WIND FARMS AT SWELLENDAM, ALBERTINIA AND MOSSEL BAY

(Stuart hereby comments on the wind farm projects proposed for Swellendam. Albertinia and Mossel Bay.  Kindly note that far more comprehensive comments are available from us. - Ed.)

By e-mail to: rdutoit@csir.co.za

23 July 2010

Dear Mr du Toit,

COMMENTS ON DRAFT BASIC ASSESSMENT REPORT FOR THE INNOWIND WIND ENERGY PROJECT NEAR SWELLENDAM, HEIDELBERG, ALBERTINIA AND MOSSEL BAY

DEA Ref. Nos. 12/12/20/1770/1772/1773/1774

Please find below our comments on the Draft Basic Assessment Report.

1. General

· The DEADP Guidelines appear to have been very selectively quoted.

· There does not appear to be any form of Environmental Management Plan for this Phase 1 BAR. Why is this?

· What is the rationale for erecting one turbine at each site simultaneously with erecting wind monitoring masts? Have agreements or contracts been arranged with Eskom for the transfer and purchase of any power produced?

· There would appear to be little local economic benefit for these communities with apparently no permanent jobs being created.

· What plans and finances will exist for decommissioning and rehabilitation of the sites?

2. Appendix B.1.

· The photographs taken in situ on 3 sites clearly show mast stay wires. Does this mean that in reality wind monitoring masts have already been erected? If so, kindly provide the DEA authorizations.

3. Birds

Construction Phase

· There should be checks for bird breeding activity prior to construction; this should be performed by an avifauna specialist. It may in any case it would be preferable to avoid the known breeding periods of Red Data species, all of which should form part of an EMP.

Operational Phase

· An impact monitoring programme to search for and record injured and dead birds and bats should be set up, with searches being performed according to a strict protocol on a frequent basis, in view of the strong likelihood of scavenging.

· Bird flight diverters are mentioned as mitigation measures. Will they in fact be installed?

· It is recommended that injuries and carcasses should be recorded for ALL species, not only Red Data species.

· Independent observers are preferred to company appointed or contracted observers. There should be a detailed and unambiguous inspection protocol, and spot checks carried out on the observers.

· Monitoring could be hindered by seasonal variations from crop growth cycles, thus hampering access and concealing carcasses.

4. Bats

It is noted that: “A detailed bat specialist study will be undertaken during the EIA for the full wind farm by CSIR together with Dr Samantha Stoffberg of the University of Stellenbosch.  Special attention will be given to the large bat population located in the cave system (most notably De Hoop cave) in the vicinity of Bredasdorp.” (This specialist study is not mentioned in the DSR for the WEF).

5. Birds & bats

· It should be emphasized that the data resulting from any monitoring activities should be used to inform the subsequent EIA processes for the actual wind farms but cannot be used to assess the cumulative threats to birds and bats from the turbine installations themselves.

· The stay wire systems for a mast, considered in its entirety, three dimensionally, could pose a significant threat to some, particularly larger, bird species.

Yours sincerely,

Dr Stuart Shearer

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