20 April Ms Bongi Shinga Public Participation Team ACER (Africa) Environmental Consultants Via

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1 20 April 2015 Ms Bongi Shinga Public Participation Team ACER (Africa) Environmental Consultants Via Re: Environmental Impact Assessment: National Road 3, Keeversfontein to Warden (De Beers Pass Section): BirdLife South Africa comments on the Summary of the Draft Environmental Impact Assessment Report for Public Comment DEA ref. no. 12/12/20/1992 The proposed De Beers Pass Route (DBPR) splits from the existing N3 below Van Reenen, bearing in close proximity to the existing De Beers pass and joins the existing N3 again near Warden (de Frey & Niemand 2011). The two alternatives to the DBPR, namely Alternative A and C, are both closely aligned to the existing N3. The proposed DBPR will however have severe impacts in terms of habitat loss, fragmentation and degradation. Additionally, the proposed DBPR will have significant impacts on a wide range of threatened avian species, not only in terms of habitat loss and alteration, but also through displacement and mortalities associated with road construction and operation (Allan 2014, Mentis 2013, de Frey & Niemand 2011). The impact of the proposed DBPR, with or without deviations, is emphasized in the subsequent loss of ecosystem services being valued between R55.4 million and R92.2 million per year following the second year of construction. This is largely due to the severe loss and fragmentation of between 3-4 km 2 of wetland habitat, as well as significant sections of Endangered Eastern Free State Sandy Grassland and Vulnerable Northern KwaZulu-Natal Moist Grassland (Mentis 2014, Mucina & Rutherford 2006). Furthermore, the Terrestrial Ecology (de Frey & Niemand 2011), Wetland (Mentis 2014) and Avifauna (Allan 2013) specialist reports for the respective Environmental Impact Assessment all conclude that the DBPR is not supported due to the severity of environmental impacts associated with it. Additionally, impacts of the DBPR on certain significant habitat types and key conservation areas, including two Important Bird and Biodiversity Areas (IBAs), as well as 38 avian, 25 mammalian, 3 amphibian, 11 reptile and 5 invertebrate Red Data species, were listed as severe, unsustainable and fatally flawed (Allan 2014, Mentis 2013, de Frey & Niemand 2011). The proposed DBPR deviations, particularly Deviations 2, 3, 4 and Lincoln Pan, reduce the associated impacts of the proposed DBPR along these specific sections linked to each respective deviation. Deviation 4 (Gorge) is of particular significance as it obviates the need for both Deviations 1 (Klip River) and 2 (Wilge), thereby not only reducing wetland habitat lost along those respective sections, but also securing the Braamhoek Catchment and Braamhoek gorge, which currently hosts local breeding populations of at least six threatened avian species.

2 Significantly, a section of the proposed DBPR directly traverses the Alex Pan IBA (IBA_SA SA042). The Important Bird and Biodiversity Areas (IBA) Programme is a BirdLife International initiative of global importance, which aims to conserve a network of sites that are critical for the long-term survival of bird species that are: 1. Globally threatened 2. Are range-restricted 3. Are restricted to one biome and/or vegetation type 4. An area that supports a significant population of waterbirds (>20 000) and/or supports a significant proportion of the global population of a given species. The Alex Pan IBA is classified as a Global IBA and is known to host at least ten Red Data species, namely the: - Critically Endangered Wattled Crane Bugeranus carunculatus, - Endangered Grey Crowned Crane Balearica regulorum, - Endangered Botha s Lark Spizocorys fringillaris, - Endangered Cape Vulture Gyps coprotheres, - Vulnerable Denham s Bustard Neotis denhami, - Vulnerable Southern Bald Ibis Geronticus calvus, - Vulnerable Secretarybird Sagittarius serpentarius, - Vulnerable White-bellied Korhaan Eupodotis senegalensis, - Abdim s Stork Ciconia abdimii and - Blue Crane Anthropoides paradiseus. The proposed DBPR will undoubtedly compromise the conservation integrity of the globally classified Alex Pan IBA and threaten the local conservation of numerous Red Data and endemic avian species. Moreover, although Deviation 3 (Alex Pan) attempts to mitigate the associated impacts by skirting the border of the Alex Pan IBA, instead of traversing directly through it, the associated impacts will be reduced but remain significant. Mentis 2014 confirms that although Deviation 3 attempts to avoid Alex Pan IBA, it does not reduce wetland intersection and fragmentation in the area. Additionally, Allan 2013 and Mentis 2014 further confirm that Deviation 3 will still pose a significant threat to a number of globally threatened avian species that are known to utilise and occur on properties adjacent to the IBA as well, including Greywell 1820 and Somersvlakte Species of particular concern on these adjacent properties through which Deviation 3 will pass include a substantial presence of: - globally Blue Korhaan Eupodotis caerulescens, - Denham s Bustard Neotis denhami, - Maccoa Duck Oxyura maccoa and - Vulnerable Secretarybird Sagittarius serpentarius (Allan 2014). Of additional significance is the presence of South Africa s rarest wetland bird, namely the Critically Endangered White-winged Flufftail Sarothrura ayresi.

3 The presence of this species during the summer season has been confirmed in wetland habitat within the globally classified Bedford-Chatsworth IBA (IBA_SA SA043) that falls within Ingula Nature Reserve. The preferred habitat of this species, namely dense sedgebased wetland averaging 1m tall with adjacent grassland, occurs within the proposed DBPR area. The globally classified Murphy s Rust (SA_IBA SA045) and Bedford-Chatsworth IBAs are two significant examples thereof. Some of the greatest threats facing this species in South Africa include habitat loss, fragmentation and degradation through wetland damming, drainage, cultivation and development, as well as too frequent or intense burning and grazing (BirdLife International Africa Partnership Secretariat 2008). Significantly, the proposed DBPR will lead to the severe loss of wetland habitat, that being 10 times more than Alternative A, whilst additionally causing the fragmentation of habitat on a local and regional scale throughout the proposed route (Mentis 2013, de Frey & Niemand 2011). Subsequently, the DBPR poses a significant risk to the ongoing conservation of one of South Africa s rarest and most Critically Endangered wetland bird species. Ultimately, although the DBPR deviations provide a reduction in associated impacts, the overall impact of the DBPR is still severe and includes the loss of approximately 317 ha of wetland habitat, of which ha (34.4%) is completely untransformed pristine wetland habitat. Additional impacts that cannot be avoided include the loss and fragmentation of threatened high-altitude grasslands, as well as the resultant impact on numerous endemic and globally threatened avian species (Allan 2014, Mentis 2013, de Frey & Niemand 2011). Furthermore, the impact of displacement and collision mortalities during- and postconstruction are also unavoidable should the DBPR proceed, which could impact any number of the 38 Red Data Species listed for the area. The impacts of displacement and collisions are not only applicable to the direct area of construction, but can include local breeding pairs of ecologically significant: - Critically Endangered Bearded Vulture Gypaetus barbatus on Nelsonskop, - Endangered Martial Eagle Polemaetus bellicosus in Ingula Nature Reserve, - Vulnerable Verreaux s Eagle Aquila verreauxii on Tandjiesberg and - Vulnerable Lanner Falcon Falco biarmicus. Additionally, significant local roost sites hosting Endangered Cape Vulture Gyps coprotheres and Red-footed Falcon Falco vespertinus could be affected. It is for these reasons above that BirdLife South Africa opposes the DBPR, with or without deviations, based on the severity of the resultant environmental impacts being unsustainable and irreplaceable. However, if the DBPR is to proceed, it is of utmost importance that all deviations (Deviations 1, 2, 3, 4 and Lincoln Pan) be supported in order to salvage some form of conservation integrity for all affected conservation sites, habitats and/or threatened species. Furthermore and of foremost significance is that the DBPR deviations in themselves will not substitute ecological and/or habitat integrity in-light of the severity of the DBPR construction and associated habitat loss, degradation and fragmentation.

4 Specific comments to phrases not supported as included in the National Road 3 Keeversfontein to Warden (De Beers Pass Section): Summary of the Draft Environmental Impact Assessment Report for Public Comment. A. National Road 3 Keeversfontein to Warden (De Beers Pass Section): Summary of the Draft Environmental Impact Assessment Report for Public Comment (Pg. 26) It should be noted that SANRAL prefer that the DBPR with the Deviation 2A be authorised for construction 1. Whether or not deviations are utilised, the De Beers Pass Route (DBPR) will still lead to the loss and local fragmentation of at least three threatened grassland vegetation types, namely: a. Eastern Free State Sandy Grassland Classified as Endangered and only 1.8% is currently protected (Mucina and Rutherford 2006). b. Northern KwaZulu-Natal Moist Grassland Classified as Vulnerable and only approximately 2% is currently protected (Mucina and Rutherford 2006). c. Basotho Montane Shrubland - Classified as Vulnerable and only about 1.8% is currently protected (Mucina and Rutherford 2006). 2. Additionally, both the DBPR and DBPR with deviations (DBPR dev.) will lead to the severe loss of between 3-4 km 2 ( ha) of irreplaceable wetland habitat, when compared to the comparative loss of km 2 ( ha) of wetland habitat along Alternatives A and C. Significantly, between 34.4% (DBPR dev.) and 39.1% (DBPR) of the respective wetland habitat lost along the DBPR s will be entirely untransformed functional wetland habitat (Mentis 2014). 3. These respective vegetation and habitat types are not only significant due to their threatened status, but they support a large number of endemic and threatened species that only occur within these specialised niches. Further loss and fragmentation of these habitats will ultimately impact species and/or populations through the loss and degradation of habitat, displacement through construction and/or operational disturbance and mortalities associated with construction and operational activities (Allan 2013 & Mentis 2014). 4. A total of 38 Red Data avian species were recorded across the development footprint of all respective routes, whilst a significant 77% of the respective Red Data records are exclusively associated with the DBPR (Allan 2013). This further substantiates the relationship between these above mentioned habitat types and the specialised nature of many threatened avian species occurring in the area associated with the DBPR. Any fragmentation, habitat degradation and/or habitat loss could therefore have potentially severe impacts on local populations of threatened Red Data species. 5. Both the Avifaunal and Wetland specialist studies highlight fatal flaws in the associated environmental impact of the DBPR option, when compared to that of Alternatives A and C. Additionally, the Resource Economic Study estimated the loss in value of ecosystem services related to the DBPR to be between R55.4 million and R92.2 million per year following the second year of construction.

5 The DBPR, with or without deviations, will lead to the loss and degradation of significant quantities of irreplaceable habitat types, significant loss of ecosystem services and direct impact on avian species and populations in the short and long term. These rationales deem the DBPR environmentally unsustainable when faced with the quantified consequential impacts highlighted in respective specialist studies. B. National Road 3 Keeversfontein to Warden (De Beers Pass Section): Summary of the Draft Environmental Impact Assessment Report for Public Comment: (Pg. 18) Deviation 4 is not supported. The reasons are as follows: d) Impacts on biodiversity (plants and animal) between the DBPR and deviation 4 are not well defined or quantified. 1. The severe loss of irreplaceable wetland habitat was quantified by the wetland specialist study, namely Mentis The respective study quantified that the loss of wetland habitat would be severe along both the DBPR and DBPR with deviations, that being ha, when compared to the comparative loss of ha of wetland habitat along Alternatives A and C. Additionally, 62.1 ha (16.4%) of wetland habitat is saved through the DBPR deviation 4, when compared to the standard DBPR. Nonetheless, the quantified loss along DBPR and DBPR with deviations will be severe. 2. Additionally, based on the proposed routing of the DBPR deviation 4, it will obviate the need for both deviation 1 (Klip River) and deviation 2 (Wilge River) (Allan 2013). This would significantly reduce the DBPR impact in terms of quantity of wetland lost, as well as the compounding impact on associated wetland faunal species. 3. The standard DBPR without deviation 4 will pass through a gorge hosting breeding populations of two threatened species, namely Vulnerable Lanner Falcon Falco biarmicus and Vulnerable and endemic Southern Bald Ibis Geronticus calvus. Both species breed on the Braamhoek Waterfall Gorge, through which the tunnel for the DBPR will pass. This will undoubtedly lead to the displacement of two regionally threatened species and associated local breeding populations. 4. Significantly, the DBPR without deviation 4 passes in very close proximity to the Braamhoekspruit Catchment. The western slopes of the Braamhoekspruit catchment that are located closest to the proposed DBPR without deviation 4, are largely comprised of steep gradients which would naturally catch any runoff from the adjacent road surface. Subsequently, this poses a significant threat to the integrity of the Braamhoekspruit catchment in terms of long-term runoff and incidental spills being deposited in the catchment sediment at lower

6 altitudes/slope gradients. Although incidental spills pose the greatest immediate threat, the effects of general long-term runoff are detrimental and cannot necessarily be avoided. Factors that need to be considered include: a. Road runoff is known to contain numerous pollutants including heavy metals, polycyclic aromatic hydrocrabons (PAHs) and perfluorooctane sulphonate (PFSs) (Murakami et al. 2008). b. These pollutants are derived from a number of sources linked to road use and/or road infrastructure and maintenance, namely vehicle exhaust emissions, vehicle tyre residue, asphalt pavement residue and road paint residue. These all accumulate in road dust, before being washed off the surface during rainfall events and deposited in river, riparian and water catchment sediment (Ball et al. 1997, Krein and Schorer 2000 & Murakami et al. 2008). c. These pollutants are detrimental to both human health and aquatic ecosystems as they carcinogenic compounds that are acutely and chronically toxic (Murakami et al. 2008). d. Significantly, some of these respective pollutants, including NO3, Mn, Ni, alkaline earth metals, PFOS and FOSA, are not treated by natural soil processes and would contaminate surface water sources and possibly infiltrate and contaminate groundwater sources (Murakami et al. 2008). e. These above mentioned factors do not account for incidental large scale spills linked to vehicle accidents and/or road construction activities near the catchment, which would without question directly threaten the integrity of the Braamhoekspruit catchment. f. If the integrity of the catchment is compromised, it would threaten water supply for both human and agricultural use in the local and broader area, aquatic and adjacent terrestrial ecosystems, faunal and floral populations reliant on these respective ecosystems, the operation of the Ingula Pumped Storage Scheme located below the catchment and therefore also indirectly electricity generation from this respective plant. g. Quantified data on eighteen Red Data species have been collected and are known to opportunistically, seasonally or permanently occur and/or rely on the respective Braamhoekspruit catchment (Table 1, 2 & 3).

7 Table 1: Avian Red Data species known to occur and/or rely on the Braamhoekspruit catchment. Full Name Scientific Name Regional Red List Status Cape Vulture Gyps coprotheres Endangered (EN) Black Harrier Circus maurus Endangered (EN) African Marsh- Harrier Circus ranivorus Endangered (EN) Southern Bald Ibis Geronticus calvus Vulnerable (VU) Black-rumped Buttonquail Turnix nanus Vulnerable (VU) White-bellied Korhaan Eupodotis senegalensis Vulnerable (VU) Lanner Falcon Falco biarmicus Vulnerable (VU) Denham s Bustard Neotis denhami Vulnerable (VU) Secretarybird Sagittarius serpentarius Vulnerable (VU) Bush Blackcap Lioptilus nigricapillus Vulnerable (VU) Pallid Harrier Circus macrourus Black-bellied Bustard Lissotis melanogaster Blue Crane Anthropoides paradiseus Half-collared Kingfisher Alcedo semitorquata Table 2: Mammalian Red Data species known to occur and/or rely on the Braamhoekspruit catchment. Full Name Scientific Name Regional Red List Status Oribi Ourebia ourebi Endangered (EN) Leptailurus Serval African Marsh Rat serval Dasymys incomtus

8 Table 3: Pisces Red Data species known to occur and rely on the Braamhoekspruit catchment. Full Name Scientific Name Regional Red List Status Chubbyhead Barb Barbus anoplus Endangered (EN) C. National Road 3 Keeversfontein to Warden (De Beers Pass Section): Summary of the Draft Environmental Impact Assessment Report for Public Comment: (Pg. 18) Deviation 3 is not supported as the justification for this deviation appears to be not well substantiated. 1. As highlighted in the avian specialist report Allan 2014, the proposed DBPR without deviation 3 directly traverses through Alex Pan Important Bird and Biodiversity (IBA) Area and the subsequent impact on a host of threatened avian species known to both breed and roost in the IBA would be severe. Species of particular concern known to utilise the Alex Pan IBA include ten threatened species, namely the: - Critically Endangered Wattled Crane Bugeranus carunculatus, - Endangered Grey Crowned Crane Balearica regulorum, - Endangered Botha s Lark Spizocorys fringillaris, - Endangered Cape Vulture Gyps coprotheres, - Vulnerable Denham s Bustard Neotis denhami, - Vulnerable Southern Bald Ibis Geronticus calvus, - Vulnerable Secretarybird Sagittarius serpentarius, - Vulnerable White-bellied Korhaan Eupodotis senegalensis, - Abdim s Stork Ciconia abdimii and - Blue Crane Anthropoides paradiseus. A South African endemic species listed as globally, Blue Korhaan Eupodotis caerulescens, is also known to inhabit the Alex Pan IBA and is of conservation concern. Additionally, the habitat provided by the Alex Pan IBA is ideal for two South African threatened and endemic species, namely the Endangered Rudd s Lark Heteromirafra ruddi and Endangered Botha s Lark Spizocorys fringillaris. 2. It is important to note that although deviation 3 edges along the southern border of Alex Pan, as opposed to traversing through it as per the proposed DBPR without this deviation, this section of road is still likely to have a high impact on respective avian species inhabiting Alex Pan. As determined by the specialist study, it is not only the Alex Pan IBA property (Farm No. 1529) that supports these threatened species, but the two adjacent properties as well, namely Greywell 1820 and Somersvlakte 1178 (Allan 2013). The value of these adjacent properties for the conservation of these species locally is further substantiated in that at least seven out of the nine

9 respective Red Data species have are likely to have home ranges that would overlap into these adjacent properties (Hockey et al. 2005). Furthermore, the Vulnerable Yellow-breasted Pipit Anthus chloris has not been listed on the Alex Pan IBA property, but is known to occur on these adjacent properties. 3. Additionally, the respective Alex Pan deviation courses the specific section of DBPR road away from a section of pristine threatened grassland that is listed as Endangered and also further away from Tandjiesberg, which hosts an active breeding pair of Vulnerable Verreaux s Eagle Aquila verreauxii. It is for these reasons, that if the DBPR proceeds, it is of utmost importance that deviation 3 be included to reduce the potentially severe impacts on a large number of avian species, nine of which are Red Data species. The proposed DBPR without deviation 3 would undoubtedly severely compromise the integrity of the Alex Pan IBA. However, as mentioned even with deviation 3, the DBPR poses a significant threat to a large range of avian species and associated habitats present in the immediate area. D. National Road 3 Keeversfontein to Warden (De Beers Pass Section): Summary of the Draft Environmental Impact Assessment Report for Public Comment: (Pg. 26) It should be noted that SANRAL prefer that the DBPR with the Deviation 2A be authorised for construction for the following reasons: This is on land that is owned by SANRAL. The acquisition of land for the Deviations (Deviation 4, (the Gorge) and Deviation 3 (Alex Pan)) will be a time consuming process and can delay the start of construction of the new road, and therefore traffic congestion on the existing N3/R103 as a result of predicted traffic growth will be experienced. BirdLife South Africa strongly opposes the negation of deviations 3, 4 and/or Lincoln Pan. In accordance with the rationale provided above for both deviations 3 and 4, it is strongly recommended that these deviations be supported for the conservation of numerous significant habitat types and a large number of Red Data avian species, many of which are endemics, highly localised, sensitive and have established breeding populations in the given areas. Without these deviations the impact on both habitats and avian populations would be immense. Yours sincerely, Nicholas Theron with Simon Gear Conservation Manager (KZN) Policy & Advocacy Manager