’s Nek,
Garden Castle forming the key tourism attractions in the area. Tourism activities are
abundant along Sani Pass itself and range from 4x4 and quad biking tours, to
accommodation and numerous ecotourism and cultural activities. Accommodation
facilities (ranging from upmarket lodges to backpackers accommodation) and curio
shops are found along the first section of the Sani Pass. However no development is
found from the start of the uKhahlamba Drakensberg Park to the Lesotho Boarder
Post.
Tourism flow through the Sani Pass area was assessed based on information
collected by Border agencies and tour operators in the region. An estimated 50 000
people on average cross the South Africa / Lesotho border post at Sani Pass each
year, based on data collected through interviews. “Returning visitors” comprise about
50% of these border crossings. According to tour operators, about 50% of the return
crossings in KwaSani (or 12 500) are Lesotho economic visitors (i.e. people who
cross the border into South Africa to shop, seek medical help, or bring children to
school). The remaining 50% of return crossings are eco tourists, including both
foreign and domestic visitors.
The tourism industry, which includes employment primarily in transport services,
lodging, and (to a lesser extent) retail trade, appeared to generate few jobs for
residents of the impact area in 2001. However, a more detailed assessment of the
tourism employment base will be conducted in the Impact Assessment Phase of the
EIA when ADEC will obtain employment data at the 3, 4, and 5-digit levels of
standard industrial classification (SIC).
(a) Eco-Tourism
The eco-tourism niche comprises the largest component of the tourism flow through
the area. The niche delivers relatively high per-visitor impacts because this group
tends to include visitors who stay longer and spend more. According to tour
operators, about 90% of the tourists (11 250) are wilderness enthusiasts who visit
because of the natural setting and scenic beauty of the Sani Pass and surrounding
areas. The remaining 10% (1 250) tends to include bird or flyer watchers.
Based on a survey conducted of tour participants by the Sani Branch of the Wildlife
and Environment Society of South Africa (WESSA), the following elements were rated
highest in terms of their importance to the overall visitor experience through the area:
•
•
Mountains (80%)
•
Scenery (72%)
•
Wilderness (60%)
•
Lesotho and Local Culture (49%)
•
Flowers (45%)
•
Adventure (43%)
•
4x4 Driving (42%)
•
Birds (40%)
•
People (40%)
•
Geology (32%)
•
History (28%)
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•
Direct Route to/from South Africa (7%)
This list was generated primarily by participants in organised tours, thus there is likely
to be a bias in favour of topics covered by the tour operators. Many of the tours are
organized around nature and wilderness adventure. Furthermore, the questionnaire
did not provide space for any other responses beyond those listed above.
Nevertheless, it would appear that topography and scenic views are most important to
the visitor, along with the sense of “wilderness” and adventure that is projected
throughout the route. Human and cultural interventions accounted for just three of the
12 topics most often cited by the surveyed tourists as important to the overall
experience. Since many of these tourists are visiting other parts of South Africa (or
are from South Africa), the uniqueness of visiting a completely different country like
the small mountain kingdom of Lesotho is an important part of the “adventure.” Use of
the road itself was mentioned by only 7% of participants as important (presumably to
their overall tour itinerary).
(b) Visitor Origin
Foreign tourists are a significant proportion of the visitor base to Sani Pass,
accounting for an estimated 63% of all visits. The majority of these tourists originate
in the U.K. (17%) and Germany (15%). Other important international sources are:
Belgium (7%), Holland (6%), and other European nations (8%). Domestic tourists
account for 37% of the visits, originating from all parts of South Africa. The South
Africans visit primarily during vacation and school holidays.
(c) Routing
The routing of tourists through Sani Pass is handled primarily by group tour operators,
accounting for as much as 62% of all visits, with 26% of tourists travelling in their own
vehicle. International visitors with tour itineraries that include the Drakensberg
typically initiate their trips in Johannesburg or Cape Town.
(d) Seasonality
The season is said to last from mid-September to May, although tours are conducted
throughout the year. December and school holidays are peak periods. Bird watching
is in season from mid September through March, peaking in October and November.
Flyer watching is in season from mid-December to mid-March, with most visitors
arriving in January and February.
(e) Tariffs
Typical tariffs for a six-person group tour range from R2 150 (R358 per person),
morning tea and lunch inclusive. If only one person travelled on this tour alone,
he/she would pay the full R2 150. Some tour operators charge R350 to R370 per
person, excluding tea and lunch.
4.8
Aesthetics
4.8.1 Topography
The Sani Pass Road crosses the UDP from south-east to north-west through a
relatively narrow pass. The incline increases steadily to approximately km 28 where
the angle of incline increases considerably to the summit at km 33. The steep and
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diverse landscape through which the road passes, is one of the primary reasons for
the aesthetic appeal of this section of the Drakensberg.
The mountain range is majestic and dramatic with steep slopes, incised valleys and
high rising peaks. The winding and sinuous road is moulded to the landscape
following its natural form. Views and experiences are constantly changing as one
ascends or descends the Pass. Several pristine streams also cross the road as they
flow down steep narrow side valleys and provide some of the most important scenic
experiences along the route.
The lower sections of the Pass consist of shallow soils derived from Karoo Sequence
sediments and dolerite while the upper steeper sections consists of shallow acidic
litho soils derived from the massive Drakensberg basalts of the Stormberg Group
(Low and Rebelo, 1996). These basalts give rise to the dramatic landscape with the
existing road, retainment walls, cuttings and tills reflecting the existing colours and
textures of the surrounding landscape.
4.8.2 Vegetation Cover
The vegetation along the route falls within the Moist Upland Grassland vegetation
(lower section) and the Alti Mountain Grassland vegetation type within the Grassland
Biome (Low and Rebelo, 1996). As a result of the lack of diversity and height of the
grassland vegetation cover, the Pass is left visually exposed, especially the upper
reaches, and does not blend into the landscape or allow the landscape to accept
visual changes or intrusion.
4.8.3 Landscape Diversity
Landscape diversity is a function of topography, vegetation and land use. The greater
the diversity, the greater is the potential for the Road to blend with the surrounding
landscape.
The diversity of this section of the Sani Pass is influenced by the topographical
features rather than any land use pattern or vegetation cover, namely the massive
topographical features of the Drakensberg such as the steep slopes, incised valleys,
craggy peaks and scarp faces. The great height of the mountains is sufficient to throw
patterns of light and shadows across the face of the range which continuously change
throughout the day and the season. Changes in the vegetation create subtle colour
and texture patterns. The landscape diversity at a macro scale is considered high as
it allows the Road to be visually “absorbed” into the landscape where it does not
appear visually dominant or out of place or scale when viewed against the backdrop
of the Drakensberg and the play of light and shadow.
However, at a local scale the visual diversity is lower as vegetation height and pattern
plays a larger role than does the effect of light and shadow and does not readily
accommodate any visual change to the landscape resulting in the road being highly
visible with a high visual contrast.
4.8.4 Landscape Character
The spirit, or sense of place, is that quality imparted by the aspects of scale, colour,
texture, landform, enclosure, and in particular, the land use. The sense of place of
the Sani Pass is defined by the backdrop of the massive and dominating Drakensberg
Mountains, as well as the partially enclosed valley through which the road passes
together with the extensive views to the south and east across a vast picturesque
landscape that extends to the distant horizon. The Pass is located within a landscape
which has a strongly defined sense of place, an extensive, broad, massive and
picturesque landscape and a very high visual quality that is vivid and unified.
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The visual quality of the landscape, or visual significance given to a landscape
determined by cultural values and the landscape’s intrinsic physical properties
(Smardon, et el. 1986), through which the road passes, can be regarded as high due
to the scale of the landscape, the relatively pristine visual state of the environment
and the visual diversity that create a unified and vivid quality.
Visual scale is the apparent size relationship between landscape components or
features and their surroundings (Smardon, et al. 1986). The vertical and horizontal
scale can be regarded as broad, massive and expansive due to the great height of
the Drakensberg and the extensive views over many kilometres to and from the
mountain. As such, the enormous scale tends to dominate most man-made features
in the Sani Pass valley, reducing their perceived scale considerably due to the
relative scale. The height of the mountains provides a visual backdrop that limits
viewing the road and its associated structures in silhouette.
4.8.5 Visibility
Views from the road extend for many kilometres to the south and east with the
viewing distance increasing as the viewpoint increases in elevation. Critical views are
those from the surrounding hill slopes and the higher elevations from where the road
can be seen by road users and tourists within the World Heritage Site.
Views of the Pass are theoretically possible from the edges of the extended views,
however, the road is only visible from 5-10 km away when the light is right with
visibility further reduced when the Pass is in shadow or is broken up by shadows.
During the dry, winter months when the vegetation is dry and brown in colour, the
Pass is even less visible as it becomes camouflaged by the surrounding vegetation
colour. However, during the wet, summer months the road and the cleared road
reserve are in high contrast to the surrounding area which turn brilliant green in colour
and tends to focus attention to the road.
4.9
Cultural Heritage Environment
4.9.1 History
The San hunter-gather people have been in the uKhahlamba-Drakensberg mountain
range for centuries, long before the Bantu-speaking peoples arrived in southern
Africa. By the end of the first half of the first millennium AD, the Bantu-speaking
farming communities were migrating into the region occupying the foot-hills and
valleys below the uKhahlamba Drakensberg mountain range. The Bantu-speaking
communities introduced settled life, domesticated livestock, crop production and the
use of iron (Huffman, 2007). Over the next centuries into the second millennium AD,
the Nguni groups in the region developed giving rise to socio-cultural complex
societies that eventually led to the rise of African complex societies such as the
Basotho and Zulu Kingdoms in the 1800s AD.
In 1835 the Voortrekkers with horses and wagons arrived in the foothills of the
uKhahlamba-Drakensberg Mountains. The encroaching settlement of Voortrekkers
amongst the foothills of the Drakensberg, the shrinking of the San’s traditional hunting
grounds and the political dynamics among the Nguni-Zulu farming led to further
instability and hardships particularly for the San. Soon the San themselves were
being targeted and being shot in tensions and battles over resources. Clashes over
hunting grounds, private ownership of land, and the arrival of cattle led to increasing
numbers of cattle raids by the San people. Eventually the situation became so bad
46
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that the San were hunted and decimated by the settlers. By the 1880s, the white
settlers had established farms and settlements in Underberg-Himeville at the base of
the Sani Pass (Wright and Mazel, 2007). The cultural visual landscape began to shift
with new stone-wall houses and sheds surrounded by imported eucalyptus, pine and
wattle trees connected by wagon tracks. On the foothills, settlements grew around
magistracies and trading stores such as Himeville and Underberg below the Sani
Pass (ibid). The last sighting of San people in the Drakensberg Mountains was in the
early 1880's (Wright and Mazel 2007) and by the turn of the century the San had all
but disappeared.
In the uKhahlamba Drakensburg area, early conservation efforts led to the
establishment of the Natal National Park in 1916. It changed its name to the Royal
Natal National Park in 1947. Through time, more and more land along the length of
the mountain range was added to the protected area, some by the Natal Parks, Game
and Fish Preservation Board and some by the Department of Forestry. Late in the
20th century the majority of land along the length of the Drakensberg had become
consolidated and was administered in its entirety by the Natal Parks Board. The
Board later combined with the KwaZulu Department of Nature Conservation and the
new KwaZulu-Natal Nature Conservation Service was formed. In 2000 the
organization became known as Ezemvelo KwaZulu-Natal Wildlife and the UDP was
nominated and listed as a mixed UNESCO World Heritage Site in December of the
same year for its natural and cultural heritage significance.
According to UNESCO World Heritage Commission (2000), the UDP possesses the
following natural and cultural universal characteristics:
•
Natural criteria (iii) and (iv)
The UDP has exceptional natural beauty with soaring basaltic buttresses,
incisive dramatic cutbacks and golden sandstone ramparts. Rolling high
altitude grasslands, the pristine steep-sided river valleys and rocky gorges
also contribute to the beauty of the site. The site's diversity of habitats protects
a high level of endemic and globally threatened species, especially of birds
and plants.
•
Cultural criteria (i) and (iii)
Criterion (i): The rock art of the uKhahlamba-Drakensberg is the largest and
most concentrated group of rock paintings in Africa, south of the Sahara and is
outstanding both in quality and diversity of subject.
•
Criterion (iii)
The San people lived in the mountainous uKhahlamba/Drakensberg area for
more than four millennia, leaving behind them a corpus of outstanding rock art
which throws much light on their way of life and their beliefs.
Heritage resources present in the UDP WHS include the following:
•
•
•
•
Archaeology
Palaeontology
Built Heritage
- Architectural Heritage
- Architectural Conservation Areas
- Protection of the Architectural Heritage
- Significant Graves and Burial grounds
Natural Heritage
- Local Biodiversity
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•
•
•
•
- Protected Species
Trees
Avi-fauna
Fauna
Intangible cultural heritage and community identity
4.9.2 Archaeology
The southern uKhahlamba-Drakensburg region contains archaeological sites ranging
from Stone Age to Late Iron Age (Write and Mazel, 2007). Stone Age materials are
usually associated with several rock shelters and caves in the uKhahlambaDrakensburg Mountain range whereas Iron Age sites are recorded in the foothill and
uplands below the escapement (Huffman, 2007). The range also contains many
caves and rock-shelters with the largest and the most concentrated group of 4000
years old San prehistoric rock paintings on the African continent and the world at
large. The major prehistoric rock shelters and cave sites - such as Good Hope 1
Shelter, Collingham Shelter and Eland Cave - are well known in the mountain region,
but not immediately on the Sani Pass project area.
Nonetheless, no immediate archaeological sites were observed in the vicinity of the
Sani Pass Road project area. This is most probably because of the fact that caves
and rock shelters that could have formed foci of prehistoric habitation appear located
away from the road route which is the primary focus of this study. There are however,
some rock shelters which exist in the ravines that run through the vicinity of the Pass.
The proposed project’s receiving environment along the road route is unlikely to
contain Iron Age archaeological sites because the affected landscape is too high for
prehistoric farming communities to have settled voluntarily to pursue their farming
activities. The sourveld of the region only supplied good grazing for a limited period
during first rains but very poor grazing during the winter dry season (Write and Mazel,
2007: 73). The open grass land did not provide firewood or timber the farmers would
have required for energy and construction. However, this does not rule out the use of
the mountain slopes for grazing purposes by the prehistoric pastoralists during spring
and summer.
The road earmarked for upgrading in this project follows the Mkomazana River valley
which has potential to yield Late Iron Age sites that may be associated with political
dynamics that preceded the mfencane. Around the 1830s, the region also witnessed
the massive movements associated with the mfencane (‘wandering hordes’). The
causes and consequences of the mfencane are well documented elsewhere (e.g.
Hamilton 1995; Cobbing 1988; also see Wright and Mazel, 2007:76-9). During this
period, different competing farming groups retreated in and out of the mountains for
safety and security during these troubled times.
4.2.1 The Development of the Sani Pass
The Sani Pass was originally developed as a bridal path in 1913 and became an
established route used by trains of horses, mules and donkeys that carry large
volumes of maize, timber, fuel, blankets, clothing and household goods over the
uKhahlamba-Drakensburg Mountains and returned down the Pass with wool and
mohair from Lesotho. As a result of the success of the route, the Sani Pass Trading
store at Good Hope was established and served the route for many years. This trade
grew considerably alongside the demand for tourism into Lesotho which led to the
establishment of a track for four-wheel-drive vehicles over the Pass by a group of
South African entrepreneurs in the 1950s. The Pass was opened to commercial
vehicle traffic in 1955 by David Alexander, whose company, Mokhotlong Mountain
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Transport, was the first to operate on the Pass. By 1980, the track had been
developed by the South African and Lesotho governments into a road usable by large
trucks. Ever since the Sani Pass had remained a strategic link between the two
countries in the southern uKhahlamba-Drakensburg region.
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5
SCOPING PHASE APPROACH AND METHODOLOGY
5.1
EIA Process
The NEMA EIA Regulations (Government Notice No R386 and R387) identify a
number of “listed activities” for which authorisation is required. In order to obtain this
authorisation, either a “Basic Assessment Process” or “Scoping and EIA Process”
must be followed. Basic Assessments are typically required for activities that have
less detrimental impact, whilst the Scoping and EIA process is required for larger
projects that typically have potentially significant detrimental impact on the
environment. Both processes include some form of public participation.
This environmental authorisation process commences with an Environmental Scoping
Phase (hereafter referred to as the ‘Scoping Phase’). Following submission of a
Scoping Report and associated Plan of Study for the Impact Assessment Phase, to
and approval by the DEAT, the Impact Assessment Phase will be initiated. A
prescribed PPP runs concurrently with the Scoping and Impact Assessment Phases.
The aim of Scoping is to determine the issues, concerns and queries of Interested
and Affected Parties (I&APs), potential impacts, potential alternatives, specialist
studies required (as necessary) and the scope of the Impact Assessment Phase.
The Impact Assessment Phase addresses the issues that have been raised during
the Scoping Phase; assesses alternatives to the proposed activity in a comparative
manner; assesses all identified impacts and determines the significance of each
impact and formulates appropriate mitigation measures. The Impact Assessment
Phase thus comprises the actual assessment of potential impacts and the compilation
of a comprehensive EIA Report.
The Impact Assessment Phase may include specialist studies, which need to be
included in the EIA Report and must also include a Draft EMP for the construction
and operational phases of the project.
Figure 5 summarises the Scoping and EIA Process, which is required in terms of the
NEMA EIA Regulations.
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Figure 5: EIA Process Flow Diagram
EIA Process Flow
PUBLIC
EAP
DEAT
Submit
application to
DEAT
Acknowledge
receipt
within 14 days
Scoping Phase
Authorities
meetings
Notice boards
Newspaper
adverts
40 day
comment
period on BID
Conduct PPP
Notify stakeholders
Distribute Background
Information (BID)
Prepare
(DSR) including
Plan of Study for EIA
30 day
Comment
period on DSR
Solicit comments
on DSR
Reply in 30 days:
Accept DSR
or
Reject DSR
Submit
Final Scoping Report
(FSR) to Authority
or
Require
amendments
Assessment Phase
Prepare Draft
Environmental
Impact Report (EIR) &
draft Environmental
Management Plan
(EMP)
30 day
comment
period
Advise IAPs
of
Environmental
Authorisation
Solicit comments on
the
Draft EIR / EMP
Decide within
60 days:
Accept EIR
or
Refer for
reviews
or
Request
amendments
Submit final
reports to Authority
or
Reject EIR
Environmental
Authorisation
Grant or refuse
authorisation
within 45 days
of acceptance
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5.2
Scoping Phase
5.2.1 Objectives
The Environmental Scoping Phase has been undertaken in accordance with the
requirements of sections 24 and 24D of the NEMA, as read with GNR 385
(Regulations 27-36), 386 and 387 of the NEMA and the IEM Information Series
(DEAT, 2002). The objectives of the Scoping Phase are to:
•
•
•
•
•
Ensure that the process is open and transparent and involves the authorities,
proponent, project team, stakeholders and general public
Identify the important characteristics of the affected environment
Ensure that feasible alternatives are identified and selected for further
assessment
Assess and determine possible impacts of the proposed project on the
biophysical and socio-economic environment
Ensure compliance with the relevant legislation.
An important aspect of the Scoping Phase is the Public Participation Process (PPP),
which aims to:
•
•
•
•
•
•
Ensure all relevant I&APs have been identified and invited to engage in the
scoping process
Raise awareness, educate and increase understanding of I&APs about the
proposed project, the affected environment and the environmental process
being undertaken
Create open channels of communication between I&APs and the project team
Provide opportunities for I&APs to identify issues or concerns and suggestions
for enhancing potential benefits and to prevent or mitigate impacts
Accurately document all opinions, concerns and queries raised by I&APs
regarding the project
Ensure the identification of the significant alternatives and issues related to the
project as proposed by I&APs.
5.2.2 Scoping Report Requirements
The Scoping Phase for this project has been undertaken to ensure compliance with
the requirements of the NEMA EIA Regulations. This Scoping Report has been
compiled in accordance with the following requirements:
•
•
•
•
•
•
Provide the details and expertise of the EAP undertaking the EIA process
Describe the proposed location for the activity along with all applicable
alternatives
Provide a baseline 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 project
Identify all relevant legislation and guidelines that have been considered for
the project
Provide a description of the environmental issues and potential impacts,
including cumulative impacts that have been identified
Provide the methodology that will be adopted in assessing the potential
impacts that have been identified, including any specialist studies that will be
undertaken.
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•
•
Outline the PPP that has been undertaken for the project to date
Provide a Plan of Study for the Impact Assessment Phase.
The following sections provide more detail on the tasks undertaken as part of the
Scoping Process.
5.3
Pre-application Consultation
A pre-application meeting was held with the representatives of the DEAT on 21 April
2008. The purpose of the meeting was to introduce the project and to discuss and
obtain clarification on the following:
•
•
•
•
•
•
•
The application procedure and provincial environmental authority involvement
The applicable listed activities
Other government departments and the legislative requirements
DEAT document review
The scope of the PPP and advertising requirements
Alternative assessment scope
Specific DEAT requirements.
A meeting with EKZNW, the administrators of uKhahlamba Drakensberg Park (UDP),
had been held on 03 March 2008, prior to the meeting with the DEAT. The purpose of
the meeting was to introduce the project and to discuss and obtain clarification on the
following:
•
•
•
•
•
5.4
Specific EKZNW requirements
Available ecological baseline data from EKZNW records
Specialist studies required
Key stakeholders to be contacted
Key issues to be considered.
EIA Application
Subsequent to the pre-application meeting, the EIA application to undertake the listed
activities was submitted to DEAT on 06 May 2008. Arcus GIBB received the
acknowledgement of the application form and authorisation to proceed and the
project was allocated reference number 12/12/20/1184.
5.5
Specialist Investigations
As a result of the nature and location of the proposed project and the potential
impacts on the environment, various specialist studies will be undertaken as part of
the EIA. The following studies have been initiated during the Scoping Phase and will
continue during the Impact Assessment Phase.
Table 4 in Chapter 1.3.2 details the specialists, their roles and fields of expertise and
organisations. Appendix C references copies of the specialist’s Curriculum Vitae.
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5.6
The NEMA EIA Regulations (Government Notice Act No. R385) specify that a Public
Participation Process (PPP) must be conducted as an integral part of the EIA and in
accordance with Sections 56 of the Regulations and associated guidelines.
This Chapter outlines the procedures followed during the undertaking of the PPP for
the proposed project. The processes undertaken adheres to the NEMA principle
whereby the participation of all Interested and Affected Parties (I&APs) 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 [NEMA, Section 2(1)(f)].
The main objectives of the PPP are to:
•
•
•
•
•
Inform I&APs about the proposed project and the Scoping and EIA Process
Establish lines of communication between I&APs and the project team to deal
with potentially contentious issues
Provide ample opportunity to all parties to exchange information and express
their views and raise issues and concerns
Obtain contributions of I&APs and ensure that all issues, concerns and
queries raised are fully documented and carried forward in the EIA process
Identify all the significant issues that need to be addressed in the EIA.
In order to fulfil the above-mentioned objectives, a number of tasks were undertaken
as noted below.
5.6.1 Identification and Involvement of Stakeholders and I&APs
Section 56 of the NEMA EIA Regulations outlines the requirements for the notification
and involvement of all potential I&APs. These requirements include to:
•
•
•
•
•
•
Fix a notice board at a conspicuous place on all alternative sites
Give written notice to:
- The landowners and occupiers of the sites and those within 100m of the
alternative sites or those directly influenced by the activity under consideration
- The municipal councillor of the affected wards
- The municipality which has jurisdiction in the area
- Any organs of state having jurisdiction in respect of any aspect of the activity
Place an advertisement in a local newspaper or official Gazette
Place an advertisement in a provincial and or national newspaper if the impact
extends beyond ‘local’ boundaries
Make information containing all relevant facts in respect of the application
available to potential I&APs
Facilitate participation by potential I&APs in such a manner that all potential
I&APs are provided with a reasonable opportunity to comment on the
application.
Arcus GIBB adhered to these requirements as detailed in the sub-sections below.
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5.6.2 Register of I&APs
As part of the requirements for NEMA EIA Regulation 57, Arcus GIBB has developed,
maintained and is constantly updating an electronic I&AP register for the project.
Bearing in mind that I&APs are still welcome to register, refer to Appendix E for a
copy of the latest I&APs register. (Note that the register includes role players and
stakeholders.)
As noted in Chapter 4.1.2, in compiling the Phase 2 database, the Phase 1 I&AP
database was obtained from ACER Africa. Each I&AP was contacted telephonically
requesting whether they wanted to be included in the Phase 2 I&AP database.
5.6.3 Notification of Key Stakeholders
At the commencement of the Scoping and EIA Process, Arcus GIBB identified key
stakeholders such as municipal authorities, government departments and
environmental groups that have jurisdiction over-or potential interest in-the activity
and provided them with written notification.
In addition to various stakeholder focus groups meetings with the key stakeholders
identified below, stakeholders were also sent a Background Information Document
(BID) detailing technical information about the project and the EIA process to be
followed (refer to Chapter 5.1 above for further detail).
Relevant stakeholders were contacted telephonically and were invited to a meeting to
identify the key issues associated with the project. See Appendix E for the I&AP
Register. The key organisations and stakeholders identified through the public
participation process include:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Kwa Sani Municipality: Local Council
Kwa Sani Municipality: Department of Planning & Development
Department of Agriculture and Environmental Affairs (DAEA)
AMAFA – KwaZulu Natal Heritage
Department of Water Affairs and Forestry (DWAF)
KwaPitela Development Committee
Border Control Operating Co-ordinating Committee (BCOCC)
Ezemvelo KZN Wildlife (EKZNW)
National Immigration: Pietermaritzburg
South African National Roads Agency Ltd (SANRAL)
Taxi Association - Lesotho
Taxi Association – KZN
Wildlife and Environment Society of South Africa (WESSA) - KZN Region
Southern Drakensberg Community Tourism Organisation (SDCTO)
Tourism KwaZulu-Natal
5.6.4 Registered I&APs from the Sani Pass Phase 1 Project
Arcus GIBB received a copy of the I&APs Register for the EIA Process for the Sani
Pass Phase 1 Project from ACER Africa. Arcus GIBB contacted all parties on this
register either telephonically or in writing at an early stage of the PPP to invite them to
register as I&APs for the Scoping and EIA Process for Phase 2 of the Sani Pass
Upgrade. Any parties which indicated that they wish to be retained as I&APs for
Phase 2 were included on the Phase 2 I&APs Register and were provided with BIDs.
5.6.5 Landowner Notification
All landowners within the 100 m radius of the proposed development area have been
notified of the proposed development via the distribution of the BIDs.
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5.6.6 Media Notices
Due to the proposed projects location within a World Heritage Site and its extent up to
the Lesotho border, the proposed project will not only impact and affect local parties,
but will have provincial, national and international consequences. Based on the
NEMA EIA Regulations, it was therefore reasoned that the Scoping and EIA Process
must be advertised to a wider audience and the project was therefore advertised at a
national level. A media notice detailing information about the project and the EIA
process that is currently in progress, as well as an invitation for the registration and
participation of I&APs, was placed in a national, regional and local newspaper as per
Table 10.
Table 10: Media Notice Newspaper Details
Area
Newspaper
Date
National
Regional
Local
The Sunday Times
The Mercury
The Mountain Echo
11 May 2008
15 May 2008
16 May 2008
Refer to Appendix F for copies and proof of these media notices.
It was, however, still recognised that mechanisms other than media notices would be
more effective in informing inform I&APs in Lesotho of the proposed project and as
such the PPP was extended to include Lesotho (e.g. notice boards, liaison with
border authorities, meetings with local government).
5.6.7 Notice Boards
Notice boards detailing information about the project and the Scoping and EIA
Process, as well as invitation to register as I&APs, were strategically fixed at various
conspicuous points along the Sani Pass route as well as in public places in Himeville
and Underberg, as detailed in Table 11.
These notice boards were designed to the specification of Section 56 (3) of the NEMA
EIA Regulations. See Plates 9-16 for proof of Notice Boards displays.
Table 11: Notice Board Details
Location
Description
Old Trading Post
Fixed to the kiosk which faces the road
Fixed to the boom operator cubicle (after approval was received
from border post officials)
Background Information Document (BID) was also displayed
behind the window of the passport control office, and copies of
BIDs were left for I&APs to take
Fixed to the veranda wall of the border post office and the gate at
the border post (after approval was received from border post
officials)
Placed at the entrance of the Kwa Sani Municipal Office. Copies of
BIDs were left for I&APs to take
Placed at the entrance of the Library. Copies of BIDs were left for
I&APs to take.
Placed on the front window of the Underberg Spar and on the
notice boards in the store.
Placed on the front window of the centre and BIDs were left for
I&APs to take.
South African Border Post
Lesotho Border Post
KwaSani Municipal Office
Underberg Library
Underberg Spar
Southern Drakensberg
Tourist Information Centre
in Underberg
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OK Shopping Centre
Himeville Arms Hotel
Placed on the front window of the Store.
Place in the entrance foyer of the Himeville Arms Hotel.
5.6.8 Background Information Document
The BID was compiled in English, Sotho and Zulu and distributed to all registered
I&APs in South Africa and Lesotho and to various venues as indicated in Table 12
(Refer to Appendix G for a copy of the BID). The BID introduces the proposed project
and contains background information on the project, the proponent, consultants and
the proposed Scoping and EIA process and associated PPP to be followed. It also
includes an invitation to I&APs to register and submit any comments to Arcus GIBB in
writing. A locality map is also included.
BIDs were placed at the local public library in Underberg and at the Kwa Sani
Municipality Office. In addition, BIDs were delivered to various places of business in
Underberg, Sani Top and Lesotho. Refer to Table 12 for an indication of the BID
distribution points.
Table 12: List of Background Information Document Distribution Points
Date
13/05/08
13/05/08
13/05/08
13/05/08
13/05/08
13/05/08
13/05/08
13/05/08
13/05/08
1625/05/08
08/09/08
09/09/08
09/09/08
09/09/08
10/09/08
10/09/08
BID Distribution
Site Notices
Placed
Sani Pass Hotel
Himeville Forge Hardware Store
Underberg Spar
Southern Drakensberg Tourist Information Centre in
Underberg
The Underberg Memorial Library
OK shopping centre
Himeville Arms Hotel
Kwa Sani Municipality Building
Border Control Facility at the Border Post
The BID was distributed through Email / Post and Fax to all
I&APs on Database
Sani Top Chalet
Meeting with traders at Mokhotlong
Meeting with the District Administrator and Government
Departments at Mokhotlong
Meeting with Mokhotlong Taxi Association
No. 10 Riverside B&B on the Route to Mokhotlong
Meeting Bless Mhlomi – Sani Top Store Owner
5.6.9 Stakeholder Meetings
Various Key Stakeholder meetings were held with different public sectors,
organisations and individuals. The purpose of these meetings was to offer key
stakeholders an opportunity to raise issues, concerns with regard to the proposed
development. All the concerns and issues raised during the PPP, including proposed
alternatives, are discussed in this DSR with supporting minutes of the meetings
included in Appendix H. No minutes of meetings held between 08 and 10 September
2008 are available as these meetings were conducted by the social specialist as part
of their study. Records of these meetings will, however, be documented in the Social
Impact Assessment Report included in the Impact Assessment Phase.
A chronological list of the meetings is tabulated in Table 13 below:
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Table 13: Chronological List of Meetings
Date
27/03/08
03/03/08
27/03/08
21/04/08
20/06/08
21/06/08
08/09/08
09/09/08
09/09/08
09/09/08
10/09/08
10/09/08
Organisation
EKZNW – Meeting with Southern uKhahlamba
Region Conservation Manager
EKZNW - Meeting with the Regional Planning
Department
Location
Cobham Nature
Reserve, Underberg
Queen Elizabeth
Park,
Pietermaritzburg
Pre-application meeting and site visit with DEAT SSI Offices,
officials
Pietermaritzburg and
Sani Pass
Authorities Meeting - AMAFA, DAEA, BCOCC,
SSI Offices,
DWAF, KwaSani Municipality
Pietermaritzburg
Stakeholder Meeting - Tour Operators and the Himeville Arms Hotel,
Taxi Associations
Himeville
Stakeholder Meeting - KwaPitela Community
KwaPitela School,
KwaPitela
Sani Top Chalet - owner
Sani Top Chalet
Mokhotlong District Stakeholder Meeting – Mokhotlong Hotel,
District Administrator, and local government Mokhotlong
representatives from Police, Trade and
Marketing, Roads and Health Departments
Meeting with Mokhotlong Taxi Association
Mokhotlong Hotel,
Mokhotlong
Meeting with traders at Mokhotlong
Mokhotlong
No. 10 Riverside B&B
Route to Mokhotlong
Meeting Bless Mhlomi – Sani Top Store Owner
Sani Top
5.6.10 Open Day and Public Information Sharing Meeting
An open day and public meeting is scheduled at the Underberg School Hostel on the
06 December 2008. The meeting will be divided into two components, the first being
the Open Day, where posters will be displayed which explain the various components
of the EIA. The intention is to provide an informal environment in which I&APs can, in
the own time, learn about the project and discuss their issues and concerns one-onone with the project team and the technical specialists. Subsequently, the formal
public meeting component will be held at the same venue during which a more formal
presentation will take place as per the standard meeting format.
The purpose of the meeting is to discuss the proposed development further, to raise
any additional issues and concerns and to allow I&APs to make informed comments
on the DSR. An attendance register will be distributed at the meeting and will be
appended to the FSR.
5.6.11 Interested and Affected Parties and Stakeholder Comments
NEMA EIA Regulation 58 entitles registered I&APs to comment in writing, on all
written submissions made to the competent authority as part of the environmental
authorisation and to raise any issues or concerns which they believe may be of
significance to the consideration of the application. Copies of all comments and
issues raised during the PPP will be consolidated into an Issues and Concerns
Report (ICR), (See Appendix I), which summarises each response received from all
I&APs. All comments received in response to the DSR will be incorporated into ICR
prior to submission of the FSR to the DEAT. Refer to Appendix K for the original
comments received by I&APs.
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5.7
Compilation of the Draft Scoping Report and Public Review
This Environmental Scoping Report was compiled in accordance with the
requirements of the NEMA EIA Regulations (DEAT, 2006). The DSR will be available
from 03 December 2008 at the following public places listed below for public review
and comment until 23 January 2009 (52 days). Registered I&APs will be informed of
the availability of the DSR for review as the report is distributed.
•
•
•
•
Underberg Library
Electronic copies of the Report are available on CD on request or alternatively can be
downloaded from the Arcus GIBB website: www.gibb.co.za.
Any comments received on the Draft Scoping Report or any new comments or issues
raised during, or as a result of the Public Information Sharing Meeting, will be
recorded in the Issues and Concerns Report (ICR) and will be appended to, and
addressed in, the Final Scoping Report (FSR) to follow.
5.8
Compilation of the Final Scoping Report
Comments received on the DSR will be recorded in the ICR and responded to. Where
necessary, the appropriate amendments will be made to the Final Scoping Report
(FSR) before submission to the DEAT for review. At the same time of submission of
the FSR to the DEAT for authorisation, copies of the FSR will be placed at the same
venues as indicated for the DSR (refer to Chapter 5.7) for those I&APs who wish to
review the FSR. Any further comments that I&APs may have on the FSR will have to
be submitted by I&APs directly to the DEAT Assessing Officer for consideration in the
review process.
5.9
Comments Register
All I&AP written comments received subsequent to the publishing of the media
notices and the distribution of the BID have been recorded in the ICR which is
included in Appendix I. Responses to each comment submitted are also provided.
Comments received from authorities are included in Appendix J.
Comments made at the various meetings held with key stakeholders are recorded in
the minutes of each meeting and have not been repeated in the ICR.
5.9.1 WESSA Tourism Survey
Included in the Wildlife and Environment Society of South Africa (WESSA)
submission, was the results of the Tourism Survey that was conducted between
November 2007 and March 2008. 685 questionnaire responses were returned and
analysed by WESSA. Due to the volume of the survey, the responses have not been
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included in the ICR including a few of the questionnaires that were sent directly to
Arcus GIBB. A full copy of the Study and the results is available from WESSA. The
results as included in the WESSA submission are, however, documented in the ICR.
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6
POTENTIAL ENVIRONMENTAL IMPACTS AND ISSUES
6.1
Introduction
In terms of Regulation 29 of the EIA Regulations which describes the contents of a
Scoping Report, sub-regulation (f) states that the Scoping report must contain “a
description of environmental issues and potential impacts, including cumulative
impacts, that have been identified.”
The purpose of this chapter is, therefore, to provide a brief description of both the
potential positive and negative environmental impacts which could occur as a result of
the upgrading of the Sani Pass Road (P318): Phase 2. The chapter does not attempt
to assess, rank in terms of significance or mitigate any of the identified impacts or
issues, positive or negative. The Plan of Study described in Chapter 7 describes the
methodology by which the impacts will be assessed in the Impact Assessment Phase.
Table 14 below provides a summary of the Potential Impacts and Issues identified to
date.
Although not assessing impacts, this chapter will identify those consolidated issues
which are known at this stage to be significant and require specialist input and
investigations either to research and understand the impact/issues, and/or to
determine their significance. The motivation and need to undertake the specialist
studies for these impacts is described in the Plan of Study.
The impacts associated with activities during construction are usually short lived and
mitigated in a Draft EMP, included in the Draft EIAR. Once approved, the EMP will be
implemented on-site and enforced by regular monitoring with submission of audit
reports to the DEAT Compliance Department. As a living document, the EMP can be
modified, with approval from the DEAT, to suit the conditions, constraints and
practicalities of the construction once it has begun.
It is expected that additional impacts and issues will be identified during the public
review process and the Impact Assessment Phase. These will be highlighted,
described and assessed as per all other impacts in the Impact Assessment Phase.
Table 14: Summary Table of Potential Impacts and Issues
Impacts / Issues
Source
P1* P2** I&APs
*
*
*
*
*
*
Biophysical
Soil Erosion and Sedimentation
Potential Water and Soil Pollution
Ecological Impacts
Destruction of Rare Species Habitats
Sedimentation of the Mkomazana River
Disturbance of Avi-faunal Species
Disturbance of Faunal Species
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
Socio-Economic
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Change to Sense of Place
Sani Pass Tourism
Changes for Commercial and Private Road Users
Local Economic Development and Job Creation
Changes in Human Movement and Trade Patterns
Safety and Security Risk
Impacts on Road Safety and Travelling Conditions
Sporting Events
Safety and Security of Local Residents
Disruption to Road Users
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
Economic
Economic Benefits
Economic Disbenefits
Employment
Economic Impacts on Tourism
*
*
*
*
*
*
*
*
*
*
*
*
Visual / Aesthetic
Construction Camps and Associated Activities
Construction of the Road
Slopes and Vegetation
Rehabilitation
*
*
*
*
*
*
*
Cultural Heritage
Impact on Geological and Fossil Material
The Loss of a Historical 4x4 Road
Cultural Heritage Resources
*
*
*
Road Surface
Road Maintenance
Construction
Construction Activities
Waste Management During Construction
Construction Timeframes
Disruption in Traffic Flow During Construction
Safety Impacts
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*P1 = Phase 1
**P2 = Phase 2
6.2
The DOT has provided a motivation to explain the decision to undertake the proposed
project. The environmental need to upgrade the road i.e. to halt current environmental
degradation and prevent further damage, is well understood and accepted by all
parties. The social, economic and tourism need and desirability has, however, been
identified as an issue and criticised by many of the I&APs who find the DOT’s
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motivation inadequate and unjustified with little supporting evidence. Many
questioned how the DOT could, without undertaking the relevant feasibility studies,
decide that upgrading the Sani Pass Road was a feasible project with an overall
positive benefit. They further questioned whether the DOT had considered the
negative repercussions in their decision to propose the project.
6.3
Biophysical
6.3.1 Soil Erosion and Sedimentation
Both during the construction and operation of roads, particularly gravel roads, there is
increased exposure of sediments to processes of erosion. In the Drakensberg, this
erosion potential is naturally significant high due to the highly erodible soils, the high
concentration of surface runoff and the very steep gradients. On the Sani Pass (both
on the road and above and below the Pass), this erosion potential is further amplified
by poor stormwater control and poor road engineering, resulting in substantial erosion
along almost the entire length of the Pass during most heavy rainstorms, particularly
those points at which the Road transects drainage lines. Most significant of these are
the switchbacks near the summit which repetitively cross the main drainage line down
the escarpment. This mobile sediment is transported along the road and into gullies
and drainage streams before being deposited into the Mkomazana River below.
6.3.2 Potential Water and Soil Pollution
In addition to sedimentation of water resources discussed above, water and soil
pollution may result from a number of construction-related activities. Aquatic
environments may become subjected (directly and indirectly) to pollution from
fuel/chemical spills that are associated with construction activities and vehicles.
Physico-chemical pollution of the river and associated aquatic ecosystems may also
occur through point source pollution discharge (e.g. treated and untreated sewage).
Construction camps require services and infrastructure to handle the transport,
treatment, and disposal of sewerage. If such services do not function properly, there
is the potential that aquatic ecosystems will become polluted. There will also be
domestic waste and construction waste (such as containers, bags, rubble, etc.),
which will need to be disposed of correctly to prevent pollution.
6.3.3
Hard surfacing the road can cause the velocity of the post-construction run-off to
exceed the pre-construction run-off and coupled with intense summer rainfalls this
can impact on the river systems and water sources if it is not managed. Increases in
the hydrological flow of rivers can change the type of habitat that is supported by a
particular water regime. This in turn affects the vegetation and animals that are
dependent on that specific eco-system.
6.4
Ecological Impacts
6.4.1 Destruction of Rare Species Habitats
It is well known that certain species of biota have very specific habitat requirements
which restrict the existence of such species and often populations become confined
to suitable areas for their survival. In some cases such areas may be fairly isolated
resulting in the species becoming classified as a rare occurrence. If their specific
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habitat is threatened further by degradation or construction, then they can become
endangered and possibly extinct.
Restructuring the road will involve a large portion of the adjacent vegetation to be
removed. The vegetation biome on the Sani Pass is unique to the area and a large
percentage of the plant species are endemic, threatened or red data species. As such
destruction of the environment could result in these species being lost forever.
6.4.2 Sedimentation of the Mkomazana River
Erosion in turn causes sedimentation of water courses, wetlands and dams and this
in turns affects biodiversity as there is loss of habitat, reduced ecological functioning
and as a result, loss of biodiversity. There are numerous rare and endangered
species in the area that may be affected by sedimentation of the head of the
Mkomazana River, such as the Wattled Crane and Maluti Minnow.
Less obvious aquatic species are also likely to be affected as sedimentation can
destroy micro-habitats and bring about the localised demise of a species. Sediments
are a unique water quality problem, when compared to typical polluting ecological
function of a water body.
Amphibians, in particular, are sensitive to environmental disturbance, given, amongst
other things, their biphasic (terrestrial and aquatic) lifestyles, permeable skins and
varyingly specialised (particularly breeding) habitat requirements. It has been
determined from various fish and river surveys that the Maluti Minnows do not occur
in rivers which contain moderate to heavy silt loads (Pike, 2008). Excessive deposits
of sediment on the substrate of rivers would impact negatively on Maluti Minnows
populations. It is predicted that with the upgrade of the Sani Pass the amount of
sediment run-off is likely to decrease, thus benefiting these species.
6.4.3 Disturbance of Avi-faunal Species
Sani Pass is an internationally renowned bird watching site and there is concern that
the upgrading of the pass will in turn affect the birds currently found in this area. It is
commonly observed that there are fewer birds seen along tarred roads than along dirt
roads in the same habitats and this is because proportionately more birds are killed
along roads where the speed of the vehicles is higher and so they learn to avoid such
roads. Construction as well as ongoing maintenance is likely to disturb bird species
and reduce the chances of seeing them on the Pass. It is possible that bird-based
tourism will shift to other localities because most bird watchers prefer to be away from
the crowds, they seek solitude and a sense of being at one with the natural world.
6.4.4 Disturbance of Faunal Species
The construction of the Road and its eventual use could impact on the fauna of the
Pass mainly as a result of the disruption and/or destruction of their feeding and
roosting habitats through construction activities e.g. blasting and grading of banks
and in-fills. Noisy construction activities and the increase in human activity on the
Pass during the construction phase are likely to disturb resident faunal species and
cause them to leave the area.
Animals could also be killed by construction activities if they take cover in their nests
in areas where construction is taking place and are then destroyed or covered by
collapsed material. Fauna are also at risk from poaching by local labourers who might
use the opportunity of working on the Pass to hunt the animals for food.
Pollution and contamination of food and water resources from poor waste
management and littering may also impact on the fauna and needs to be properly
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managed. This impact remains a real threat for the life of the Pass as the number of
road users increases and the amount of litter and waste produced and disposed of on
the Pass increases.
Animals would also be more at risk once the upgraded Road is completed as the
higher average vehicle speed will probably result in more animals being knockedover. Increased traffic volumes and increased speeds also create increased road
noise which would scare the animals away and deter them from returning.
6.5
Socio-Economic
6.5.1 Change to Sense of Place
Sense of place is influenced by many different elements that all have an effect on the
way in which it impacts on, and is interpreted by, any particular person and these may
include cultural, psychological and environmental factors. These factors all influence
the way in which a person interprets a particular sense of place experience and the
emotional reaction it elicits (ACER Africa, 2004). Sense of place is thus, subjective
and highly individual. Changes in the character of the area due to the increased
number of people visiting the area, noise levels and traffic, and the change to visual
character of the surrounds are anticipated as a result of the upgrading of Sani Pass.
Strong opposition was raised in Phase 1 with regards to surfacing the Road as it was
believed that this would cause the Sani Pass Road to lose its “sense of remoteness”
and sense of being off “the beaten track” and thus lose popularity as a tourist
destination. The Report also identified nuisance factors such as noise and dust during
construction which would detract from the experience particularly for activities such as
bird-watching.
Another concern that was raised was the aesthetics of the construction camps, which
on previous road projects in the area, have detracted from the sense of place,
particularly to tourists. Traffic congestion and movement of construction plant along
the road may also affect the sense of place during construction.
6.5.2 Sani Pass Tourism
The local economy is strongly based on tourism and tourists may be deterred from
visiting the area for the duration of the construction phase. This may financially impact
on tour operators and facilities supporting tourism such as accommodation facilities
and restaurants. Tour operators may also lose business if they are unable to access
Sani Pass within a specified time period during the day. Booking agents, tourists and
event organisers may also start using alternative destinations should the Pass
become inaccessible for extended periods of time.
6.5.3 Changes for Commercial and Private Road Users
As mentioned the road is only accessible by 4x4 vehicles which limits the amount of
people who can use the road. Traders, tour operators and taxi use the route
extensively, transporting local residents and tourists on a daily basis. The condition of
the road means that vehicles require regular, costly services. An upgrade of the road
service will reduce these maintenance cost as well as the dependency on 4x4s.
6.5.4 Local Economic Development and Job Creation
The local economy of Kwa Sani is strongly founded on tourism, dairy farming and
plantation forestry. A major construction project such as the upgrading of the Sani
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Pass, as well as changes in the tourism market could significantly affect the local
economy of the area, in particular the towns of Himeville and Underberg.
6.5.5 Changes in Human Movement and Trade Patterns
The proposed upgrading of the Sani Pass could positively impact on human
movement and trade patterns and result in improved quality of life and social wellbeing for both South African and Basotho households. The movement of people
between South Africa and Lesotho along the Pass also includes a wide range of other
business people and government officials, who would also benefit from the upgrading
of the Sani Pass.
6.5.6 Safety and Security Risk
The current state of the road forces motorists to travel cautiously at a safe, slow
speed resulting in very few accidents recorded on the Pass. There is a concern that
upgrading the road will allow motorists to travel faster, which is one of the objectives
of the upgrade (minimum speed of 30km/h), resulting in more accidents, particularly
as the upgraded Road will allow inexperienced drivers access to the Pass.
Smoothing and hard-surfacing the Road will also make the Pass more dangerous in
snowfalls. Vehicles travelling the Pass in these conditions will have reduced traction
as the snow and ice will make the Road surface much more slippery. Risks of
accidents increases significantly with the possibility of vehicles sliding off the Road
into the valley below.
Upgrading of the road will also allow easier movement between Lesotho and South
Africa encouraging cross border crime which is already a problem in the region. Crime
such as muggings and hijackings could also increase as the Road will become more
accessible by all forms of vehicles.
6.5.7 Impacts on Road Safety and Travelling Conditions
There is concern that a hard surfaced road will allow motorists to travel faster,
increasing the number of accidents. In addition it is believed that a hard surface will
become more dangerous during snowfalls than a dirt road. The safety of drivers
during the construction phase may be jeopardised.
During construction, travelling conditions along the P318 will be poor due to the
movement of heavy construction vehicles in the area, high levels of dust and/or mud,
loose road material and the lower standard of the diversion road.
To ensure safety of motorists during construction, standard safety practices are put in
place, including reduction in speed limits in the vicinity of the construction site,
appropriate signage and manned flagging stations. There will also be movement of
construction vehicles along other district and main roads (gravel and surfaced) and
through the towns of Himeville and Underberg driving to and from borrowpits and
quarries with material. This will have an impact on traffic flow (as these trucks will
travel much slower than the maximum speed limit) along these routes. On smaller
gravel roads, there is likely to be considerable dust, especially during winter months
and road condition may deteriorate, resulting in poor travelling conditions.
During construction, there will also be increased danger to pedestrians, cyclists and
equestrians (horse-riders) along the P318 itself, the haulage roads to and from
borrow pits and quarries through the towns of Himeville and Underberg. Many people,
both locals and tourists travel on foot in the area and up the Pass. The increased
volume of traffic and speed of travel with no pavement for pedestrians, poses a safety
risk to both the pedestrians and vehicle drivers.
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Many I&APs are concerned about speeding on the upgraded road, and as a result,
are concerned that there will be more accidents. This is a key issue on South African
roads where a high proportion of accidents are proven to be the direct result of
speeding.
6.5.8 Sporting Events
Phase 1 recognised that there are a number of sporting events6 held throughout the
year which are either held close to or include the Sani Pass as part of the routing of
the events. Changes to the nature of the Pass or prevention from accessing the Pass
as part of events, could result in a significant impact on the sporting events and the
local economy and tourism which rely on these events for income.
Popular sporting events such as the Sani Stagger and the Sani Pass Transfrontier
Mountain Bike Race have been established around the rugged and challenging
conditions of the Sani Pass. Upgrading the Pass is likely to negatively impact these
events as the participants would no longer find the same level of enjoyment and
excitement from racing on a smooth road.
6.5.9 Safety and Security of Local Residents
I&APs raised the concern that their safety and security would be further jeopardised
by the upgraded road and improved access, which they believe would result in an
increase in crime, particularly violent crime and stock theft which are both already
prevalent in the area.
6.5.10 Disruption to Road Users
During construction, the flow of traffic will be affected due to the movement of
construction vehicles in the area and reduced speed limits. Limited duration, daytime
“stop/go” control points will also be implemented during the construction of alignment
improvements or blasting. However, disruption to traffic flow will be minimised and
traffic accommodated through the provision of a gravel surfaced detour/diversion road
parallel to the P318.
During construction the road will have to be closed for select hours, disrupting the
traffic flow.
6.6
Economic
6.6.1
Economic Benefits
As one of the main motivations for the proposed project is the projected economic
benefit to both SA and Lesotho as a result of the improvement of the link road
between the two countries, the proposed project is expected to, and intended to,
impact on the micro and macro-scale economy of the region. These projected
benefits include:
•
6
Provision of access to the UDP from both sides of the escarpment and
incorporate the border and park access controls
Events include the Sani Stagger (an annual marathon run up and down the pass, attracting well over 300 entrants), the Sani Transfrontier
mountain bike race (also attracting around 300 entrants) and the Sani Pass wildflower walk (attracting around 100 participants) (Mr & Mrs R
Suchet, Sani Lodge, I&AP submission).
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•
•
•
•
•
•
Reduction in the distance between the eastern Free State through Maseru to
Durban by up to 150km
Opening of the Eastern Lesotho Highlands to tourism development
Strengthening and extension of the business and trade links between the
Mokhotlong area and the businesses in Underberg and Pietermaritzburg
Improvement in transportation infrastructure
Improved accessibility to amenities for both the Basothos and the South
Africans, but particularly the residents of Lesotho’s mountain districts of
Qacha’s nek, Mokhotlong, and Sehlabathlebe, who are relatively dependent
on access to Pietermaritzburg and Durban for supplies, shopping, and
markets
Opening of a new scenic tourism route between the eastern Free State and
KwaZulu-Natal via Lesotho.
6.6.2 Economic Disbenefits
The proposed upgrade is expected to impact positively on the economy of the region
at both a macro- and micro-scale. The project could, however, also have inadvertent
negative impacts which directly affect the same economy. Such impacts could
include:
•
•
•
•
•
•
Collapse of Sani Pass 4x4 Tours market
Loss of tourism market (local and international) due to the Sani Pass, which is
the main draw card to the area, losing its appeal to tourists i.e. loss of the
“Experience of Sani Pass”
Loss of jobs resulting from the anticipated decline in tourism
Loss of local jobs to Basothos who can now travel more easily between SA
and Lesotho
Collapse of sports-based events which feature the Sani Pass
Loss of income to tourism-and sports-related business such as hotels, B&Bs,
restaurants etc.
As a result of the potential significant loss of the 4x4 tours market, local tour operators
have questioned the need and desirability of the proposed project and the anticipated
economic benefits, in terms of both whether the benefits will out-weigh the potential
economic losses, and whether the benefits justify the construction cost.
6.6.3
Employment
Employment opportunities and job creation was recognised in Phase 1 and has,
again, been identified in Phase 2 as an issue requiring consideration and
management. This is not only in terms of actually creating the opportunities, but also
in terms of meeting the expectations of the local communities in both SA and Lesotho
that there will be employment opportunities.
Due to the nature of the project high in the mountains in a very constricted workspace
using specialised techniques, it is expected that most of the specialised work will be
undertaken by specialist contractors experienced in Pass road construction. However,
there will definitely be a need for unskilled labour during the construction of the road
which will be sourced from the local area. Not only will the project provide direct and
indirect employment opportunities but could also provide experience and training to
the labourers who would then increase their chances of employment on other, similar
construction activities in the future.
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Those employed will have increased income levels and therefore there will be local
economic spin-offs through increased levels of spending in the area. The local
economy also benefits through informal traders that sell food, goods and services to
construction staff. Procurement of materials and plant hire, as well as expenditure on
accommodation, food and general living commodities will also benefit the local
economy (ACER Africa, 2006).
Employment creation could, however, also generate the following negative impacts:
•
•
Tension and fighting between factions over limited job opportunities
Increased littering and damage to the environment adjacent to the road due
the behaviour of a large predominantly illiterate and unskilled workforce
6.6.4 Economic Impacts on Tourism
Tourism throughout the area is oriented towards adventure and eco-tourism, much of
which is leveraged by the “rough” conditions of the Sani Pass Road in its current
state. The proposed project will intentionally “smooth” the road out making it
accessible to ordinary sedan-type motor vehicles. The repercussions on tourism
revolve around two key points; the first being that tourists would now not have to
utilise the services of 4x4 tour operators to access the Pass and Lesotho; and the
second that the change in the “Experience of Sani Pass” may deter tourists from
visiting the region.
In both cases, the result is loss of business opportunities and income for many
players in the tourism and hospitality industry in the region.
Most highly affected would be the 4x4 tours industry, particularly those operators who
rely solely on taking tourists on trips up and down the Sani Pass. Those tour
operators who have expanded their services or modified their business strategies are
expected to lose a large proportion of their base income but may still be able to
sustain their businesses, even if not to the same level of success or profit.
Should the upgraded Sani Pass modify or lose its appeal or “experience”, the
attraction for the tourists will be lost and Sani Pass will no longer be the main draw
card to the region. According to the survey conducted by WESSA, many tourists have
indicated that should the Pass be upgraded and hard-surfaced, they would not return
primarily because the attraction of the “wilderness experience” had been removed.
The result would be the decrease in tourists to the region which would have
significant impacts on all tourism-related industries and employment in these
industries. The significance of the decrease in tourists and the significance of the
associated impacts will be determined.
6.7
Visual / Aesthetic
As already noted, the tourism value of the Sani Pass is in its appeal as a “wilderness
experience”. Part of this experience is in the visual and aesthetical value of the
existing Road. Upgrading of the Road and the associated infrastructure could
significantly alter the visual aspects of the Road and the “experience” resulting in a
number of possible impacts both during construction and once complete if not
properly considered and addressed. Aspects, which are expected to have, or create,
visual impacts are described below:
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6.7.1 Construction Camps and Associated Activities
•
The construction of site offices, construction camps, servitudes and temporary
access roads will require excessive clearing and stripping of topsoil. These
cleared areas will contrast strongly with the surrounding environment.
•
The location of the construction camp sites can impact visually on the area.
Camp sites located above the Road behind vegetation are less unsightly then
those located below the Road with no camouflage
•
The relatively random and disorganised layout of the construction camps can
be visually distracting
•
Bright security and construction camp lighting at night can distract from the
serenity of the nature park.
6.7.2 Construction of the Road
•
Areas and/or specific sites of high aesthetic value along the route may be
disfigured, lost, or destroyed by the re-routing and modification of sections of
the Road
•
New access roads constructed during the upgrade may leave permanent
visual scarring if not rehabilitated
•
The compromising of views from, or the alteration of, the ambience of natural
areas
•
Improperly constructed and un-maintained construction sites can be untidy
and unsightly
•
Dust generated from construction activities is aesthetically unpleasing
particularly when it blows into the valley obscuring the view
6.7.3 Slopes and Vegetation
•
Cut and fill slopes become highly visible if not re-vegetated and shaped to
blend in with the existing topography
•
Open and un-rehabilitated landscape scarring can occur in areas where
rehabilitation is not managed or maintained
•
Site engineering such as cut and fills could remain aesthetically incompatible
with the surrounding landscape even after rehabilitation. Edges may not blend
in with the landscape or cut slopes may be too steep to be adequately revegetated.
6.7.4 Rehabilitation
•
High seed bank of alien species in the topsoil can lead to the uncontrolled
spread of exotic invader plant species. This could create a vegetated area that
is visually contrary to the surrounding landscape.
•
Road reserves will have to be cleared of vegetation during construction and
post-construction as part of the Road maintenance. This increases the visibility
of the Road from all view points and detracts from the uniformity of the visual
landscape.
6.8
Cultural Heritage
6.8.1 Impact on Geological and Fossil Material
The entire uKhahlamba-Drakensburg Mountain range region is an outstanding
geological formation which is acknowledged in the UNESCO World Heritage Site
listing. There are numerous caves and rock formations located in the Drakensberg
area which showcase San rock art and fossils. These artefacts could be destroyed
during excavation and construction.
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6.8.2 The Loss of a Historical 4x4 Road
The Sani Pass is one of the highest rated 4X4 routes in southern Africa and is one of
the most popular among 4x4 enthusiasts and highly recommended by 4x4 Club and
the Land rover Club in South Africa. This makes the Sani Pass Road route a highly
significant living heritage experience for the local and international motoring visitors.
The proposed development will completely remove the 4x4 qualities of the route.
6.8.3 Cultural Heritage Resources
AMAFA aKwaZulu-Natali (AMAFA) was notified of the Phase 1 upgrade and
requested that a Heritage Impact Assessment (HIA) be conducted. The study by
eThembeni revealed no heritage resources of significance. A HIA was also conducted
in 2004 for the border post relocation site (± km 14), also by eThembeni. AMAFA has
stated no objection to the project, provided that the recommendations in the report
are met and the necessary permits obtained when and where required. Similarly, a
HIA will need to be undertaken for Phase 2 as both of the previous HIAs were specific
to a focal point or section of Road and therefore did not consider the Sani Pass.
6.9
6.9.1 Road Surface
Review of the Road alternatives by the Project Engineers have indicated that, in order
to meet the design specifications criteria and achieve the current project objectives
(motivation), the Road cannot be gravel-surfaced and must be hard-surfaced. Three
(3) types of hard surfaces are currently under investigation by the project engineers,
namely concrete, asphalt and “chip and spray”. Each type of hard surface differs in
composition, method of construction and maintenance requirements. The costs of
materials and construction of each also vary significantly.
Concern was raised during discussions with key stakeholders that hard-surfacing the
road would have significant detrimental impacts including direct negatives impacts on
the tourism industry, particularly the 4x4 tour operators whose core business relies on
the ruggedness and poor condition of the Pass road. Hard-surfacing and ‘smoothing’
the Road would allow ordinary vehicles to access the Pass and thereby remove the
need to use 4x4 tour operators. This would achieve one of the objectives of the
project although to the possible detriment of the 4x4 tourism industry. In addition, the
tourism industry is of the opinion that hard-surfacing and smoothing the Road would
impact negatively on the “experience” of the Sani Pass and sense of place to the
point where tourism in the Southern Drakensberg would collapse.
The tourism industry has indicated that their preferred option is that the entire Road
be retained as a gravel road. However, if this is not possible, their alternative is for the
upper section from the current Border Post to the summit to remain a gravel surface.
In addition, they have indicated their preference for concrete rather than asphalt as
the hard-surface material as it will have a lower visual impact and will detract less
from the character and sense of place.
In contradiction to this, other key stakeholders, such as the taxi operators and local
communities, support the hard-surfacing of the entire Road as it reduces the wear
and tear on their vehicles, allows all standard vehicles to access the Pass, reduces
travel time, provides a more comfortable trip, and reduces the cost of travel.
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6.9.2 Road Maintenance
The observation was made by the current users of the Pass that the DOT is not
maintaining the existing Pass Road which has left it in a severe state of degradation
and the concern was raised that the new road would eventually meet the same fate.
It was also raised at one of the stakeholder meetings that it is more difficult to
maintain a hard surfaced road than a gravel road and it was also pointed out that a
hard-surfaced road in poor condition is more dangerous than a gravel road in poor
condition, jeopardizing the safety of motorists using the Road. Furthermore, a
degraded hard-surfaced road is harder wearing on motor vehicles.
6.9.3 Construction
(a) Construction Activities
The nature of the construction activities of the proposed project have the potential to
cause significant on- and off-site environmental damage. Such activities include:
•
•
•
•
•
•
•
•
•
Movement of machinery
Movement of people
Cutting and filling of slopes and banks
Blasting of rock faces
Culvert and bridge construction of water courses
Construction of retaining walls
Laying road surface
Mixing of materials
Construction and operation of the camp sites
(b) Waste Management During Construction
Waste generated on the site during construction will include solid and liquid waste
comprising general litter, general waste, hazardous waste, sanitary waste and
contaminated water. Improper management of all waste, will result in both direct and
indirect soil and water pollution. Considering the sensitive nature of the area, such
pollution, regardless of volume or concentration could lead to significant ecological
damage at both a local and regional scale. In terms of pollution, the Mkhomzana
River and its feeding tributaries are most at risk.
(c) Construction Timeframes
The concern was raised that the construction schedule, once set, would not be met
as has happened with Phase 1. This would have severe repercussions for all users of
the Pass should the construction be delayed or take longer than anticipated.
Factors/challenges which need to be considered in calculating the construction
schedule include:
•
•
•
•
•
•
The steep terrain
Confined work space
Required daily closure periods for construction to take place
Extreme climate conditions
Volatile weather conditions
Inexperienced contractors
(d) Disruption in Traffic Flow During Construction
The original TOR for the design of the upgraded road include a specification that the
Pass be accessible at all times. However, in developing the construction methodology
it was realised that, realistically, considering type of construction activities taking
place e.g.: blasting, and the dangers they pose to the public, the Pass would have to
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be closed for periods of time (hours to days). This could severely impact on the
people who use and rely on the Pass daily.
6.10
Safety Impacts
There is concern that after the upgrade, the Pass will become more dangerous to
users for the following reasons:
•
•
•
•
The increased speed limit and traffic volume may result in more accidents
occurring on the pass
The build up of ice on the Pass creates dangerous conditions for motorists
The increase in traffic volume and speed could pose a risk to visitors/tourists
and bird watchers stopped on the side the road
The increase of inexperienced drivers on what can still be deemed as a
dangerous road to travel may increase the number of accidents on the road.
Issues associated with the construction of the pass may be:
•
•
•
•
•
•
•
•
6.11
Accidents caused by human error
The risks associated with using large machinery in a small confined area
The risk of machines toppling into the valley
The risk of construction workers falling off the cliffs during construction
The risk of the road and unstable slopes/banks collapsing during construction
Extreme and unpredicted storms and flashfloods
Dangers posed to the users of the pass during construction (eg: Taxis, tour
operators etc.)
Hazards of Pass – steep slopes, cliffs, gradient of road
Through their initial investigations and consultations with various stakeholders, the
engineering consortium has identified a number of engineering challenges, which
would need to be considered in their design and construction specifications. These
include the following, in no particular order of priority:
•
•
•
•
•
•
•
The Sani Pass traverses a World Heritage Site and is an eco-tourism route
and attraction
Extreme weather conditions with very hot and very cold (below freezing)
temperatures, severe storms and drought, heavy downpours and flashfloods
and regular snow and ice in winter
Minimising impacts on pristine ecological and heritage features such as water
falls, vegetated slopes, rapture nesting sites, etc.
The road traverses many drainage lines which channel significant amounts of
water during heavy downpours and flashfloods
High rate water erosion along most of the route
Rock falls, rock slides and potential avalanches along most of the route
Steep terrain and narrow working space, which present a significant safety risk
and difficult construction and operation working conditions
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•
•
•
6.12
Unstable geological structures along certain sections and particularly the
upper sections of the pass
Certain geological features present restrictions and obstructions which would
require controlled cut, fill and blasting Identifying, selecting and designing the
required structures and features to be technically sound while at the same
time blend in and do justice to the characteristics of a wilderness area
Keep the road reasonably accessible for road users during construction.
Cumulative Impacts
In terms of Regulation 29 of the EIA Regulations which describes the contents of a
Scoping Report, sub-regulation (f) states that the Scoping report must contain “a
description of environmental issues and potential impacts, including cumulative
impacts, that have been identified.” The NEMA EIA regulations define cumulative
impact as follows: “in relation to an activity, means the impact of an activity that in
itself may not be significant but may become significant when added to the existing
and potential impacts eventuating from similar or diverse activities or undertakings in
the area.”
The previous sub-sections identified both the potential positive and negative
environmental impacts which could occur as a result of the upgrading of the Sani
Pass Road (P318): Phase 2. The impacts identified above are direct and immediate
whereas cumulative impacts may not be significant on their own but become
significant when coupled with others.
The Scoping Phase of this EIA has not identified or considered cumulative impacts as
further investigation of the potential impacts and issues and their significances is
required in the Impact Assessment Phase before the cumulative effects can be
accurately defined and assessed.
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7
PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT ASSESSMENT
The Plan of Study (POS) for the Impact Assessment Phase describes the approach
to the Assessment, as required in terms of Section 29(i)(a) of Regulation GNR 385
promulgated in terms of the NEMA. In accordance with Regulation 29(i) of the NEMA,
this POS includes:
•
•
•
•
•
•
•
A description of the tasks that will be undertaken as part of the Environmental
Impact Assessment process
The potential impacts requiring further investigation
Details of the specialist investigations that need to be undertaken and the
manner in which such tasks will be undertaken (Terms of Reference)
An indication of the stages at which the competent Authority will be consulted
A description of the proposed method of assessing the environmental issues
and alternatives, including the option of not proceeding with the activity
Particulars of the PPP that will be conducted during the EIA process
Any specific information required by the DEAT.
To date the Scoping phase of the EIA has been completed and the DSR (this
document) distributed to the authorities and I&APs for review.
The potential environmental impacts associated with the proposed development have
been identified and described through the Scoping exercise in the context of the
biophysical, social and economic aspects of the area. These potential impacts will be
assessed in more detail in the Impact Assessment Phase of the EIA.
7.1
Impact Assessment Phase Tasks
The following tasks are required to be undertaken during the EIA process:
•
•
•
•
•
•
•
•
•
•
Appoint specialists to undertake the specialist investigations and confirm the
scope of work required to fulfil the TOR
Review of the specialist reports and amendment where necessary
Discuss the specialist report results and conclusions with the DEAT, DAEA,
EKZNW and the DOT
Incorporate the assessments in the Draft EIA Report (DEIR)
Distribute the DEIR to I&APs and authorities for review
Convene a public open day and public meeting
Collate and address any comments/concerns documented by I&APs
Incorporate issues and responses into the Final EIA Report (FEIR)
Submit the FEIR to the DEAT for consideration
Inform I&APs of the submission of the FEIR to the DEAT and make copies
available for review
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7.2
Competent Authority Consultation
The Competent Authority (DEAT) will be consulted at the following key stages:
•
•
•
•
7.3
A meeting at the initiation of the Impact Assessment Phase to discuss
possible timeframes and to clarify any queries or concerns regarding the EIA
process
A consultation meeting will be held with DEAT approximately two weeks after
the distribution of the DEIR to discuss any additional comments from I&APs as
well as the outcome of the specialist studies. An indication of the DEAT’s
satisfaction with the process undertaken to that stage should also be clear
after the meeting
The FEIR will be submitted to the DEAT once all outstanding issues have
been resolved.
The DEAT may convene a meeting post-submission of the FEIR should it be
deemed necessary
Environmental Impacts and Issues
A broad range of potential environmental impacts and issues were identified and
described during the Scoping process (Chapter 5). Many of these can be grouped
into ‘over-arching’ impacts which, are cumulatively significant and therefore warrant
the need for specialist investigation and assessment as part of the Impact
Assessment Phase of the project. The consolidated significant issues and their
respective specialist studies are tabulated below:
Impact
Ecological health of the Mkomazana
River
Social structure of the region
Local and regional economy
cultural heritage
Visual and aesthetic value of the
Sani Pass
Tourism in the region
7.4
Specialist Study
Riverine and Aquatic Impact Assessment
Social Impact Assessment
Economic Impact Assessment
Visual Impact Assessment
Considered in both the Social and
Economic Studies
Terms of Reference for Specialist Studies
The initial TOR for the specialist impact assessment studies to be undertaken are
provided below. If accepted by the DEAT, the TOR will define the scope of work for
the specialists for the Impact Assessment Phase. The specialists must adhere to the
following requirements as prescribed in the DEAT guideline for specialist involvement
(2002):
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•
•
•
•
•
•
Indicate exactly how much of a particular resource or community (human or
biological) will be affected, how intensely, and for what duration
Perform a sensitivity or vulnerability analysis
Identify current and future sources of risk associated with the proposed project
during construction, operation and decommissioning
Assess and evaluate potential impacts on the area of influence according to
the prescribed parameters and characteristics, including magnitude, spatial
scale, timing, duration, reversibility/irreversibility, probability, significance and
acceptability
Propose and explain mitigation measures for unavoidable impacts, and
enhancement measures, according to the prescribed format, giving detailed
prescriptions for their implementation and methods to assess their likely
success
Provide a detailed monitoring programme for mitigation measures and project
implementation activities, explaining what should be monitored, when, how,
how often and by whom.
The following specialist studies or Impact Assessments and respective TOR are
therefore proposed to address the specific issues identified:
7.4.1 Riverine and Aquatic Impact Assessment
The proposed assessment will establish the condition of the aquatic ecosystems
within the study area, which includes the longitudinal extent of the Mkomazana River,
its tributaries and wetlands affected by the Phase 2 road construction. This will be
made possible from various sources; namely:
•
•
Historical aquatic biodiversity data available for the Mkomazana River which
will be reviewed so as to determine whether there are records of important
species in the area, and
The aquatic biodiversity for the area which will be assessed following
comprehensive aquatic surveys.
- Data recorded from the aquatic surveys, as well as historical data, will be
utilised to give an indication of the current pre-impact condition prior to the
commencement of the Phase 2 road construction. The current condition of the
aquatic ecosystems reflects the base-line from which any negative impacts
generated during the construction phase can be noted. Aquatic specialist and
indicator species will be targeted during the field surveys (including fish,
amphibians, macro-invertebrates and diatoms) and suitable sampling
techniques employed to ensure successful monitoring of these biotic
components.
- In order to achieve the above, several SASS and amphibian sites will be
monitored and an extensive approach will be adopted to assess the
longitudinal stretch of the Mkhomazana River and its major tributaries of fish
and amphibian species.
- The full aquatic study will be seasonally defined to account for seasonal
variations of aquatic biodiversity which varies according to wet and dry
seasons (Need not confirmed).
- Sensitive areas that are more prone to impacts arising during road
construction will be highlighted.
- Recommendations regarding mitigation protocols will be suggested to reduce
the significance of possible impacts.
- Impact significance will be assessed using prescribed impact assessment
methodology provided by Arcus GIBB.
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7.4.2 Social Impact Assessment
The objective of the Impact Assessment Phase will be to quantify and assess the
significance of the social impacts associated with the proposed upgrade of the Sani
Pass. This will include an assessment of the issues identified during the Scoping
Phase as well as any new impacts identified during the Impact Assessment Phase
(by the social impact assessment team or in other specialist studies). The activities
undertaken during this phase will include, but are not limited to:
•
•
•
•
•
•
•
•
•
•
Document review (including relevant scoping report and other relevant
specialist study reports)
Review any changes to details and plans of proposed upgrade
Identify and describe the affected social environment in South Africa and
Lesotho (the social context)
Social base assessment and identify what current social issues occur in the
affected areas
Field reconnaissance to identify and engage stakeholders and review social
context
Determine zones of impact/influence (i.e. primary, secondary, tertiary)
Determine the overall significance (by assessing extent, duration, severity,
frequency, probability, etc.) of positive and negative impacts in South Africa
and Lesotho, using qualitative and quantitative social techniques
Assess cumulative impacts
Identify mitigation options for social impacts and re-assess significance of
impacts if mitigation is undertaken
Assess alternatives
Impacts that will be included in the assessment, but not limited to, will include:
•
•
•
•
•
•
•
•
Road users (commercial and private)
Change in tourism experience and associated operations
Human movement and trade patters (not involving economic assessment)
Safety and security
Sports and recreation activities
Employment and associated social benefits
Capacity and delivery of services in the local area
Changes to the sense of place in Underberg and the surrounds
7.4.3 Economic Impact Assessment
The Economic Impact Assessment will consider the dynamics of the economy of the
region and anticipate how and what the change to the economy will be if the Road is
upgraded, particularly with respect to tourism. Numerous concerns noting the demise
of the tourism industry, particularly the 4x4 tours industry have been raised while
other considerations have identified possible alternative tourism opportunities. Both
need to be assessed and weighted through an Economics Study by undertaking the
following tasks:
•
•
•
•
•
Undertake field reconnaissance and interviews
Refine the economic base assessment
Undertake a direct construction period employment & income assessment
Undertake a direct sustainable (annual) employment & income assessment
Undertake an indirect impacts assessment considering:
- logistics and opportunity cost savings
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-
taxi services
tourism market niches and marketability
property development impacts
Others (based on Scoping Phase)
Associated business turnover
Business employment and personal income
7.4.4 Visual Impact Assessment
The purpose of the Visual Impact Assessment (VIA) is to determine the impact of the
proposed development on the visual and aesthetic character of the area. The
rationale for this study is that the construction of the road upgrade may fundamentally
alter the landscape character and sense of place of the local environment. The
primary objective of this specialist study is therefore to identify the potential impact of
the proposed development on the character and sense of place of the area. This
specialist study will have the following objectives:
•
•
•
•
•
•
•
Describe the visual character of the site by evaluating components such as
topography, road features and landscape character. This will record the Status
Quo of the visual environment
Identify elements of particular visual quality that could be affected by the
proposed project
Describe and evaluate the visual impacts of the individual components of the
proposed project from identified critical areas and view fields. This assessment
should assess impacts according to the criteria and terminology as indicated
by the Consultant
Recommend mitigation measures to reduce the potential visual impacts
generated by the components of the proposed project for inclusion into the
EMP and the engineering design
Determine the extent of the visibility of the project from surrounding areas
Propose relevant aspects to be included in a visual monitoring programme
Identify requirements for further investigation if these fall outside the current
scope of the project.
7.4.5 Heritage Impact Assessment
The HIA will identify and describe (in terms of their conservation and / or preservation
importance) sites of cultural and archaeological importance that may be affected by
the proposed Sani Pass Upgrade project and will include the identification of
gravesites, historical sites, rock art sites, etc. The following methodology will be used:
•
•
•
Describe affected natural and cultural heritage environment and determine the
status quo
Describe the existing natural and cultural heritage landscapes and
environment and the tangible and intangible heritage resources most likely to
be impacted on. These will be documented in different categories of
significance.
Indicate how physical cultural properties or living heritage resources will be
affected:
- Typical impacts on physical cultural properties protected under the AMAFA Act
(Act No. 10 of 1997) and the NHRA (Act No. 25 of 1999) that could be
expected from the road upgrade development will be listed as well as the
expected impact on contemporary living heritage on the proposed
development route.
- Impacts will be quantified based on duration, frequency and mitigation levels
and a full description of predicted impacts (direct and indirect) will be provided.
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Gaps in baseline data will be highlighted and discussed.
An indication of the confidence levels will be given.
The best available data sources will be used to predict the impacts, and
extensive use will be made of local knowledge.
Assessment of impacts:
- Identify and describe management measures.
- The potential impact on the physical and intangible cultural properties will be
assessed and evaluated according to the magnitude, spatial scale, timing,
duration, reversibility, probability and significance taking into consideration the
resources' significance threshold as defined in the AMAFA Act (Act No. 10 of
1997) and the NHRA (Act No. 25 of 1999) and SAHRA/AMAFA Regulations.
Identify and describe impacts to archaeological and cultural resources that
may be present on the proposed project site.
Propose and explain mitigation measures:
- Practical mitigation measures will be recommended and discussed. These
evolve around total protection of Grade 1 to 3 Heritage Resources; salvage/
rescue; relocation; or preserve by record before destruction permit is issued by
SAHRA.
- Describe the importance or significance of these sites and whether these sites
need to be conserved, protected or relocated.
- Describe the procedures for mitigation or relocation of sites and provide an
indication of time required for these management measures to be
implemented.
Summarise residual impacts after mitigation:
- An impact summary will be provided, discussing expected impacts before and
after mitigation.
- Indicate a monitoring programme:
- If a need for a monitoring programme is evident, it will be highlighted and a
programme proposed.
- Monitoring may be a critical element of mitigating for archaeological and
palaeontological resources that may be encountered during development.
- Should a Phase 2 HIA study be required, such a plan will be presented
and management recommendation made to be incorporated in the project
EMP.
-
•
•
•
•
7.5
Methodology for Impact Significance Scoring
The significance (quantification) of potential environmental impacts identified during
scoping and identified during the specialist investigations will be determined using a
ranking scale, based on the following (terminology has been taken from the Guideline
Documentation on EIA Regulations, of the Department of Environmental Affairs and
Tourism, April 1998):
•
Occurrence
- Probability of occurrence (how likely is it that the impact may occur?)
- Duration of occurrence (how long may it last?)
•
Severity
- Magnitude (severity) of impact (will the impact be of high, moderate or low
severity?)
- Scale/extent of impact (will the impact affect the national, regional or local
environment, or only that of the site?)
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Each of these factors has been assessed for each potential impact using the following
ranking scales:
Probability
Duration
1 - very improbable (probably will not
happen
2 - improbable (some possibility, but low
likelihood)
3 - probable (distinct possibility)
4 - highly probable (most likely)
5 - definite (impact will occur regardless of
any prevention measures)
1 - of a very short duration (0–1 years)
2 - of a short duration (2-5 years)
3 - medium-term (5–15 years)
4 - long term (> 15 years)
5 - permanent
Extent
Magnitude
1 - limited to the site
2 - limited to the local area
3 - limited to the region
4 - will be national
5 - will be international
0 - small and will have no effect on the
environment
2 - minor and will not result in an impact on
processes
4 - low and will cause a slight impact on
processes
6 - moderate and will result in processes
continuing but in a modified way
8 - high (processes are altered to the extent that
they temporarily cease)
10 - very high and results in complete
destruction of patterns and permanent
cessation of processes
The environmental significance of each potential impact will then be assessed using
the following formula:
Significance Points (SP) = (Magnitude + Duration + Extent) x Probability
The maximum value is 100 Significance Points (SP). Potential environmental impacts
were rated as high, moderate or low significance on the following basis:
< 30 significance points = LOW environmental significance.
31- 60 significance points = MODERATE environmental significance
> 60 significance points = HIGH environmental significance
7.6
Arcus GIBB will prepare a draft EMP which is required as part of the EIA submission.
The purpose of the EMP is to control the impacts of construction and operational
activities. The effective implementation of an EMP will ensure that the required works
are conducted in an environmentally sound manner and that the potential negative
impacts of construction and operational activities are minimised and/or prevented.
The draft EMP document details the responsibilities and authority of the various
parties involved in the project and contains Environmental Specifications to which the
Contractor and Operator are required to adhere, throughout the duration of the
construction and operational phases. The draft EMP will cover impacts that have
been identified in the EIA Process and which could potentially arise during the
construction and/or operation of the road. The EMP will cover the following aspects:
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•
•
•
•
•
•
•
7.7
Project background information
Identification/listing of project and operational activities
Implementation and operational instructions
Roles and responsibilities of parties with regard to environmental management
Environmental training and awareness material for construction staff
Environmental specifications e.g. protection of biodiversity and sensitive
environments, rehabilitation, public safety and perceptions, traffic control,
material and waste management, litter, containment and disposal of
hazardous substances (e.g. paints, waste oils) etc.
Measurement of compliance with the EMP.
Public Involvement
The PPP for the Impact Assessment Phase of the Project will involve the following
tasks:
7.7.1 Announcement of the Availability of the Draft EIR and Draft EMP
At this point, the specialist studies would have been completed and the Draft EIR and
Draft EMP would be ready for public review. A letter will be circulated to all registered
I&APs, informing them of progress made with the study and the availability of the
Draft EIR and Draft EMP for comment. The DEIR will be distributed to the same
locations as the DSR was distributed during the Scoping Phase.
7.7.2 Public Review of Draft EIR and Draft EMP
The EIA Guidelines specify that stakeholders must have the opportunity to verify that
their issues have been captured and assessed before the EIA Report will be
approved by the competent authority (DEAT). The DEIR provides this opportunity and
will be written in a way which makes it accessible to stakeholders in terms of
language level and general coherence.
As part of the process to review the Draft EIR and Draft EMP, stakeholder workshops
with an open day and Public Meeting, identical to that held during the Scoping Phase,
will be arranged to afford the public the opportunity to obtain first-hand information
from the project team members and also to discuss their issues and concerns.
Contributions at this meeting will be considered in the Final EIR.
7.7.3 Announcement the Availability of the Final EIR and Draft EMP
After comments from I&APs have been incorporated into the Final EIR, all
stakeholders on the database will receive a letter informing them that the Final EIR
and Draft EMP have been submitted to the DEAT for consideration. Electronic copies
of the FEIR will be available should the I&APs wish to review the documents
submitted to the DEAT. The I&APs will be informed that should they wish to submit
comments on the FEIR, these must be submitted directly to the DEAT and copied to
the EAP.
7.7.4 Announcement of Authorities’ Decision
Based on the contributions by the stakeholders, the decision of the authorities may be
advertised through the following methods:
•
•
Letters to individuals and organisations on the database
Advert in local or regional newspapers.
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8
CONCLUSION AND WAY FORWARD
8.1
Conclusion
The DOT proposes to continue with Phase 2 of the upgrading of the existing Sani
Pass Road (P318). The proposed Phase 2 upgrade entails a complete re-grading and
resurfacing of the Sani Pass from a gravel to a hardened surface, all-weather road.
The upgrade will include road widening, re-alignment of sections, new bridges,
stormwater control and attenuation systems, bank and slope stabilisation and road
servitude rehabilitation.
The project engineers are in the process of designing the upgraded road. Of the road
design alternatives available, the engineers have selected Alternative 5 as the
preferred road option. This option will include improved geometrics, upgraded
drainage, constructed bridges and retaining walls, hard surfaced from km 14 to km
33. Of the pavement alternatives considered, the engineers have recommended that
granular base and foam bitumen base pavement structures be further investigated
during the preliminary design process for possible use on the lower section (km 14 –
25) and CRCP on the upper section (km 25 – km 33).
The Draft Scoping Report identifies and describes the environmental impacts and
issues associated with the Phase 1 road upgrade. Through technical scoping and the
PPP a range of positive and negative impacts and issues were identified. Of these,
broader categories of ecological, social, economic, tourism, cultural heritage and
aesthetic have been recognised as requiring further investigation before an accurate
assessment of both the broader scale and more specific impacts can be undertaken.
Similarly, identification and assessment of cumulative impacts can only take place
once the potential impacts are more thoroughly understood.
In terms of the EIA process, Arcus GIBB is satisfied that the legal requirements have
been met and that there has been appropriate consultation regarding the proposed
project. I&APs have been afforded the opportunity be involved in the process and
voice their concerns and issues both at meetings and in written response to
documentation distributed about the project. I&APs are given opportunity to review
the DSR to ensure their issues shave been accurately captured and submit
comments for inclusion in the Final Scoping Report.
8.2
Way Forward
Comments on the DSR will be recorded in the ICR which will be amended as
necessary, and where appropriate, changes will be incorporated into the FSR before
it is submitted to the DEAT for review. The DSR includes the PoS for EIA will be
submitted to the DEAT for review. Whilst the specialist studies are already underway,
upon receipt of comment from the DEAT regarding the FSR, the TOR for these
studies will be amended should it be required. Following completion of the specialist
studies, a DEIR will be compiled and will follow a similar PPP as that undertaken for
the Scoping Phase whereby opportunities for engagement will be provided through
stakeholder meetings and dissemination of project information. I&APs will again be
afforded the opportunity to review the DEIR prior to submission to the DEAT for
assessment.
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9
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Piper 2008. The ornithological importance of the Sani Pass 1/50,000 grid-cell 2929CB
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86
Rev 0 / Dec 2008
DOCUMENT CONTROL SHEET
(FORM IP180/B)
CLIENT
:
Department of Transport
PROJECT NAME
:
PROJECT No. :
Sani Pass Upgrade EIA
J27344
Environmental Impact Assessment for the Proposed Upgrade of the Sani
Pass Road (P318): Phase 2 Scoping Report
TITLE OF DOCUMENT :
ELECTRONIC
LOCATION
P:\J27344 - DOT Sani Pass Upgrade\Phase A - Scoping\REPORTS\Draft Scoping
Report\J27344-Sani Pass Draft Scoping Report.doc
:
Approved By
ORIGINAL
DATE
NAME
Reviewed By
Prepared By
NAME
NAME
R. Stow
R. Stow
T. Henstra
SIGNATURE
SIGNATURE
SIGNATURE
01/12/2008
Prepared by
Prepared By
Prepared By
ORIGINAL
NAME
NAME
NAME
DATE
SIGNATURE
SIGNATURE
SIGNATURE
Approved By
Reviewed By
Prepared By
REVISION
NAME
NAME
NAME
DATE
SIGNATURE
SIGNATURE
SIGNATURE
Approved By
Reviewed By
Prepared By
REVISION
NAME
NAME
NAME
DATE
SIGNATURE
SIGNATURE
SIGNATURE
This report, and information or advice, which it contains, is provided by Arcus GIBB solely for internal use and reliance by its Client in
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the information made available to Arcus GIBB at the date of this report and on current SA standards, codes, technology and construction
practices as at the date of this report. Following final delivery of this report to the Client, Arcus GIBB will have no further obligations or duty
to advise the Client on any matters, including development affecting the information or advice provided in this report. This report has been
prepared by Arcus GIBB in their professional capacity as Consulting Engineers. The contents of the report do not, in any way, purport to
include any manner of legal advice or opinion. This report is prepared in accordance with the terms and conditions of the Arcus GIBB
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REVIEW STATEMENT
(FORM IP180A)
Applicable for Proposals, Technical Reports, Progress Reports, Tender Docs, Tender Adjudication Reports, etc –
NOT FOR DESIGN REVIEW
Project / Proposal No. J27344...............................
Project / Proposal Name:
Sani Pass Upgrade EIA
1. Preparer to enter the details of the project and document to which this form applies, and to sign and date the form. (*PL to
enter source details where document was prepared externally e.g. sub/co-consultants.)
Preparer / (Source*):
Document Title
Document Purpose
R Stow .....................................................
Date Required:
Environmental Basic Assessment Proposal For The
Proposed eThekwini Freeway Management System
01/12/2008 .................................................
Document No / Version
0
2. Use the following checklist as guidance to assist in a systematic appraisal of the document. (V1, V2, V3 denotes the versions
reviewed – mark with a [if correct] or X [if incorrect]).
TECHNICAL REVIEW
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references (Regulations, Codes,
Standards etc.).
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Adequacy of argument or analysis.
Appropriateness of recommendations.
Health, Safety and Environmental
impact.
Financial, multiplier.
Contractual, Commercial, Risk.
EDITORIAL REVIEW
Project title, number and Workcode.
Table of Contents, Pagination.
Appendices, Cross-references.
Document number and version
identifier.
Arcus GIBB report template and front
cover
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4. Reviewer please sign and date the statement when satisfied with the quality of the document.
I/We have reviewed this document against the requirements of the task specification. My/Our review comments and
reservations have been resolved to my/our satisfaction. This document is presentable and technically fit for delivery. (delete as
appropriate)
Reviewer
R. Stow .....................................................................................................Date: 20/11/2008............................................................
Comments : ..........................................................................................................................................................................................................

J27344-Sani Pass Draft Scoping Report

Transcription

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