Annex C. DEA Pre-Application Meeting Records

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1 Annex C DEA Pre-Application Meeting Records

2

3 IOX Submarine Cable System Environmental Impact Assessment Pre-Application Meeting South Africa Department of Environmental Affairs 30 May 2018 Insert then choose Picture select your picture. Right click your picture and Send to back.

4 Contents Introduction Meeting Objectives Project Overview Environmental Impact Assessment Process Questions and Discussion

5 Introduction IOX is a Mauritius-based ICT company formed to develop a new telecommunication cable system which will connect India and Africa and provide high speed and low latency network access to enhance businesses in these geographies and across industries. IOX proposes to build a submarine cable from India to South Africa via Mauritius and Rodrigues Island IOX intends to install the cable by May 2019 ERM has been appointed as the Independent Environmental Assessment Practitioner 3

6 Proposed Cable Route 4

7 Project Area of Influence Project Area of Influence (AoI) includes: Republic of South African Economic Zone Territorial Waters Beach East London IDZ (decoupled from the EIA) Competent Authority in this instance is the National DEA Section 24(C) of the Act defines the competent decision-making authority which is normally the provincial environmental department. However, in cases where the project footprint transverses international boundaries, the National DEA becomes the competent authority

8 Meeting Objectives To provide an overview of the Project ie, the proposed installation of the IOX Submarine Cable System, near the East London Industrial Development Zone To confirm the process for the Environmental Impact Assessment 6

9 Project Overview Copyright 2017 by ERM Worldwide Group Limited and/or its affiliates ( ERM ). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM.

10 Project Background and Motivation The project will involve the marine installation of approximately 24km marine fibre optic cable inside the EEZ and Territorial waters with a coastal landing in East London IDZ The proposed landing site in South Africa is located near the East London IDZ in the Eastern Cape The project will enable improved communication capacity and internet services The installation of the IOX Cable will be parallel to the SAFE system, as the SAFE cable has reached the end of its lifespan 8

11 Project Components The project components include: Marine fibre optic cable Beach Man Hole (BMH) (4m x 2m x 3m) (Inside IDZ) Terrestrial fibre optic cable (inside IDZ); and Cable Landing Station (CLS) (inside IDZ) 9

12 Cable Landing Location in South Africa 10

13 Site Alternatives Considered Five site alternatives were considered: Option 1 (selected): Sandy cove very close to the EL-IDZ Option 2: Cove close to the Cove Rock private residential development Option 3: Property located between Buffalo River, R72 road and the coast Option 4: Close to the Hood Point deep sea outfall sewer pipe Option 5: Within the jurisdiction area of the Buffalo River port 11

14 12

15 Technical Alternatives Considered Two options for installation of the cable at the beach are being considered: Horizontal Directional Drilling (HDD) The development of the landing of a marine telecommunications cable near East London IDZ, entails horizontal directional drilling from the IDZ to a water depth of 10 to 15 m. Trenching The development of the landing of a marine telecommunications cable in the East London IDZ, entails digging of a trench down the beach into the intertidal zone Selection of the preferred option will be made based on results of route survey

16 Potential Impacts Dust and noise generation from construction activity during installation Disturbance of the seabed and to marine ecology during cable installation Potential to encounter marine heritage resources during installation Temporary disruption to fishing activities during installation; possible Positive direct impact on employment (construction related); further indirect positive impacts during operation from access to improved connectivity 14

17 EIA Process Copyright 2017 by ERM Worldwide Group Limited and/or its affiliates ( ERM ). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM.

18 Listed Activities Trenching Horizontal Directional Drilling GN R 327 Activity 15, 17 and 19A Activity 15 GN R 325 Activity 14 Activity 6 and 14 GN R 324 Activity 12 Full Scoping and EIA Processes in terms of: National Environmental Management Act, 1998, (Act No. 107 of 1998), as amended (NEMA) EIA Regulations Listing Notice 1 (GNR R327), Notice 2 (GNR 325) and Notice 3 (GNR 324)

19 We are here 17

20 Public Participation Process during Scoping Public Participation Process to be undertaken during Scoping Phase includes: Disclosure of the Draft Scoping Report for comment for 30 days Public notice in three newspapers Notification at the site Hardcopies placed at the Library and Municipal Office Written notification to identified key stakeholders Placement of the draft Scoping Report on the project website Direct engagements (meetings) with: Local government authorities Resident associations Fisheries representatives 18

21 Public Participation Process during EIA Public Participation Process to be undertaken during EIA Phase includes: Disclosure of the draft EIA report for comment for 30 days Hardcopies placed at the Library and Municipal Office Written notification to registered stakeholders Placement of the draft EIA Report on the project website 19

22 Specialist Studies The EIA will be informed by specialists studies conducted by subject matter experts: Fisheries Marine Heritage Marine Ecology 20 Source: ERM Source: Shutterstock Source: ERM

23 Questions and Discussion Overall EIA approach De-coupling of the EIA and battery limit Alternatives Responsible authority for sea bed rights Specialist studies Public Participation Process Commenting authorities Other permitting requirements 21

24 Contact IOX Cable Ltd (Project Proponent) Mr Chris Albert Tel: Postal address: Pope Hennessy Street, 6th Floor Hennessy Court, Port Louis, Mauritius ERM (EIA Consultant) Ms Vicky Stevens Tel: Postal address: Postnet Suite 90, Private Bag X12, Tokai,

25 Copyright 2017 by ERM Worldwide Group Limited and/or its affiliates ( ERM ). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM.

26 Additional Resources For HDD For general cable laying

27 25

28 Environmental Resources Management 1 st Floor Great Westerford 240 Main Road, Rondebosch 7700, Cape Town, South Africa Subject/Ref Environmental Impact Assessment Pre-Application Meeting with respect to the Indian Ocean XChange (IOX) Subsea Cable System Venue Environment House 473 Steve Biko Road Arcadia Pretoria Date of Meeting 30 May 2018 Postnet Suite 90 Private Bag X12 Tokai, 7966 Cape Town, South Africa Tel: Fax: Present Zama Langa (ZA) DEA Case Officer Vincent Chauke (VC) DEA Environmental Officer Nyiko Nkosi (NN) DEA Environmental Officer Danie Smit (DS) DEA Director Chulumanco Myataza DEA Environmental Officer (CM) Chris Albert (CA) IOX Head of Facilities Henry Camp (HC) Partner in Charge Vicky Stevens (VS) Environmental Assessment Practitioner Distribution As above Date 6 June 2018 The following are the minutes of a meeting held with the South Africa Department of Environmental Affairs with respect to the IOX Subsea Cable System, a proposed new telecommunication cable system. The meeting was held to present and discuss the proposed development with the DEA prior to the submission of a formal application for Environmental Authorisation. Introductions Ms Z Langa welcomed everyone and introductions were made by all attendees The National Department of Environmental Affairs will be the Competent Authority for the Environmental Authorisation in South Africa The project is being developed by IOX Cable Ltd., a Mauritius-based company formed to develop the project. The cable will run from India to Africa and provide high speed, low latency network access to enhance businesses in these geographies and across industries. A new IOX Group company has been registered in South Africa and is called Indian Ocean Xchange SA (Pty) Ltd. This company will be the Proponent for the purposes of the Environmental Authorisation in South Africa. Environmental Resource Management South Africa has been appointed by IOX as the Independent Environmental Assessment Practitioner. Meeting Objectives To provide an overview of the Project To confirm the process for the Environmental Impact Assessment The presentation is included as an Annex to these minutes.

29 Environmental Resources Management Project Overview ERM provided an overview of the development. The Project in terms of authorisation is the installation and operation of a subsea cable system. The system components comprise primarily the fibre optic cable. The cable will run along the seabed entering South Africa s Exclusive Economic Zone (about 24 km offshore) to a landing point near the City of East London. The subsea cable will be buried in the seabed at water depths <900m. At depths >900m, the subsea cable will rest on the seabed. The cable will terminate at a purpose built facility (referred to as a Beach Manhole (BMH)) within the East London Industrial Development Zone (IDZ). CA provided an explanation to the background of the project and how its fits into the current telecommunications network. The system will be open access (as opposed to being owned and operated by a closed telecommunication operator consortium). The project is in part providing additional telecommunications capacity to supplement the existing SAFE system which is close to design life operating capacity and won t be able to meet future market growth demands. ERM presented the analysis done to identify the preferred landing site. Five locations were evaluated and the preferred option was determined to be the East London IDZ location on the basis of environmental conditions and avoiding areas of activity that could pose risk to the cable. The IDZ location also has existing national telecommunications infrastructure and is already designated as an industrial zone. ERM and IOX presented the two options under consideration for the cable shore crossing: Horizontal Directional Drilling (HDD) or trenching. Both techniques are still under evaluation. Issues being considered include cost and environmental impacts. DEA advised that the preferred alternative be finalized before the submission of the draft EIA report. DEA also advised that the applications for all required permits are in place prior to submission of the draft EIA report. Environmental Impact Assessment Process ERM explained that in terms of the South Africa National Environmental Management Act (NEMA) the proposed Project triggers Listed Activity 14 in Government Notice GNR 325 Listing Notice 2: The development and related operation of (iii) any other structure or infrastructure on, below or along the sea bed. GNR 325 activities are those that require a comprehensive assessment (Scoping and an EIA). ERM will confirm whether any other listed activities are triggered based on the preferred method for shore crossing. DEA suggested that the listed activities are not to be quoted verbatim and only relevant wording have to be included. In terms of process, ERM are proposing to submit the Scoping Report at the same time as the Application for Environmental Authorisation. At the same time, the Scoping Report will be disclosed to the public for 30 days to allow for comment. Public notice will be made in three newspapers. Direct notification will be made to potentially interested and affected parties based on a stakeholder identification process. At the same time direct engagements (meetings) will be held with representatives of local government, resident associations, and fishing groups. The DEA agreed in general with this approach. Environmental Resources Management 2 IOX Pre-Application meeting

30 Environmental Resources Management The DEA recommended that stakeholder meetings are used to educate and share information with stakeholders to minimize the risk of appeal later on in the process. The DEA confirmed that the battery limits of the project are where the cable enters South African territorial waters (EEZ) to the where the cable enters the boundary of the East London IDZ. Infrastructure within the IDZ is covered by the IDZ s existing Environmental Authorisation. The DEA advised that the Scoping Report be submitted to South Africa government departments directly because certain departments are restricted from downloading documents from public sources. Installation of the subsea cable is planned to commence in May As such, the South Africa EIA Process needs to commence immediately to have the Environmental Authorisation in place. ERM expects to submit the Application and Scoping Report by 5 July Specialist Studies ERM are proposing to commission specialist studies for: fisheries and fishing; marine and coastal ecology and marine heritage. DEA advised that if the trenching option was chosen as the preferred option for the shore crossing, a terrestrial fauna and flora may also be required depending on the environmental conditions of the specific location. DEA advised that specialist studies be done independently. General Discussion DEA confirmed that Oceans and Coasts Agency should be consulted with regards to confirming requirements for seabed rights and for requirements for Coastal Waters Discharge Permit (which may be required for HDD). DEA suggested the following government stakeholders as potential interested and affected parties: Department of Agriculture, Forestry and Fisheries Department of Environmental Affairs: Oceans and Coasts Agency South African Maritime Safety Authority National Ports Authority Buffalo City Metropolitan Municipality IDZ Oil and Gas Exploration Right Holders (for areas where the cable will be located) South African Heritage Resources Agency. DEA expressed willingness to meet again as required to consult on the EIA process. DEA suggested specifically that the Proponent meet again prior to submission of the EIA report to discuss and advise on pending issues. Environmental Resources Management 3 IOX Pre-Application meeting

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