Comments on Langefontein Wind Farm

08 December 2010

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DRAFT SCOPING REPORT: PROPOSED LANGEFONTEIN WIND ENERGY FACILITY ON A SITE EAST OF R27 WITHIN THE WEST COAST NATIONAL PARK (DEA REF 12/12/20/2031)

COMMENT:

The Draft Scoping Report to hand (e.g. Chapter 1: paragraph 1.3) conveniently conflates the need for wind- energy exploitation in South Africa with the need for this specific (LANGEFONTEIN) project. Recent wind atlas research conducted in South Africa more specifically by researchers at the University of Cape Town suggests that the conditions necessary for viable exploitation of wind –energy exist in many hitherto unremarked sites in the interior of the Cape and of the country .The national need for wind-energy exploitation cannot therefore be transposed ,as the Introduction to the Report apparently simplistically attempts to do ,to the Langefontein site that is the subject of the Draft Scoping Report . Whilst wind energy exploitation is the “right thing to do”, it is important also that it be done in the “right place”. It make little sense to compromise or further compromise the integrity of (eco) tourism and nature areas amongst others whilst alternative sites exist where the global cost-benefit of wind energy development may be superior. The EIA process needs seriously and credibly to address this issue and more specifically to address far more comprehensively the choice of site for this proposed wind energy development. More specifically the proposers need to identify credible alternative sites for comparative analysis. The basic question to be addressed is simply, Why Langefontein?

The only alternative to the proposal currently on the table in the Draft Scoping Report is the “do nothing” alternative. However, the objective treatment of even this alternative does not hold much promise if the content of Chapter 1: paragraph 2.4.6 is anything to go by. Again the energy bogey-man is invoked to summarily dismiss the no-development alternative with the simple statement that there would be a loss of energy generating potential. It is quite correctly stated that should the “do-nothing” alternative be sustained this pristine area would remain a part of the” West Coast National Park for further consolidation of vegetation types into a contiguous marine terrestrial park unit Langefontein contains relatively pristine populations of Hopefield Sandplain Fynbos and the property includes culverts that pass under the R27.This provides a natural linkage corridor for biota to cross the R 27.” The energy bogey-man argument is totally inappropriate here since this facility or others like it addressing the wind energy development needs of the country would most certainly be possible at other sites which are not taken into account. The consequences of not developing Langefontein site is disingenuously presented in the report, as a loss of wind energy generation potential for South Africa which clearly is an insupportable and heroic assertion. The other arguments presented in paragraph 2.4.6 to dismiss the no-development alternative are equally shallow and need significant reconsideration as does the entire treatment of the no-development alternative in a manner that is credible and not merely a “rite of passage” as reflected in the Draft Scoping report. For one thing the no-development option would leave the West Coast National Park view shed protection zone, the Northern part of the Park itself and portions of the biosphere buffer area associated with the core area comprising the West Coast National Park uncompromised ,not to mention the view shed of major tourist routes in the area. Claims of “job creation” for example are also misleading-job creation for whom? Due to low skills levels of local inhabitants jobs created will without significant intervention be mainly for imported workers , as experience shows ,with associated employment expectations leading in any event to nett in migration far in excess of local labor demand created by such projects ,with associated socio-economic implications for the West Coast . The factors and the West Coast capacity to deal with them need to be specifically addressed in the EIA as they stand to present a significant impact of such a higher-technology project on the fabric of local West Coast socio-economic circumstances. The job creation argument in motivation and association with such matters as the loss of coastal sectors can only be credibly applied to projects that will create employment for local coastal people. Not only the promises of jobs to be delivered by the project ,but also the profile of the skills required in relation to those available in the West Coast community (and the education levels necessary upon which to build the requisite skills) are crucial elements that need attention in the EIA phase.

KEY AREAS OF CONCERN

The following key areas of concern need to be addressed in the EIA process.

Land ownership

Although this specific piece of land were duly registered in the name of the Republic of South Africa was it subsequently proclaimed National Park in 2005.The contractual agreement between the then custodians of the land ,Department of Works and Oelsner Group lapsed in 2009 and were to the best of our knowledge not renewed. Any renewal of the contractual agreement after the 2005 proclamation was to be done by the South African National Parks. Such renewals do not exist.

Extend of development area:

The already lapsed contractual agreement only specifies the use of 400 hectares whereas the application exceeds well over 700 hectares? The contact only refer to the north eastern piece of the land and are extremely vague on the exact location of the proposed site.

Alternative site options:

The Draft Scoping report only refer to 2 development options as the one is the preferred option site and the other the No-development option. It is this organizations opinion that the No-development option are hugely inadequately persuade as it only refer to the potential loss of energy generation capacity and never elaborate on the sustainable eco-tourism potential that would be eliminated for at least the next 25 years and thereafter.

The preferred option also cause huge confusion as it refers to approximately 700 hectares whereas the contract only allows 400 hectares of the same land. There are no specific indication of where other infrastructure are to be installed such as grid links, roads and substations.

The applicant also dismally fails to produce any other alternative sites besides the preferred and no-development sites .The only other variations in the application is the various layout plans of the turbines. All these different layout plans are presented on exactly the same geographic area. Changing the design outlay does not at all or necessarily change the impact on the site and therefore does not qualify as an alternative development site alternative.

* The impacts on avifauna in the area. With structures of the height and cadastral extent of the proposed development in the proximity of the Langebaan Lagoon ,The Saldanha Bay Islands and the Berg river ,extensive work in the EIA phase needs to be conducted on the movements of the relevant bird species needs to be carried out. If the information is not available and the extent of putative impact cannot be determined to an acceptable level of certainty the precautionary principle would require that the EIA recommend against the proposed project and that environmental authorization not be granted.

*Potential impacts on the ecology. Detailed investigation of the sites needs to be carried out to determine the relative ecological sensitivities.

* The adequacy of a proposed 30 KM exclusion zone around the identified sensitive areas should be considered and needs to be reviewed and thoroughly motivated before entering the EIA phase.

*Areas of high sensitivity should themselves constitute total exclusion zones for development of any kind.

*Potential impacts on Heritage Resources:

*The proposed site lies contiguous to the West Coast National Park. It is essential that thoroughgoing palaeontological investigation be carried out in the EIA phase as this Scoping Report fails to mention any such provisions.

*Visual impacts and impacts on scenic routes are inadequately dealt with in the proposal. As elsewhere the visual impact is summarily dismissed with the simplistic argument that since an intrusion exists in the view shed from existing infrastructure there should now be a free for all. The fact is that the densification of such intrusions in the landscape in themselves contributes to the escalation in the degeneration of the sense of place.

The question is to what extent the presently proposed development with its huge structures projecting into the sky (higher than anything currently existing in the landscape) will cause further acceleration degeneration in the sense of place. This goes again to the matter of whether alternative more suitable sites exist for the establishment of a project such as this .We believe that the Draft Scoping Report is significantly deficient in that it does not adequately, if at all interrogate such alternatives . We believe that a comprehensive Visual Impact Assessment is required as part of the EIA process.

*Potential Noise Impacts

We are in agreement that a comprehensive noise impact assessment will be carried out in the EIA phase.

CONCLUSION:

The EIA process to follow for the Langefontein project proposal needs to address a number of issues consistent with the requirements of statute, all of which must be credibly reflected in the Final Scoping Report, namely

a) Question related to “NEED”

Is the land use within the timeframe of the existing approved SDF agreed to by the relevant environmental authority?

Are necessary services and appropriate infrastructure capacity available? Saldanha has a significantly dysfunctional and non-compliant local government in key areas of service provision.

b) Question related to “DESIRABILITY”

Can this operation be conducted elsewhere with more significant total benefit-cost? Here of course we prefer amongst others to the latest wind atlas research for the Western Cape?

Do location factors favor this land use at this place? This refers to the contextualization of this land use within a broader context. In other words, why should the proposed development occur on this specific site at this time and not elsewhere? –bearing in mind the fact that though a development may be feasible on a site, it may not be desirable on that site.

It already seems that there are incipient flaws that may well be fatal in areas of the ecology, views shed and proximity to air traffic areas ,to name a few.

Is the development the best practicable environmental option for this site.BPEO)

Would the approval of this application compromise the integrity of the existing Environmental Management Frameworks /priorities of the Saldanha Bay area? How will the activity or the land use associated with the activity applied for impact on sensitive natural and cultural areas (built and natural environment)?

What are the opportunity costs of development of the Langefontein site? Will the proposed activity or the land use associated with the activity applied for result in unacceptable opportunity costs related to alternative sites that most assuredly do exist?

PLANNING CONCERNS

The Draft Scoping Report as it stands still fails comprehensively in addressing a range of alternative consistent with the context and location of wind energy generation capacity in the Western Cape. The Final Scoping Report has to make specific provision for the accommodation of credible alternative sites for comparative analysis.

The Langebaan Ratepayers and Residents Association are therefore strongly opposed to the location of this application and acts in support of the comments of the South African National Parks whom also are opposed to this specific site application.(See attachment A) The L.R.R.A want to specifically note that we do support alternative wind energy solutions ,but not on this site.

J.A.J.Kotze

Chairperson : Langebaan Ratepayers and Residents Association

L.R.R.A