Subsequent Port EIR

THE SUBSEQUENT ENVIRONMENTAL
IMPACT REPORT FOR THE PROPOSED

PORT OF NGQURA
PREPARED BY:
Coastal & Environmental Services
67 African Street
P.O. Box 934
Grahamstown
6140
PREPARED FOR:
Coega Development Corporation
Postnet Suite No. 35
Private Bag X13130
Humewood
Port Elizabeth
6013
September 2001
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Coastal and Environmental Services. Subsequent EIR for the Port of Ngqura
EXECUTIVE SUMMARY
(I) BACKGROUND
The Coega Development Corporation (Pty) Ltd has been mandated by the South African
Government to investigate the possible implementation of the Coega Industrial Development
Zone (IDZ). A new deepwater port will be built and operated by the Port Authority Division
(PAD) of Transnet to act as the primary transport facility for the IDZ. The proposed port will
be located at the mouth of the Coega River in Algoa Bay, which lies on the south-eastern
coast of Africa near the parallels 34°S and 26°E. The area covered by this assessment is the
area enclosed by the port limits as described in Government Gazette No. 19401 of 28 October
1998. This area includes the main marine infrastructure, back-of-port activities and other land
uses seaward of the National Road.
This Environmental Impact Report (EIR) assesses the economic, social and ecological
implications of the proposed deepwater port and follows an authority approved plan of study.
This EIR does not cover, nor attempt to assess, the environmental or socio-economic
implications of the Coega Industrial Development Zone in its entirety, and is specifically
focused on the port and back-of-port activities. In addition, this report does not comment on
the overall feasibility or rationale of the IDZ, although it does comment on the economic
feasibility of the port facility.
(II) LOCATION AND GENERAL DESCRIPTION
The paleo-channel at the mouth of the Coega River allows for the economical development
of a deepwater port, which will in the final phase be able to accommodate vessels with a
16.5m draught. The port has been designed to handle containers and various bulk and
breakbulk cargoes, and to take account of projected business opportunities as well as changes
in world shipping and logistics operations. The CDC’s preferred private partner, P&O
Nedloyd/TCI consortium, have indicated that they are interested in establishing a container
terminal at the proposed port.
The harbour will have two breakwaters, with the main breakwater extending more than two
kilometres into the sea, while the lee breakwater will be just over 1km long. Five berths will
be constructed initially, with two berths each being allocated to the container terminal and dry
bulk materials facility and one to a bulk liquid materials facility. Further expansion of the
container terminal would require an additional two berths. The main construction activities
associated with the building of the marine infrastructure are the dredging of the approach
channel and turning basin; construction of quay walls and breakwaters; land excavation to
create the area for the container terminal and transport corridor and the resulting transport of
material to the east headland deposition site; and the building of a sand bypass facility.
The main land based construction activities involve the development of infrastructure and
service facilities for the future IDZ tenants and port users. This will involve preparing sites,
transport routes, water and electricity services, waste sites and telecommunications. While no
tenants have been signed up as yet, the landside development area is envisioned to encompass
a customs secure logistics park, an E-commerce park, areas designated for port related
activities and allied industries, mixed use corridor and electronic and technical clusters
(Figure i).
Executive Summary i
In terms of future development the port is expected to be developed in phases over a number
of years as a function of prevailing demand, to a possible total of 34 berths. All future
developments will be subject to separate EIA exercises.
Turning
basin
Breakwaters
Indian
Ocean
Environmentally sensitive areas Phase 1 - port

Low intensity recreation Future port development
Tank farm CDC headquarters
Industrial/office precinct Core development area boundary (below N2)
Mixed use corridor N2 National road
Industrial estate precinct Transport corridor
Business and administrative precinct Gazetted port boundary (see 1.1.2)
Academic institution Port Authority Division boundary
(west boundary is preliminary)
Figure i: General layout of port and back-of-port areas.
ii Executive Summary
(III) TERRESTRIAL ENVIRONMENT: DESCRIPTION AND

EXPECTED IMPACTS
BRIEF DESCRIPTION
Climate - Due to its location at the confluence of several climatic regimes, the most important
of which are temperate and subtropical, the Eastern Cape has a complex climate. There are
wide variations in temperature, rainfall and wind patterns, largely as a result of movements of
air masses, altitude, mountain orientation and distance from the Indian Ocean. The monthly
temperatures (°C) for Port Elizabeth are as follows:
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
MIN 16.3 16.9 15.8 12.9 10.1 7.5 7.3 8.3 10.1 12.2 13.6 15.0
MAX 25.4 25.5 24.6 22.8 21.9 20.1 19.5 19.9 20.1 20.1 22.4 24.0
Algoa Bay is situated near the junction of temperate (winter rainfall) and subtropical (summer
rainfall) climate regimes and experiences a warm temperate climate. The Port Elizabeth area
has a bimodal rainfall pattern, with peaks in spring and autumn. Rainfall ranges from 400-
800mm per year in the region, but the Coega area falls at the low end of the range, averaging
at 400mm per year.
The Coega area is subject to strong winds with from the west and west-south-west (41%
combined frequency) all year round, and east (15%) from October through to March.
Geology - The geology of the area of the proposed Coega Industrial Development Zone (IDZ)
and port is characterised by coastal limestone, overlaid by calcareous sands blown onshore.
Soils - In the south-eastern coastal region, sandy soils with variable depth and deep red sandy
clay loams overlying limestone are common. The southern coastal belt is characterised by
coastal sands, sandy soils, lime-containing lithosols and weakly developed soils on rock. The
soils of the IDZ can be described as relatively deep, red, lime-rich sandy clay loams.
Geohydrology - The Coega River valley represents the only major incision into the coastal
landform in the area between the Swartkops and Sundays rivers. Over time, the river has
created a floodplain valley between 400 and 1 000m wide. It is a relatively small sand-bed
river, and is the most significant surface water feature associated with the proposed Coega
IDZ. The river and estuary is currently used by a commercial salt works for industrial
purposes, and to a limited degree the estuarine beach area is used for recreational purposes
(shore angling). The incised river valley forms a natural route through which a transportation
corridor can be constructed linking the port with the industrial hinterland. It also provides a
location for a harbour basin with reduced earthworks and dredging costs.
The southern portion of the designated IDZ is underlain at depth by an artesian aquifer formed
by sandstones and quartzites of the Table Mountain Group. Confining this aquifer are a
succession of eastward-thickening Cretaceous formations (Uitenhague Group) up to 1 200m
thick near the coast.
Vegetation - The vegetation of the Eastern Cape is complex and is transitional between the
Cape and subtropical floras. Detailed studies have been carried out on the terrestrial
vegetation within the back-of-port area and the vegetation can be broadly divided into four
categories: dune vegetation, inland vegetation, salt marsh vegetation and secondary vegetation
(Figure ii).
Executive Summary iii

Dune vegetation: Three distinct zones are evident in the dune vegetation, viz. foredunes, dune
woodland and dune grassland. The foredune vegetation is similar to that found all along the Eastern
Cape and is well conserved in the nearby Alexandria and Cape Reciefe nature reserves. The dune
woodland is heavily infested with Acacia Cyclops, which in much of the woodland is the dominant
species. Within the dune woodland there are patches where very few trees and shrubs are present and
the area is dominated by grasses.
Inland vegetation: Inland of the dunes and beyond the maritime influence is Subtropical Transitional
Thicket. This vegetation is characterised by dense impenetrable thickets within the valleys, while the
arid flat-topped ridges with shallow soils are characterised by more open veld where bushclumps are
dispersed in grasslands in approximately equal areas. The thicket is dominated by two forms viz.
Mesic succulent thicket and Bontveld, both of which are of high conservation importance.
Salt marsh vegetation: Salt marshes surround the salt reclamation ponds of the salt works, and
remnants of the salt marsh communities can be found on the pond banks. These salt marshes exhibit
little zonation, indicating that they have been severely disturbed by the surrounding infrastructure.
Secondary vegetation: The Secondary Grassy Fynbos present in this area is a result of bush clearing
of Bontveld and Mesic Succulent Thicket. This secondary vegetation contains the grassy fynbos
elements present in the Bontveld and a few remnants of the Thicket. However, most of the tree and
shrub components have been removed. Several patches of thicket have been cleared for pastures.
Figure ii: The main vegetation types in the port and back-of-port areas.
A total of 2 endangered, 4 vulnerable, 2 rare and 23 protected plant species are present in the
study site with the Bontveld containing 2 endangered, 2 rare, 4 vulnerable and 15 protected
species. The vulnerable endemic Syncarpha recurvata also occurrs in the Bontveld. This
species is known to occur in only two other sites, namely at Kaba Valley and at Grassridge,
and therefore has a high conservation priority. The Dune Woodland contains 3 vulnerable
species, 1 endangered species and 18 protected species, and the Mesic Succulent Thicket
iv Executive Summary
contains 1 endangered species and 7 protected species. The Dune Grassland and Foredune &
Hummock community contained 2 and 3 protected species respectively. No endangered,
vulnerable or rare species were present in the Secondary Grassy Fynbos, the Cynodon
dactylon pastures or the salt marsh communities. However, the Secondary Grassy Fynbos and
the Cynodon dactylon pastures contained one protected species.
Fauna - There is a general lack of pristine terrestrial habitats in the Coega region. This
means that some components of the terrestrial fauna have been severely impacted by previous
human activity, particularly the loss of vegetation, invasion of alien vegetation, local
extinction of large mammals, and varied industrial developments, most conspicuously the salt
works.
Birds: Due to its varied habitats, the Coega region has a diverse avifauna and over 150 species are
resident or common visitors to the region. Most diversity occurs in the thicket clumps, although the
shore and estuary both support specialised avifaunas. A range of terrestrial, estuarine and marine birds
of conservation importance are found in significant numbers in the area. Two species of tern as well as
the Cape gannet and African penguin are either endangered or vulnerable while the Caspian tern,
Chestnutbanded plover, Cape cormorant and the Greater and Lesser flamingos are near threatened. In
terms of habitats that may be impacted upon, Jahleel Island, which is located close to the main
breakwater, is a globally important Bird Area.
Reptiles: Within the proposed port area and adjacent coastal region there are 56 species of reptile.
This includes 21 snakes, 27 lizards and eight chelonians (tortoises and turtles). The majority of these
are found in Mesic Succulent Thicket and riverine habitats. Only a few species are found in the coastal
dunes and estuarine habitats. The list of reptiles of special concern is significant since it includes five
endemic species (two of which are endangered), four endangered sea turtles, one rare species and four
species at the periphery of their range. More than a third of the species found are described as
relatively tolerant of disturbed environments, provided migration corridors of suitable habitat are
maintained to link pristine habitats.
Amphibians: Knowledge of amphibian species diversity in the Coega region is limited and based on
collections housed in national and provincial museums. It is estimated that as many as 17 species may
occur. However, none of these species are endemic or of conservation concern.
Mammals: Of the 63 mammal species known or expected to occur in the Coega area, two species are
endemic, Duthie’s golden mole (Chlorotalpa duthiae) and the pygmy hairy-footed gerbil (Gerbillurus
paeba exilis). Both occur in the dune vegetation, which forms only a limited area of the proposed port
area. Thirteen of the 63 species are Red Data Book species, and five of these are medium to large in
size, occupying relatively large ranges, and will be adversely affected by development as their ranges
become restricted. However, apart from the two endemic small mammals, no significant breeding
populations of the other species of conservation concern are known to occur in the Coega region.
Terrestrial invertebrates: The invertebrate fauna of the coastal dunefields of Algoa Bay and its
associated vegetation has not been extensively studied. The distribution of the terrestrial invertebrates
found along the coast is dependent to a large degree upon the extent and composition of the natural
vegetation. One grasshopper species, Acrotylos hirtus, is endemic to the dunefields. There are three
rare butterflies which are known from a number of scattered localities in the Coega region.
SUMMARISED IMPACTS O N THE TERRESTRIAL EN VIRONMENT
The ecological implications on the terrestrial environment that the construction and operation
phases will have can be grouped into 15 key issues viz.
Issue 1 – Loss and fragmentation of sensitive habitats
Executive Summary v
Issue 2 – Loss of biodiversity

Issue 3 – Loss of species of special concern
Issue 4 – Destruction of habitats important to migratory species
Issue 5 – Introduction of alien species
Issue 6 – Substantial increase in road traffic
Issue 7 – Changes in hydrodynamics and water quality
Issue 8 – Changes in fire regimes
Issue 9 – Electricity consumption
Issue 10 – Water consumption
Issue 11 – Disposal of solid and liquid waste
Issue 12 – Noise levels
Issue 13 – Air quality
Issue 14 – Lighting
Issue 15 – Risk of explosions
28 specific impacts were identified from these 15 issues and all were found to be negative.
After mitigation no impacts were found to constitute a fatal flaw to the project. There were,
however, a number of impacts of high and moderate significance associated with the
construction phase. The impacts of HIGH significance were orientated around two issues,
viz. Loss and fragmentation of sensitive habitats and the Loss of species of special concern.
Specifically, the impact that the construction phase would have on the Bontveld and salt pans
were regarded as being of high significance. The impact that construction would have on
endangered/rare or vulnerable birds was rated as being HIGH, while the construction impacts
on plants, reptiles and butterflies were rated as being MODERATE.
Issues primarily restricted to the construction phase which were found to have impacts of
LOW significance after mitigation were: importance to migratory species (low- moderate),
introduction of alien species, substantial increase in road traffic, changes in hydrodynamics
and water quality, and changes in fire regimes.
The majority of issues and impacts associated with the operational phase, viz. electricity and
water consumption, air quality, waste disposal, lighting and risk of explosions were found to
be of LOW significance after mitigation. The impact that noise may have on people was
rated as being HIGH due to the proximity of St George’s Strand to the port operations. It
must, however, be noted that these ratings were made with limited information and on the
premise that the Environmental Management System outlined in Appendix B will be fully
implemented and audited.
Terrestrial Impacts
(Construction and Operation)
Very High
18%
High
50%
Moderate
32%
Low
Figure iii: Negative terrestrial impacts associated with the development of the port and back-
of-port areas.
vi Executive Summary
IV) MARINE ENVIRONMENT: DESCRIPTION AND EXPECTED

IMPACTS
BRIEF DESCRIPTION
General location - Algoa Bay lies on the southeastern coast of Africa near the parallels 34°S
and 26°E and is the easternmost and largest of a series of long-spiral bays along this coastline.
It faces the southwest Indian Ocean, where the dominant oceanic-scale feature is the Agulhas
Current, which flows polewards with its core close to the continental shelf. Two headlands,
Cape Recife and Cape Padrone, separated by a distance of about 70km, enclose the Bay and
form a wide mouth which opens onto the eastern Agulhas Bank. The Bay extends for 90km,
80km of which comprise surf-swept sandy beaches. Two major rivers, the Swartkops and the
Sundays, flow into the Bay. The St Croix Island group, consisting of St Croix, Brenton and
Jahleel, is located a few kilometres offshore from the Coega River mouth.
Hydrology and circulation - Tides around South Africa are classified as semidiurnal and
microtidal. The tidal period within the bay is 12 hours and 25 minutes. Sea surface
temperatures vary from greater than 22°C in summer to less than 14°C in winter. However,
considerable variability occurs on a day to day basis, particularly with the advent of
upwelling. Most of the swell around South Africa originates from storms in the Southern
Ocean, to the southwest of the continent, as well as from strong, local westerly winds.
Sediment patterns - The beach state between the Swartkops, Coega and Sundays river mouths
is generally the intermediate type, transverse bar and rip subtype. This type of beach is
characterised by waves 1–1.5m high and small widely spaced rip currents every 150–300m
running oblique to the shoreline. The swash zone is generally shallow with low waves
breaking on the lee of or behind the terraces.
Wave driven longshore drift moves sand along the beach. The wave energy is moderate to
high; the prevailing swell is generated in the westerly gale belt and approaches the south coast
from the southwest. Net sand movement due to these waves/swells is in a northward
direction, although there is movement in both a northerly and southerly direction
Algoa Bay Islands - The Algoa Bay Island Nature Reserve comprises the Bird and St Croix
Island groups. Both these island groups have been declared an Important Bird Area (IBA), as
they are inhabited by threatened and endangered species. These islands are formed by
outcrops of super- mature, erosion-resistant Peninsula sandstone of the Table Mountain group
and are almost bare of any vegetation. St Croix has a maximum elevation of 53m and is 12ha
in size, while Brenton and Jahleel are considerably smaller, having areas of 1 and 2ha
respectively, and do not rise mo re than 20m above sea level.
The seals and seabirds, which breed and roost on the islands, play an integral role in the
functioning of the marine ecosystem of Algoa Bay. The islands also play a national and
international role in the conservation of three seabird species, the Cape gannet, African
penguin and Roseate tern. The largest gannet colony in the world is at Bird Island, the largest
African penguin colony in southern Africa is at St Croix, and the only confirmed sites where
Roseate terns breed in South Africa are at Bird and St Croix islands.
Fish - The fish fauna of Algoa Bay is typical of the eastern Agulhas Bank and is made up of
both South African endemics and wide-ranging southern African endemics. Being part of the
Executive Summary vii

transition zone between the warmer waters of the northeast coast of Africa and the cool west
coast, the Eastern Cape is ichthyologically an important and unique region.
Reptiles - The giant leatherback sea turtle (Dermochelys coriacea), the loggerhead sea turtle
(Caretta caretta) and the hawksbill sea turtle (Eretmochelys imbricata) have all been recorded
feeding in Algoa Bay. There are few records of any southern African sea turtles breeding on
Eastern Cape beaches, although nests of the leatherback turtle have been recorded from sandy
beaches in Port Alfred, Woody Cape and Oubostrand.
Marine mammals - The marine mammal fauna of South Africa comprise 35 whale, dolphin
and seal species. Ten species are relatively common in Algoa Bay, albeit some only
seasonally. Southern Right whales use the shallow waters of Algoa Bay to give birth and
nurse their young. This species usually make its appearance in June and increases in
abundance to reach peak numbers in August to October, when up to 40 animals frequent the
Bay at any one time. 200 to 400 humpback dolphins of southern Africa’s estimated
population of less than 1 000 animals, from False Bay through to Mozambique, live in Algoa
Bay, predominantly around inshore rocky reefs. Bottlenose dolphins are more abundant and
their preferred sites are around Cape Recife, Bird Rock and the section between the
Swartkops River and Sundays River beach. Cape fur seals are commonly seen, even in the
existing port, with their most northerly distribution being Black Rocks in the Bird Island
Group.
SUMMARISED IMPACTS O N THE MARINE ENVIRONMENT
In total there are 11 issues and 24 impacts associated with the construction and operation of
the Port of Ngqura on the marine environment, all of which are negative. The main issues are:
Issue 1 – Specific impacts on the nearshore environment

Issue 2 – The effect of the port on the physical environment
Issue 3 – The effect of dredge spoil dumping at sea on commercial and recreational fishing activities
Issue 4 – The effect of dredge spoil dumping at sea on recreational boating
Issue 5 – Biological contamination through introduced organisms
Issue 6 – Impacts on sites of marine archaeological importance
Issue 7 – Effects on adjacent industries
Issue 8 – Pollution associated with the operation of the port
Issue 9 – Disturbance of fauna associated with the operation of the port
Issue 10 – Maintenance dredging
Issue 11 – Risks associated with increased shipping
Impacts after mitigation are predominantly LOW, but there are a number of HIGH and
VERY HIGH impacts. The construction of the Port of Ngqura is a considerable engineering
undertaking. The construction will take approximately 36 months, with many activities being
run in parallel, many of which (e.g. dredging) will be done on a 24-hour basis. The size,
duration and nature of the construction has the potential, if poorly managed, to impact
significantly on the environment. The majority of pre- mitigation construction impacts are
severe or very severe, which indicates that if the process is poorly managed and the
recommendations made in this EIA and the subsequent Environmental Management Plan are
not heeded, the impacts may well be significant. The impacts are, however, generally short
term and localised, and if the recommendations are successfully implemented, the overall
environmental significance of the majority of the impacts will be reduced. With successful
mitigation, no impacts are regarded as fatal flaws to the project.
viii Executive Summary

Marine Impacts
4% 8%
Very High
17%
High
Moderate
46%
Low
No significance
25%
Figure iv: The post- mitigation construction and operational marine impacts (-) of the
proposed harbour.
There is only one construction impact of VERY HIGH significance, viz. the impact of an
introduced marine invasive organism. The problem of alien invasives exists throughout the
world’s ports and is presently the focus of a large amount of research interest. The impact is
rated as VERY HIGH due to the tremendous damage that invasive organisms can have.
Mitigatory measures such as a strictly enforced ballast water plan must be implemented and
the dredgers must be thoroughly cleaned prior to arrival in South African waters. These
measures will serve to reduce the possible incidence but cannot ensure that no invasives are
introduced.
Algoa Bay is an important habitat to a number of bird species of special concern (e.g. African
penguins and Roseat terns). The overall significance of the impacts of construction will be
LOW for most marine bird species but due to the conservation importance of certain species,
is rated as HIGH. The only other impact of HIGH significance is the possible impact on the
adjacent abalone farm. The port and IDZ have the potential to impact on the abalone farm
operations but as yet only a desktop study identifying possible impacts has been undertaken.
As the CDC have undertaken to relocate or buy out the operation, the exact magnitude,
probability and nature of the impacts have not been fully established. Until an in-depth
examination of the desktop assessed impacts is undertaken, the impact is regarded as being
HIGH.
The impact on the general ecology was rated as MODERATE, due to the occurrence of
species of special concern such as certain birds and cetaceans. For other aspects of the
ecology of the bay, e.g. benthic invertebrates and fish, the impact is regarded as being LOW.
The operation of the port will result in four main environmental issues (Issues 8 -10), viz.
pollution, disturbance of fauna, maintenance dredging and risks associated with increased
shipping. The only impact of VERY HIGH significance is a catastrophic oil spill, which in
turn is related to another impact of HIGH significance, namely increased risk of ship
collision. The possibility of a major oil spill is unlikely but the significance is rated as being
VERY HIGH due to the immense damage that a large spill could have on the ecology of
Algoa Bay. The correct management of the port, inspection of inbound vessels and sound
emergency capability may reduce the likelihood of a major spill and attempt to contain a spill,
but if an accident were to occur, the damage will in all probability be severe.
Executive Summary ix
The other impact of HIGH significance is related to the disturbance of birds of special
concern. Unfortunately the port is located next to Jahleel Island and close to other islands
within the St Croix group. These islands are important habitats for a number of birds with
conservation importance and the construction and operation of the port may well disturb the
more sensitive species. All the impacts associated with pollution during the operational phase
are rated as being severe or very severe prior to mitigation, which indicates that the poor
management of the port and IDZ could result in large amounts of pollution entering the
harbour or atmosphere. These potential impacts can, however, be managed and the
significance of the impacts are MODERATE (cargo spills and ship biocides) or LOW
(general ship and port waste, polluted stormwater runoff, ship exhaust emissions) after
mitigation and management.
(V) SOCIO-ECONOMIC DESCRIPTION AND EXPECTED IMPACTS
BRIEF DESCRIPTION
Regional overview - The Eastern Cape is the second largest of the nine new provinces, has the
fourth highest population density and the second highest percentage of children under the age
of 15. The province is one of South Africa’s most poverty stricken and least developed areas.
Sixty-four percent of the Eastern Cape’s population is reported to be living in poverty. In the
Port Elizabeth-Uitenhage metropole, 60% of the potentially economically active population
are employed. However, these figures are unbalanced in terms of population structure: the
severity of unemployment in the township areas is estimated to be 50 – 60%. The Eastern
Cape’s Human Development Index was measured at 0.51 in 1991, which is South Africa’s
second lowest HDI after the Northern Province and captures the extent of poverty and
deprivation in the province.
Sub-regional overview - While the regional benefits of the successful implementation of the
project should not be overestimated, there is some potential for the Coega project as a whole
to have negative local impacts. These manifest themselves in the disruption of existing social
networks and modes of livelihood. Current land use patterns in the port area indicate that the
number of people likely to be directly affected by the development of the port and back-of-
port activities is relatively low. It is estimated that there are 45 households in the greater port
area. The community in the region can be characterised as being poor with the following
characteristics:
• The total population of the households resident within the port is 146 persons, giving
an average of 3.2 persons per household.
• The households are generally headed by males (80%) with Xhosa being the home
language.
• The majority of the residents are functionally illiterate.
• A population growth rate is difficult to predict but townships close by may well be
growing at about 4.5% per annum.
• Only 38% percent of family heads are employed on a full time basis.
• Seventy-six percent of all earners have an income of less than R1 000 per month. The
majority of households have a disposable income of between R100-R200 per month,
while some have a negative disposable income (<6%). Very little saving was detected
in the community.
x Executive Summary
• Many of the residents have lived in the area for over 10 years. As suc h a high degree
of community stability has been generated and homesteads are generally well
established.
• Dwellings are constructed out of a variety of materials, e.g. brick, mortar, corrugated
iron, wood, clay, manure and bricks. Although liveable, more than half the dwellings
were found to have no ceilings, which is associated with weak insulation and therefore
ineffective in keeping out extreme cold or hot.
• The community in the proposed Coega IDZ area appeared to be healthy but some
children are inadequately nourished (13.8%) and some severely malnourished (5.2%).
• The most common diseases encountered in the area are mostly related to shack
dwelling, including tuberculosis (11.7% of households) measles, meningitis, typhoid
and gastro-enteritis.
Existing economic activities - Existing economic activities within the port area include the
salt works and farming operations. It is anticipated that the construction of the port will have a
significant impact on the operations of the salt works. A further concern is the Marine
Growers Abalone Farm. Although this farm does not fall directly in the port area, it may be
impacted on by the port operation
SUMMARISED IMPACTS O N THE SOCIO - ECONOMIC ENVIRONMENT
The socio-economic impacts associated with the development of the Ngqura Port are both
positive and negative. The primary socio economic issues were:
Issue 1 – Expansion of the skills base

Issue 2 – Direct and indirect economic implications
Issue 3 – The ability of the port to act as a catalyst for growth
Issue 4 – Implications on existing businesses
Issue 5 – Resettlement
Issue 6 – Disruption of graves
Issue 7 – Changes to social systems and structures
Issue 8 – Closure of recreational facilities
Issue 9 – Visual impacts of the port area
Issue 10 – Influx of people to the area
Issue 11 – Air emission impacts associated with construction traffic
Issue 12 – Operational, noise, air and light pollution
Issue 13 – Sites of historical or cultural interest
Issue 14 – Impact on the proposed Greater Addo National Park
The main positive impacts are related to the expansion of the regional skills base and the
direct and indirect economic benefits of the construction and operation of the facility. The
benefits associated with the port were, however, found mainly to be of LOW significance,
particularly when put into context of the capital expenditure of the project. The main reasons
for the LOW significance is that the facility will not generate large numbers of jobs during
construction or operation, and the impact of the port on the regional economy will be
negligible. In addition, a significant portion of the construction budget will leave the country,
as foreign companies will be involved with large sections of the construction (e.g. dredging)
and the CDC’s preferred private partner for the container terminal is also an international
company. The MODERATE economic impact is related to the indirect economic impact that
the port may have. The main regional benefit will be from the indirect employment in
industries concerned with the import and export of cargo and in the industries attracted to the
IDZ because of the proximity of a container terminal. It must be noted, however, that the port
is only the transport infrastructure for the IDZ and that the IDZ should be regarded as the
vehicle to create jobs and economic growth for the entire Coega development. As stated in the
Executive Summary xi
introduction, the economic viability and the potential for the Coega initiative to create wealth
falls outside of the scope of this EIA.
The ability of the port to act as a catalyst for growth in the IDZ is presently unknown but there
will be some induced economic growth around the provision of services for the container
terminal. While the port may provide the IDZ with the transport infrastructure required for an
internationally competitive IDZ, characteristics of the IDZ itself (e.g. location, labour,
incentives, tax regimes, political stability etc.) will determine whether it is a success. The
most important finding of the economic cost benefit analysis was the existing and future need
for a container terminal in the South African port system, and that the Port of Ngqura can be
economically justified to fulfil this role. The fact that the proposed port can be justified
independently to the IDZ is important to no te when considering the viability of the Coega
development as a whole. It must, however, be emphasised that no existing need (i.e. excluding
any future possible need generated by the IDZ) was identified for the proposed bulk and
breakbulk berths and that these berths are presently not economically viable without rerouting
traffic from other ports.
Positive Impacts
Very High
40% High
Moderate
60%
Low
Figure v: Positive socio-economic impacts associated with the Port of Ngqura.
There are a number of negative impacts associated with the building and operatio n of the port
and back-of-port area, quite a number of which are of HIGH or VERY HIGH significance.
The negative impacts of VERY HIGH significance revolve around the impact that the port
may have on existing businesses in the region. These impacts must be considered in a serious
light in that the aim of the Coega development is to bring economic growth to the region and
any job losses associated with the proposed port and back-of-port area must be carefully
considered. In particular, the possible impacts that the port will have on the salt works and
abalone farm are rated as being severe or very severe before mitigation, and while the two
scenarios associated with the abalone farm have the potential to be amicably resolved and
thus be of NO SIGNIFICANCE, no agreements have been reached thus far. The possible
buyout and closure of the salt works is a VERY HIGH negative impact and every effort
should be made to relocate the salt works, provided that an environmentally suitable site can
be found. The port and IDZ may also impact upon the future land use options immediately
adjacent to the port and IDZ. The exact economic impact on the shareholders in these
properties is undetermined due to the difficulty in appraising future plans rather than actual
losses or imp acts associated with existing operations.
xii Executive Summary

Since negotiations between P&O Nedloyd and PAD regarding the operational arrangements,
have not been finalised, the specific impacts of the new port on the existing port at Port
Elizabeth remain unclear. Any arrangement which jeopardises the current operations viz.
containerisation or bulk and breakbulk cargoes has the potential to be a severe impact of
HIGH significance.
In terms of relocation the lack of an integrated Resettlement and Compensation plan has
resulted in it being impossible to assess individual or household impacts however a survey
indicated that many of the people now have access to housing and facilities (such as water,
sanitation, transport), which are of a better quality than in their original communities and the
impact on them is slightly beneficial to beneficial. If meaningful and successful mitigatory
actions are implemented as soon as possible, which should go a long way in ensuring that no
parties are worse off after the move, then the overall impact may well be LOW to
MODERATE (+). There will however be a number of individuals particularly in the sensitive
sectors of the community who may still experience a negative impact on their livelihoods. If
the correct mitigatory measures are implemented this may be reduced to one of LOW (-)
overall significance.
Negative Impacts
12% 4%
19% Very High
High
Moderate
31% Low
No significance
34%
Figure vi: Negative socio-economic impacts associated with the Port of Ngqura (3 impacts
were rated as Do Not Know).
The loss of recreational facilities is of MODERATE significance while the visual impact that
the port will have on the surrounding areas is of MODERATE to HIGH significance. The
possible influx of people into the region is also regarded as a significant negative impact and
the authorities and CDC must make provision for this eventuality, as a project of this size is
bound to elicit an influx in a poor province such as the Eastern Cape. The impacts associated
with hauling of vast quantities of material in the construction area could result in very severe
impacts if the required mitigatory measures are not put in place. If dust suppression is
successful then the impact will be of MODERATE significance.
The last issue of HIGH or MODERATE significance is the impact that the port may have on
the proposed Greater Addo National Park. The most severe impacts are related to the visual
intrusion that the proposed port will have on the park and the associated loss of sense of place
that the park will experience. These impacts are rated as being of MODERATE to HIGH
significance but must be viewed in the context of the park currently being located in close
Executive Summary
xiii
proximity to townships and industrial areas. The port will also have a MODERATE impact
on the park in terms of general port operations as species of special concern will be impacted
upon. In conclusion, the Eastern Cape is a poor province and while in an ideal world it would
be better to have as little industrialisation close to the park as possible, this luxury cannot be
afforded and the two initiatives, while not being in harmony, are not mutually exclusive.
(VI) CONCLUSION
In order to aid the decision- making authorities, who need to decide on the desirability of the
proposed Ngqura Port from an environmental perspective, it is important to consider the
concepts of sustainability, equity and efficiency. In order to do so, these concepts are first
briefly defined below.
Sustainability can be defined as “meeting the needs of the present generation without
compromising the needs of future generations”.
Equity deals with the fair distribution of benefits among people. For development to be
sustainable in the broad sense, it must be equitable. In other words, the benefits arising from
development must be distributed fairly among all people who rightly have a stake in the
development.
Efficiency means the choice between alternative development strategies or projects, taking
into account which of the alternatives will return the greatest present and future benefits for a
given cost in resources. Efficiency is usually described by translating costs and benefits into
monetary terms.
The National Environmental Management Act, NEMA states that “Development must be
socially, environmentally and economically sustainable”.
Ngqura Port - Sustainability

In terms of sustainability, one of the key findings of the cost benefit analysis is that the
proposed port, if limited to a container terminal, is economically weakly sustainable without
the IDZ. It is, however, not recommended that the port be built if the IDZ is not viable i, as
expansion of the container handling capacity in South Africa could be undertaken through the
expansion of the Port of Richards Bay. Nevertheless the port can be regarded as being
warranted without the IDZ, and as such can only benefit from being part of a successful
industrial zone. If the IDZ is a success, the port will be an economically sustainable project.
However, the overall decision to go ahead with the port is inextricably linked to the viability
of the IDZ.
In terms of ecological sustainability, the project will impact on a number of species of special
concern and threatened habitats. Many of the impacts can be mitigated against and no
biophysical impact is thought to be severe enough to curtail the project, provided that the
required mitigatory actions are implemented and effective. In terms of social sustainability,
the project has the potential to provide (in the context of the capital expenditure) limited direct
jobs and economic input into the regional economy. The project will, however, possibly result
in a greater impact through induced or secondary inputs into the regional fiscus. Again it
i
While the MERIT report indicates that the proposed port and container terminal (excluding bulk and break bulk berths) would be
sustainable at Coega, the rationale behind not recommending the building of the port, should the IDZ not be viable, is linked to the initial
reason for the building of the port in the first place, which was to provide an international gateway for the Coega IDZ. This is not to say that
future investigations by PAD may not find this site to be suitable. However, any future investigations would be subject to an independent
EIA process.
xiv Executive Summary

should be noted that the project is providing the infrastructure for other businesses to utilise,
and thus the main economic and social benefits should be derived from the IDZ and other
industrial centres utilising the port. If the IDZ is a success then the port, as a pivotal
component of the IDZ, will contribute significantly to the social and economic sustainability
of the region.
Ngqura Port - Equity

The concept tha t a project should be equitable is to ensure that all stakeholders in a
community should derive the benefits from the project. The benefits associated with the
construction of the port (jobs and contracts) are not entirely equitable, in that components of
the capital expenditure will be spent on foreign contractors (e.g. dredging). The jobs and
contracts that are available will be equitably distributed, as the CDC and PAD have equitable
labour and materials procurement policies. The distribution of jobs will also favour those
stakeholders that have been negatively impacted by the project through actions such as
resettlement. The specific aim of the Coega Project as a whole is to uplift the region, socially
and economically.
Ngqura Port - Efficiency

The question of whether the proposed port is an efficient use of taxpayers’ money is
fundamentally linked with the Coega Project as a whole. In order to answer this question, one
needs to examine the viability and rationale behind the entire Coega Project, which is outside
of the scope of this EIA.
In conclusion, the provision of infrastructure as capital intensive as that of the proposed port
should only be authorised if the authorities are fully informed regarding the sustainability of
the Coega Project as a whole. What should also be recognised is that a final decision to
support and fund the Coega Project will most likely not only be based on a purely economic
best return basis, but also include aspects such as the strategic development of a previously
and presently economically marginalised area of South Africa. This decision, as with most
“business” decisions, will include a margin of calculated risk. The process and the
information used by the government to come to a final decision must nevertheless be
transparent to ensure that accountable and responsible development occurs.
Executive Summary xv
TABLE OF CONTENTS
TABLE OF CONTENTS
EXECUTIVE SUMMARY..................................................................................................... i
CHAPTER 1: INTRODUCTION ......................................................................................... 1

1.1 BACKGROUND.................................................................................................... 1
1.1.1 General .................................................................................................... 1
1.1.2 Area covered by the EIR ......................................................................... 1
1.2 MOTIVATION FOR A DEEPWATER PORT ..................................................... 6
1.2.1 Industrial growth catalyst ........................................................................ 6
1.2.2 Location and general description............................................................. 6
1.3 OBJECTIVES OF THIS REPORT, THE SUBSEQUENT
ENVIRONMENTAL IMPACT REPORT............................................................ 7
1.4 APPROACH AND STRUCTURE OF THE REPORT ......................................... 7
1.4.1 Approach to the EIA .................................................................................... 7
1.4.2 Structure of the report .................................................................................. 9
1.5 SPECIALIST STUDIES COMMISSIONED ...................................................... 10
1.5.1 Bontveld study............................................................................................ 10
1.5.2 Risk assessment.......................................................................................... 10
1.5.3 Visual assessment....................................................................................... 11
1.5.4 An economic evaluation of the proposed Port of Ngqura and
development of a container terminal.......................................................... 11
1.5.5 Dredging, excavation and disposal............................................................. 11
1.5.6 Air quality impact assessment.................................................................... 11
1.5.7 Resettlement impact report......................................................................... 11
1.6 ASSUMPTIONS OF THE REPORT................................................................... 11
CHAPTER 2: ENVIRONMENTAL IMPACT ASSESSMENT PROCESS .................. 13

2.1 INTRODUCTION................................................................................................ 13
2.2 THE EIA PROCESS IN SOUTH AFRICA......................................................... 13
2.2.1 Introduction................................................................................................ 13
2.2.2 Scoping phase............................................................................................. 13
2.2.3 Environmental impact assessment phase ................................................... 14
2.2.4 Record of decision...................................................................................... 16
2.3 IDENTIFIED ACTIVITIES REQUIRING AUTHORISATION........................ 16
2.4 RELATIONSHIP BETWEEN THE VARIOUS PORT EIA
ASSESSMENTS ................................................................................................. 17
2.5 THE EIA PROCESS FOLLOWED IN THIS STUDY........................................ 20
2.5.1 General process .......................................................................................... 20
2.5.2 Public participation process ....................................................................... 20
2.6 ASSESSMENT CRITERIA ................................................................................. 22
2.6.1 Temporal scale ........................................................................................... 22
2.6.2 Spatial scale ................................................................................................ 22
2.6.3 Severity/beneficial rating scale .................................................................. 23
2.6.4 Significance scale ....................................................................................... 23
2.6.5 Risk or likelihood scale .............................................................................. 25
2.6.6 Degree of certainty or confidence .............................................................. 25
2.7 STRUCTURE AND RESPONSIBILITY OF THE EIA TEAM ......................... 25
2.8 ASSESSMENT OF ALTERNATIVES ............................................................... 26
2.8.1 Approach taken with respect to alternatives .............................................. 26
2.8.2 Screening of port options in Algoa Bay..................................................... 26
CHAPTER 3: PROJECT DESCRIPTION ....................................................................... 29

3.1 INTRODUCTION................................................................................................ 29
3.2 NATURE AND EXTENT OF THE PORT (INFRASTRUCTURE) .................. 29
3.2.1 General layout ............................................................................................ 29
3.2.2 Functions .................................................................................................... 31
3.2.3 Parameters affecting the port layout ........................................................... 31
3.2.4 Port development phases ............................................................................ 34
3.3 BACK-OF-PORT................................................................................................. 45
3.4 POSSIBLE FUTURE DEVELOPMENTS .......................................................... 50
3.4.1 Port ............................................................................................................. 50
3.4.2 Landside developments.............................................................................. 50
CHAPTER 4: DESCRIPTION OF THE TERRESTRIAL ENVIRONMENT.............. 53

4.1 INTRODUCTION................................................................................................ 53
4.2 CLIMATE ............................................................................................................ 53
4.3 GEOLOGY........................................................................................................... 54
4.4 SOILS ................................................................................................................... 55
4.5 GEOHYDROLOGY AND HYDROLOGY ........................................................ 55
4.5.1 Catchment drainage .................................................................................... 55
4.5.2 Surface water .............................................................................................. 56
4.5.3 Artesian system .......................................................................................... 57
4.6 AMBIENT AIR QUALITY AND NOISE........................................................... 58
4.6.1 Ambient air quality..................................................................................... 58
4.6.2 Ambient noise ............................................................................................ 58
4.7 VEGETATION AND FLORISTICS ................................................................... 59
4.7.1 Dune vegetation.......................................................................................... 59
4.7.2 Inland vegetation........................................................................................ 61
4.7.3 Salt marsh vegetation................................................................................. 63
4.7.4 Secondary vegetation ................................................................................. 63
4.7.5 Floristics..................................................................................................... 63
4.7.6 Vegetation in a regional context ................................................................. 67
4.7.7 Vegetation in a national context ................................................................. 68
4.7.8 Environmental sensitivity........................................................................... 68
4.8 TERRESTRIAL FAUNA .................................................................................... 69
4.8.1 Birds ........................................................................................................... 70
4.8.2 Reptiles ....................................................................................................... 71
4.8.3 Amphibians ................................................................................................ 73
4.8.4 Mammals .................................................................................................... 73
4.8.5 Terrestrial invertebrates.............................................................................. 74
CHAPTER 5: TERRESTRIAL IMPACTS AND MITIGATION .................................. 77

5.1 INTRODUCTION................................................................................................ 77
5.1.1 Project actions associated with construction.............................................. 77
5.2 KEY ISSUES ....................................................................................................... 77
5.2.1 Introduction................................................................................................ 77
5.2.2 Construction issues..................................................................................... 81
5.2.3 Operational issues ...................................................................................... 98
5.3 CONCLUSIONS................................................................................................ 105
CHAPTER 6: MARINE DESCRIPTION........................................................................ 107

6.1 GENERAL ALGOA BAY DESCRIPTION...................................................... 107
6.2 HYDROLOGY AND CIRCULATION PATTERNS ....................................... 107
6.3 COASTAL SEDIMENT DYNAMICS.............................................................. 109
6.4 THE ALGOA BAY ISLANDS .......................................................................... 110
6.4.1 General description .................................................................................. 110
6.4.2 Island biota ............................................................................................... 111
6.5 THE MARINE BIOTA ...................................................................................... 114
6.5.1 Marine phytoplankton.............................................................................. 114
6.5.2 Marine fauna ............................................................................................ 114
CHAPTER 7: MARINE IMPACTS AND MITIGATION ............................................ 119

7.1 INTRODUCTION.............................................................................................. 119
7.1.1 Project actions or activities associated with construction and operation
of the port................................................................................................. 119
7.2 KEY ISSUES – CONSTRUCTION PHASE..................................................... 120
7.3 KEY ISSUES – OPERATIONAL PHASE........................................................ 131
7.4 CONCLUSIONS................................................................................................ 140
CHAPTER 8: SOCIO-ECONOMIC DESCRIPTION ................................................... 143

8.1 INTRODUCTION.............................................................................................. 143
8.2 REGIONAL ECONOMIC OVERVIEW........................................................... 143
8.3 THE SUB-REGIONAL SOCIAL AND ECONOMIC ENVIRONMENT........ 144
8.3.1 Socio-economic profile ............................................................................ 144
8.3.2 Services .................................................................................................... 148
8.3.3 Health profile............................................................................................ 150
8.3.4 Existing economic activity....................................................................... 150
CHAPTER 9: SOCIO-ECONOMIC IMPACTS AND MITIGATION ........................ 153

9.1 INTRODUCTION.............................................................................................. 153
9.2 ECONOMIC IMPACTS .................................................................................... 153
9.2.1 Background .............................................................................................. 153
9.2.2 Key economic issues ................................................................................ 155
9.3 SOCIAL ISSUES ............................................................................................... 165
9.4 CONCLUSIONS................................................................................................ 179
CHAPTER 10: FINAL DISCUSSION AND CONCLUSIONS ..................................... 183

10.1 INTRODUCTION............................................................................................ 183
10.2 SIGNIFICANT ISSUES/IMPACTS ASSOCIATED WITH THE
PROPOSED PORT ........................................................................................... 184
10.2.1 Background ............................................................................................ 184
10.2.2 Negative impacts.................................................................................... 184
10.2.3 Positive impacts...................................................................................... 186
10.2.4 Future impacts........................................................................................ 187
10.3 FINAL CONCLUSIONS ................................................................................. 187
10.3.1 Concepts of sustainability, equity and efficiency................................... 187
10.3.2 Criteria evaluation.................................................................................. 188
10.4 RECOMMENDATIONS ................................................................................. 190
CHAPTER 11: REFERENCE LIST................................................................................ 191

11.1 REFERENCES USED IN THIS EIA............................................................... 191
11.2 SPECIALIST STUDIES UNDERTAKEN FOR THIS, THE SUBSEQUENT
PORT EIA......................................................................................................... 200
11.3 SPECIALIST STUDIES UNDERTAKEN FOR THE INITIAL
ENVIRONMENTAL IMPACT ASSESSMENT AND THE STRATEGIC
ENVIRONMENTAL ASSESSMENT.............................................................. 200
11.4 SPECIALIST STUDIES UNDERTAKEN FOR THE REVISED
ENVIRONMENTAL IMPACT ASSESSMENT ............................................. 201
11.5 OTHER SPECIALIST STUDIES UNDERTAKEN FOR THE COEGA
DEVELOPMENT ............................................................................................. 202
APPENDIX A: PLAN OF STUDY
APPENDIX B: COEGA DEVELOPMENT CORPORATION ENVIRONMENTAL
MANAGEMENT POLICIES AND SYSTEM
APPENDIX C: SPECIFIC RECOMMENDATIONS FOR INCLUSION IN THE
CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN FOR
THE PORT OF NGQURA
APPENDIX D: FINAL PUBLIC PARTICIPATION REPORT FOR THE

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT FOR THE
PROPOSED PORT OF NGQURA
APPENDIX E: A FORENSIC AUDIT OF THE RELOCATION PROCESS AND

IMPACTS OF THE PROPOSED PORT OF NGQURA
TABLE OF ISSUES
1a. Terrestrial Construction Issues...................................................................................81
Issue 1: Loss and fragmentation of sensitive habitats ................................................................. 81
Issue 2: Loss of biodiversity .................................................................................................... 86
Issue 3: Loss of species of special concern................................................................................ 89
Issue 4: Destruction of habitats important to migratory species .................................................. 93
Issue 5: Introduction of alien species........................................................................................ 94
Issue 6: Substantial increase in road traffic ............................................................................... 95
Issue 7: Changes in hydrodynamics and water quality ............................................................... 95
Issue 8: Changes in fire regimes............................................................................................... 96
1b. Terrestrial Operational Issues ....................................................................................98

Issue 9: Electricity consumption............................................................................................... 98
Issue 10: Water consumption................................................................................................... 99
Issue 11: Disposal of solid and liquid waste .............................................................................. 99
Issue 12: Noise levels .............................................................................................................100
Issue 13: Air quality ...............................................................................................................101
Issue 14: Lighting ..................................................................................................................102
Issue 15: Risk of explosions....................................................................................................102
2a. Marine Construction Issues.......................................................................................120

Issue 1: Specific impacts on the nearshore environment............................................................120
Issue 2: The effect of the port on the physical environment .......................................................124
Issue 3: The effect of dredge spoil dumping at sea on commercial and recreational fishing
activities...................................................................................................................125
Issue 4: The effect of dumping at sea on recreational boating (sailing) .......................................126
Issue 5: Biological contamination through introduced organisms...............................................126
Issue 6: Impacts on sites of marine archaeological importance ..................................................128
Issue 7: Impacts on adjacent industries ....................................................................................128
2b. Marine Operational Issues ........................................................................................131

Issue 8: Pollution associated with the operation of the port .......................................................131
Issue 9: Disturbance of fauna associated with the operation of the port ......................................134
Issue 10: Maintenance dredging ..............................................................................................136
Issue 11: Risks associated with increased shipping ...................................................................137
3a. Economic Issues..........................................................................................................155

Issue 1: Expansion of the skills base........................................................................................155
Issue 2: Direct and indirect economic implications ...................................................................156
Issue 3: The ability of the port to act as a catalyst for growth ....................................................158
Issue 4: Impact on existing businesses.....................................................................................160
3b. Social Issues................................................................................................................165

Issue 5: Resettlement .............................................................................................................165
Issue 6: Disruption of graves ..................................................................................................166
Issue 7: Changes to social systems and structures.....................................................................167
Issue 8: Closure of recreational facilities .................................................................................168
Issue 9: Overall visual impacts of the port area ........................................................................169
Issue 10: Influx of people to the area.......................................................................................170
Issue 11: Air emission impacts associated with construction traffic ...........................................171
Issue 12: Operational noise, air and light pollution ...................................................................172
Issue 13: Sites of historical or cultural interest .........................................................................172
Issue 14: Impact on the proposed Greater Addo National Park..................................................173
CHAPTER 1:
INTRODUCTION
1. INTRODUCTION
1.1 BACKGROUND
1.1.1 GENERAL
The Coega Development Corporation (Pty) Ltd has been mandated by the South African
Government to investigate the possible implementation of the Coega Industrial Development
Zone (IDZ). A new deepwater port will be built and operated by the Port Authority Division
(PAD) of Transnet to act as the primary transport facility for the IDZ1 . The proposed port will
be located at the mouth of the Coega River in Algoa Bay, which lies on the south-eastern
coast of Africa near the parallels 34°S and 26°E (Figure 1.1a).
In order to ensure that important environmental issues were addressed at an early stage in the
planning and decision making process, the Coega Development Corporation (CDC), on behalf
of PAD, commissioned a series of Environmental Impact Assessments (EIAs) for the
proposed new port. The initial port Environmental Impact Report (EIR) and subsequent
Revised Port EIR spanned the period 1997 – 2000, but due to changes in environmental
legislation and port design, they are no longer entirely relevant to the new port proposal.
Much of the background information, issues raised and assessments made have been used in
this, the Subsequent EIR. The history, relationship between the different port EIRs and the
environme ntal process followed thus far are covered in more detail in Chapter 2.
This Environmental Impact Report (EIR) assesses the economic, social and environmental
implications of the proposed deepwater port and follows an authority approved plan of study
(see Appendix A). This EIR does not cover, or attempt to assess, the environmental or socio-
economic implications of the Coega Industrial Development Zone in its entirety and is
specifically focused on the port and back-of-port activities. In addition, this report does not
comment on the overall feasibility or rationale of the IDZ, although it does comment on the
economic feasibility of the port facility.
1.1.2 AREA COVERED BY THE EIR

The area covered by this assessment is the area enclosed by the port limits as described in
Government Gazette No. 19401 of 28 October 1998. This area can be broken down into two
main sections, viz. the seaward and the landward areas.
The seaward area of the port is bounded by a line commencing at the extreme point on the
east bank of the Swartkops River, thence due east (true) for a distance of one nautical mile (1
609m) to a point in the Indian Ocean; then from that point to a second point in the Indian
Ocean one nautical mile due east (true) from Cape Recife; then from tha t point to a third point
in the Indian Ocean one nautical mile south east (true) from the extreme point on the east
bank of the Sundays River; then along the high water mark between the extreme point of the
east bank of the Sundays River and the extreme point of the east bank of the Swartkops River,
excluding the islands of Jahleel, St Croix and Brenton, and the 500m marine reserve
surrounding each island (Figure 1.1b). This enables the PAD to control all shipping activities
within the defined area.
1
While the PAD and CDC are distinct entities in the Coega Development, environmental issues in the IDZ and
port will be co-managed.
Chapter 1: Introduction 1
a)
Figure 1.1a: The Coega IDZ and Port of Ngqura relative to Africa (a), South
Africa (b) and the Port Elizabeth Metropole (c).
Africa
c)
RSA
Cape
Padrone
Ngqura Port
b)
St Croix
Island Group
Johannesburg Swaziland
Port Elizabeth
Metropole
REPUBLIC OF
Lesotho Durban Algoa Bay
SOUTH AFRICA
Eastern Cape
Cape Town East London
Port Elizabeth Cape Recife
2 Chapter 1: Introduction
Port basin
Landward port limits
Seaward port limits

Sundays River
Islands and exclusion zone
Swartkops River
Indian Ocean
Algoa Bay
Cape Recife
Figure 1.1b: The seaward and landward gazetted Port Boundaries.
The land area of the port is bounded to the north west by the N2 national road; to the north
east by the boundary between Hougham Park and Sonop Farms; to the south west by the line
joining a point on the N2 National Road and the high water mark, which will become the
boundary between St George’s Strand and the Coega IDZ; and to the south east by the high
water mark between these two boundaries (Figure 1.1b and Figure 1.1c).
Existing tracks and paths

Existing secondary roads
Existing arterial roads
Existing rail
Gazetted Port limits
CDA boundary
302/23 IDZ boundary
Markman Industrial 302/27
302/6 Shoreline
302/28
303/11 N2 N
303/2 ationa
l Roa
d
580 Sonop
Neptune
ERF 1 303/4
Wells Estate 303/5
303/6
303/8
Figure 1.1c: Cadastral map clearly outlining the various boundaries. The 8CR Property Trust
and Abalone Farm (both within 303/8) falls outside the Core Development Area and IDZ
boundaries.
While the above two figures outline the port limits as indicated in the Government Gazette the
areas under the jurisdiction of the Port Authority Division (PAD) and that which will be
ceded2 to the CDC are outlined in Figure 1.1d.
According to the CDC Framework Plan for the Industrial Development Zone, the port limits
(as defined in the Government Gazette) will include a wide range of industrial clusters and
corridors (Figure 1.1d).
2
PAD will sell at historical cost to the CDC those portions of land acquired by it and falling outside of the port,
as determined by the finalised port and IDZ boundaries.
Turning
basin
Breakwaters
Indian
Ocean

Figure 1.1d: The different industrial clusters that have been incorporated within the landward
port limits.
1.2 MOTIVATION FOR A DEEPWATER PORT 3

1.2.1 INDUSTRIAL GROWTH CATALYST
Soon after the democratic elections of 1994, the Government of South Africa initiated its
Spatial Development Initiative (SDI) Programme. The SDI programme is a short term
investment strategy that aims to unlock inherent economic potential in specific spatial
locations in southern Africa through using public resources to leverage private sector
investment.
The SDI initiative aims to create jobs and opportunities for the empowerment of previously
disadvantaged communities by encouraging economic growth, and can be regarded as a
mechanism to implement aspects of the Government’s economic strategy as set out in its
Growth, Employment and Redistribution (GEAR) policy.
The initiative consists of eleven SDIs at varying stages of delivery. The Department of Trade
and Industry has indicated the possibility of Industrial Development Zones being linked to
five of the SDIs. These are Gauteng, Richards Bay, East London, Coega and Saldanha. New
industrial development with a view to beneficiation of raw materials and export of higher
value added products is the main focus of the proposed Coega Industrial Development Zone.
A key to attracting industry to the proposed Industrial Development Zone is the provision of
an effective transport operation for imports to and exports from industries located in the zone.
The provision of the new port is seen by the CDC as an enabler to attract business to the
Industrial Development Zone and must be viewed as a catalyst for development. The success
of the Industrial Development Zone and the port are inextricably linked as the port represents
the enabling infrastructure for cargoes into and out of the Development Zone.
1.2.2 LOCATION AND GENERAL DESCRIPTION

The paleo-channel at the mouth of the Coega River allows for the economic development of a
deepwater port, which will in the final phase be able to accommodate vessels with a 16.5m
draught. The depth and protected environment of Algoa Bay in conjunction with an adjacent
IDZ establishes Coega as one of the best locations for a deepwater harbour on the South
African coast.
The port has been designed to handle containers and various bulk and break bulk cargos, and
to take account of projected business opportunities as well as changes in world shipping and
logistics operations. In addition, future plans for the port may incorporate the relocation from
the existing Port Elizabeth harbour of the manganese ore facility and the oil storage tanks.
The CDC’s preferred private partner, P&O Nedloyd, have indicated that they are interested in
establishing a container terminal at the proposed port.
The harbour will have two breakwaters, with the main breakwater extending more than two
kilometres into the sea, while the lee breakwater will be just over 1km long. Five berths will
be constructed initially, with two berths each being allocated to the container terminal and dry
bulk materials facility and one to a bulk liquid materials facility. Further expansion of the
container terminal would require an additional two berths.
3
The motivation in Section 1.2 has been provided by the Port Authority Division and the Coega Development
Corporation.
1.3 OBJECTIVES OF THIS REPORT, THE SUBSEQUENT

ENVIRONMENTAL IMPACT REPORT
The most common perception of an EIR is as a planning tool, since assessments are done to
forecast and evaluate the impact of a proposed project and its alternatives. As a planning tool,
an EIR serves to inform the authorities and interested parties of the likely impacts of a
proposed project and highlights environmental issues to be considered when making
decisions.
In order to contribute towards sustainable development, an EIR should not only identify and
evaluate the significance of environmental impacts, but should also suggest ways to mitigate
any negative impacts and optimise positive ones. In order for the EIR to contribute in this
positive manner, the environmental assessment needs to start in the early stages of project
planning, since environmental input into the design is most valuable while the project is being
developed. This allows the environmental assessment to develop from a report to an actual
process, and to become fully integrated with project planning.
The long history of environmental studies on the various port options (see Chapter 2) has
allowed for environmental issues to become a component of the design process for the port.
This has enabled some of the mitigatory measures, identified by this and previous studies (e.g.
Strategic Environmental Assessment, CSIR 1997) to be incorporated into project design. One
example is the inclusion of a sand bypass system in the port design, which should greatly
reduce the impact of the port on the longshore sediment dynamics of the region.
In summary, this EIR aims to:

• communicate the results of the EIA of the proposed port to the PAD, the Coega
Development Corporation and the public.
• assist the responsible authorities (Department of Economic Affairs, Environment and
Tourism of the Province of the Eastern Cape and the National Department of
Environmental Affairs and Tourism) to take an informed decision regarding the
environmental acceptability of the proposed project.
• inform interested and affected parties of developments related to the proposed port and
reflect comments received from them on the draft EIR.
1.4 APPROACH AND STRUCTURE OF THE REPORT
This Environmental Impact Report is a standalone report but makes reference to the numerous
specialist studies and EIRs that have been undertaken to assess the possible environmental
impacts of the proposed Coega IDZ Development. Those specialist studies that were
specifically commissioned for the port are presented in a two-part Specialist Studies Series,
viz. Part 1 – Specialist Studies from previous Port EIAs and Part 2 – Specialist Studies for the
Subsequent Port EIA. The reader is encouraged to review these specialist studies as they
include a level of detail on specific issues not appropriate to an EIR.
1.4.1 APPROACH TO THE EIA

The scope of work contained in the Plan of Study (Appendix A) is quite broad and
incorporates more than port or port associated issues, in that it covers an area which includes
other activities/clusters within the area of the Development Zone defined as “back-of-port”
(e.g. mixed use zone, electronic cluster). Thus there is a dual scope of work, as the report is
required to cover both port issues and landside issues. This is further complicated in that the
detail available on the port (primary marine infrastructure) is far greater than landside
activities/clusters as these have not been designed yet. The Pla n of Study recognised this
problem and states, “As it is unlikely that the detail of the landside development will be
available at this early stage of planning, a model, which speculates on the configuration of the
full landside development, will be used to make an assessment of the environmental impacts”.
The level of information available on the landside industrial clusters only provides a broad
classification of the industries which may be found within those clusters and thus no specific
project actions can be assessed at this stage. In contrast, information is available to undertake
assessments of specific project actions surrounding the construction and operation of the port.
The Coega Rezoning EIA (CES 2000) had similar difficulties when evaluating the proposed
land uses in the entire Development Zone, as limited specific project action information was
available.
The scope of work for the Rezoning EIA and the assessment of the landside developments
stipulated in this EIA overlap greatly. The Rezoning EIA assessed the entire Development
Zone including the port, while this EIA is required to re-examine the landside developments
seawards of the national highway. For this reason the assessment of the landside activities
draws on the work that was undertaken in the Rezoning EIA (CES 2000). In this regard, it
must be noted that the assessments in this EIR have been undertaken assuming that the
Environmental Management System outlined in Appendix B will be adhered to by the CDC.
In particular, the Open Space Management Plan, Tenant Approval Procedure, Environmental
Guidelines, Environmental Design Manual, Environmental Management Plans for
Construction and Environmental Targets must all be completed, approved and operational
prior to construction. Due to the lack of information on the proposed activities or tenants, it
must be noted that the purpose of the assessment of landside activities is to inform the
authorities and Interested and Affected Parties (IAPs) of the type of impacts that could be
expected from the various industrial clusters (assuming the guidelines itemised in Appendix B
are adhered to). This EIA therefore does not make specific application for the various
industries associated with these clusters. Tenants wishing to locate in any of the landside
clusters (e.g. Mixed use, Electronics, Port Related activities or E-commerce), and who wish
to undertake activities which invoke the EIA regulations, will still be required to obtain
approval from the relevant authorities, usually the Department of Economic Affairs,
Environment and Tourism (DEAE&T) in the Eastern Cape.
Application is, however, made for all construction activities associated with building the port
and providing the required infrastructure for the core development zone below the N2 (see
Chapter 3). Application is also made for the operation of the port, which includes the bulk,
break bulk and container terminals and infrastructure in the back-of-port area (logistics park,
offices, transport corridors, workshops, container terminal). The building and operation of the
tank farm will be subject to a separate EIA.
The varied project actions in the initial phase as well as any future tenants will be subject to
applicable legislation pertaining to the protection of the environment. They will have to
comply with the following acts.
i) The Environmental Conservation Act (1989)
ii) The National Environmental Management Act (1998)
iii) The Sea Shore Act (1935)
iv) The Minerals Act (1991)
v) The National Water Act (1998)
vi) The Dumping at Sea Control Act (1980)
vii) International Convention for the Prevention of Pollution from Ships Act (1986)
viii) Prevention and Combating of Pollution of the Sea by Oil Act (1981)
ix) The Shipping General Amendment Bill (1996)
x) The Sea Fishery Act (1988)
xi) Sea Birds and Seals Protection Act (1973)
xii) National Heritage Resource Act (1999)
A thorough review of the legislation which pertains to the Port was undertaken by Cohen &
La Cock (1997) (see Specialist Studies Series - Part 1). Further impact specific legal
information was undertaken in the Revised EIA (CEN 2000; see Specialist Studies Series -
Part 1) and a legal review (Appendix F) was also conducted in the risk assessment (WSP
2001, Specialist Studies Series - Part 2).
The Plan of Study requires that an appraisal be made of the full development and not only
Phase 1, which was the case in the Revised EIA. Again the information available on future
developments is scant and will vary greatly as future needs change. The approach taken in
this EIA will be to identify and discuss potential issues associated with the future
development scenarios rather than discuss specific impacts. These future developments will
obviously be subject to Environmental Impact Assessments and the issues identified in this
EIA should provide an important framework for that process.
Numerous recommendations and proposals have been made since the initial studies on the
proposed Coega Development were undertaken as far back as 1996. The nature, structure and
function of the port have, however, evolved substantially since many of these earlier studies.
This EIR has taken cognisance of, but is not bound to any previous recommendations.
Specific recommendations pertaining to the current project have been formulated and
included in this report.
1.4.2 STRUCTURE OF THE REPORT

Chapter 1 - Introduction
This chapter outlines the background to the report, the objectives of the assessment as well as
the assumptions made. The chapter also provides a brief motivation regarding the building of
the port.
Chapter 2 - Environmental Impact Process

In Chapter Two the environmental legislative process in South Africa is discussed with
specific reference to the proposed port. The process followed from the inception of
environmental work on the port in 1996 to this, the subsequent EIA, is discussed. As the
review of alternatives is an important aspect of an environmental evaluation of a project,
chapter two provides an overview of the screening process undertaken in the Init ial and
Revised EIRs. The structure and responsibilities of the assessment team are also outlined.
Chapter 3 - Project description

A full description of both the port and back-of-port structure is provided. The primary project
actions e.g. dredging are specifically discussed.
Chapters 4 & 5 - Terrestrial description and Terrestrial impacts and mitigation

Chapter Four provides a detailed description of the terrestrial environment in the region, while
Chapter Five assesses and rates the possible impacts, both positive and negative, that the port
and back-of-port may have on the terrestrial environment.
Chapters 6 & 7 - Marine description and Marine impacts and mitigation

Chapter Six provides a detailed description of the marine environment around the proposed
port, while Chapter Seven assesses and rates the possible impacts, both positive and negative,
that the port and back-of-port may have on the marine environment.
Chapters 8 & 9 - Socio-economic description and Socio-economic impacts and

mitigation
Chapter Eight describes and discusses the social and economic environment in and around the
Coega region. Chapter nine discusses and assesses the various impacts that the port will have
on the economic and social attributes of the Coega area and the Eastern Cape as a whole.
Chapter 10 - Final Discussion and Conclusions

Chapter Ten provides an overview of the entire EIR and specifically discusses the key
environmental issues associated with the proposed port and the key recommendations made.
Chapter 11 - References
Chapter eleven contains all the references quoted in the report as well as specific lists of the
specialist studies that were undertaken for the various port EIAs.
Appendix A - Plan of study for the EIR.
Appendix B - Coega Development Corporation Environmental Management Policies and

Systems.
Appendix C - Specific recommendations for inclusion in the construction Environmental

management Plan for the port of Ngqura.
Appendix D - Final Public Participation. For the Subsequent EIR for the Port of Ngqura.
Appendix E - Additional Specialist study on resettlement.
1.5 SPECIALIST STUDIES COMMISSIONED
As mentioned, numerous specialist studies have been commissioned for the two prior port
EIAs (see Chapter 11), with five standalone studies being initiated for this, the Subsequent
Port EIA. While considerable research has been conducted on various biophysical aspects
surrounding the building of a port at Coega, a number of information gaps were identified in
consultation with IAPs and the authorities. The following studies were commissioned and are
found in Part 2 of the Specialist Studies Series.
1.5.1 BONTVELD STUDY

The conservation status and nature of Bontveld in the Eastern Cape and in the IDZ in
particular has been widely debated, with the Rezoning EIA (CES 2000) recommending that
further work should be undertaken on this vegetation type. The Bontveld study was
undertaken by Dr Natalie Birch and investigated the extent of Bontveld in the Eastern Cape,
and more specifically the conservation status and impact that the Coega Development would
have on this vegetation type.
1.5.2 RISK ASSESSMENT

Environmental Impact Assessments are by nature partly qualitative and often rely on
professional judgement to assess impacts. The need for a more quantitative approach to
assessing some of the potentially devastating yet unlikely impacts associated with ports was
identified in the review of the Revised Port EIA. The areas that were identified as needing an
intensive quantitative assessment were:
• The risks associated with increased shipping in the Algoa Bay area.
• The risks of pollution and oil spills as a result of the port development.
• The risks associated with ballast water and the possible introduction of alien species.
• The risk of collisio n between vessels and marine mammals.
This risk assessment was undertaken by David Sinclair (Metoc plc) and Mike Howard (WSP).
1.5.3 VISUAL ASSESSMENT

A visual assessment on the proposed development was undertaken by Megan Anderson and
this updates the previous visual assessment prepared by OVP Associates in association with
Megan Anderson Landscape Architects (OVP 1999).
1.5.4 AN ECONOMIC EVALUATION OF THE PROPOSED PORT OF NGQURA

AND DEVELOPMENT OF A CONTAINER TERMINAL
One of the biggest information gaps that was identified in the Revised EIR was the lack of a
thorough economic appraisal of the proposed port. A study was undertaken by Dr Bernal
Floor and Dr Henriette van Niekerk of Maritime Education Research and Information
Technology (Pty) Ltd (M.E. R.I.T). This assessment aimed to establish through a cost benefit
study whether the economic costs associated with the provision of the port of Ngqura at
Coega will be justified by its benefits.
1.5.5 DREDGING, EXCAVATION AND DISPOSAL

One of the biggest project actions associated with the building of the port is dredging and the
subsequent disposal of material. A specialist study was commissioned to examine possible
alternatives, impacts and mitigatory actions associated with both the dredging and disposal of
material. This study was conducted by CES in conjunction with EnviroFish Africa (Pty)Ltd.
1.5.6 AIR QUALITY IMPACT ASSESSMENT

The impact that the construction and operational phases of the port may have on air quality
was identified as an area which required specialist modelling and assessment. Drs Burger and
Watson of Environmental Management Services (EMS) conducted a study investigating the
emissions associated with the construction and operation of the port.
1.5.7 RESETTLEMENT IMPACT REPORT

In addition to the five specialist reports commissioned for the Draft Subsequent Port EIR an
additional specialist study concerning resettlement was conducted for the Final EIR. This
report while not required in the Plan of Study (see appendix A) was required to adequately
address the comments raised by IAP’s during the comments period.
The report takes a forensic audit approach to establish how the people were moved, what
involvement they had in the process and what the current impact is. The report is found in
Appendix E.
1.6 ASSUMPTIONS OF THE REPORT
The main assumptions in this report are presented below:

• The specialist reports commissioned for this, the Subsequent Port EIR, were based on
maps and information supplied by the PAD, the Coega Deve lopment Corporation and
the consulting engineers in February 2001. Similarly this EIR is based on information
supplied up until the end of February 2001 (see Chapter 3, Project Description) and
does not take into consideration any changes from that time onwards.
• The consulting engineers took cognisance of the major issues outlined in the Initial
and Revised Environmental Impact Assessments in their design and planning of the
port area.
• An Environmental Management System based on the conditions of approval will be
implemented before construction of the port or the back-of-port area begins.
• An Environmental Management Plan based on the conditions of approval will be
designed for the construction and operation of the port and will be available before
construction commences.
• The necessary hazardous and general waste disposal sites will be established by the
responsible Local and Regional Authorities. The Coega Development Corporation will
assist in the facilitation of the process.
• The Coega Development Corporatio n will negotiate equitable solutions with current
industries (mariculture and salt works), as previous studies have indicated that they
will need to be relocated or closed down.
• The Coega Development Corporation will ensure the necessary rezoning of the Coega
Development Zone and port area. This EIA does not address land rezoning issues.
• The recommended mitigation measures will be implemented by the Port Authority
Division and where appropriate by the Coega Development Corporation.
CHAPTER 2:
ENVIRONMENTAL IMPACT
ASSESSMENT PROCESS
2. ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

2.1 INTRODUCTION
This chapter provides an outline of the EIA process in South Africa and discusses the process
that has been followed in this and previous Coega Port EIAs. The relationship between the
different phases of the EIA is also explained, along with the rating system used in this study.
The role of public participation in the port EIA process is specifically addressed and
explained. Lastly the approach that this EIA has taken to assess alternatives, and the make-up
and responsibilities of the environmental assessment team is discussed.
2.2 THE EIA PROCESS IN SOUTH AFRICA
2.2.1 INTRODUCTION
An Environmental Impact Assessment (EIA) involves three phases (Figure 2.2a), namely the
scoping phase, the environmental impact assessment phase and the record of decision phase.
Each phase is concluded with the production of a report and public review or appeal. This
process ensures an open participatory approach to a study, with the full involvement of
Interested and Affected Parties in order to ensure that all the impacts are identified and that
planning and decision making is informed, transparent and accountable.
2.2.2 SCOPING PHASE

The scoping phase has four key objectives:
• To provide for the involvement of Interested and Affected Parties (IAPs) in the
identification of issues;
• To identify reasonable alternatives;
• To ensure that all key issues and environmental impacts that will be generated by the
project are identified;
• To identify any Fatal Flaws.
Consultation with the relevant authorities
The first step of the EIA process involves consultation with the relevant authority involved
with the decision making process concerning the authorisation of the proposed project. The
main purpose of this is to clarify the requirements of the regulations and procedures to be
followed.
An “Application for Authorisation” for the proposed project is completed by the proponent
and the environmental consultant, and submitted to the authority involved. At this stage the
authority also registers the activity. A “Plan of Study” is completed by the environmental
consultant and submitted to the authority for approval. The Plan of Study indicates the
procedure to be followed and includes an estimated time frame for each activity.
Public participation process

Interested and Affected Parties play an important role in the process, as many of their
concerns and issues can be included in the project proposal, to ensure a development which is
as environmentally acceptable as possible.
In order to inform the public of the proposed project and to invite members of the public to
register as Interested and Affected Parties (IAPs), the proposed project is advertised in local
Chapter 2: Environmental Impact Assessment Process 13

newspapers. The public have two weeks from the time the advert is published to register as
IAPs.
A Background Information Document (BID) is then prepared and posted to all registered and
identified IAPs. The purpose of the BID is to inform the public of the project and the
environmental consultants involved.
If it is necessary, a public meeting is held where issues and concerns are gathered. Other
means of involving the public include holding focus group meetings and an open house.
Issues and concerns raised by the public are included in the draft scoping report. It is
attempted to provide detailed solutions to the majority of concerns at the scoping phase. For
this reason, it is advantageous for the public to be involved in the development proposal at the
conceptual stage, so that concerns can be included in the project design.
Scoping report
The draft scoping report is usually released for public and authority review. The availability
of the report is advertised in the local newspaper and is situated at an easily accessible
location.
Additional comments, issues and concerns raised by IAPs and the authorities are included in
the final scoping report. The scoping report is lodged with the relevant authorities, who will
decide whether the project can go ahead or not, and/or whether an EIA is required to further
investigate issues and alternatives. Should an EIA not be required, the Record of Decision is
issued at this stage.
2.2.3 ENVIRONMENTAL IMPACT ASSESSMENT PHASE

The main purpose of this phase is to gather and evaluate environmental information, so as to
provide sufficient supporting arguments to evaluate overall impacts, consider alternative
options, and make a valued judgement in choosing the best development alternative. The
resulting document is an Environmental Impact Report (EIR).
Consultation with the re levant authorities

If the decision is that an EIA is required, a plan of study for this might be required. On
acceptance, the EIA process can go ahead.
The level of an impact assessment will depend on the nature and extent of the development
proposal in terms of its complexity, the sensitivity of the environment and issues identified
during the scoping process.
Environmental impact report

Specialist input to the proposed project is included at this stage. The EIR consists of an
introductory section, a specialist section and an environmental impact section, where impacts
are assessed and rated according to a scale. Mitigation measures are usually given by the
specialist consultants and included in the last section.
14 Chapter 2: Environmental Impact Assessment Process

APPLICATION Application to authority for activities listed in terms of section 21 of the Environmental
PROCEDURE Conservation Act, 1989
Submit Plan of Study for Scoping to the relevant authority
Authority review and approval of Plan of Study
Advertise the project in newspapers and any other means to ensure the majority of the public are
made aware of the proposed project
SCOPING PHASE AND PUBLIC
Identify Interested & Affected Parties (IAPs)
Circulate Background Information Document to IAPs

INVOLVEMENT
Advertise and hold Public meeting
Preparation and release of Draft Scoping Report for public and authority review
Prepare Final Scoping report incorporating comments and issues raised by authorities and IAPs and submit
to the authority
Authority will then either authorise the project and issue the Record of Decision, reject the project or
recommend an EIA as the way forward
Submit Plan of Study for the EIA to the relevant authority
Authority review and approval of Plan of Study

EIA PHASE
Specialist involvement
Prepare EIR and submit to authority and IAPs for review
Prepare the Comments Report

PHASE
ROD
Submit EIR and Comments Report to the authority involved for the Record of Decision
Figure 2.2a: A brief overview of the EIA process.

Public participation process

The EIR is made available for public and authority review. The availability of the report is
advertised in the local newspaper and is situated at an easily accessib le location.
Additional comments, issues and concerns raised by IAPs and the authorities are included in a
Comments Report.
The EIR, including the Comments Report, is then lodged with the relevant authorities.
2.2.4 RECORD OF DECISION

Upon thorough examination of the EIR, the authority will either issue a Record of Decision
(ROD), which either authorises the project or rejects it, or require further details to clarify
certain issues. Should authorisation be granted, the ROD usually carries Conditions of
Approval. The proponent is obliged to adhere to these conditions.
A copy of the ROD is sent to all registered IAPs. The public have one month in which to
appeal the decision, should they wish to do so. An appeal must be submitted to the authority
involved.
2.3 IDENTIFIED ACTIVITIES REQUIRING AUTHORISATION
The construction and operation of the proposed Ngqura Port will result in a number of listed
activities being undertaken. This Environmental Impact Assessment makes application to
undertake the following listed activities:
1. The construction or upgrading of:

(a) Transportation routes and structures, and manufacturing, storage or handling facilities
for any substance which is dangerous or hazardous and is controlled by national legislation.
Access routes will be required in the designated port area and the Port Authority Division
(PAD) have indicated that they will consider the relocation of the ore dumps and tank farm
currently located within the Port Elizabeth harbour. With the proposed movement of the tank
farm being after phase 1, it is recommended that a separate EIA be conducted on this activity
prior to authorisation.
(b) Roads, railways and associated structures outside the borders of town planning schemes.
Roads and railway lines will need to be built within the area designated as the port area.
(c) Marinas, harbours and all structures below the high water mark of the sea.
The port will require extensive structures e.g. breakwaters, berths etc to be built.
(d) Canals and channels, including diversions of the normal flow of water in a river bed and
water transfer schemes between water catchments and impoundments.
The proposed harbour will divert the flow of water in the Coega River.
(e) Dams, levees or weirs affecting the flow of a river.

Parts of the port will be located in the mouth of the Coega Estuary.
2. The reclamation of land below the high water mark of the sea and in inland water
including wetlands.

2.4 RELATIONSHIP BETWEEN THE VARIOUS PORT EIA

ASSESSMENTS
As mentioned in the introduction to Chapter 1, the environmental assessment of the Ngqura

Port was initiated in 1996 and since then has undergone a number of iterations (Table 2.4a).
The most important documents produced thusfar are:
a) Environmental Impact Report on a proposed harbour in the vicinity of Coega, Port

Elizabeth. This document is now termed the Initial Environmental Impact Report.
b) Draft Environmental Impact Report for the proposed Port of Ngqura, Port Elizabeth. This
report is now termed the Revised Environmental Impact Report.
Initial Environmental Assessment (1996 – 1997)

The initial environmental assessment was undertaken during a period when the project was
evolving very rapidly. The lack of detail about the development precluded a quantitative
assessment being made and created uncertainty about the potential environmental effects of
some of the project actions. To overcome these limitations, a worst-case scenario was
accepted and the precautionary principle adopted throughout the initial impact assessment. A
number of options were assessed at this stage, which ranged from extending the existing Port
Elizabeth Harbour to a number of designs in and around the mouth of the Coega Estuary. This
study formed the basis on which PAD and Coega decided to move to a detailed design phase.
Revised Environmental Assessment (1998 – 2000)

With the move to the detailed design phase of the project, many of the design issues were
clarified, which resulted in more accurate assessments of the potential impacts. The port
design during this period was orientated to providing an inter- modal transhipment point for
bulk cargoes for industries in the Industrial Development Zone and hinterland. The Coega site
was selected and three berths were planned (see Plate 2.4a). A number of additional specialist
studies were commissioned on the possible impacts on the birds, vegetation, fishing and water
circulation in and around the Coega area. This EIA provided the platform for the subsequent
EIA and CEN is gratefully acknowledged.
Subsequent Environmental Assessment (this study)

After the submission of the revised environmental impact report (CEN 2000), Government
ratified the recommendation of the CDC of selecting P&O Nedloyd/Technology and
Communications International as their preferred private partner for the development of the
proposed port. The consortium’s proposal included the development of a container terminal
and transhipment hub in the Port of Ngqura, associated with an industrial park, logistics
centre and electronic commerce (e-commerce) business park. The construction of a container
terminal necessitated several structural changes to the port configuration, as well as changes
to the back-of-port structures and activities. The new design now incorporates two main
breakwaters, with the main breakwater extending more than two kilometres into the sea, while
the lee breakwater will be just over 1km long. Five berths will be constructed initially, with
two berths each being allocated to the container terminal and dry bulk materials facility and
one to a bulk liquid materials facility. Further expansion of the container terminal would
require an additional two berths. While the breakwater design has only undergone slight
modification from the one proposed in the revised EIR, the increase from three to five (and
possibly seven) berths has resulted in a scale change in many activities. After analysing the
proposed changes, the authorities recommended that the CDC conduct a subsequent
environmental assessment in accordance wit h the process as stipulated in the regulations.

Table 2.4a: Process followed during the Initial and Revised Environmental Impact
Assessments.
June 1996: Scoping
Scoping of possible fatal flaws for the construction of a port in the vicinity of Coega commenced during June 1996. A team to undertake the
EIA was appointed during late November 1996.
⇓
December 1996: Scoping
A Draft Scoping Report listing issues and proposed studies was published and made available to Interested and Affected Parties, at an Open
House in December 1996.
⇓
December 1996: Open House
Public comment on Draft Scoping Report was made and aspects of the proposed project were discussed.
⇓
December 1996 - January 1997: Specialist Studies
Based on the Scoping exercise, appropriate specialist studies were commissioned to address the issues identified and determine conditions
and guidelines under which the proposed port could proceed.
⇓
January 1997 - ongoing
Public Participation Process: Three Public Meetings were held in Port Elizabeth, Motherwell, Kwazakhele and Uitenhage.
⇓
February 1997
The specialist studies, which were commissioned, were subjected to reviews at workshops attended by other experts in the field of concern.
⇓
February - March 1997: Draft EIR
The Draft Environmental Impact Report (EIR) and Summary Report, which addressed key environmental issues and recommended measures
and conditions to enhance and/or mitigate impacts, was drafted.
⇓
March 1997: Open House
The Draft EIR was made available and public comment sought. Two response workshops were held on 20 March 1997, where key areas of
concern were discussed.
⇓
April 1997: Final date for comment on Draft EIR
Analysis of comments received and revision of draft EIR commenced. A Response Report on comments received was produced by the CSIR
and included as part of the final SEA.
⇓
May 1997: Submission of Final EIR
Final EIR, SEA and Response Report submitted to PAD and the Industrial Development Zone Initiative. These reports were made available
in Libraries for public review.
⇓
June 1997: Integration
The EIR was to be integrated with the financial and other studies undertaken by the Coega Industrial Development Initiative.
⇓
June 1998: Decision
PAD decided to proceed to the detailed design phase for the port.
⇓
July 1998: Submission of plan of study
Submission of a proposal for the revision of the EIA to the Department of Economic Affairs, Environment and Tourism, Province of the
Eastern Cape.
⇓
August 1998: Additional Specialist Studies
Based on the review exercise, appropriate specialist studies to address the issues identified during initial study and the known changes to
design and location were undertaken.
⇓
October 1998
Advertisement placed in local newspapers calling for interested/affected parties to identify themselves.
⇓
Draft EIR
The Draft Environmental Impact Report (EIR) and Summary Report was released for public information.
⇓
Open House
The findings of the Draft EIR were presented at an open house in Port Elizabeth.

Plate 2.4a: The port design assessed in the Revised Port EIR.
Bu
lk
ter
mi
nal
Con nal area
term
taine
i
r
Basin
-16 m CD
Jahleel Island
Entra
nce
Port basin
chann
Construction sites
el
Access roads
Construction and
haul roads
Figure 2.4a: Port and back-of-port structure assessed in this, the subsequent EIR.

2.5 THE EIA PROCESS FOLLOWED IN THIS STUDY

2.5.1 GENERAL PROCESS
After the decision was made to conduct a subsequent environmental assessment of the port, a
pre-application meeting was held on 6 July 2000 to establish the requirements of the
subsequent investigation. The following procedure was agreed upon and has been followed:
Submission of a plan of study for scoping

The plan of study for scoping was submitted to the National Department of Environmental Affairs and Tourism and the Eastern Cape
Department of Economic Affairs, Environment and Tourism.
⇓
Public review of the scoping report
⇓
Submission and approval of a plan of study for the EIR
Once the scoping report was accepted by the authorities, a plan of study was submitted to and approved by the National Department of
Environmental Affairs and Tourism and the Eastern Cape Department of Economic Affairs, Environment and Tourism.
⇓
Commissioning and completion of additional specialist studies
The additional specialist studies viz. Risk assessment, Economic study, Bontveld appraisal, Air quality and Dredging study
were all commissioned in early 2001.
⇓
Compilation of the Draft Subsequent EIR
⇓
Public review of the EIR
⇓
Final subsequent EIR of the Port of Ngqura
2.5.2 PUBLIC PARTICIPATION PROCESS

Sandy & Mazizi Consulting cc. were appointed to facilitate the process of Public Participation
for the Subsequent Environme ntal Impact Report for the Port of Ngqura. The process as
detailed below follows an authority approved plan for public participation.
The following provides a brief overview of the various stages of the Public Participation
process:
• Stage 1: Notification and Distribution of the Subsequent Draft Port EIR for Comment
• Stage 2: Public Meetings and Consultation with I&APs
• Stage 3: Issues and Response Trail
• Stage 4: Public Participation Report
• Stage 5: Submission to Authorities
The following outlines the process in more detail:
Notification and Distribution of the Subsequent Draft Port EIR

As agreed with the Authorities, the Subsequent Port EIR and information sharing around its
availability would take place as follows:
Report in Libraries - the report was placed in the following libraries: Govan Mbeki, Newton
Park, Walmer, Motherwell, New Brighton, Uitenhage Main Library and Despatch; University
of Port Elizabeth; Port Elizabeth Technikon; University of Cape Town; and Rhodes
University.

Report Distribution - Distribute Subsequent Port EIR to relevant authorities and key I&APs.
Distribute Executive Summary of the Subsequent Draft Port EIR to other identified I&APs.
I&AP Notification - Notify all I&APs in writing of the availability of the Subsequent Port
EIA. ALL 980 I&APs on the database were notified and sent a Briefing Paper. Although a
period of 21 days was agreed to with the Authorities for public comment, 28 days were
provided.
Advertisements - Advertisements notifying I&APs of the availability of the Subsequent

Report and encouraging I&APs to register their interest were placed in the following
newspapers: Sowetan, Business Day, Daily Dispatch, Herald and Die Burger.
Loudhailer Announcements - In addition to the plan of study and in order to create awareness
in the disadvantaged community of the Public Meeting at Centenary Hall, loudhailer
announcements were made.
Public Meetings and Consultations with I&APs

In addition to submitting written comments I&APs were provided the opportunity to raise
issues and concerns on the Subsequent Port EIA for Coega through Public Meetings, an Open
Day and Networking meetings.
The following Open Day and Public Meetings were held.

• Open Day
1 August 2001, 10am - 6pm, Port Elizabeth City Hall
• Public Meetings
31 July 2001, 5:30pm, Raymond Mhlaba Sports Centre, Motherwell
2 August 2001, 5:30pm, Centenary Hall, New Brighton
The Open Day provided I&APs with the opportunity to view information presented in the
Draft Subsequent EIR, engage with Specialist Cons ultants and note issues of concern and/or
additional recommendations. This meeting was advertised in local and regional newspapers
and all I&APs were invited to attend.
While only the Open Day was planned for and approved by the Authorities, two additional
Public Meetings were held in the disadvantaged community - one in Motherwell and the other
in New Brighton. A total of 461 I&APs were reached through the Open Day and Public
Meetings.
Networking Meetings
In order to accommodate a wide range of I&APs with different interests and to ensure that
key I&APs were consulted through the public participation process, a series of networking
meetings were held. The purpose of the meetings was to provide I&APs with background
information on the process and engage them in discussion on issues, concerns and
recommendations that they may have with regards to the Subsequent Draft EIR.
Approximately 45 organisations were consulted through the networking phase and the
facilitators met with an approximate total of 310 I&APs.
Other I&APs were contacted telephonically and encouraged to submit their comments in
writing.

Issues and Response Trail

The issues, concerns and recommendations raised by I&APs through the public participation
process have been summarised into an Issues Trail which has been submitted to the relevant
specialist consultant and other parties for their response.
The Issues and Response Trail is a mechanism to indicate to I&APs how the issue they have
raised is addressed in the Final EIR or will be addressed in future, e.g. through the
Environmental Management Programme. (See the Public Participation Report in Appendix D
for the Issues and Response Trail.)
Final Report
The last stage in the public participation process is the submission of the Final Public
Participation Report, which is attached as Appendix D of this Report.
Once a decision has been made on the project, all I&APs will be notified in writing of the Record
of Decision (ROD).
2.6 ASSESSMENT CRITERIA
The rating system used for assessing issues in this EIR is primarily based on three criteria,
namely:
1) The relationship of the issue to temporal scales (Box 2.6a);

2) The relationship of the issue to spatial scales (Box 2.6b); and
3) The severity of the issue (Box 2.6c).
These three criteria are combined to describe the overall importance rating, namely the
significance (Box 2.6d). In addition, the following parameters are used to describe the issues:
4) The risk or likelihood of the issue occurring (Box 2.6e); and

5) The degree of confidence placed in the assessment of the issue (Box 2.6f).
2.6.1 TEMPORAL SCALE

The temporal scale defines the significance of the impact at various time scales, as an
indication of the duration of the impact.
Box 2.6a: Temporal scale used in the EIA.

• Short term - less than 5 years. Many construction phase impacts will be of a short duration.
• Medium term - between 5 and 20 years.
• Long term - between 20 and 40 years (a generation) and from a human perspective, essentially
permanent.
• Permanent - over 40 years and resulting in a permanent and lasting change.
2.6.2 SPATIAL SCALE

The spatial scale defines physical extent of the impact.
Box 2.6b: Spatial scales used in assessing issues.
• Household - this scales applies to households along the affected area.
• Localised - at localised scale and a few hectares in extent, including port and immediate surrounds.
• District - Port Elizabeth metropole or Algoa Bay.
• Regional - Eastern Province.
• National - South Africa.
• International

2.6.3 SEVERITY/BENEFICIAL RATING SCALE

The severity scale was used by the various specialists in order to scientifically evaluate how
severe negative impacts would be, or how beneficial positive impacts would be, on a
particular affected system (for ecological impacts) or a particular affected party. It is a
methodology that attempts to remove any value judgements from the assessment, although it
relies on the professional judgement of the specialist.
Box 2.6c: Severity/beneficial scale used in the EIA.
Very severe Very beneficial

An irreversible and permanent change to the affected A permanent and very substantial benefit to the affected
system(s) or party(ies) that cannot be mitigated. For system(s) or party(ies), with no real alternative to
example, the permanent change to topography achieving this benefit. For example, the creation of a
resulting from a quarry. large number of long term jobs.
Severe Beneficial
Long term impacts on the affected system(s) or A long term impact and substantial benefit to the affected
party(ies) that could be mitigated. However, this system(s) or party(ies). Alternative ways of achieving
mitigation would be difficult, expensive or time this benefit would be difficult, expensive or time
consuming or some combination of these. For consuming, or some combination of these. For example,
example, the clearing of forest vegetation. an increase in the local economy.
Moderately severe Moderately beneficial
Medium to long term impacts on the affected system(s) A medium to long term impact of real benefit to the
or party(ies) that could be mitigated. For example, affected system(s) or party(ies). Other ways of optimising
constructing a narrow road through vegetation with a the beneficial effects are equally difficult, expensive and
low conservation value. time consuming (or some combination of these), as
achieving them in this way. For example, a slight
improvement in the (local) roads.
Slight Slightly beneficial
Medium or short term impacts on the affected A short to medium term impact and negligible benefit to
system(s) or party(ies). Mitigation is very easy, cheap, the affected system(s) or party(ies). Other ways of
less time consuming or not necessary. For example, a optimising the beneficial effects are easier, cheaper and
temporary fluctuation in the water table due to water quicker, or some combination of these. For example, a
abstraction. slight increase in the amount of goods available for
purchasing.
No effect Don’t know/Can’t know
The system(s) or party(ies) is not affected by the In certain cases it may not be possible to determine the
proposed development. severity of an impact.
2.6.4 SIGNIFICANCE SCALE

The ENVIRONMENTAL SIGNIFICANCE scale is an attempt to evaluate the importance of a
particular impact. This evaluation needs to be undertaken in the relevant context, as an impact
can either be ecological or social, or both. The evaluation of the significance of an impact
relies heavily on the values of the person making the judgement. For this reason, impacts of
especially a social nature need to reflect the values of the affected society. A six-point
significance scale has been applied (see Box 2.6d).
In many cases scientists have to produce an assessment in the absence of all the relevant and
necessary data. American legislation (CEQ regulations at 40 CFR 1502.22) has considered
these limitations, and makes the following recommendations:
“When an agency is evaluating reasonably foreseeable significant adverse effects on the
human environment in an Environmental Impact Statement (EIS) and there is incomplete or
unavailable information, the agency shall always make clear that such information is lacking
if the incomplete information is essential to a reasoned choice among alternatives. If the
overall costs of obtaining it are not exorbitant, the age ncy shall include the information in the
EIS”.

There are two acceptable procedures to follow to compensate for a shortage of data:
1. It is more important to identify likely environmental impacts than to precisely evaluate the
more obvious impacts.
All assessors (the different specialists) try to evaluate all the significant impacts, recognising
that precise evaluation is not possible. It is better to have a possible or unsure level of
certainty on important issues than to be definite about unimportant issue s.
2. It is important to be conservative when reporting likely environmental impacts.

Because of the fact that assessing impacts with a lack of data is more dependable on your own
scientific judgement, the rating on the certainty scale cannot be too high. If the evidence for a
potential type of impact is not definitive in either direction, the conservative conclusion is that
the impact cannot be ruled out with confidence, not that the impact is not proven. It is for
these reasons that a degree of certainty scale has been provided, as well as the categories
DON’T KNOW and CAN’T KNOW.
Box 2.6d: The significance rating scale.
VERY HIGH
These impacts would be considered by society as constituting a major and usually permanent change to the (natural
and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects.
Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance.
Example: The establishment of a large amount of infrastructure in a rural area which previously had very few
services, would be regarded by the affected parties as resulting in benefits with a VERY HIGH significance.
HIGH
These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as
HIGH will need to be considered by society as constituting an important and usually long term change to the (natural
and/or social) environment. Society would probably view these impacts in a serious light.
Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating
of HIGH over the long term, as the area could be rehabilitated.
Example: The change to soil conditions will impact the natural system, and the impact on affected parties (in this
case, people growing crops on the soil) would be HIGH.
MODERATE
These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts
rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium
term change to the (natural and/or social) environment.
Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY
significant.
Example: The provision of a clinic in a rural area would result in a benefit of MODERATE significance.
LOW
These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts
rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and
usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely
to have little real effect.
Example: The temporary change in the water table of a wetland habitat, as these systems are adapted to fluctuating
water levels.
Example: The increased earning potential of people employed as a result of a development would only result in
benefits of LOW significance to people who live some distance away.
NO SIGNIFICANCE
There are no primary or secondary effects at all that are important to scientists or the public.
Example: A change to the geology of a particular formation may be regarded as severe from a geological
perspective, but is of NO significance in the overall context.
DON’T KNOW

In certain cases it may not be possible to determine the significance of an impact, for example, the primary or
secondary impacts on the social or natural environment given available information.
Example: The effect of a particular development on people’s psychological perspective of the environment.
2.6.5 RISK OR LIKELIHOOD SCALE

The risk or likelihood of all impacts taking place as a result of project actions differs. There is
no doubt that some impacts would occur if the port goes ahead, but certain other (usually
secondary) impacts are not as likely, and may or may not result from the port. Although these
impacts may be severe, the likelihood of them occurring may affect their overall significance
and will be taken into account.
Box 2.6e: The risk or likelihood scale.
Very unlikely to occur – the chance of these impacts occurring is extremely slim, e.g. an earthquake destroying
back-of-port area.
Unlikely to occur – the risk of these impacts occurring is slight, but impacts such as a catastrophic shipping
accident may occur.
May occur – the risk of these impacts is more likely, although not definite, for example the disturbance of nesting
birds on Jaheel Island.
Will definitely occur – there is no chance that this impact will not occur, for example the clearing of vegetation for
the back-of-port area.
2.6.6 DEGREE OF CERTAINTY OR CONFIDENCE

It is also necessary to state the degree of certainty or confidence with which one has predicted
the significance of an impact. For this reason, a ‘degree of certainty’ scale has been provided
to enable the reader to ascertain how certain we are of our assessment of significance:
Box 2.6f: The degree of certainty or confidence used in this EIA.
Definite: More than 90% sure of a particular fact. To use this, one will need to have substantial supportive data.
Probable: Over 70% sure of a particular fact or the likelihood of that impact occurring.
Possible: Only over 40% sure of a particular fact or of the likelihood of an impact occurring.
Unsure: Less than 40% sure of a particular fact or the likelihood of an impact occurring.
2.7 STRUCTURE AND RESPONSIBILITY OF THE EIA TEAM
Coastal and Environmental Services (CES) are the principal consultants for this
Environmental Impact Assessment (EIA). In terms of the EIA, CES are responsible for:
• co-ordinating and managing the EIA;

• ensuring that the EIA is comprehensive and internationally acceptable;
• ensuring that Interested and Affected Parties (IAPs) have had the opportunity to
comment and that their comments are considered in light of the project;
• identifying and assessing environmental impacts and making recommendations
regarding the mitigation of negative impacts and optimisation of positive ones.
CES are based in Grahamstown, South Africa and have extensive experience preparing EIAs
in the Eastern Cape. CES have been previously involved in the Coega Project, having
undertaken the Rezoning EIA, Coega Kop EMPR and the overall integration report, and are
therefore well versed on the issues surrounding the Coega Development as a whole.
A number of different agencies were involved in reassessing many of the existing issues that
pertain to the port, as well as assessing some new issues that have been identified through the

recent specialist studies. The CES team for this EIA consisted of Dr Ted Avis, Dr Angus
Paterson, Dr Natalie Birch, Dr Aidan Wood and Mr Paul Vorwerk. CES were responsible for
overall co-ordination, project management and reassessment of previously identified issues.
CES also co-ordinated the dredge disposal and Bontveld specialist studies. The following
specialists were also involved in the EIA:
• Dr Warwick Sauer (Enviro -Fish Africa) – Marine ecosystems and dredging study;
• Dr William Branch (Bayworld) – Terrestrial ecosystems and dredging study;
• Dr Henriette Van Niekerk (MERIT) – Economic cost benefit analysis;
• Dr Bernal Floor (Transport Research Associates) – Economic cost benefit analysis;
• Ms Megan Anderson (Megan Anderson Consulting) – Visual assessment;
• Prof Tris Wooldridge (University of Port Elizabeth) – Dredging study;
• Dr Echaart Schumann (Independent) – Dredging study;
• Mr Mike Howard (WSP Environmental) – Risk Assessment; and
• Mr David Sinclair (METOC, United Kingdom) – Risk Assessment.
• Dr Hilda Van Vlanderen – Resettlement
2.8 ASSESSMENT OF ALTERNATIVES
2.8.1 APPROACH TAKEN WITH RESPECT TO ALTERNATIVES

One of the facets of an EIA is the assessment of alternatives. These alternatives include
demand alternatives, activity alternatives, location alternatives, process alternatives,
scheduling alternatives and input alternatives.
On the basis that government has already taken an ‘in principle’ decision to proceed with its
Spatial Development Initiatives, and in some cases their associated Industrial Development
Zones, a policy decision was taken by the Ngqura Environmental Committee (NEC)4 not to
consider alternative land uses. Indeed the evaluation of alternative land uses is more suited to
a Strategic Environmental Assessment (SEA), as initially done on the Coega Development
(CSIR 1997), and falls outside the scope of this EIA. This EIA rather focuses on the
identification and mitigation/optimisation of the potential environmental issues associated
with the proposed port.
That is not to say that other alternatives have not been assessed. During the Initial
Environmental Impact Assessment a range of port options in Algoa Bay were assessed
(Section 2.6.2). In addition a number of alternatives were thoroughly investigated in various
specialist studies (Part 2 - Specialist Studies for the Subsequent Port EIA), for example, the
dredging, excavation and disposal study revealed a number of location and activity
alternatives.
2.8.2 SCREENING OF PORT OPTIONS IN ALGOA BAY

An initial screening exercise was cond ucted on six port options during the Initial
Environmental Impact Assessment. A thorough review of this screening exercise is available
in Chapter 2 of the Revised Port EIR, pages 46-52.
The options considered were:
4
The Ngqura Environmental Committee is made up of the CDC, National Department of Environmental Affairs
and Tourism, Eastern Cape Department of Economic Affairs, Environment and Tourism, and various other
stakeholders.

Option 1 - The concept was to modify and extend the existing port facilities at Port Elizabeth
to provide the bulk cargo handling capacity and a short term storage capacity. The scheme is
to expand Berth 14 of the Port Elizabeth port and provide a rail wagon system.
Option 2 - The idea was a masterplan development for the existing Port Elizabeth port that
would take Port Elizabeth into the 21st century and would provide cargo-handling facilities for
the Coega Industrial Zone. The scheme was to construct a new outer port on the northern side
of the existing port. The scheme would allow for a new improved import/export facility to
handle ore imports and the manganese exports that are currently exported from Berths 13 &
14.
Option 3 - This option investigated an offshore jetty system which would have involved the
transport of cargo by means of smaller bulk carriers or lighters from the existing port to the
offshore jetty and then onto the Industrial Development Zone via a conveyor system.
Option 4 - The model was to provide the minimum essential berthing and cargo handling
facilities at Coega.
Option 5 - The concept was to provide a comprehensive industrial port at Coega that would
be able to import and export the bulk cargo generated by the industrial development at Coega.
The scheme considered would have provided two access embankments and 7 berths, which
would be protected by integral or separate breakwaters.
Option 6 - This scheme was an alternative to option 5 and provided an inner sheltered port
for 4 berths as well as an access embankment to the shore and 3 berths.
The screening process conducted by Watermeyer, Prestedge and Retief used the following
main criteria, viz. Financial implications, Social implications, Ecological implications and
planning and future development considerations.
On analysis, the following was ascertained:
Option 1 was eliminated because of the potential for greater visual and air pollution in the
Port Elizabeth area from the increased importing of ore as well as the impact of the corridor.
Option 3, the offshore jetty located away from Coega, was eliminated because of the high
down time and the greater risk of shipping accidents.
Option 4, although offering greater protection than Option 3, will still be faced with a high
down time and a greater risk of shipping accidents, and was therefore eliminated.
Option 2, the expansion of the Port Elizabeth port to the north and Option 5, an offshore port
at Coega were screened as the best overall options and subjected to further investigation.
Options 2 and 5 were then assessed at a broad level, taking into account potential ecological
and visual impacts as well as possible social disruptions of the proposed conveyor link.
From an ecological perspective, the preferred port option was Option 2, which had a lower
negative ecological impact but a higher negative social impact. The conveyor route associated
with Option 2 was, however, shown to have high negative ecological and social impacts.
Option 5 had higher ecological impacts when compared to Option 2, but had lower negative
social impacts. Option 5 offered the greatest potential for economic growth.

The Initial Environmental Assessment concentrated on an investigation of Option 5, a

comprehensive industrial port at Coega that would allow for the import and export of bulk
cargo generated by the industrial development at Coega.

CHAPTER 3:
PROJECT DESCRIPTION
3. PROJECT DESCRIPTION
3.1 INTRODUCTION
The purpose of this chapter is to provide a broad description of the proposed project with a
view to the identification, classification and evaluation of the impact of the proposed port and
landside development on the affected environment. The project, for descriptive purposes, can
be broken into two clear sections, viz. port (the actual port infrastructure e.g. breakwaters,
turning basin, quays etc) and the back-of-port area, which includes the various industrial
clusters (port related activities, E-commerce and Logistics and Mixed use). The information
available on the port construction is relatively detailed. The information available on the
back-of-port area is less detailed and therefore the description is relatively generic in nature,
as not all the clients for these clusters have been identified.
The nature and extent of the port is addressed in section 3.2 with a view to orientating the
reader as to the major components of this aspect of the project, its timing and spatial extent.
The port development phases are also discussed. Prior to construction, a detailed
Environmental Management Plan (EMP) must be drawn up and specific recommendations to
guide this document are outlined in Appendix C. It is also assumed that the EMP will build
upon the generic environmental outlines previously produced for the CDC, namely the
Construction of Infrastructure and Tenant Concessionaire Projects – Construction
Environmental Management Procedure (African Environmental Solutio ns 1999 Report No. 14
000 E/1) and the Environmental Design Manual (African Environmental Solutions November
1998 Report No. 14000 D/1).
Section 3.3 provides a description of the back-of-port area including planning, design and site
investigations and operations. The future phases of the project are outlined in Section 3.4. It
should be noted that the project description provided below is based on the best available
information at the time of writing.
3.2 NATURE AND EXTENT OF THE PORT (INFRASTRUCTURE)
3.2.1 GENERAL LAYOUT

The maritime infrastructure of the port comprises three main components. These are the
breakwaters, the quay walls, and the dredged navigation basin and channels. These
components are discussed with relevant technical information in the following paragraphs and
are shown in Figures 3.2a and b. The main land based developments associated specifically
with the port are expected to include transportation corridors for conveyors and road and rail
access, a container terminal, staging yards, dry bulk stockpiles, a bulk liquid tank farm and
port administration buildings. These land based developments are discussed in section 3.3.
The main breakwater (eastern) is on the northeastern side of the port entrance and extends
from the beach in a southerly direction for a distance of approximately 2 500m (Figure 3.2b).
At its head it will stand in 16.5m of water and project 10m above sea level for the bulk of its
length. The secondary breakwater (western) extends from the beach in an easterly direction
for a distance of just over 1 100m. At its head it will stand in 14.5m of water. The cross
sectional width of the breakwater will be approximately 120m wide on the seabed in the
deeper areas. The crown section on the top of the breakwater will have a width of 12.2m. The
breakwater will be constructed using core rock (5kg to 2 000kg), armour rock (2 tonne to 5
tonne) and Dolos concrete armour units (30 tonnes).
Chapter 3: Project Description 29

While the breakwaters have changed slightly since earlier designs (See Revised EIA - CEN
2000) the rock required from the Coega Kop is still within the scenarios evaluated for the
Environmental Management Plan and Report EMPR (CES 2000b).
The 4km long approach channel will extend from the –18m contour in the south, to the port
entrance (Figure 3.2b). The width of the approach channel will vary from 300 metres to 500
metres at the bend and be dredged throughout to –18m chart datum (CD). From the entrance
channel through the turning basin and into the berth areas, the seabed will be dredged to –16
metres chart datum. The entrance channel will have a width of approximately 380m, the
turning basin a diameter of 800m, whilst the container berth manoeuvring area will have a
minimum width of 350m.
The container terminal, located on the northwest side of the port, will comprise 620m of
berthing quay wall with a depth of –16.5 m chart datum. The container handling area will
comprise a 400m wide paved area behind the quay for the storage of containers. A further
100m wide transportation corridor, which will include access roads and rail, will be located
behind the container terminal. This transportation corridor will provide a link to national,
regional and local transport networks. Various offices and maintenance facilities will also be
established near the terminals and berths. A dry bulk berths totalling 600m of quay wall will
be located in the central portion of the basin. In the early stages of the port these berths will
perform a multi-purpose role, handling break bulk and other miscellaneous cargo.
Quarry
Haul road
Salt works
Markman Port
industrial
Figure 3.2a: Layout of the Port of Ngqura (Phase 1) and surrounding area
(Approximate Scale 1 : 50 000).
30 Chapter 3: Project Description

Dry bulk product will be moved by conveyor via the transportation corridor to or from a
proposed 300 by 1 000m bulk materials storage area located north of the N2. This site will be
serviced by rail and road. The bulk liquid berth will be used to offload bulk liquids (mainly
fuels) to a tank farm located on the northeastern bank of the river. This facility will at some
stage be moved from Port Elizabeth to Coega. The area will provide a 500m radius buffer
zone within which no development will be allowed.
The natural longshore movement of sand in Algoa Bay is north/south with an average nett
movement from the south to the north. The breakwater structures are expected to interrupt this
process. In order to maintain the continuous movement of sand, a permanent sand bypass
system will be installed.
The sand bypass system will consist of a fixed row of jet pumps deployed from a jetty, a
pump house, a slurry pipeline, booster pump stations and a discharge point. The jet pumps
will be installed on the southwestern side of the port, and will pump sand around to the north-
eastern side of the port. The system will be designed to maintain the current dune and beach
forms on the adjacent coastline by artificially assisting the longshore drift.
3.2.2 FUNCTIONS
The primary function of the port will be to act as an inter- modal transfer point for bulk cargo
and containers for industries in the Development Zone and the hinterland, and as a
transhipping hub for long distance container traffic. The land areas beyond the quayside will
serve as staging and storage areas for transit cargo.
3.2.3 PARAMETERS AFFECTING THE PORT LAYOUT

The parameters affecting the port layout are the conditions at the site and the spatial,
operational, engineering and environmental requirements. The resultant port layout is
dependent on the interaction of these parameters. The different parameters, their effects and
accommodation in the port layout are discussed in the following paragraphs.
Site conditions
The terrestrial topography is typified by coast parallel dunes up to 30m high, which give way
to uniformly undulating hills up to 50m high within 3-4km of the coast. The construction
area for the maritime infrastructure component of the port is in the nearshore zone, beach and
adjacent foredune habitat at the mouth of the Coega River. The beach is periodically eroded
by the Coega River when it is in flood.
The Coega River valley represents the only major incision into the coastal landform in the
area between the Swartkops and Sundays rivers. Over time, the river has created a floodplain
valley between 400 and 1 000m wide, which extends inland and has been extensively
developed as a commercial salt works. The incision is a relatively natural route through which
a transportation corridor can be constructed, linking the port with the industrial hinterland. In
order to accommodate the transport corridor, cuttings will need to be undertaken. The Coega
River has been canalised around the north side of the salt works and runs through the area of
proposed port construction.
The geology of the site is characterised by Quaternary alluvial and estuarine sediments in the
estuary and dunes, and Tertiary formations in the flanking hills, which overlie Cretaceous
mudstones, siltstones and sandstones. To the north of the estuary evidence of quartzitic
sandstone has been recorded at depth. Of primary importance to the location of the port is the
existence of an asymmetric palaeo-channel, filled with discontinuous layers of gravel, sand,

silt and clay. The dredging of the harbour basin to –16m CD will ostensibly be in
unconsolidated material. The quay walls have been orie ntated to take advantage of the
palaeo-channel in this respect.
The wind conditions at the Coega River mouth and surrounding areas are characterised by
three dominant directions, these being WSW-SSW, E-ESE and NW-NNW. The wind
velocities at Coega have an expected 1 in 1 year return velocity of 16m/s, a 1 in 10 year return
velocity of 17.3m/s, and a 1 in 50 year return velocity of 18.1m/s. The data used to calculate
these values was collected at four wind stations located at Cape Recife, Port Elizabeth
Airport, Coega River mouth and at the Sundays River.
Figure 3.2b: Layout plan of the Port of Ngqura (Phase 1) and approach channel
(Approximate Scale 1 : 30 000).

The wave and current conditions have been determined using data measured by a sub-surface
directional buoy in 16.5m of water. The results have indicated that the currents in Algoa Bay
respond rapidly to the wind conditions. There are two distinct deep sea wave directions, the
SW waves and the E waves. Significant wave heights for a 1 in 5 year and 1 in 50 year return
periods are 7.6m and 9.1m respectively. The waves from the SW refract around Cape Recife
and approach the port from the SSE. The waves from the E refract and approach the port from
the SE. The entrance to the port has therefore been orientated to face S, thus reducing wave
penetration into the harbour.
Spatial requirements
The spatial requirements of the port are, to a large extent, determined by the design ship and
landside infrastructure requirements. The design ships are represented by an 80 000 dwt dry
bulk carrier and 4 500 TEU container vessel. An allowance has been made for future vessels
of up to 400m in length in the turning basin. The cost of dredging and extending the main
breakwater wo uld be the only factors limiting larger ships being considered in the future.
The landside infrastructure requirements are determined by the method of cargo loading and
unloading, the mode of transport of the cargo on land, and the storage areas required. The
steepness of the slopes on the north-eastern side of the river channel leaves a limited area for
back of quay infrastructure. Bulk liquid berths, which require a relatively small amount of
back of quay infrastructure, have therefore been proposed for this area. Bulk and container
berths have been proposed for the area on the south-western side of the port, where there is a
larger area available for storage of cargo, unloading and loading equipment with direct access
to the transportation corridor.
Operational requirements
Berths in the master plan layout have been located such that the transhipment operations are
undertaken efficiently with minimal delays whilst weather downtime is minimised. Berth and
channel depths reflect the need to minimise ship delays.
Engineering requirements
The layout has been engineered to maximise the economic benefits of the palaeo-channel by
minimising hard rock dredging and maintaining the breakwaters in relatively shallow water.
The secondary breakwater arm has been located so as to allow for a future basin to be
developed with minimal effect on existing structures. The breakwaters will be of rubble
mound construction, allowing maximum use of the materials available in the nearby quarry.
The alignment of the quay walls and port layout allows further berth development up the
Coega River.
Environmental requirements
The construction of the port will respond to environmental requirements in several ways. The
master plan layout maintains a 500m exclusion zone around Jahleel Island and provides for
containment in the event of spillages within the port. Provision has been made for the
construction of a sand bypass system to move the sand around the port to maintain the
longshore drift. The contractor will be required to comply with all applicable legislation
pertaining to the protection of the environment during construction.

3.2.4 PORT DEVELOPMENT PHASES

The project life cycle consists of the site investigation, planning and design stage (2 years);
the construction stage (3 years); the operations stage (100 + years); and the decommissioning
stage (2 years). The different stages are discussed below.
Stage 1: Site Investigation, Planning and Design

The site investigation, planning and design commenced in August of 1997 and has involved
approximately 45 design and 50 sub-contract specialists over a period of approximately 48
months.
Geotechnical investigations
The geological and geotechnical studies included the investigations by Marine and Coastal
Geo-consultants, Gibb Africa and Fairbrother Drill. These investigations represent the most
direct localised impact on the site where material sampling was undertaken. All work was
undertaken within the existing legal framework, with only minor physical disturbance being
evident. The following work was undertaken:
• A jet probe survey to verify marine geophysical interpretations and to give an indication
of the dredgeability of the unconsolidated upper sediment horizon.
• An offshore vibrocoring programme to determine the geotechnical properties,
composition and texture of sediments in the approach channel for possible dredging
purposes.
• A detailed onshore geotechnical investigation to determine conditions and evaluate the
significance of the geology with particular reference to dredging and founding conditions
in the Coega Estuary.
• A detailed offshore geotechnical investigation to determine conditions and evaluate the
significance of the geology with particular reference to dredging and founding conditions
in the area offshore of the Coega Estuary.
• An investigation to determine the feasibility of dewatering for the excavation for
construction of the quay walls and river channel.
• Trial dredging to give an indication of what materials may have to be dredged and the
problems that may be encountered during dredging.
• Dredge material sampling and testing for contaminants.
Surveys
Surveys of the Coega River estuary and the area offshore of the Coega River mouth were
undertaken. These include:
• A marine geophysical survey using boomer and pinger seismic systems to map the
stratigraphy to a depth of –20m.
• A sidescan sonar survey to map surficial sediments with collection of bathymetric data for
mapping of seafloor morphology.
• An aerial survey covering the Coega River and estuary extending to the eastern boundary
of the development zone and inland to the northern boundary of the development zone.
Apart from localised bed surveys, all survey work was undertaken using remote sensing
techniques.
Marine data collection

Marine data collection and evaluation was undertaken to establish specific field conditions for
design, construction and operation purposes of the proposed Coega Port. The specific field
conditions were investigated by:
• a sub-surface wave buoy in 16.5m water depth

• wind station at Hougha m Park, on Jahleel Island and in the Coega River valley
• current buoy in 16.5m water depth
• sea level tide gauge in Port Elizabeth harbour
• quarterly beach surveys
The evaluation of the collected data is presented in report 256/J01 series 001, Summary of
Field Data on Coastal Processes, of January 2001, originating from Prestedge Retief Dresner
Wijnberg (PRDW).
Environmental
Apart from the specialist environmental studies undertaken, data was collected during the site
investigations for the assessment of dredge material characteristics and baseline beach form
stability. This information was used to develop the design basis for dredging and sand
bypassing.
Stage 2: Construction
This section describes the construction of each of the main maritime infrastructure of the port.
There will be four major components, viz. site preparation, breakwaters and quay walls,
dredging and sand bypass system. Site preparation is expected to take 8 months to complete
and involves a work force of approximately 100 people. The next phase will involve
construction of the breakwaters, quay walls and sand bypass system, as well as the required
dredging. These combined activities will run concurrently and are expected to take 36 months
to complete and involve approximately 800 construction personnel at its peak. Landside
infrastructure will take approximately 18 months and involve 250 people subsequent to the
commencement of the marine works.
The various aspects of the construction are described in the following paragraphs. In order to
minimise the impact of construction, all contractors will be obliged to meet with specific
contractual requirements when executing the works. Specific recommendations to be
considered in the EMP and subsequent contracts are outlined in Appendix C.
Site Preparation5
This activity comprises the preparation of the disused Coega Kop Quarry, provision of
essential services to future construction sites and the interlinking roadways from the quarry to
the construction sites. The works will consist of the following:
• Fencing of the Coega Kop Quarry site.

• Construction of a haul road of 6.0km, as well as deviations of the N2 over a distance
of 1.4km and closing of Road 435. The haul road will link the quarry at Coega Kop
with the port and will be designed to carry 70 tonne dump trucks. This will allow for
the transport of armour rock and various other materials mined at the quarry to Joorst
Park. The haul road will underpass the N2 freeway in large diameter culverts and
include the temporary deviation of the N2.
• Construction of an access road of 4.5km. The access road will run from Joorst Park to
the port construction site seaward of the primary dunes and joins the secondary
breakwater and quay wall sites with offramps, continuing through to the main
5
Some of the aspects of the site preparation fall outside of the area covered in this EIA. It should be noted that
this EIA covers the area seawards of the N2 (see section 1.1.2). No application is being made concerning
activities outside this area.

breakwater site. The Coega River is crossed by means of a road over temporary
culverts.
• Upgrading of the existing site access road from the St George’s Park interchange to
Joorst Park and the construction of approximately 1.5km of new road from Joorst Park
to the main contractor’s yard.
• Provision of electrical and water main service connection points. Water supply will be
provided at various locations around the port construction site.
• Fencing of the haul road. A 1.4m high perimeter fence will be provided along the haul
road.
Main maritime infrastructure (breakwaters, quay walls, dredging and sand bypass
system)
Site establishment
It is expected that the contractor will establish the main construction site in the area around
Joorst Park with a secondary site at the river mouth for the quay wall construction (Figure
3.2b). All work carried out on and in these areas must comply with the requirements outlined
in Appendix C. These requirements relate to: access and traffic control, areas identified as
requiring protection, site clearing and stabilisation, rehabilitation, waste disposal, dust control,
fires and air quality, the handling, storage and disposal of hazardous substances,
environmental awareness and control on site, compliance with SA environmental and other
legislation, stormwater management and emergency procedures.
Breakwaters
It is possible to construct the breakwaters using both land based and marine based
construction, or just using land based construction. Construction near the root of the
breakwaters will not be possible using marine based equipment. It is envisaged that core
material for the breakwaters will be placed using tip trucks on the breakwaters. The material
would then be pushed into the sea using bulldozers. Armour layers consisting of armour rock
and dolosse will be placed using cranes based on the breakwater (Figure 3.2c). It will be
possible to place core material and armour layers from a barge into the breakwaters in waters
where depth is sufficient. If barging is required, a temporary construction berth will be
required, but this will be within the existing footprint of the harbour development
The site establishment element of breakwater construction will include the clearing of the
quarry, setting up of 2 batch plants, each with a capacity of 80m3 /hr to mix concrete for dolos
construction, preparation of an area for stockpiling of dolosse and setting up of 4 gantry
cranes each with a 32 tonne capacity for dolos handling.
The heads of both breakwaters will comprise caissons constructed in a dewatered excavation
onshore. After flooding of the excavation during the dredging activities, the caisson will be
floated into position and placed on a stone bed.
The total length of time required for construction of the breakwaters is anticipated to be 27
months. There are four main phases, the first being site establishment, which will take an
anticipated 12 weeks. The second will be construction of the main breakwater to chainage
910, and the secondary breakwater to chainage 450. The third will be construction of the main
breakwater to chainage 1 715 and the secondary to chainage 830. The last phase will be the
completion of both breakwaters and placement of cassions.

While construction is proceeding, it is anticipated that 5 500m3 of rock will be placed with
230 truck round trips from the quarry in a 20-hour day. Dolosse will be cast and placed at a
rate of 70 units per day, with one truck trip per unit from the casting yard.
118.47
40.24 12.2 66.03
+10.3
+5 +7
+6,5 2
1 +5.5
+4
30t DOLOSSE 1.33
1 30t DOLOSSE CHART DATUM
-3 -3
1.5
-7 1
-9
(2t to 5t)
1.33 2,5m THICK ROCK ARMOUR 1.33
-11.9
1 1
CORE (0,005t to 2t) -16,7
SECTION 18
Figure 3.2c: Typical breakwater section. Dimensions shown are in metres.
Quay walls
The quay walls are expected to be constructed in dewatered excavations above the present
beach line (dry) whilst below sea level quays could be constructed with caissons or driven
piles (wet). During the site establishment phase the contractor will be required to set up
systems to dewater the ground around the excavations on a continuous basis during
construction so as to keep the seepage into the excavations to a minimum. During the site
establishment phase, the contractor will also be required to design and construct a temporary
channel deviation to deal with river flows for the duration of the construction works.
The onshore portion of the quay walls are expected to be voided mass concrete gravity
structures, constructed in a period of 25 months. The first phase will involve excavations for
the foundations. The second phase, the construction of the east and west quay walls, will
commence 3 months after the excavation has commenced. The excavation of the basins and
container terminal area will require the removal and disposal of approximately 9 million cubic
metres of material. Various disposal sites (Figure 3.2d) were identified in close proximity to
the works (East headland, Neptune Valley, salt works, the outer basin reclamation, the tank
farm area, and limited areas above the high water mark on the eastern beaches) and their
suitability was assessed in the Dredging, Excavation and Disposal specialist report (See
Specialist Studies Series - Part 2). The areas that were deemed to be most acceptable were the
east headland site and the outer basin reclamation site, with these two sites being able to
accommodate the vast majority of the material. The impacts reported in this EIR assumes that
the recommendations of this study will be adhered to. Neptune Valley was regarded as a “no
go” option and no deposition of material must take place in that region. All the areas used for
disposal will be landscaped and revegetated in order to minimise the visual/aesthetic impact.
Once the point has been reached where construction below sea level has been completed, the
excavations can be flooded. The third phase will be the completion of the part of the
structures above the water line, including the mass capping, services tunnels and crane rail. A
typical quay wall section is shown in Figure 3.2e.

Bu
lk
ter
mi
na
Con inal ar
term
l
tain
er
Basin
ea
-16 m CD
Jahleel Island
Disposal Sites
Entra
Outer basin
nce
Tank farm
chann
Salt works
el
Neptune Valley
East headland
North east beach
Figure 3.2d: Dry excavation disposal options.
The quay walls constructed in the wet may be built using caissons or driven piles. Caissons
will be constructed in the dewatered excavation and then floated out and positioned on the
quay wall alignment on a pre-dredged stone bed. The phasing of the work is expected to be
determined by construction and flooding of the dry excavation. The wet construction of quay
walls is expected subsequent to the commissioning of the quay walls constructed in the dry.
A typical section with a proposed container gantry crane is illustrated in Figure 3.2e.

a) Bulk crane b) Container gantry crane
Figure 3.2e: Typical section through quay walls.
Dredging work
A detailed appraisal and description of the proposed dredging work is covered in the
Dredging, Excavation and Disposal specialist report (Specialist Studies Series - Part 2). The
dredging of the port approaches, basin and berthing areas will require the removal of some 14
million m3 of material. Dredging work will extend from the –18m CD contour offshore at the
beginning of the approach channel to the +5m CD contour onshore at the inland side of the
river channel. Work will be undertaken in exposed and protected waters. Dry excavation may
supplant dredging where this proves more economical. The dredging process is expected to
take between 9 and 27 months to complete depending on whether dry excavation is used or
not.
There are a number of alternatives regarding the disposal of dredge spoil. These alternatives
have been examined in detail in the Dredging, Excavation and Disposal specialist study (see
Specialist Studies Series - Part 2). The options which have been recently considered are two
offshore sites and the outer basin reclamation site (Figure 3.2f). The closer offshore site is
directly off the Coega River mouth and runs along the 30–35 metre depth contour, while the
second site is further offshore and is found in deeper water (40–45m). The disposal aspect of
the overall Dredging, Excavation and Disposal report recommended that site 1, the inshore
site, was suitable for the open marine disposal of material, and the impacts associated with
this option have been used in this EIR. A full appraisal of both sites is available in the
specialist study. Offshore disposal of dredge material will be carried out under strict
conditions that have been formulated using the ANZECC, PIANC and South African
Guidelines (Specialist Studies Series - Part 2). A permit will be obtained from the Department
of Environmental Affairs for the marine disposal of up to 20 000 000 cubic metres of material
for this purpose. A number of recommendations and operating guidelines to be followed have
been formulated (see Appendix C) and these should be included in the EMP.
The approach and entrance channels will comprise some 3 million m3 whilst the harbour basin
will yield some 11 million m3 . Additional allowance has been made for sand redistribution
during construction. The nature of the material is expected to be predominantly fine sand to
coarse gravel interspersed with clay and shell lenses. The river channel is expected to yield
cobbles up to 200mm in size at depths of –13m to –16m CD. Zones of mudstone and siltstone

are also expected in this area with possible isolated outcroppings of quartzitic sandstones in
the northeastern section of the basin. Sampling work carried out to date has yielded no
evidence of contaminants (Connell and Parsons 1999).
15m 20m
Coega River 30m
2km
St Croix
N
Jahleel
Brenton
F 150m boundary
15m around Brenton
31
15.8
20m
Site 1
35
Swartkops River
46
44
Site 2
50m
20m
46
15m 30m
Figure 3.2f: Dredging disposal site options.
Dredging is expected to be carried out by trailing suction hopper dredgers and by a cutter
suction dredger. The trailing suction dredger (Figure 3.2g) is a ship that is suited to coastal
navigation and has the ability to load its own hold, called the hopper, by means of centrifugal
pumps. The hold is overfilled with a water/sand mixture. The heavier sand settles at the
bottom of the hopper whilst the water overflows in the surrounding water body, resulting in
increased turbidity.
Discharge is normally by means of a bottom dumping arrangement or occasionally by pump

discharge, which is usually to the shore. The main advantages of the trailing suction hopper
dredger is its relative immunity to adverse weather and sea conditions, an independence of
operation, an ability to transport spoil over long distances, a relatively high rate of production,
and a simple and inexpensive mobilisation procedure. Its main disadvantages are an inability
to dredge compact materials, an inability to work in areas of very restricted navigation,
sensitivity to significant concentrations of foreign matter or debris, and a tendency to dilute
fine materials severely during the loading process.
The intake end of the suction pipe is fitted with a ‘draghead’ designed to maximise the
concentration of solids entrained from the seabed. The bearing pressure of the draghead on the
seabed is usually controlled by an adjustable pressure compensating system, which acts

between the draghead and the hoisting winch. This system also serves to alleviate the effects
of vertical movement of the ship relative to the seabed due to waves or swell.
Figure 3.2g: Trailing suction dredger shown from the side and front.
The cutter suction dredger (Figure 3.2h) is the most commonly used dredging vessel and is
generally the most efficient and versatile. The main advantages of the cutter suction dredger
arise because it is equipped with a rotating cutter head surrounding the intake end of the
suction pipe, it can efficiently dig and pump all types of alluvial materials and compacted
deposits, it has the capability of pumping material long distances to upland disposal areas, the
ability to operate in shallow water, and produce a reasonably uniform level bottom at a
relatively high production rate. The dredger is, however, limited by the fact that it requires
calm waters for operation. It is therefore not suitable for dredging in open waters.
If hard rock of is encountered, this will have to be removed using underwater drilling, blasting
and dredging. Underwater blasting will be subject to a range of requirements outlined in
Appendix C.
Figure 3.2h: Cutter suction dredger viewed from the side and top.
Sand bypassing scheme:

The primary functions of the sand bypass scheme (Figure 3.2i) are to maintain continuity of
littoral transport of sediment and to ensure that the entrance to the port does not become

affected by a sand bar. The former is an environmental requirement, and the latter an
operational requirement.
Initial estimates indicate that the net longshore movement of sand is approximately 150 000
m3 in a north easterly direction. These estimates correlate well with the observed build up at
the existing harbour in Port Elizabeth. The sand bypass system will move sand from the root
of the secondary breakwater and discharge it north of the main breakwater. The sand bypass is
constructed from several components as discussed in the following paragraphs.
The sand will be collected on the south western side of the port on the outside of the
secondary breakwater. The system for collection of sand is envisaged to be a series of jet
pumps mounted on a fixed jetty across the surf zone on the southwest side of the breakwater.
Localised sumps will be excavated into the rock to provide sufficient storage for the systems.
The sand, in the form of a slurry, will be pumped via the pumphouse at the base of the
secondary breakwater. It will travel in pipelines located in the services corridor around the
back of the port. The movement of the slurry will be facilitated by booster pump stations
along the way. The slurry will be discharged onto the beach on the north eastern side of the
main breakwater for continued transport by natural means down the beach.
The sand bypass unit will be operational once the breakwater construction is completed.
Figure 3.2i: Layout of the sand bypass system.

Landside infrastructure
Details of the landside infrastructure requirements are not as yet clearly defined. In
anticipation of changing requirements of tenants, the landside infrastructure will be designed
to provide the greatest flexibility possible.
It is envisaged that the north eastern quay will be used for liquid bulk cargo. This quay will
therefore require liquid bulk cargo handling equipment. The cargo will be transported to a
bulk liquid tank farm by pipeline.
It is envisaged that the south western quay walls be used for bulk cargo and containers. These
quays will therefore require bulk loaders and unloaders and gantry cranes. Transportation of
bulk cargo materials of a granular or powder form will be done using a conveyor system.
Break bulk cargo and containers will be transported by railway or road.
The transportation corridor will run from the port along the south western side of the Coega
River into the development zone. It could include roadway, railway, conveyor and pipeline
transport facilities. The corridor runs through undulating sand dunes and will therefore require
cut and fill earthworks. The sides of the cut and fill sections will be stabilised and vegetated to
prevent erosion.
Approximately 4 million m3 of bulk earth works will be needed to create the container
terminal. This will involve the removal of a significant portion of the western headland (see
Figure 3.2i). This material will be deposited at sites as indicated for the dry excavations
(Figure 3.2d). The recommended sites are the east headland site, outer basin reclamation site
and behind the quay walls (see Dredging, Excavation and Disposal Specialist Report
Specialist Study series – Part 2). All manmade slopes will be stabilised to prevent future
slumping.
A number of buildings will be erected by the Port Authority Division (PAD). These will
include port administration, workshops, access control and port control structures. The entire
area will be fenced and controlled access provided. All terminals will be flood-lit 24 hours a
day, 365 days a year.
Stage 3: Operations
The operation of the port is expected to continue over an extended period of time (more than
100 years). During this period it is expected that development of the port will continue within
the present boundaries as a function of increasing traffic and changing commodities. This
section addresses port operations based on what is currently understood to be the type and
volume of shipping traffic.
The first phase of the project is expected to accommodate the traffic requirements for a
container terminal. Total gross tonnage expected at the port is 3 million tonnes per annum of
neo and dry bulk commodities, and 300 000 TEUs in containers per annum. An additional
berth aimed at accommodating bulk liquid products is expected to handle up to 1 million
tonnes per year.
An operational port aimed at serving these requirements is expected to comprise a PAD and
separate terminal operators that will probably be independent of the PAD. All activities
carried out in the port will comply with existing legislation.

Port Authority Division

The Port Authority Division (PAD) will own the land and associated infrastructure. As land
owner, the authority will act as the regulator for activities undertaken by others in the port
area. The authority is expected to maintain direct control over marine, engineering,
administration and emergency services.
Marine services encompass port control, all pilotage, tug works and support vessels within the
port. Two large tugs, a pilot vessel and ancillary craft for pollution control and maintenance
work are to be stationed at the Coega or Port Elizabeth ports. The marine services will be
responsible for all ship movements and associated safety in the area.
Engineering services will be responsible for the maintenance of all infrastructure within the
port area. This will include civil, electrical, mechanical and the maintenance of buildings.
The administration of the port will comprise the human resources, financial and accounting,
planning, audit and information technology functions. Initially port administrative activities
will be at Port Elizabeth but then, as the need develops, they are expected to be transferred.
Emergency services will be provided to accommodate loss of control situations within the
port area. These may comprise fires, flooding, spillages and other hazardous situations.
Contingency plans for dealing with oil and other hazardous spills will be implemented as in
other ports in South Africa.
Initially marine services are likely to be sourced from the existing port of Port Elizabeth. This
will continue until shipping traffic through the Port of Ngqura warrants the stationing of
dedicated vessels there.
Port operations
The primary purpose of the port is the transhipment of cargo. Port operations are expected to
be concessioned out by PAD to specialised operators in designated areas. Basic infrastructure
and services will be provided by PAD, who will also regulate activities undertaken by the
operators.
The ultimate harbour development is expected, as mentioned earlier, to accommodate 34 deep

water berths. The development of these facilities will be a function of the growth in traffic in
the port. At this stage five berths will be established. The container terminal will comprise
two berths south east of the Coega River.
Two break bulk and bulk berths have been identified for other industries utilising the port.
The berth on the north eastern side of the channel will be a general purpose berth but in time
will become a designated for bulk liquid (fuels) and will probably accommodate the products
currently being shipped through Port Elizabeth harbour. This will be preceded by the
construction of a new tank farm at Coega to replace the Humewood facility. All expansions
to the port, including the relocation of the tank farm and the ore dumps, will be subjected to a
specific impact assessment prior to their approval.
In addition to development zone cargos, the export of dry bulk materials from the hinterland
through the multipurpose berths is also envisaged.

Stage 4: Decommissioning
The decommissioning of the port is difficult to visualise at this point in time. The
establishment of a facility of this nature provides numerous development opportunities well
beyond the practical planning horizon of the port. It is unlikely that this infrastructure will be
removed. Changes in economic activities and associated technologies will in all likelihood
lead to the re-development of the port in the future in order to accommodate the relevant
needs at that time.
3.3 BACK-OF-PORT
The back-of-port area is defined as that area within the gazetted port limits excluding the main
port infrastructure outlined in Section 3.2. The area encompassed in back-of-port can be
identified in Figure 3.3a.
Stage 1: Site Investigations, Planning and Design

The parameters affecting the layout and development of the back-of-port areas are the
topographical features and the spatial, operational, planning and environmental requirements.
The resultant development layout will take cognisance of these parameters. The different
parameters, their effects and their accommodation are reviewed hereunder.
Site conditions
The terrestrial topography between the N2 and the coast is typified by parallel dunes up to
30m high, which give way to undulating hills up to 50m high. The Coega River valley
represents the only major incision into the coastal landform.
The geology of the area and the meteorological and maritime conditions have been reported
on in chapters four and five.
Spatial requirements
The spatial requirements of the activities planned for the back-of-port area have been
addressed in the Town Planning and Urban Design Reports (Metroplan September 2000).
Flexibility is a prerequisite for a successful Industrial Development Zone (IDZ) and a large
variation in plot size is being accommodated. The public domain will include public transport,
private vehicles, lorries, cyclists and pedestrians.
An Open Space Management Plan has been developed and linkages between local
development nodes have been provided. Generally, larger plots are located on the perimeters
of the local development nodes and there is an increase in density towards the central focus
areas.
Operational requirements
The operational requirements of the security and emergency services as well as the
operational requirements of the utility service providers have been accommodated in the
planning and design. The particular requirements in respect of efficient transportation and
logistics operations have also been addressed, as these are key success factors for IDZs.
Engineering requirements
The key engineering requirements relate to roads and the gravity services, viz. sewerage and
stormwater management. The topography of the area dictates the locations of the gravity
services.

The geology of the area designated for the landside developments of the port allows the
development of light industries. The area is not suitable for the development of heavy and
medium industries.
Turning
basin
Breakwaters
Indian
Ocean

Figure 3.3a: The landside developments showing the main clusters and activities.

Environmental requirements
The general ecology of the area is outlined in detail in Chapter 4. In summary, the area is
degraded in places by over-grazing and alien species but there are a number of sensitive
environments such as the coastal dunes and Bontveld.
Stage 2: Construction
In accordance with National Government’s policy, the construction work will be divided into
packages to permit maximum benefit to SMMEs and to allow labour intensive activities
where appropriate.
There will be a central site establishment area for all the contractors, which will be located
adjacent to Joorst Park. The Tender Documentation will include specific requirements for the
following:
- Access and control of traffic

- Identification of areas requiring protection
- Rehabilitation using appropriate indigenous vegetation
- Dust control
- Waste disposal including handling, storage and disposal of hazardous substances
- Maintenance of air and water quality
- Approved emergency plan
- Stormwater management
- Compliance with Environmental Legislation
- Environmental awareness
All contractors will be required to have an approved Environmental Management Plan in

place and to designate an Environmental Officer. Overall responsibility for environmental
management will be vested in the CDC, and the NEC will continue to exercise its mandate to
monitor all environmental work associated with the Coega Project.
Infrastructure and service facilities

Transport requirements
The initial transport requirements include the provision of an efficient road and rail network
that adequately caters for commuters and freight. This involves constructing or developing
existing main and secondary distributor roads as well as local service roads, including signage
and lighting and the construction of rail services for commuters and freight.
Later transport developments that are envisaged include a transport corridor as well as
possible air transport facilities. The transport corridor should provide conveyance for bulk
minerals from the proposed storage area to the quays as well as pipelines for chemical and
petroleum products being transported from the proposed tank farm to the quayside.
Potable water
The main principle for water provision is the development of a dual reticulation (“fresh” and
recycled water) system. The main aims are to provide primary and secondary potable water
and return effluent reticulation, including fire fighting and irrigation systems, as appropriate.
This will involve the construction of the Coega Kop reservoirs, the main bulk feeder line into
the IDZ and the distribution mains within the IDZ. It will eventually also require the
augmentation of the Nooitgedagt Treatment Works and the reservoir supply main off the
Grassridge-Motherwell pipeline.

Wastewater and wastewater treatment

The main aims are to provide a primary and secondary sewerage reticulation system including
pumping stations that will allow for reuse of treated effluent for industrial and irrigation
purposes. This will involve the implementation of a scheme to produce approximately 20 ML
of treated effluent per day at the Fishwater Flats Treatment Works (FFTW) for distribution to
the IDZ, including additional filtration works and a pump station at FFTW, a pumping main
from FFTW to the IDZ and storage reservoirs at the IDZ. Additional work will be required
later, e.g. construction of the Coega Treatment Works.
Stormwater/flooding
The main aim is the provision of an efficient and reliable stormwater management system to
ensure the safety of people and limit the risk of loss of life and damage to property during
flooding. This will involve the construction of a main open stormwater channel, closed
culverts servicing each tenant site and stormwater detention ponds.
Electricity
The CDC aims to provide a primary electricity supply at 132/200 KV and an electricity
reticulation at 11 KV with a secondary electricity reticulation utilising underground cabling
and including sub-stations. There are two scenarios for the provision of these facilities.
The first involves Eskom providing electricity for large customers (>100 Megavolt Amps-
MVA) from the Grassridge sub-station using overhead lines, with electricity for smaller
customers being provided by the Port Elizabeth Municipality from Motherwell, Aloes and
eventually Grassridge. The required lines, cables and sub-stations will be constructed as
required in designated servitudes.
The second scenario is the development and provision of the electricity supply within the IDZ
by a private initiative.
Waste site
A new (hazardous) waste site will be developed to serve the IDZ and the region. A number of
candidate sites have been identified outside the boundaries of the IDZ.
Telecommunications
The CDC aims to provide primary and secondary telecommunications reticulation utilising
underground cabling.
Other features
These involve the use of hard and soft landscaping in the public and private domains.
Buildings and industries

The exact numbers and types of buildings have not been designed or envisaged as yet, and the
method of construction and the phasing of the activities have similarly not been established.
Although a customs secure Logistics Park, to support and complement the transhipment
Container Terminal, and an E-commerce park, to enhance the national capacity for trading
using the Internet, are proposed to be built in the IDZ.
Stage 3: Operation
It is anticipated that the Core Development Area (CDA) will be fully developed within 15-25
years. The timeframe for the ultimate development of the IDZ is 75-80 years. The studies that
have been undertaken have assessed, as far as is practical, the impact of the ultimate

development. The planning and design of the bulk infrastructure takes into account the
requirements of the ultimate development.
The landside development area will encompass a customs secure Logistics Park, an E-
commerce park and areas designated port and Allied Industries, Mixed Use Corridor and
Electronic/Technical Clusters. The designated areas are planned to include the following
industries or activities:-
- Head Offices
- Regional Offices
- Warehousing and storage
- Transit areas
- Custom secure areas
- Port related light industry
- Marine allied industry
- Chandlers
- Electrical and Electronic Instruments
- Electrical and Electronic Appliances
- Scientific and Medical Instruments
- Textiles and Clothing
- Catering
- Printing
- Food Processing
- Furniture and Furnishings
- Pharmaceutical Products
- Cosmetics
- Vinyl Production
- Leather Goods (Tertiary)
- Breweries
- Soft Drink Bottling
- Liquor Related Industries
- Customs Secure Areas
- Consumable Product Industries
In accordance with the IDZ Regulations, there will be an operational entity authorised to
manage the IDZ. The CDC has applied for a provisional Operators Permit and the specific
requirements that will have to be met by the operator are clearly set out in the IDZ
Regulations. In pursuance of the CDC’s stated aim of matching world’s best practise, the
zone, the CDC and all tenants, developers and concessionaires will be required to comply
with:-
- ISO 9001 in terms of Quality Management

- ISO 14001 in terms of Environmental Management
Further, the CDC’s Tenant Approval Procedure sets out requirements and standards, which in
a number of instances exceed the requirements of national legislation. In particular, a network
of air and water quality monitoring stations has already been established to determine baseline
data. This network will be extended as the zone develops. Air quality data will be used in an
American EPA approved air dispersion model. Sea water quality will also be monitored on a
regular basis by a team based at UPE.

Stage 4: Decommissioning
The decommissioning of this infrastructure is hard to visualise. As far as can reasonably be
foreseen, the bulk infrastructure will remain substantially as planned. Upgrading and
replacement works will be carried out on an as-required basis. Since the principal predicate of
the detailed engineering designs is whole- life costing, the bulk infrastructure will be designed
for the greatest efficiency.
3.4 POSSIBLE FUTURE DEVELOPMENTS
3.4.1 PORT
The port is expected to be developed in phases over a number of years as a function of
prevailing demand. It is envisaged that the port may in time be enlarged to a total of 34 berths
(Figure 3.4a). The details of each phase will depend on the needs of the existing and
anticipated users at that time. Future berthing areas will be created by extending the south-
western and north-eastern quay walls of phase 1 inland, and constructing separate quay walls
in the outer basin. A new EIA will be required for any additions to the port as described in
this chapter. Figure 3.4a illustrates a conceptual framework for the future port development.
The plan shows the additional berths and areas demarcated for back-of-port activities.
3.4.2 LANDSIDE DEVELOPMENTS

Further landside developments below the N2 are hard to visualise, with technological and
economic development over the timeframes being considered not being predictable with any
degree of accuracy. Particular buildings could be modified and re-used, or in other instances
could be demolished and plots or even whole local areas could be re-developed. All such
activity will be subject to control by the IDZ Operator in terms of ISO 14001 or subsequent
re-enactments.
Local development areas will radiate out from Neptune Road along the two secondary
distributor roads. Should development proceed at a rate that is significantly greater than
anticipated, then the remainder of the IDZ east of the Coega River will be implemented
earlier.

Figure 3.4a: Conceptual master plan for the final Port of Ngqura development. This shows
further developments of berths up the paleo-channel and outside of the present secondary
breakwater.

CHAPTER 4:
DESCRIPTION OF THE
TERRESTRIAL ENVIRONMENT
4. DESCRIPTION OF THE TERRESTRIAL ENVIRONMENT

4.1 INTRODUCTION
The terrestrial environment includes both the biotic (living) and abiotic (non- living) resources
found on land. Both biotic and abiotic factors contribute to and form essential parts of the
larger terrestrial ecosystem (CSIR 1997). This chapter overviews the biotic components of the
terrestrial ecosystem in the vicinity of the proposed Port of Ngqura. It details the fauna and
flora of the region, as well as the abiotic components including groundwater, geology,
climate, soils, air quality and noise. Details of the physical environment are summarised from
previous specialist reports undertaken for various iterations of the project and associated
developments. These are listed (p239-240) in the Revised Environmental Impact Assessment
(CEN 1999). The current account of the terrestrial fauna and flora has been updated,
incorporating recent taxonomic revisions. In some cases this has affected the conservation
status of species, and has necessitated re-assessment of environmental impacts upon them.
4.2 CLIMATE
Due to its location at the confluence of several climatic regimes, the most important of which
are temperate and subtropical, the Eastern Cape has a complex climate. There are wide
variations in temperature, rainfall and wind patterns, largely as a result of movements of air
masses, altitude, mountain orientation and distance from the Indian Ocean (Stone 1988).
Exceptionally high temperatures may be experienced during berg wind conditions, which
occur frequently during the winter, with maximums of well over 30°C not being uncommon.
Extreme temperatures also occur during summer, with little accompanying wind. Areas closer
to the coast experience cooling due to onshore sea breezes (Burger and Scorgie 1998). The
average maximum and minimum temperatures for Port Elizabeth are shown in Table 4.2a.
Table 4.2a: Average monthly temperatures (°C) for Port Elizabeth (1960-1980) (Stone 1988).
MIN 16.3 16.9 15.8 12.9 10.1 7.5 7.3 8.3 10.1 12.2 13.6 15.0
MAX 25.4 25.5 24.6 22.8 21.9 20.1 19.5 19.9 20.1 20.1 22.4 24.0
Algoa Bay is situated near the junction of temperate (winter rainfall) and subtropical (summer
rainfall) climate regimes and experiences a warm temperate climate. The Port Elizabeth area
has a bimodal rainfall pattern, with peaks in spring and autumn. Rainfall ranges from 400-
800mm per year in the region, but the Coega area falls at the low end of the range, averaging
at 400mm per year (Coetzee et al. 1996). The average monthly rainfalls for Port Elizabeth are
listed in Table 4.2b.
Table 4.2b: Average monthly rainfall (mm) listed for Port Elizabeth (1980-1996).
36.5 33.4 47.7 40.7 62.9 65.1 50.0 60.3 59.9 57.2 58.7 41.3
The Coega area is subject to strong gradient winds with a strong prevalence from the west and
west-south-west (41% combined frequency) all year round, and east (15%) from October
through to March. These winds occur mainly during the day and generate a significant amount
of fugitive dust (CSIR 1997). Particulate matter may be carried for considerable distances
from the source before being deposited downwind along these well-defined prevailing
directions (Burger and Scorgie 1998).
Chapter 4: Terrestrial Description 53

In addition to seasonal shifts in the wind field, diurnal variations in the wind regime occur.
These diurnal variations are due to the influence of land-sea breeze circulation on the airflow
of the region. Land-sea circulation arises due to the differential heating and cooling of land
and water surfaces. During the day, the land is heated more rapidly than the sea, which results
in a pressure gradient that generates a sea breeze (onshore wind). During the night, the land
cools more quickly than the sea, which results in an offshore wind (Burger and Scorgie 1998).
The atmosphere is neutral to very stable at night, which results in the reduction in the
dispersion potential. During stable or very stable conditions with light winds, surface
inversions can occur, trapping pollutants below the inversion. Alternatively, during conditions
of neutral stability during the day, an Internal Coastal Boundary Layer may occur. The result
is that, whether a plume is emitted either above or below this boundary layer, stack emissions
will experience enhanced fumigation towards the surface, close to the source (CSIR 1997).
4.3 GEOLOGY
The geology of the Eastern Cape coastal belt is complex, with a number of strata and rock
formations of different ages being evident (CES 1997). Most of the Eastern Cape rock
formations are sedimentary, with rock types such as sandstone, mudstone, limestone,
conglomerate and tillite being relatively common (CEN 1997).
The metropole of Port Elizabeth is situated on Peninsula Sandstone Formation of the Table
Mountain Group (a member of the Cape Super Group). This formation consists of course-
grained super- mature sandstone and is relatively resistant to erosion. It forms the bedrock of
Algoa Bay and emerges as outcrops in the bay as the islands of St Croix, Jahleel, Bird and
Brenton, and on land as Coega Kop. The substrates between these islands are recent marine
deposits. The beaches are comprised of dune and marine sands and the whole bay is
unconsolidated sand with the exception of Cape Recife, Woody Cape and Cape Padrone
(CEN 1997).
The geology of the area of the proposed Coega IDZ is characterised by coastal limestone,
overlaid by calcareous sands blown onshore. The dune and marine limestone are not all of the
same age. Three marine incursions and subsequent limestone deposition phases seem to have
occurred, each progressively younger and at lower altitude seawards (Marker 1988).
The upper region of the Swartkops River lies in the quartzites of the Table Mountain Group,
while its tributary, the Elands River, flows over Bokkeveld Group shales, a region which
tends to have well-drained acid soils. Below the confluence of these two rivers, the Swartkops
River flows across shales of the Uitenhage Group, which tend to be poorly drained (CEN
1997).
The geology of the Coega River is mainly of marine or estuarine origin. The pre-Cretaceous
basement comprises Table Mountain Group quartzites and shales of the Bokkeveld Group,
forming a trough into which the Cretaceous deposit of the Uitenhage Group was deposited.
Tertiary to recent deposits overlay this group.
The Coega Fault extends from west of Groendal Dam eastwards towards the coast just to the
west of the Coega River mouth, dipping at between 30° and 60° for about 120km. It is a
normal tensional fault, with a vertical southward throw of 500m to 100m, an offset that places
basement sandstones to the north in lateral contact with Cretaceous shales, siltstones and
sandstones to the south. The fault is seismically active (SRK 1999). Its location is shown in
Plan 3 of the Coega Development Framework Plan (Coega Implementing Authority 1999).
54 Chapter 4: Terrestrial Description

4.4 SOILS
In the south-eastern coastal region, sandy soils with variable depth and deep red sandy clay
loams overlying limestone are common. The southern coastal belt is characterised by coastal
sands, and sandy soils, lime-containing lithosols and weakly developed soils on rock (Plate
4.4a). Table 4.4a lists the various soil types particular to the different areas around Algoa Bay.
Plate 4.4a: A typical soil cross-section in the Coega area.
Table 4.4a: Description of soils within the Algoa Bay area (CEN 1997).
Area in Algoa Bay Description of Soil

City of Port Elizabeth Weakly developed lime-rich soils
Coega area & proposed IDZ Relative ly deep, red, lime-rich sandy clay loams
Alexandria dunefield Coastal sands and sandy soils
4.5 GEOHYDROLOGY AND HYDROLOGY

4.5.1 CATCHMENT DRAINAGE
The Coega catchment is approximately 45km long, 15km wide and has a total area of about
550km2 . Current land use in the catchment area is mainly agriculture with a fair amount of
natural subtropical thicket vegetation. Changes in land use from Agricultural to Special
Purposes will increase the area of paved surfaces, which will result in a substantial increase in
runoff, particularly in storm events. The total annual runoff will, however, not increase
appreciably because the area lies within a region of high evaporation (CSIR 1997). Various
authors indicate that recharge of underground aquifers in areas where Table Mountain Group
rocks are exposed at the surface may be 15% of mean annual precipitation.

4.5.2 SURFACE WATER

The Coega River valley represents the only major incision into the coastal landform in the
area between the Swartkops and Sundays rivers. Over time, the river has created a floodplain
valley between 400 and 1 000m wide. It is a relatively small sand-bed river, and is the most
significant surface water feature associated with the proposed Coega IDZ. However, except
for the estuary and associated salt works, the river is mostly located outside the proposed Core
Development Area. The river is currently used by a commercial salt works for industrial
purposes, and to a limited degree the estuarine beach area is used for recreational purposes
(shore angling). The incised river valley forms a natural route through which a transportation
corridor can be constructed linking the port with the industrial hinterland. It also provides a
location for a harbour basin with reduced earthworks and dredging costs. The Coega River
has been canalised around the north side of the salt works and runs through the area of
proposed port construction.
The Coega River is regarded as a sensitive system and is vulnerable to contamination (African
Environmental Solutions 1996). A further study was undertaken (African Environmental
Solutions 1999) to determine the preliminary classification of the Coega River based on the
classification system presented in Table 4.5a. The Coega River was divided into four reaches,
and each section classified according to Table 4.5a. Table 4.5b provides the classification of
the four reaches of the Coega River.
No other natural bodies of standing water occur in study area, although small temporary
wetland areas associated with the coastal dunes may exist.
Table 4.5a: Classification of rivers according to present ecological state.
Present Description of Perceived Conditions

Ecological
State Within Desired Range
A Unmodified, or approximates natural condition; the natural abiotic template should not be modified.
The characteristics of the resource should be determined by unmodified natural disturbance regimes.
There should be no human induced risks to the abiotic and biotic maintenance of the resource. The
supply capacity of the resource will not be used.
B Largely natural with few modifications; only a small risk of modifying the natural abiotic template
and exceeding the resource base should be allowed. Although the risk to the well-being and survival
of especially intolerant biota (depending on the nature of the disturbance) at a very limited number of
localities may be slightly higher than expected under natural conditions, the resilience and
adaptability of biota must not be compromised. The impact of acute disturbances must be totally
mitigated by the presence of sufficient refuge areas.
C Moderately modified; a moderate risk of modifying the abiotic template and exceeding the resource
base may be allowed. Risks to the well-being and survival of intolerant biota (depending on the
nature of the disturbance) may generally be increased with some reduction of resilience and
adaptability at a small number of localities. However, the impact of local and acute disturbances must
at least be partly mitigated by the presence of sufficient refuge areas.
D Largely modified; large risk of modifying the abiotic template and exceeding the resource base may
be allowed. Risk to the well-being and survival of intolerant biota (depending on the nature of the
disturbance) may be allowed to generally increase substantially with resulting low abundance and
frequency of occurrence, and a reduction of resilience and adaptability at a large number of localities.
However, the associated increase in the abundance of tolerant species must not be allowed to assume
pest proportions. The impact of local and acute disturbances must at least to some extent be mitigated
by refuge areas.
Outside Desired Range
E Seriously modified. The losses of natural habitats and basic ecosystem functions are extensive.
F Critically mo dified. Modifications have reached a critical level and the system has been modified
completely with an almost complete loss of natural habitat.

Table 4.5b: Classification of the four reaches of the Coega River (African Environmental
Solutions 1999).
Reach Region Class Index

Upper reaches of the catchment. A typical example of the
1 reach is at the bridge over the Coega River on the R75. ± 20- C
30m wide, not pristine but not seriously degraded or
disturbed.
Middle reaches of the catchment. A typical area is reflected at
2 the bridge on the road to Addo (R355). 20-30m wide but C
appears to be more disturbed than the upper reaches.
This reach incorporates the proposed Coega IDZ. The
3 influence of humans is more evident than in the upper or D
middle reaches. Appears to be slightly more degraded than the
other two areas.
This area is to the west of the N2 highway and includes the
4 river estuary. The salt works has had a major impact on the F
river in this reach.
4.5.3 ARTESIAN SYSTEM

The Coega Ridge Aquifer unit
The southern portion of the designated IDZ is underlain at depth by an artesian aquifer formed
by sandstones and quartzites of the Table Mountain Group. Confining this aquifer are a
succession of eastward-thickening Cretaceous formations (Uitenhage Group) up to 1 200m
thick near the coast. It is one of the few artesian systems in southern Africa and the only one
of practical importance in the country. This artesian system is protected under the
Government Proclamation No. 260 of 1957 and No. 958 of 1958.
The Coega Ridge Aquifer covers an area of approximately 525km2 and receives recharge
from the exposed Winterhoek Mountains to the north-west of Uitenhage. The groundwater
flow is largely controlled by the west- north-west/east-south-east strike of the bedding that
parallels the anticlinal fold axis and the strike of the Coega Fault. In the southern portion of
the Coega IDZ, the regional groundwater flow direction in the Coega Ridge Compartment is
modified and has a dominant north-easterly trend. The Coega Fault forms a recharge
boundary rather than an impermeable boundary to the compartment (SRK 1998).
The long term artesian yield of the Coega Ridge Aquifer is 90l/s, irrespective of the number
and yield of individual groundwater abstraction points. Average borehole yield is 3l/s.
Overexploitation of the aquifer has led to several periods where artesian yields and the
piezometric head have dropped, which led to the regulation of drilling and abstraction (SRK
1998, 1999).
Groundwater quality in the Coega Ridge Aquifer deteriorates relatively little along the flow
path from west to east and has been C14 dated at 28 000 years near Coega Kop. In general, the
water is mildly acidic due to oxidation of pyrite in the Table Mountain Group and exhibits
low conductivities (average 29mS/m) because of the chemically inert nature of the aquifer
host rock, but is often high in iron (Fe) and manganese (Mn). The Total Dissolved Solids are
in the range of 150 to 500mg/l, with sodium chloride (NaCl) being the dominant ions.
Overall, the water quality can be considered as moderate to good (SRK 1999).

Sundays River and Kirkwood Formations

The relatively impermeable clays have thin discontinuous sandstone horizons that yield low
sustainable volumes of poor quality water. The only exceptions are where boreholes have
yielded water from sandstone units within the clays that are connected through a system of
stacked channel sands to the water under pressure in the Coega Ridge Aquifer Unit below
(SRK 1998).
Groundwater flow is towards the sea in the east and down toward the Sundays River, which
forms a local base level in the north-east. The gentle groundwater gradient does not imply a
highly permeable formation but represents a remnant of a groundwater system that is
equilibrating slowly in the absence of significant recharge.
Groundwater derived from the Cretaceous formations in the study area is characterised by
NaCl. Electrical conductivities average 860mS/m and chloride is uniformly high as a result of
the marine environment of deposition of the Cretaceous formations. The water tends to be
very hard (brak), unpotable and is used for stock watering purposes in the area (SRK 1998).
The Alexandria Formation

The Alexandria Formation would form an ideal aquifer if it were saturated. It is likely that
with the construction of large paved surfaces, stormwater runoff and downpipes, water of
variable quality will be introduced into this formation (SRK 1998).
Pleistocene and recent sediments

These semi-consolidated, variably cemented and loose sediments have significant primary
porosity but the low rainfall and high evaporation rates inhibit direct recharge (SRK 1998).
4.6 AMBIENT AIR QUALITY AND NOISE
4.6.1 AMBIENT AIR QUALITY

Air quality is a broad term referring to the ambient air conditions in terms of gaseous and
particulate pollutants presently experienced in the area. The recent history of Port Elizabeth
air quality is one of gradual improvement. Major sources of particulate matter in the central
city and industrial suburbs during the 1970s and 1980s have either ceased operation or had
additional control measures implemented. This improvement in air quality was driven by
international pressures from parent companies on their local subsidiaries (CSIR 1997).
Based on current South African guidelines, the air quality in the Eastern Cape and the Port
Elizabeth area is relatively good, with all specific indices lying between background
concentrations and less than 50% of the guidelines. There are, however, presently a number of
businesses in the Markman Industrial Area creating unpleasant odours. The present air quality
allows for the establishment of an industrial area, and the opportunity to manage emissions in
a way that strives to maintain this standard. Any major industrial development with heavy
industries will alter this present air quality. South African air quality legislation is
inappropriate for sustainable development and is currently in a state of change (CSIR 1997).
4.6.2 AMBIENT NOISE

Areas that are usually detrimentally affected by noise include residences, educational
institutes, places of worship, offices, hospitals, parkland and recreational areas. The proposed
maximum permissible rating levels are based on national and international recommendations
and guidelines. Most codes of practice and legislation relating to environmental noise
incorporate the desired activity and time of day as part of the process that assesses and

controls noise. In South Africa, the procedures for the measurement, assessment and control
of environmental noise are contained in the Noise Control Regulations of the Environmental
Conservation Act 73 of 1989 and the SABS Code of Practice 0103-1997 for “The
measurement and assessment of environmental noise with respect to annoyance and speech
communication” (Jongens Keet Associates 1999).
Safetech (1998) took baseline noise measurements at various locations around Coega Kop. It
was found that the measurements taken at Motherwell, taken between the Addo road and the
start of the township’s houses, all exceeded the rating levels for urban districts, which apply
in this case. Nearby noise sources contributing to the rating level were passenger vehicles and
trucks using the road. The informal settlement at the Old Mission School, which is classed as
a rural district, has a rating level for ambient noise of 45 decibels (daytime SABS 0103:
1994). It is probable that these levels will be exceeded when haul vehicles pass the settlement.
4.7 VEGETATION AND FLORISTICS
The vegetation of the Eastern Cape is complex and is transitional between the Cape and
subtropical floras. Many taxa of diverse phytogeographical affinities reach the limits of their
distribution in this region. The region is best described as a tension zone where four major
biomes converge and overlap (Lubke et al. 1986). The region to the east of Port Elizabeth, as
far as the Alexandria dune fields, lies within a rain shadow. As a consequence, succulent
vegetation is extensive all along the coastal region, stretching inland towards Uitenhage and
Addo. The vegetation has been described as Subtropical Transitional Thicket (Cowling
1984), a dense, spiny vegetation type unique to the region. While species in the canopy are of
subtropical affinities and are generally wide spread, the succulents and geophytes in the
understory are of karroid affinities and are often localised endemics.
Detailed studies have been carried out on the terrestrial vegetation within the back-of-port
area (CES 1997, Finch 1996, Cambell 1998) and can be broadly divided into four categories:
dune vegetation, inland vegetation, salt marsh vegetation and secondary vegetation (Figure
4.7a).
4.7.1 DUNE VEGETATION

Three distinct zones are evident within Dune Vegetation, the Foredunes and Hummocks, the
Dune Woodland, and the Dune Grassland.
Foredunes and Hummocks

The area of mobile sand just behind the beach is dotted with small, vegetated dunes. The
hummock dunes are mounds of sand that are formed when plants reduce local wind speed and
cause sand deposition. Foredunes form semi-continuous cordons just above the spring high
water mark. Both types of dune are vegetated by similar dominant species, but the foredunes
may have greater species diversity due to greater stability.
The dominant species on the foredunes and hummocks include, Scaevola plumieri (L.) Vahl,
Gazania rigens (L.) Gaertn. var. uniflora (L.f.) Rössl., Tetragonia decumbens Mill., and
Chrysanthemoides monilifera (L.) T. Norl. subsp. rotundata (DC.) T. Norl.
Similar foredune and hummock vegetation is found all along the sandy coast of the Eastern
Cape (Lubke et al. 1986) and the vegetation type is well conserved in the nearby Alexandria
and Cape Recife nature reserves.

Figure 4.7a: The different vegetation types in the port development area.
Dune Woodland
The Dune Woodland (Plate 4.7a) stretches for about half a kilometre south of the Coega
River, while it forms a slightly wider band north of the river.
The Dune Woodland is heavily infested with Acacia cyclops a. Cunn. Ex G. Don (rooikrans),
and in much of the Woodland it forms the dominant species. The infestation has reduced the
diversity of these portions of the Woodland and consequently only pockets of uninfested
Woodland exhibit a high species diversity. Where sands are shallow over calcrete, the
indigenous component is dominated by stunted Olea exasperata Jacq. Where the sands are
slightly deeper, Pterocelastrus tricuspidatus (Lam.) Sond. dominates. Sideroxylon inerme L.
subsp. inerme, Brachylaena discolor DC. and Rhus crenata Thunb dominate the mature Dune
Woodlands which are found on the deep sands sheltered from onshore winds.
Examples of pristine Dune Woodland are rare along the coast of the Eastern Cape, however
Alexandria Nature Reserve does contain an example of near pristine Dune Woodland. A
relatively inaccessible pocket also occurs in the Skelmhoek dune field, which is south of the
Sundays River.

Plate 4.7a: A view of the Dune Woodland cover in the Coega area.
Dune Grassland
Within the Dune Woodland north of the Coega River there is a patch where very few trees
and shrubs are present and the area is dominated by grasses. This grassland may be secondary
in nature as it contains grasses, sedges and forbs commonly found in the Dune Woodland.
Acacia cyclops forms the major tree and shrub component within the Grassland, indicating
that this area has been cleared.
4.7.2 INLAND VEGETATION

Inland of the dunes and beyond the maritime influence lies the Subtropical Transitional
Thicket. This vegetation is characterised by dense impenetrable thickets within the valleys
while the arid flat-topped ridges with shallow soils are characterised by more open veld with
bushclumps dispersed in grasslands where the shrub and grassland are present in
approximately equal areas.
Mesic Succulent Thicket

Cowling (1984) produced a classification where he divided Subtropical Transitional Thicket
into syntaxonomic and structural units, which produced two orders, Kaffrarian Thicket and
Kaffrarian Succulent Thicket. Everard (1987) identified four types in the two orders defined
by Cowling (1984), viz. Mesic Succulent Thicket and Xeric Succulent thicket in the order
Kaffrarian Succulent Thicket, and the Mesic Kaffrarian Thicket and the Xeric Kaffrarian
Thicket in the order Kaffrarian Thicket. In a revision of Acocks’ veld types, Low and Rebelo
(1995) have classified Subtropical Transitional Thicket into the Thicket Biome, which is
divided into four types, namely Dune Thicket, Xeric Succulent Thicket, Mesic Succulent
Thicket and Spekboom Succulent Thicket. Arid forms of the Subtropical Transitional Thicket
generally have a sparse field layer consisting of succulents, dwarf shrubs and geophtyes while
the more mesic forms usually have a herbaceous field layer of grasses and forbs. Floristically,
it is relatively species rich with high alpha diversity (37.3 species/100m2 ) but is low in beta
diversity (Everard 1987). The thicket of this area is of the Mesic Succulent Thicket type
(Plate 4.7b).

Euclea undulata is the dominant species in the Mesic Succulent Thicket (MST). Other
common species include Rhus longispina Eck. & Zeyh., Cassine tetragona (L.f.) Loes.,
Schotia afra (L.) Thunb. var afra, Sideroxylon inerme L., Azima tetracantha Lam. and the
climber, Rhoicissus tridentata (L.f.) Wild & Drum. Both Aloe ferox Mill. and Aloe africana
Mill. are prominent.
Two forms of the Mesic Succulent Thicket (MST) are evident, a taller form which occurs in
the Coega River valley and a wind-pruned form which occurs on Well’s Estate and the
southern portion of Neptune Valley. The canopy of the wind-pruned thicket is between 1 –
2m tall and the total vegetation cover is less than the taller form of the Mesic Succulent
Thicket. With the exception of Aloe pluridens, which is rare in the wind-pruned form, the
species composition is the same. Mesic Succulent Thicket of this low growing form,
however, only occurs between Coega and Port Elizabeth.
Plate 4.7b: A close- up of a stand of Mesic Succulent Thicket.
Bontveld
The landscape within the river valleys of the Eastern Cape can be described as undulating,
with steep river valleys and flat-topped ridges. The vegetation on these flat-topped ridges
consists of grassveld/fynbos and karroid species interspersed with near-circular bushclumps
while the vegetation along the valleys consists of thicket (Finch 1996). The thicket species
require deep soils in order to survive in an area, while the fynbos, grass and karroid species
are able to exist on much shallower soils. The soils at higher altitudes (on the ridges and
limestone plateaus), where the Bontveld occurs, are typically shallow (Campbell 1998). The
bushclumps are able to develop on these ridges owing to depressions (karsts) forming in the
calcrete terrace as a result of dissolution. These karsts become filled with pebbles and/or soil
(a soil lens develops over the depression), resulting in patches of deeper soil dispersed in
shallow soils. It is within these depressions that the bushclumps develop, while the grassy
vegetation develops on the shallow soils in between the depressions. The occurrence of
Bontveld is therefore associated with calcrete deposits (Watson 2001).

There has been a significant amount of debate over the subject of Bontveld and whether it is a
transitional vegetation type, between Thicket and Grassland or Grassy Fynbos or whether it is
in fact a separate vegetation community. Watson (2001) carried out a detailed study of
Bontveld at Grassridge, investigating the ecosystem functio ning of Bontveld as well as
possible rehabilitation after strip mining. He described Bontveld as a separate and distinctive
vegetation type, stating that the Bushclumps of the Bontveld and the Thicket vegetation were
clearly separate communities with a definitive species composition.
The Bontveld on the study site is found between the Thicket of the northern bank of the
Coega Valley and the Dune Vegetation. The bushclumps are dominated by Euclea undulata,
and contain typical Bontveld clump dominants such as Scutia myrtina (Burm.f.) Kurz, Rhus
incisa L.f., Rhus pterota Presl and Ehretia rigida (Thunb.) Druce. Themeda triandra Forssk.,
Passerina rigida Wikstr. and Sutera microphylla (L.f.) Hiern. dominate the grassland
component.
4.7.3 SALT MARSH VEGETATION

Salt marshes surround the salt reclamation ponds of the salt works and remnants of the salt
marsh communities can be found on the pond banks. These salt marshes exhibit little
zonation, indicating that they have been severely disturbed by the surrounding infrastructure.
The salt marshes on the southern bank of the Coega basin are dominated by Sarcocornia
perennis (Mill.) A.J. Scott and Chenolia diffusa Thunb. The northern banks are steeper and
terrestrial vegetation has encroached into this salt marsh community. The submerged plants
Zostera capensis Setch. and Ruppia cirrhosa (Petag.) Grande. are also present.
4.7.4 SECONDARY VEGETATION

Secondary Grassy Fynbos
The Secondary Grassy Fynbos present in this area is a result of bush clearing, of Bontveld and
Mesic Succulent Thicket. This secondary vegetation contains the grassy fynbos elements
present in the Bontveld and a few remnants of the Thicket. However, most of the tree and
shrub components have been removed.
Cynodon dactylon pastures

Several patches of thicket have been cleared for pastures. These areas contain a dense cover
of Cynodon dactylon (L.) Pers. This grass dominates the area, resulting in a very low species
diversity. Only 26 species were found to occur in these pastures.
4.7.5 FLORISTICS
The vegetation of the study site consists mainly of elements of the Tongoland/Pondoland
phytochorion, subtropical species, mainly woody, which extend down the coast and inland up
the Eastern Cape rivers (Lubke et al. 1986; Lubke 1988). Also present are a number of the
elements from the Karoo region down towards the coast. Thus the complement of species
which occur in the region would be many of the subtropical species as well as the karoo plants
growing in these diverse vegetation types.
Species of special concern

There are a number of species that are either rare, vulnerable, endangered or endemic within
this study site. These are listed in Table 4.7a. Endemic species are those that are unique to a
defined area; endangered species are in danger of extinction. Vulnerable species are likely to

move into the endangered category and rare species have small world populations that are not
at present endangered or vulnerable but are at risk, as a threat could cause a critical decline.
The Bontveld, Dune Woodland and the Mesic Succulent Thicket displayed a high species
richness. Most of the endemic species were found in the Bontveld (33), followed by the Dune
Woodland (22). The Mesic Succulent Thicket and the Secondary Grassy Fynbos both had 11
endemic species, while in the Foredune & Hummock community and the Dune Grassland
only three endemic species were recorded. One endemic species was recorded in the
Cynodon dactylon pastures, while there were no endemics in the salt marsh community.
A total of 2 endangered, 4 vulnerable, 2 rare and 23 protected species were present in the
study site (Table 4.7a). The Bontveld contained 2 endangered species, 2 rare species, 4
vulnerable species and 15 protected species. The vulnerable endemic Syncarpha recurvata
(Plate 4.7c) occured in the Bontveld. This species is known to occur in only two other sites,
namely at Kaba Valley and at Grassridge and therefore has a high conservation priority
(McGwynne 1995). The Dune Woodland contained 3 vulnerable species, 1 endangered
species and 18 protected species, and the Mesic Succulent Thicket contained 1 endangered
species and 7 protected species. The Dune Grassland and Foredune & Hummock community
contained 2 and 3 protected species respectively. No endangered, vulnerable or rare species
were present in the Secondary Grassy Fynbos, the Cynodon dactylon pastures or the salt
marsh communities. However, the Secondary Grassy Fynbos and the Cynodon dactylon
pastures contained one protected species.
Table 4.7a: List of Rare, Endangered, Endemic and Protected species, compiled from
Campbell (1998) and CES (1997).
Species Family Community Status

Foredune & hummocks, Dune
Pentaschistis heptamera Poaceae Endemic
grassland, Bontveld
Dune Woodland, Bontveld,
Chondropetalum microcarpum Restionaceae Protected
Grassy Fynbos
Aloe africana Asphodelaceae Dune Woodland, Bontveld Endemic, Protected
Aloe humilis Asphodelaceae MST, Bontveld Protected
Aloe lineata Asphodelaceae MST Protected
Aloe pluridens Asphodelaceae MST Protected
Aloe ciliaris Asphodelaceae Bontveld Protected
Aloe striata Asphodelaceae Bontveld Protected
Bontveld, Grassy Fynbos,
Bulbine frutescens Asphodelaceae Endemic
Pastures
Haworthia cooperi Asphodelaceae Bontveld Protected
Haworthia transluscens Asphodelaceae Bontveld Protected
Kniphofia citrina Asphodelaceae Dune woodland Protected
Gasteria croucheri Asphodelaceae Dune woodland Endemic, vulnerable
Protasparagus crassicladus Asparagaceae Bontveld Endemic
Brunsvigia gregaria Amaryllidaceae Dune woodland Endemic
Cyrtanthus spiralis Amaryllidaceae Dune woodland Vulnerable
Cyrthanthus clavatus Amaryllidaceae Bontveld Rare
Boophane disticha Amaryllidaceae MST Protected
Dune woodland, MST,
Hypoxis stellipilis Hypoxidaceae Endemic
Bontveld, Grassy Fynbos
Dune woodland, Bontveld,
Hypoxis zeyheri Hypoxidaceae Endemic
Grassy Fynbos
Foredune & hummocks, Dune
Chasmanthe aethiopica Iridaceae Protected
grassland
Aristea anceps Iridaceae Dune woodland Bontveld, Protected
Aristea pusilla Iridaceae Dune woodland, Bontveld Protected
Gladiolus maculatus Iridaceae Dune woodland, Bontveld Protected
Tritonia lineata Iridaceae Dune woodland, Bontveld Protected
Satyrium membranaceium Orchidaceae Bontveld Endemic
Thesium scandens Santalaceae Dune woodland, MST Endemic
Rhoiacarpos capensis Santalaceae Bontveld Endemic
Lampranthus productus Mesembryanthemaceae Dune woodland, Bontveld Endemic
Lampranthus spectabilis Mesembryanthemaceae MST, Bontveld Endemic


Platythyra haeckeliana Mesembryanthemaceae MST, Bontveld Endemic
Rhombophyllum rhomboideum Mesembryanthemaceae Bontveld, Grassy Fynbos Endemic
Foredune & hummock, Dune
Silene primuliflora Caryophyllaceae Endemic
grassland
Adromischus cristatus Crassulaceae Endemic
Grassy Fynbos
Cotylendon velutina Crassulaceae Dune woodland, MST, Bontveld Endemic
Crassula intermedia Crassulaceae MST, Bontveld Endemic
Crassula perfoliata Crassulaceae MST Protected
Crassula mesembryanthhoides Crassulaceae Bontveld Endemic
Crassula pyramidalis Crassulaceae Bontveld Protected
Indigofera glaucencens Fabaceae Endemic
Grassy Fynbos
Indigofera disticha Fabaceae Bontveld, Grassy Fynbos Endemic
Indigofera sulcata Fabaceae Dune woodland Endemic
Psoralea repens Fabaceae Dune woodland Vulnerable
Zygophyllum uitenhagense Zygophyllaceae Endemic
Grassy Fynbos
Polygala ericifolia Polygalaceae Dune woodland Endemic
Muraltia squarrosa Polygalaceae Dune woodland, Bontveld Endemic
Euphorbia coerulescens Euphorbiaceae MST Endemic
Euphorbia fimbriata Euphorbiaceae MST, Bontveld Endemic
Euphorbia ledienii Euphorbiaceae MST, Bontveld Endemic
Euphorbia meloformis Endemic, Endangered,
Euphorbiaceae MST, Bontveld
Protected
Euphorbia globosa Rare, Protected,
Euphorbiaceae Bontveld
Endemic
Euphorbia gorgonis Euphorbiaceae Bontveld, Grassy Fynbos Endemic
Euphorbia polygona Euphorbiaceae Bontveld Endemic
Euphorbia stellata Euphorbiaceae Bontveld Endemic
Phylica gnidioides Rhamnaceae Dune woodland Endemic
Hermannia sulcata Sterculiaceae Dune woodland Endemic
Erica glumoflora Ericaceae Endemic
Grassy Fynbos
Rapanea gilliana Dune woodland,
Myrsinaceae Endangered, Endemic
Bontveld
Sideroxylon inerme Saptaceae MST, Bontveld Protected
Pachypodium bispinosum Apocynaceae MST, Bontveld Endemic, Protected
Pachypodium succulentum Apocynaceae Bontveld Protected
Walafrida nitida Selaginaceae Dune woodland Endemic
Blepharis procumbens Acanthaceae Endemic
Grassy Fynbos
Felicia zeyheri Asteraceae Dune woodland Endemic
Foredune & hummock, Dune
Felicia echinata Asteraceae Endemic
grassland, Dune woodland
Senecio pyramidatus Asteraceae Dune woodland Endemic
Syncarpha recurvata Asteraceae Bontveld Vulnerable, Endemic
Metalasia aurea Asteraceae Bontveld Endemic
Othonna rufibarbis Asteraceae Bontveld6 Endemic
6
Red data categories have been developed by the World Conservation Union (IUCN). The following categories
are briefly outlined below:
Endangered – Taxa in danger of extinction and whose survival is unlikely if the causal factors continue
operating.
Vulnerable – Taxa believed likely to be moved into the endangered category in the near future if the causal
factors continue operating. Included are species of which all or most of the populations are decreasing because of
overexploitation, extensive destruction of habitat or other environmental disturbance and species with
populations which have been seriously depleted and whose ultimate security is not yet assured.
Rare – Taxa with small or restricted populations which are not at present endangered or vulnerable but which
are at risk. These species are usually localised within restricted geographical areas and habitats, or are thinly
scattered over a more extensive range.
Indeterminate – Species that are suspected of being threatened but for which insufficient information is
currently available.
Endemic – Native, restricted or found naturally only in a particular locality or distribution range.

Plate 4.7c: The vulnerable species Syncarpha recurvata.
Alien and invasive species

A component of the vegetation that decreases the conservation value of the vegetation is the
degree of invasion by exotic species. The most common exotic invader in the site is Acacia
cyclops and the presence of numerous seedlings indicates that the infestation is spreading in
all areas. The alien species found at the study site are listed in Table 4.7b. The Dune
Woodland has the highest number of exotics and the highest percentage cover of exotics (50 –
90% cover), the Foredune and Hummock community has the second highest infestation of
alien species with a percentage cove r of 30%. Ten percent of the total cover of the grassveld
within the Bontveld was covered by alien species, while the bushclumps of the Bontveld only
had a 1% cover of alien species. The Secondary Grassy Fynbos had a high infestation of alien
species (25% cover), a feature common in secondary or disturbed vegetation types.
Table 4.7b: List of alien plants (compiled from Campbell (1998) and CES (1997)).

Foredune & Hummock,
Cortaderia selloana Poaceae Dune grassland, Dune Alien
woodland
Foredune & Hummock,
Amophila arenaria Poaceae Dune grassland, Dune Alien
woodland
Foredune & Hummock,
Thinopyrum distichum Poaceae Alien
Dune woodland
Briza maxima Poaceae Dune woodland Alien
Sisymbrium orientale Caryophllaceae Dune grassland Alien
Foredune & Hummock,
Dune grassland, Dune
Acacia cyclops Fabaceae woodland, Salt marsh, Alien invader
MST, Bontveld, Grassy
fynbos, pastures
Acacia longifolia Fabaceae Dune woodland Alien invader


Acacia saligna Fabaceae Dune woodland Alien invader
Acacia karroo Facaceae MST Declared invader
Melilotus indica Fabaceae Dune woodland Alien
Sesbania punicea Fabaceae Dune woodland Alien, Declared weed
MST, Bontveld, Grassy
Opuntia aurantiaca Cactaceae Alien invader
Fynbos
Opuntia ficus-indica Cactaceae MST, Bontveld Alien invader
Solanum nigrum Solanaceae Dune woodland Alien, Declared weed
Solanum sisymbrifolium Solanaceae Dune woodland Alien Declared weed
Datura ferox Solanaceae Dune woodland Alien, Declared weed
Nicotiana glauca Solanaceae Dune woodland Alien
Tarchonanthus camphoratus Asteraceae Dune woodland Declared invader
4.7.6 VEGETATION IN A REGIONAL CONTEXT

La Cock (1992) examined the conservation status of Subtropical Transitional Thicket and
regeneration of seedlings. He showed that this vegetation is very vulnerable to change and
therefore has a high conservation status, although at present only about ten percent of the total
extent of this vegetation type is conserved (Everard 1990, La Cock et al. 1990). The study
revealed that the germination and establishment of species was slow and the survival rate low.
The advance of thicket was found to occur from within the bushclumps but the establishment
of woody species in open environments was almost non-existent. Thus, although many
woody species may advance into grasslands through the expansion of bush clumps, the major
complement of species are very vulnerable to disturbance and sensitive to change (Palmer and
Avis 1996). These factors contribute to the difficulty of rehabilitating disturbed areas.
At a regional level the vegetation of the Eastern Cape is complex, with 14 distinct vegetation
types occurring within a 60km radius of the study area. This is due to the complex geology,
climate and transitional nature of the vegetation of the Eastern Cape. At this scale the
vegetation of the study area falls almost exclusively under the classification of Mesic
Succulent Thicket. Although Mesic Succulent Thicket dominates the vegetation of Algoa
Bay for approximately 15km inland, this is the only extensive patch of Mesic Succulent
Thicket in the sub-region.
The area of each vegetation type within the study site, as a portion of the total area of that
vegetation type in the Eastern Cape, will contribute to the importance of the conservation
value for each vegetation type. The areas of each of the vegetation types for the study site and
for the Eastern Cape are given in Table 4.7c.
Most of the vegetation types on the site do not constitute more than 5% of the total extent of
vegetation for the Eastern Cape. However, the study site represents a large percentage of the
total extent of the wind-pruned form of Mesic Succulent Thicket within the Eastern Cape.
The proportion of Bontveld within the study area represents only a small proportion of the
entire extent of Bontveld within the Eastern Cape. However, the loss of Bontveld from the
Coega area would further impact on the reduction of the Mesic Succulent Thicket Bontveld
type as the Bontveld at Grassridge is already under threat from mining. Therefore the
removal of the wind-pruned Thicket and the Bontveld from the site will constitute a
significant loss of these forms of vegetation.

Table 4.7c: Area of each of the vegetation types found on the study site and for the Eastern
Cape site (compiled from Campbell (1998)).
Area in Eastern Percentage

Vegetation type Area on site (km2 )
Cape (km2 ) on site
Foredune and Hummock 7.2 212 3.4
Bontveld 5.5 156 3.5
Salt Marsh 0.7 65 1.08
Mesic Succulent
12.5 19 310 0.06
Thicket
Wind-pruned MST 6.6 35 19
Dune Woodland 4.8 20 096 0.02
4.7.7 VEGETATION IN A NATIONAL CONTEXT

The vegetation in the Eastern Cape comprises a large portion of the South African biomes,
namely Forest, Thicket, Savannah, Nama Karoo and Fynbos. It is the convergence of these
biomes that result in the complexity of vegetation types in the Eastern Cape. At a national
level, Mesic Succulent Thicket is restricted to the Algoa Bay area, stretching from the
Gamtoos Valley eastwards to the Alexandria dunefield, and 15–30km inland (CES 1997).
4.7.8 ENVIRONMENTAL SENSITIVITY

Various criteria have been used to classify the back-of-port area into three categories of
sensitivity (high, moderate and low), reflecting both the sensitivity of the natural environment
(e.g. vegetation types) to development and the potential exposure of development to
constraints imposed by the natural environment and landscape. The present condition of the
site has also been taken into consideration, as it must be acknowledged that certain areas have
been previously disturbed, for example the pastures. Criteria that apply to the sensitivity of
the vegetation types and habitats within the area include: response to habitat fragmentation,
susceptibility to alien plant invasions and conservation importance. A map (compiled from
CES (1997) and CEN (1999)) showing the extent of the three sensitivity classes within the
study area is presented in Figure 4.7b. These sensitivity categories are defined as follows:
Low Sensitivity: These are areas that have been seve rely disturbed and/or already
contain development. These areas can be developed provided that
constraints, mitigating measures and alternatives are examined.
Moderate Sensitivity: The vegetation and habitats in these areas have had limited
disturbance. Conditions for limited development include the
preparation of a detailed EIA that specifically addresses mitigatory
measures, which at the very least meet existing environmental
standards.
High Sensitivity: These either occur in areas with a high sensitivity, or are zones that
have important ecological functions. No development should take
place in these areas, but it is recognised that in certain exceptional
cases, development may need to take place. Under such circumstances
mitigatory measures that exceed existing environmental standards are
required.

Figure 4.7b: A map showing the three different sensitivity areas in the port development
zone.
An overlay of the proposed land use and sensitivity map reveals that a large proportion of the
proposed development area has been defined as being of high sensitivity and is therefore not
suitable for development. The area includes the Bontveld, the Foredune and Hummocks, and
the Mesic Succulent Thicket (MST), found on the steep slopes as well as the wind pruned
form of MST.
Areas that have a high degree of alien plant infestation or have been previously disturbed,
such as the salt marsh community, have been defined as being of low sensitivity. The Mesic
Succulent Thicket (not including the area of steep slopes and the wind-pruned form) has been
defined as moderately sensitive. Although this vegetation type is of high importance locally,
the significance decreases at a regional scale because a large area of pristine MST is found in
the valleys above the Gamtoos River.
4.8 TERRESTRIAL FAUNA
The following faunal review is based on a synthesis and update of details presented in
previous faunal reports summarised in the Initial and Revised EIAs. Species lists for the
various taxonomic groups, e.g. birds, reptiles, amphibians and mammals, are given as
appendices in these reports (CES 1997; CES 2000; CEN 1997, etc.). They are not repeated
here. In some cases, the taxonomic and/or conservation status of a species has changed due to

recent scientific investigations (some as yet unpublished). These are highlighted in the
following review as they may modify the severity of impacts (discussed in Chapter 5) relative
to those published in earlier EIAs.
There is a general lack of pristine terrestrial habitats in the Coega region. This means that
some components of the terrestrial fauna have been severely impacted by previous human
activity, particularly the loss of vegetation, invasion of alien vegetation, local extinction of
large mammals, and va ried industrial developments (most conspicuously the salt works and
brick fields). Not all of these impacts have been negative. Hypersaline habitats in the
artificial salt pans have formed ideal conditions for a number of specialised birds, including
two species of flamingo and Chestnutbanded plover. In balance, however, the diversity of the
terrestrial fauna is reduced in comparison with its original state.
4.8.1 BIRDS
Due to its varied habitats, the Coega region has a diverse avifauna and over 150 species are
resident or common visitors to the region (CES 1997). Most diversity occurs in the thicket
clumps, although the shore and estuary both support specialised avifaunas. A number of
terrestrial birds are of conservation concern. Threatened occasional visitors to the region
include the blue crane (Anthropoides paradiseus), Stanley’s bustard (Neotis denhami), the
Martial eagle (Polemaetus bellicosus) and the African marsh harrier (Circus ranivorus). All
are considered Vulnerable in South Africa (Barnes 2000). It is estimated that there are fewer
than 100 pairs of Stanley’s bustard in the Eastern Cape. They use open habitats such as
provided by the open grasslands of Bontveld habitat within the IDZ and are frequently
recorded in the area. Other terrestrial species of conservation concern in a regional context
include the secretary bird (Sagittarius serpentaris) and the Knysna woodpecker (Campethera
notata). Both are considered Near Threatened in South Africa (Barnes 2000). No breeding
populations of all these terrestrial species are known in the Coega region, and with the
exception of Stanley’s bustard all are uncommon visitors.
Of more immediate conservation concern are water and sea birds associated with the coastal
dune habitat and seashore. Threatened seabirds utilising these habitats in the Coega area are
well-documented (e.g. La Cock and Cohen 1997; Wooldridge et al. 1997; Boshoff and
Sigwela 1998; and references therein). Endangered species (Barnes 2000) include Roseate
(Sterna dougalli) and Damara terns (Sterna balaenarum), whilst the African black
oystercatcher (Haematopus moquini) and Caspian tern (Hydroprogne caspia) are classed as
Near Threatened (Barnes 2000). Roseate and Damara terns are two of the most endangered
coastal species in South Africa. The former breeds on the offshore islands, but forages in the
surf zone and has been observed roosting in the dunes along the boundary of the port area.
Damara terns breed in the coastal dunes and are threatened by habitat loss and human
disturbance (CEN 1997; CSIR 1997).
Estuarine habitats are among the most threatened in southern Africa. Although the Coega
Estuary is now extensively modified from its natural condition due to the development of the
Coega Salt Works, it remains an important bird habitat, particularly for specialist salt-tolerant
species. Among these are a number of Near Threatened species (Barnes 2000), including the
Chestnutbanded plover (Charadrius pallidus), and the Greater (Phoeniconaias ruber) and
Lesser (Phoeniconaias minor) flamingo. The estuary is also used as a feeding and resting
ground by large numbers of Palaeractic wading birds during the austral summer, and is the
eighth most important wetland in the Eastern Cape Province. It is home to one of only two
colonies in the Eastern Cape of the winter-breeding grey-headed gull (Larus cirrocephalus).

A number of Important Bird Areas (IBA) have been identified within the Algoa Bay region
(Barnes 1998). Although none fall within the port or larger Coega IDZ area, the harbour
breakwaters do approach closely to Jahleel Island. This small islet currently forms part of the
Algoa Bay Island Nature Reserve, which is to be incorporated within the framework of the
Greater Addo National Park initiative in the near future (Kerley and Boshoff 1997). The
islands of the Algoa Bay Island Nature Reserve are listed as a Globally Important IBA
(Barnes 1998). They form the only islands along a 1 777km stretch of coastline between
Cape Agulhas and Inhaca Island in southern Mozambique. The islands were selected as a
Globally Important IBA because they are of national and international importance in the
conservation of the Cape gannet, African penguin and Roseate tern.
The conservation status and population estimates for some threatened seabirds summarised in
the Initial EIA (CES 1997) and Revised EIA (CEN 1999) reports for Coega are now outdated.
Revised status estimates are represented in Table 4.8a.
Table 4.8a: Threatened Birds in the Coega region.
Species Common Name Status

Sterna dougallii Roseate tern Endangered *
Sterna balaenarum Damara tern Endangered *
Morus capensis Cape gannet Vulnerable *
Spheniscus demersus African penguin Vulnerable *
Polemaetus bellicosus Martial eagle Vulnerable
Neotis denhami Stanley’s bustard Vulnerable
Circus ranivorus African marsh harrier Vulnerable
Hydroprogne caspia Caspian tern Near Threatened *
Charadrius pallidus Chestnutbanded plover Near Threatened *
Phalocrocorax capensis Cape cormorant Near Threatened *
Haematopus moquini African black oystercatcher Near Threatened
Phoeniconaias minor Lesser flamingo Near Threatened *
Phoeniconaias ruber Greater flamingo Near Threatened *
Sagittarius serpentaris Secretary bird Near Threatened
Campethera notata Knysna woodpecker Near Threatened
* significant populations occur in the Coega region
4.8.2 REPTILES
The Eastern Cape is home to 133 reptile species, nearly a third of those recorded in South
Africa and 27% of those occurring in the subcontinent. More than half of the Eastern Cape’s
endemic reptile species occur in the Algoa Bay area, giving the region a high conservation
value (Branch 1988a and b). Within the proposed port area and adjacent coastal region there
are 56 species of reptile. This includes 21 snakes, 27 lizards and eight chelonians (tortoises
and turtles) (CES 1997). The majority of these are found in Mesic Succulent Thicket and
riverine habitats. Only a few species are found in the coastal dunes and estuarine habitats.
The list of reptiles of special concern is very significant since it includes five endemic species
(two of which are endangered), four endangered sea turtles, eight CITES- listed species
banned from International Trade in Endangered Species, one rare species and four species at
the periphery of their range (Table 4.8b). More than a third of the species are described as
relatively tolerant of disturbed environments, provided migration corridors of suitable habitat
are maintained to link pristine habitats.

The taxonomic and conservation status of several species has changed since reptiles were
summarised in the Initial EIA (CES 1997) and Revised EIA (CEN 1999) reports for Coega.
The most significant change concerns recognition of the Albany adder (Bitis albanica) as a
valid species, and not an eastern race of a more widespread species (Branch 1999a). It is now
considered endemic to the Albany region of the Eastern Cape Province, from Port Elizabeth to
near Committees Drift, 25km northeast of Grahamstown. It has been found in open regions in
Mesic Succulent Thicket (previously Valley Bushveld) and also Bontveld, a unique and
poorly-studied open mosaic of grassland and thicket underlain by limestone. Only eight
specimens of this seriously endangered species have ever been collected. The first specimen
was found in Port Elizabeth 86 years ago, and four others near Grahamstown in 1934. In the
subsequent 65 years no further specimens have been found. These two populations are
probably extinct. Three recent specimens (1985, 1995 and 1997) were all collected in the
Algoa Bay hinterland (Colchester and Grassyridge). The latter lies close to the Coega
Industrial Development Zone and is also severely impacted by strip mining of the underlying
limestone. The Albany adder meets all the criteria (IUCN 2000) for inclusion as Globally
Endangered in the International Red List as it occurs in very low numbers, has suffered a
range contraction, and the only known population is subject to obvious environmental threats
(Branch 1999b). Although not recorded within the confines of the greater Coega IDZ, the
species does appear to be found in association with Bontveld habitats, and the only known
population is within close proximity to the Coega IDZ.
Fitzsimons longtailed seps (Tetradactylus fitzsimonsi) is known from a few specimens

collected in the Algoa Bay region. It has previously been treated as an isolated western race
of the African longtailed seps (T. africanus), and included as a species of conservation
concern in the Coega region (CEN 1997). The taxonomic status of the species should be
upgraded, and it is best considered as a relictual evolutionary species. It is known from less
than 20 specimens, and collection records indicate that it appears to prefer Grassy Fynbos
habitat (Branch, unpubl. obs.). The species may be threatened by increased fire regimes and
loss of habitat. However, although the species is of conservation concern, it is not known
from the Coega IDZ, and the existing habitats within the region appear unsuitable for the
species. It is not considered further in this report or in the environmental impacts associated
with the proposed port.
Table 4.8b: Reptile species in the Coega region that are listed in the International Red Data
Book of Reptiles and Amphibians (CEN 1997).

Cordylus tasmani Tasman’s girdled lizard Endemic *
Scelotes anguineus Dwarf burrowing skink Endemic *
Acontias (meleagris) orientalis Eastern legless skink Endemic *
Pachydactylus sp. (St Croix Island) St Croix thicktoed gecko Endemic/Endangered *
Bitis albanica Albany dwarf adder Endemic/Endangered *
Bradypodion ventrale Southern dwarf chameleon CITES Appendix II *
Cordylus cordylus Cape girdled lizard CITES Appendix II *
Pseudocordylus microlepidotus Cape crag lizard CITES Appendix II
Varanus niloticus White-throated monitor CITES Appendix II *
Varanus albigularis Nile monitor CITES Appendix II *
Geochelone pardalis Leopard tortoise CITES Appendix II *
Homopus areolatus Parrot-beaked tortoise CITES Appendix II *
Cherisina angulata Angulate tortoise CITES Appendix II *
Dermochelys coriacea Leatherback sea turtle Endangered #


Chelonia mydas Green sea turtle Endangered #
Eretmochelys imbricata Hawksbill sea turtle Endangered #
Caretta caretta Loggerhead sea turtle Vulnerable #
Lamprophis fuscus Yellowbellied house snake Rare
Mabuya varia Variable skink Peripheral *
Scelotes caffer Cape dwarf skink Peripheral
Nucras taeniolata Albany sandveld lizard Peripheral
Philothamnus semivariegatus Spotted bush snake Peripheral *
* Confirmed as occurring on, or within 2km, of the Coega IDZ
# International RDB status; all are considered Vulnerable in the SA RDB
4.8.3 AMPHIBIANS
Amphibians are an important and often neglected component of terrestrial vertebrate faunas.
They are well represented in sub-Saharan Africa, from which approximately 600 species have
been recorded (Frost 1985). Currently amphibians are of increasing scientific concern as
global reports of declining amphibian populations continue to appear (Phillips 1994; and
reference therein). Although there is no consensus on a single cause for this phenomenon,
there is general agreement that the declines in many areas, even in pristine protected parks,
are significant and do not represent simple cyclic events. Frogs have been aptly called
bioindicator species, whose abundance and diversity is a poignant reflection of the general
health and well-being of aquatic ecosystems. They are important components of wetland
systems, particularly ephemeral systems from which fish are either excluded or of minor
importance. In these habitats, they are dominant predators of invertebrates, many of which
may impact significantly on humans (e.g. as vectors of disease).
A relatively rich amphibian fauna occurs in the Eastern Cape, where a total of 32 species and
sub-species occur. This represents almost a third of the species known from South Africa.
Knowledge of amphibian species diversity in the Coega region is limited and based on
collections housed in national and provincial museums. It is estimated that as many as 17
species may occur (CES 2000). However, none of these species are endemic or of
conservation concern (CSIR 1997).
4.8.4 MAMMALS
Large game makes up less than 15% of the mammal species in South Africa and much less in
numbers and biomass. In developed and farming areas, such as the study area, this percentage
is greatly reduced, with the vast majority of mammals present being small or medium-sized.
Of the 63 mammal species known or expected to occur in the Coega area, two species are
endemic, Duthie’s golden mole (Chlorotalpa duthiae) and the pygmy hairy- footed gerbil
(Gerbillurus paeba exilis). Both occur in the dune vegetation, which forms only a limited area
of the proposed port area. Thirteen of the 63 species are Red Data Book species (Table 4.8c),
and five of these are medium to large in size, occupying relatively large ranges, and will be
adversely affected by development as their ranges become restricted (CEN 1997). However,
apart from the two endemic small mammals, no significant breeding populations of the other
species of conservation concern are known to occur in the Coega region.

Table 4.8c: Mammal species of conservation concern known from the Algoa Bay region that
may occur in the Coega area (CES 1997).
Species Common Name RDB Status

Felis lybica African wild cat Vulnerable
Orycteropus afer Aardvark Vulnerable
Mellivora capensis Honey badger Vulnerable
Mystromys albicaudatus White-tailed rat Vulnerable
Cephalophus monticola Blue duiker Rare
Atelerix frontalis African hedgehog Rare
Proteles cristatus Aardwolf Rare
Poecilogale albinucha Striped weasel Rare
Graphiurus ocularis Speckled dormouse Rare
Chlorotalpa duthiae Duthie’s golden mole Indeterminate/ Endemic
Pipistrellus kuhlii Kuhl’s pipistrelle Indeterminate
Dasymys incomtus Water rat Indeterminate
Suncus infinitesimus Least dwarf shrew Indeterminate
Gerbillurus paeba exilis Pygmy hairy- footed gerbil Endemic
4.8.5 TERRESTRIAL INVERTEBRATES

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated vegetation
has not been extensively studied. The distribution of the terrestrial invertebrates found along
the coast is dependent to a large degree upon the extent and composition of the natural
vegetation (Gess and Gess 1988). One grasshopper species, Acrotylos hirtus, is endemic to the
dunefields. Of nearly 650 butterfly species recorded within the borders of South Africa, 102
(16.1%) are considered of conservation concern and are listed in the South African Red Data
Book for Butterflies (Henning and Henning 1989). Two have become extinct, whilst three
rare butterflies are known from a number of scattered localities in the Coega region.
There is confusion in the literature concerning the distribution of the rare lycaenid butterfly
Aloeides clarki. The Revised EIA (CEN 1999) records this small copper as “endemic to the
Coega area”, whilst Henning and Henning (1989) state that its distribution as “Endemic to the
Eastern Cape, inhabiting coastal flats to the north of Port Elizabeth. Also recorded along the
Sundays River and at Avontuur.” The latter, based on a single record, falls in the Western
Cape Province. It is evident that although the species is rare, it is not strictly endemic to the
Coega region. This is supported by Clark and Dickson’s (1971) comment “Found on the
Aloes-Coega Flats, eastern Cape Province; the distribution is, however, likely to be
considerably wider.” This appears to be confirmed by additional records (Sundays River and
Avontuur) listed by Henning and Henning (1989). Even if correct, however, the scientifically
important type locality for the species (Aloes, Coega Flats, Cape Province) does occur in the
Coega region, and the most well-known colony of this rare species does occur in the port
region at Neptune Valley. The foodplant of the species is an Aspalathus sp. (Fabaceae) (Clark
and Dickson 1971). Four species of Aspalathus (A. biflora, A. rubens, A. subtigens, and A.
spinosa) have been recorded from Dune thicket habitat in the Coega IDZ (CES 1997). It is
not known which, if any, are utilised by Aloeides clarki.
The status of two other rare butterflies listed as occurring in the greater Coega region in the
Revised EIA (CEN 1999) is more problematic. The small blue lycaenid butterfly
Lepidochrysops bacchus is known from widely-scattered localities in the western (Tygerberg
Hills, Malmesbury, Piketberg, Wolseley) and northern Cape (Bitterfontein, Garies,
Kamieskroon) (Clark and Dickson 1971; Henning and Henning 1989), as well as from four

localities in the Eastern Cape (Henning and Henning 1989; CEN 1999). One of these is
reported to occur in the “general area” of the Coega IDZ, but not within the port area (Pringle
1999). Its habitat is reported as “bush covered slopes, bushy Macchia, in areas receiving
between 50 and 75mm annual rainfall” (Henning and Henning 1989). This does not conform
to habitats found in the port area. Another rare small copper lycaenid, Poecilimitis pyroeis,
has a similar distribution to Lepidochrysops bacchus, extending from the southwestern Cape
to Little Namaqualand. An isolated eastern race, P. p. hersaleki, was described from
Witteklip Mountain (Lady’s Slipper) to the west of Port Elizabeth. It has also been recorded
from St Albans and from the Baviaanskloof Mountains. Its prefered habitat is given as
“well- vegetated, rocky mountain slopes (Henning and Henning 1989), although the typical
race, P. p. pyroeis, was collected “on the sand flats near the coast of False Bay” (Clark and
Dickson 1971). There is currently no evidence that this rare butterfly occurs in the Coega
area, or that a suitable habitat for the eastern race exists in the port area.
The localities of Lepidochrysops bacchus and Aloeides clarki have been mapped with regard
to the proposed Coega IDZ, and their distributions were taken into account when defining the
open space system (CES 1997). It should be noted that the presence of a host ant species
seems to be necessary for completion of the life cycles of all these butterflies. Larvae
(caterpillers) of Copper butterflies of the genus Aloeides, e.g. A. thyra (Migdoll 1994) and
presumably A. clarki (although the full life cycle of this species remains unknown), shelter
during the day in the nests of their host ant species. They emerge at night with the ants to
feed on their specific food plant(s). Larvae of butterflies of the genera Poecilmitis and
Lepidochrysops have similar associations with ant hosts. The ecological interplay between
adult butterfly, larval food plant(s) and host ant complicates the conservation of these
lycaenid butterflies as it is necessary to protect all parts of the co-adapted system.

CHAPTER 5:
TERRESTRIAL IMPACTS
AND MITIGATION
5. TERRESTRIAL IMPACTS AND MITIGATION
5.1 INTRODUCTION
Proposed land use within the port limits (port and back-of-port - see section 1.1.2) include a
port and Port Cluster, Electronics and Technical Cluster as well as a mixed use corridor
(Figure 5.2a). Various project actions are to take place within the port limits during the
development of the port infrastructure and its associated industries. Although in some cases
there will be overlap, major environmental impacts will be associated with many project
actions during the construction of the port and its associated infrastructure and industries, or
during their subsequent operation. The likely impacts arising from the various project actions
are noted below. Impacts during the construction and operational phases are discussed
separately. Some impacts may occur in both phases but are only discussed in the phase in
which they predominantly occur.
5.1.1 PROJECT ACTIONS ASSOCIATED WITH CONSTRUCTION

In general the construction activities associated with the construction phase are orientated
around providing the following land based structures and facilities:
• transportation corridors, road and rail access;

• servitudes to the port and associated industries, including power lines, water and sewage
linkages, and stormwater control;
• serviced sites for the various clusters;
• a container terminal and staging yards;
• a bulk liquid tank farm; and
• port administration buildings/offices.
Terrestrial issues are not, however, limited to the back-of-port infrastructure but may also
arise from the construction activities associated with the construction of the breakwaters, quay
walls and the possible onshore disposal of excavated material.
Fuller details of the various project actions and construction activities are found in Chapter 3,
and their locations are shown in Figures 3.2b and 3.3a in Chapter 3, as well as Figure 5.2a in
this chapter.
5.2 KEY ISSUES
5.2.1 INTRODUCTION
Environmental impacts affecting the biophysical environment are grouped into a number of
Key Issues. Issues 1–5 involve impacts on biological aspects of landscape quality and
biodiversity that directly or indirectly cause changes in the presence and abundance of
vegetation types and various faunal groups. These impacts may act in concert, synergistically
or antagonistically, to mitigate or exacerbate their compound effects. As the life of the various
faunal groups differ considerably, their responses to the same environmental issue may also
differ. They are therefore discussed as separate impacts under a specific Key Issue, e.g.
Biodiversity: Loss of amphibian diversity. Issues 6–8 relate to changes in the physical
environment and the diverse ways in which these affect the fauna. Impacts were evaluated
according to standardised criteria defined in Section 2.6. The Key Issues and Impacts are
discussed below and summarised in Tables 5.2a and 5.2c.
Chapter 5: Terrestrial Impacts and Mitigation 77

In brief, the Key Issues include:
ISSUE 1 – LOSS AND FRAGMENTATION OF SENSITIVE HABITATS

ISSUE 2 – LOSS OF BIODIVERSITY
ISSUE 3 – LOSS OF SPECIES OF SPECIAL CONCERN
ISSUE 4 – DESTRUCTION OF HABITATS IMPORTANT TO MIGRATORY SPECIES
ISSUE 5 – INTRODUCTION OF ALIEN SPECIES
ISSUE 6 – SUBSTANTIAL INCREASE IN ROAD TRAFFIC
ISSUE 7 – CHANGES IN HYDRODYNAMICS AND WATER QUALITY
ISSUE 8 – CHANGES IN FIRE REGIMES
Previous recommendations for environmental constraints on project actions

The initial Strategic Environmental Assessment of the Coega IDZ (CES 1997) identified a
number of sensitive areas, and recommended areas where development was either prohibited
(‘No Go’ areas) or constrained (‘No Go But’ areas). The selection of sensitive areas was
based on a variety of criteria, including topography, habitat fragmentation, biodiversity and
the presence of threatened fauna and flora. It should be noted that these recommendations
were precautionary in nature due to the lack of project definition and clarity at that time.
The Coega Development Framework Plan recognised the existence of Environmentally

Sensitive Areas identified in previous specialist reports, and states that:
“Intrusion into the environmentally sensitive areas should be kept to the absolute
minimum and will only be allowed close to the proposed deep water port.
Environmental mitigation measures to protect sensitive vegetation on valley slopes and
coastal dune formations and limits on ambient air quality that preclude concentrations
of medium to heavy industry, will be implemented in accordance with the
recommendations of the Environment Impact Studies.”
It further noted that environmental constraints on development at the main site included:
“Environmentally sensitive areas, Jahleel Island and the vegetation on the valley slopes
and the coastal dune formations and areas of sensitive flora and fauna (rare butterflies
and plants)”.
The Coega Framework Plan (Map 3) mapped less extensive environmentally sensitive areas
in the Core Development Area (CDA), identifying only the steep slopes on both sides of the
lower Coega River, including the Neptune’s Valley area. However, comparison of the current
proposed land use and initial sensitivity map (Figure 5.2a) reveals that large proportions of
the proposed development occur in areas previously identified as being of high sensitivity
(‘No Go’ or ‘No Go But’). These now include Bontveld in the eastern area of back-of-port;
Foredune and Hummock habitat between Coega River and St George’s Strand; and Mesic
Succulent Thicket (MST) on the slopes of both banks of the Coega River. Moreover,
excluding Neptune’s Valley, the remaining sensitive areas are extensively intruded by
proposed developments. These include a transport corridor along the western slopes of the
Coega River and extensive encroachment by the proposed tank farm on the eastern bank,
including an area of Bontveld.
78 Chapter 5: Terrestrial Impacts and Mitigation

Core Development Area
NO GO
B
NO GO?
GO But
Indian
Ocean
Core Development Area
NO GO
C
NO GO?
Turning GO But
basin
Breakwaters
Indian
Ocean
Indian
Ocean
NO GO: These either occur in areas with a high sensitivity or are zones that have
important ecological functions. No development should take place in these areas, but
it is recognised that in certain exceptional cases development may need to take place.
This would be the case for the harbour, which needs to be located along the coast,
and access routes. Conditions include the preparation of a comprehensive EIA and
Tank farm CDC headquarters mitigatory measures that exceed existing legislated environmental standards.
Mixed use corridor N2 National road GO But: These are areas with a moderate sensitivity. The vegetation and habitats
Industrial estate precinct Transport corridor in these areas have had limited disturbance. Conditions for development include the
Business and administrative precinct Gazetted port boundary (see 1.1.2) preparation of a detailed EIA that specifically addresses mitigatory measures, which
Academic institution Port Authority Division boundary at the very least meet existing environmental standards.
NO GO?: These areas have possible Bontveld vegetation and have been described
as NO GO? until the status of Bontveld could be elucidated.
Figure 5.2a: Part A shows the proposed industries in the Core Development Area and the proposed future port developments.
Part B depicts the ecological sensitivity of the back-of-port region (Coega Rezoning EIA, CES 2000) while Part C depic ts a
revision of the sensitivity map following recent work on the Bontveld.

Other recommended environmental measures

A number of additional environmental measures have been recommended in previous
specialist reports relating to the entire Coega development. They include:
• The sensitive vegetation types indicated in previous reports (CES 1997) must be provided with a “protection
status” to ensure that future planning recognises the importance of the identified areas.
• Compensatory lands to mitigate the loss of sensitive habitats, particularly the salt pan and Bontveld, should
be considered. It was recommended that the new salt pans at Tankatara, near the Sundays River, should be
investigated as a potential site. It is important that compensation lands be in close proximity to the project,
of equal or better habitat quality, and of similar vegetation community, elevation, hydrology, wind patterns,
and substrates, which would provide the greatest benefit.
• A systematic and comprehensive study of the feeding, nesting and roosting sites of estuarine and shore birds
in the Algoa Bay region is needed.
• Access roads that are created, or any other areas that are disturbed for the construction of the transmission
line and pipeline should be reclaimed when they are not needed for ongoing maintenance.
• The area of disturbance should be confined to the smallest practical area, considering topography, placement
of facilities and access roads, locations of sensitive species, public health and safety, and other limiting
factors. To the extent practical, previously disturbed areas within the project area should be used for the
placement of equipment, work staging sites or parking of vehicles.
• Access to the dunefields should be restricted.
• All contractors and employees must be instructed that their activities shall be confined to locations within
flagged or otherwise marked areas.
• Cross-country use of vehicles and equipment must be prohibited except within those portions of the project
area subject to surface disturbance.
• CDC and Portnet must advise employees, contractors and visitors of the need to adhere to speed limits and
to avoid any animals, which may be encountered on, or crossing roads to and from the project area.
• Available topsoil should be stockpiled for subsequent use during reclamation activities. Soil stockpiles
should be located away from washes and other areas prone to erosion and consolidated as appropriate to
reduce disturbance to undisturbed areas within the project area. Stockpiles should be kept shallow and dry, if
not to be used within one (1) year of initial placement, to protect seeds contained in the soil.
• Contractors, on advice from an ecologist, should salvage specimens of selected plant species from the
project area prior to construction, to be utilised during habitat enhancement activities or other project
reclamation needs.
• Weed control measures should be implemented such that introduced plants will not become established
within the project area. Manual or mechanical means of control shall be the preferred method employed. Use
of other methods (e.g. herbicides) should be cleared with the Department of Agriculture. The weed control
measures should be implemented within six (6) months of when noxious weeds are visually identified within
the project area.
• Waste and food items must be contained in closed containers to reduce attractiveness to opportunistic
predators.
• Recreational firearms and pet dogs and cats must be prohibited from the project area. The Technical Officer
must contact local animal control agents to remove feral dogs that are observed within the project area.
5.2.2 CONSTRUCTION ISSUES
ISSUE 1: LOSS AND FRAGMENTATION OF SENSITIVE HABITATS

General comments
Due to the size of the back-of-port area, a variety of habitats will be impacted. These include
the varied vegetation communities, e.g. Dune thicket, Bontveld, etc. (see Chapter 4) and other
habitats defined by their physical attributes, e.g. estuary, salt pan and shore. Different, and
often specialised floras and faunas are associated with these habitats, and they may be
impacted in different ways by the various project actions. A number of vegetation types, e.g.
Dune Woodland, Salt Marsh, Grassy Fynbos, etc. are less environmentally- sensitive, due
mainly to infestation with alien plants. Impacts on these vegetation types will therefore be of
low significance. Fragmentation of habitats can lead to the loss of viable populations,
especially in animals requiring large home ranges (e.g. birds of prey, bovids, carnivores,

primates, etc.). The disruption to gene flow between isolates also reduces biological fitness in
the long term, compromising the abilities of populations to adapt to future environmental
perturbations.
Numerous project actions result in the loss and fragmentation of sensitive vegetation. These
include all land clearance associated with the construction of the port, development of
transport links and servitudes, deposition of excavated and dredged material, development of
back-of-port industries. In addition, the construction of the port basin, breakwaters and
container area will destroy estuarine, salt pan and shore habitats.
The impact of specific habitat loss was rated using the following criteria:
i) The extent of the habitat type elsewhere in the region.
ii) The extent of the habitat presently conserved.
iii) Importance of the habitat to species of special concern, i.e. threatened or endemic
species, or those of ethnofaunal or economic importance.
Impact 1 - Loss of the Foredune and Hummock vegetation communities

Cause and comment
The development of the back-of-port area will result in the clearing of vegetation that has
been classified as sensitive and not suitable for development (Chapter 4 – Figure 4.7a & b).
The Foredune and Hummock communities have been classified as sensitive vegetation
communities as these vegetated dunes act as a barrier for sand blowing from the beach onto
the site and once disturbed are extremely sensitive to erosion. In addition, the sandy habitats
serve as habitat for a number of endemic species, including the Algoa Bay dwarf legless skink
(Scelotes anguineus), Duthie’s golden mole (Chlorotalpa duthiae) and the pygmy hairy-
footed gerbil (Gerbillurus paeba exilis).
All Foredune and Hummock habitats to the west of the Coega River to Joost Park will be lost
during the current phase of construction. Similar habitat towards St George’s Strand will be
cleared during future developments. Although similar habitat occurs to the west of the Coega
River, the port development forms a barrier to gene flow for both plants and animals, isolating
pockets of dune vegetation habitats to the west.
Due to their relatively uncomplicated vegetational structure, and the fast maturity of many of
the dominant components, rehabilitation of these habitats can be expected to take only a short
period. The impacts on these habitats will then occur over the short to medium temporal scale.
The linear nature of the habitats means they are well-connected to adjacent reservoir regions
between which vertebrates can migrate. Many of the species found in these habitats are
tolerant of disturbance.
Mitigation and management

All exposed areas must be stabilised against erosion and rehabilitated, using appropriate
indigenous vegetation, in order to prevent the remobilisation of dunes and subsequent erosion.
Access roads should be limited in order to minimise the disturbance and where possible
should run parallel to the dune system. Foredune and Hummock habitat from Joost Park to St
George’s Strand should be fully protected, pending possible removal during future phases of
the port development.

Significance statement
The loss of Foredune and Hummock vegetation will definitely occur with the development of
the back-of-port area, resulting in a permanent severe impact at a localised level. The
environmental impact resulting from the loss of this vegetation will therefore be of HIGH
significance. Implementation of mitigation measures will reduce the impact to one of
MODERATE significance.
Impact 2 - Loss of the Mesic Succulent Thicket habitat

Cause and comment
The Mesic Succulent Thicket (MST) of the steep slopes has been previously classified as
highly sensitive owing to the erosion implications of clearing steep slopes. Existing plans for
the transport corridor will, however, result in encroachment on the steep slopes. Although
subtypes of MST are well-protected in adjacent reserves (e.g. Addo Elephant National Park),
this vegetation is under pressure in the Eastern Cape due to extensive bush clearance.
Moreover, the wind-pruned subtype of MST is only found in the Algoa Bay coastal plain and
therefore has a limited distribution causing it to be classified as moderately sensitive. In
addition, MST is the major habitat occupied by the endemic Tasman’s girdled lizard
(Cordylus tasmani) and endangered Albany adder (Bitis albanica), and also serves as a refuge
for the remaining small mammal fauna and for many breeding birds.

All slopes exceeding a 1:3 gradient should ideally not be developed but were development
does take place the slopes must be stabilised and rehabilitated.. Access roads should be
limited in order to minimise the disturbance. The development should be placed so that as
little disturbance as possible occurs within the sensitive vege tation types.
The loss of Mesic Succulent Thicket vegetation will definitely occur with the development of
the back-of-port area, resulting in a permanent moderately severe impact at a localised level.
The environmental impact resulting from the loss of this vegetation will be of MODERATE
significance. Although the proposed mitigation measures constitute best practice, any clearing
of Mesic Succulent Thicket will result in a decrease in the total extent of a limited vegetation
type and therefore the impact remains one of MODERATE significance.
Impact 3 - Loss of Bontveld

Cause and comment
The Bontveld vegetation has been classified as highly sensitive (Chapter 4 sensitivity map).
The total extent of Bontveld, which is a unique vegetation type, is very limited (only 156km2 ).
Small isolated patches of Bontveld have been identified in other areas of the Eastern Cape,
but these differ in plant composition. The only other patches of Bontveld of the same
vegetation type as that found at Coega occur at Grassridge and in the Addo Elephant Park.
The removal of the Bontveld from the back-of-port area has great implications for the
conservation of Bontveld as a whole, as this vegetation type is already under severe threat
from mining in the Grassridge area. Bontveld is a major habitat occupied by the endemic and
endangered Albany adder (Bitis albanica), and the karst formation in the limestone pavement
may provide essential refugia for hibernating small reptiles.

Development and access roads should be designed so that as little disturbance as possible
occurs within the Bontveld patches. The remaining Bontveld patches should be fenced and
actively protected from illegal dumping and infestation with alien vegetatio n.

The loss of Bontveld vegetation will definitely occur with the development of the back-of-
port area, resulting in a permanent severe impact at a national level. The environmental
impact resulting from the loss of this vegetation will therefore be of HIGH significance. Even
with protection of most of the Bontveld patches, some loss and fragmentation of this sensitive
habitat will occur and therefore the impact remains one of HIGH significance.
Impact 4 - Loss of salt pan and estuarine habitats

Cause and comment
Salt marshes are important for the ecological health of estuaries as they provide nutrients and
biomass to the other organisms in the system. Salt marshes surround the salt ponds of the
solar salt reclamation system in the Coega basin. Remnants of salt marsh vegetation can be
found on the pond banks and near the Coega River mouth. The salt marshes have almost no
evidence of zonation, indicating that they are severely impacted, particularly by tracks, roads
and overgrazing. The Coega Estuary has been impacted on and modified for use by the
existing salt works.
Numerous project actions will impact on the sensitive salt pan and estuarine habitat. The main
impacts include:
• increased noise and light from heavy road traffic associated with the construction of the
port infrastructure;
• development of the transport corridor along the southwestern edge of the salt pan;
• haulage routes across the salt works for disposal of excavated material from the harbour
basin to proposed sites on the eastern headland and tank farm sites;
• high dust levels settling in the salt pans may reduce algal productivity, resulting in
reduced food resources for endangered birds; and
• proposed future development of the port extension further into the Coega River, into the
region currently occupied by the existing Coega salt works, will cause the complete loss
of this habitat.
Port construction results in the complete modification of the mouth of the Coega Estuary.
Subsequent phases of the proposed port expand into the estuary and it will take up the space
of the existing estuarine and salt pan habitat. This will directly affect the bird populations
utilising these areas. During the initial construction phase, the port will only utilise a small
area of the estuary and the salt pans will remain available as habitat for birds. The disturbance
by secondary structures and transport routes to and from the port may, however, be sufficient
to disturb birds utilising the estuary.
The hypersaline habitat of the salt pans are important feeding grounds for a number of
endangered bird species, including two species of flamingo and the chestnutbanded plover. In
addition, the pans are used as feeding and resting grounds by large numbers of Palaearctic
waders during the austral summer. Coega has been classified as the eighth most important
wetland in the Eastern Cape. Most species utilise both the estuary and the salt pans.
Several species warrant special (conservation) attention. The Coega salt pans host one of only
two colonies of the winter-breeding greyheaded gull (Larus cirrocephalus) in the Eastern
Cape. Both the lesser Phoeciconaias minor and the greater Phoenicopterus ruber flamingo
feed regularly in the salt pans. They are classified as near threatened and are fast approaching
endangered status as their specialised habitat rapidly diminishes. Six other bird species
recorded within the estuary are identified as species of conservation concern and are listed in

the South African Red Data Book. These are the Roseate tern (Sterna dougalli),
chestnutbanded plover (Charadrius pallidus), whitefronted plover (Charadrius marginatus),
African black oystercatcher (Haematopus moquini), Damara tern (Sterna balaenarum) and
Caspian tern (Hydroprogne caspia).
The high levels of disturbance during the port construction phase (blasting, heavy traffic) will
have a high negative impact on the estuarine birds using this area, causing many of them to
seek alternative sites in the vicinity. Some species will cope better than others with the
disturbance, depending on their specialised requirements. The main threats to their continued
survival derive from the destruction of breeding sites and displacement from feeding habitats.
This impact will be particularly severe for greyheaded gulls and chestnutbanded plovers
(Rare) as their breeding sites will be destroyed during construction of the port. Flamingos
(Indeterminate) and a number of migrant waders will lose a dependable food source with the
closure of the salt pans. Damara terns (Rare) and Caspian terns (Rare) will lose secluded
roosts at the Coega Pipe. It is further predicted that the two flamingo species will be
particularly negatively affected.

The area between the port and the N2 road is relatively unaltered during the phase 1
development of the port and will therefore continue to provide some habitat for the estuarine
species that currently use it. Continued existence of the salt pan habitat, even after closure of
the commercial salt works, will provide specialised habitat for threatened bird species until
implementation of possible future phases of port development. In the long term, however,
effective mitigation for birds inhabiting the Coega Estuary is unlikely due to the high levels of
disturbance during the construction and operational phases of the port.
Off-site mitigation involves identification and protection of alternative sites in the general
vicinity of the Coega Estuary. A number of potential sites within a radius of 20 kilometres
from the proposed port occur, including the Papenkuils River, various saltpans in the
Swartkops Valley, Sundays River Estuary, and new saltpans at Tankatara, near the Sundays
River. They are illustrated in Underhill, Cooper & Waltner (1980). It is unknown whether
these sites can serve as alternatives for birds displaced from the Coega Estuary. The most
recent surveys at the majority of these sites were conducted 20 years ago (Underhill, Cooper
& Waltner 1980). A systematic and comprehensive study of the feeding, nesting and roosting
sites of estuarine and shore birds in the Algoa Bay region should be considered to further
elucidate the impacts on birds.
Suitable roosting and nesting sites for shorebirds, including the greyheaded gull, may become
available on the beaches east of the port. Construction of the breakwaters will prohibit future
off-road use of the eastern beach by the public. This area, designated for “Low Intensity
Recreation” in the urban plan for the CDA, could be set aside as a protected reserve for
displaced wildlife. It lies adjacent to the Algoa Bay islands, and its control and management
may best be integrated with protection of these regions.
The loss of shore and estuarine habitats will definitely occur with the excavatio n of the Coega
palaeochannel and breakwaters, resulting in a permanent severe impact at a localised and
national level. Despite the disturbed nature of these ecosystems, they provide functional
habitats for numerous birds. Thus, the environmental impact resulting from the loss of these
habitats will be of HIGH significance. Compliance with the suggested mitigatory measures

may reduce this impact at a regional level, but the ongoing high disturbance resulting from
construction and changes in land use will locally retain a HIGH significance.
Impact 5 - Fragmentation of sensitive habitats

Cause and comment
Dune vegetation is largely continuous along the coastal region. The development of the port
will destroy habitat around the Coega River mouth, and disrupt continuity in the corridor of
dune habitats. Although there are few dune habitat specialists, they exhibit low tolerance to
habitat disturbance. However, large tracts of suitable habitat remain elsewhere in coastal
areas in the northern parts of the Algoa Bay. Species populations readily recover following
rehabilitation, and are therefore more resilient to habitat fragmentation than other specialists.
Few faunal groups have significant components of their diversity in Dune habitats. The most
significant is the pygmy hairy- footed gerbil (Gerbillurus paeba exilis), which requires open or
partially vegetated sand.
In the east, Mesic Succulent Thicket (MST) in the back-of-port area is restricted to the eastern
slopes of the Coega River, whilst in the west it is extensively fragmented by grazed clearings.
On the eastern plain it is replaced by Bontveld. Both vegetation types are threatened
elsewhere, either by bush clearance for agricultural land (MST), or from strip mining of the
underlying limestone (Bontveld). Both habitats are naturally fragmented by topographic and
edaphic factors. The thicket formation of MST forms a natural refuge for the few large
mammals surviving in the region. The karst formation of Bontveld also forms refugia for
small reptiles and amphibians. Physical features of both vegetation types therefore serve to
support a diverse fauna.

Dune vegetation is important in binding mobile sands, and preventing wind erosion of sand
sheets. The vegetation is sensitive and easily destroyed by off-road vehicle activity and as
such, activity in this region should be prohibited. The remnant coastal strip of dune vegetation
between St George’s Strand and the port will be isolated. Its maintenance and rehabilitation
will be costly if it is not protected from uncontrolled access. Proposed development in dense
MST habitat on the steep slopes on both banks of the Coega River, shown in Figure 4.7b,
Chapter 4, should be avoided. Future development of the tank farm and industrial precinct in
the eastern section of the back-of-port area must ensure that viable corridors are maintained
between Bontveld habitats.
Project actions will fragment sensitive habitats previously highlighted as occurring in areas
identified as environmentally unsuitable for development (‘No Go’ areas; Figure 5.2a). These
include areas of Dune vegetation, Mesic Succulent Thicket and Bontveld. These actions will
definitely result in a long term severe impact at a localised level. The environmental impact
resulting from the loss of this vegetation will be of HIGH significance. Even with protection
and the maintenance of linkages between sensitive habitats, it is likely that this impact will
remain of HIGH significance.
ISSUE 2: LOSS OF BIODIVERSITY

General comments
For some vertebrate groups the back-of-port area is now characterised by a reduced faunal
species richness, due to direct and indirect effects of previous and current land use. This is
particularly noticeable for large mammals, which have been largely extirpated. The avifauna

remains relatively rich, whilst the less conspicuous reptile and amphibian fauna remains
relatively unaffected.
Impact 1 - Loss of amphibian diversity

Cause and comment
The Eastern Cape has a diverse amphibian fauna, with a total of 32 species and sub-species
present. Amphibians are the least specious group of terrestrial vertebrates in the back-of-port
area, where approximately 17 species may occur. This represents almost a sixth of the species
known from South Africa, but none are endemic to the Algoa Bay region. Fortunately most
species are probably widely distributed through the coastal regions. Amphibian populations
are declining globally under a variety of local and global threats, and they ha ve been aptly
termed bioindicator species for ecosystem stability.
The main project actions impacting on amphibians include site clearance, which results in the
destruction and loss of sensitive habitats, potential loss or pollution of aquatic habitats, and
increased road mortalities as frogs migrate to and from breeding sites.

Mitigation involves the protection and maintenance of water quality in the back-of-port area;
the presence of a planned system of linked habitat corridors, particularly around water
sources; and the monitoring of seasonal movements of amphibians between breeding sites.
The construction of permanent water sources with vegetated margins may have a beneficial
impact, creating additional breeding sites for amphibians.
Project actions in the back-of-port area will probably result in a long term moderately severe
impact at a localised level on amphibian diversity. However, as the amphibian fauna within
the back-of-port area comprises widely-distributed species, it will be of MODERATE
significance.
Impact 2 - Loss of reptile diversity

Cause and comment
The Eastern Cape is home to 133 reptile species, nearly a third of those recorded in South
Africa and 27% of those occurring in the subcontinent. More than half of the Eastern Cape’s
endemic reptile species occur in the Algoa Bay area, giving the region a high conservation
value (Branch 1988b). The proposed port area and adjacent coastal region has a reptile fauna
which includes 21 snakes, 27 lizards and eight chelonians (tortoises and turtles), and contains
approximately 50% of the reptile species found within the Eastern Cape (CES 1997). The
majority of these are found in Mesic Succulent Thicket and Bontveld habitats. Only a few
species are found in the coastal dunes and estuarine habitats.

General mitigation involves the maintenance, protection and linkage of diverse habitats within
the back-of-port area; the prevention of encroachment by alien plants and animals; the control
of excessive disturbance; and prevention of chemical pollution.
impact at a localised level on reptile diversity. However, as the reptile fauna within the back-
of-port area comprises mainly widely-distributed species, it will have a MODERATE
significance.

Impact 3 - Loss of bird diversity

Cause and comment
Birds are by far the most speciose vertebrate component in the back-of-port area and probably
over 200 species can be expected. A number of summer migrants utilise the area, particularly
waders in the estuary, salt pan and shore. The Coega region has a diverse avifauna, with most
diversity occurring in the thicket clumps, although the shore and estuary both support
specialised avifaunas. The salt pans at Coega provide an important habitat for estuarine birds.
The pans are used as feeding and resting grounds by large numbers of Palaearctic waders
during the austral summer. Coega has been classified as the eighth most important wetland in
the Eastern Cape. The foredune and shore are used as roosting sites for terns, gulls and other
shorebirds.

General mitigation involves the maintenance, protection and linkage of diverse habitats within
the back-of-port area; the prevention of encroachment by alien plants and animals; the control
of excessive disturbance; and prevention of chemical pollution.
impact at a localised level on bird diversity. A number of specialist species will probably
vacate the region due to disturbance. However, the majority of bird species inhabiting the
back-of-port area have wide distributions and the project actions will cause impacts of
MODERATE to LOW significance.
Impact 4 - Loss of mammal diversity

Cause and comment
The area demarcated as land available for port development supports a low diversity of
mammals. Although potentially up to 63 mammal species may once have occurred in the
Coega region, only 23 mammal species have been recorded or are likely to remain in the
back-of-port area. Most medium and large mammals have now been extirpated and are
probably present only in low numbers or as vagrants passing through the area. Among these
the blue duiker (Cephalophus monticola) is confined to forests, thickets or dense coastal bush
(Smithers 1983) and probably occurs in the area in very low numbers. The largest mammals
still likely to be found in viable populations are the grysbok (Raphicerus melanotis) and the
common duiker (Sylvicapra grimmia), both small antelope. Bush clumps in Bontveld and
pockets of dense Mesic Succulent Thicket serve as refugia for many grazing mammals, and
also as fodder for more selective feeders. Although dune habitats support a reduced mammal
diversity, they are the preferred habitat of Duthie’s golden mole (Chlorotalpa duthiae) and the
pygmy hairy- footed gerbil (Gerbillurus paeba exilis). Both are endemic to the region.

Protection from development and disturbance of dune vegetation, Mesic Succulent Thicket
and Bontveld habitats will help to maintain high mammal diversity. Where the loss of habitat
is unavoidable, linkages between habitat fragments should be maintained. Fences should be
constructed to allow passage of small and medium-sized mammals.
impact at a localised level on mammal diversity. However, as the surviving mammal fauna

within the back-of-port area mainly comprises widely-distributed species, it will be of LOW
significance.
ISSUE 3: LOSS OF SPECIES OF SPECIAL CONCERN

General comments
No endemic or threatened amphibians occur in the back-of-port area. The proposed
developments will therefore have no impact on amphibian species.
Impact 1 - Loss of plant species of special concern

Cause and comment
The vegetation within the back-of-port area contains eight Red Data listed species, namely
two endangered species, four vulnerable species and two species that are listed as rare (See
Table 4.7a). The vulnerable, endemic species Syncarpha recurvata is present as an isolated
pocket in the Bontveld community to the east of the port development (Figure 4.7a, Chapter
4). This robust shrublet flowers from September-December, and is known to occur in only
two other sites, namely at Kaba Valley and at Grassridge and therefore has a high
conservation priority (McGwynne 1995). The site at Grassridge is under possible threat as a
licence has been issued for mining to the Pretoria Portland Cement company. The loss of this
species from the Coega site would constitute the loss of a large proportion of the existing
population of this species.

The impact to threatened plants can be mitigated by identification and protection of the Red
Data listed species prior to vegetation clearing. The population of Syncarpha recurvata and
the vegetation immediately surrounding the population, in particular, should be fenced to
prevent disturbance during the construction phase. Where possible, areas containing Red
Data listed species should not be cleared. If vegetation clearing is to take place, the species of
special concern should be relocated to patches of similar vegetation in the surrounding area.
The loss of plant species of special concern will definitely occur with the clearing of
vegetation from the back-of-port area. The loss of these species will be severe as it will
constitute a permanent loss of Red Data species and will therefore impact on a national level.
The environmental impact resulting from the loss of plants of special concern will therefore
be of HIGH significance. Successful relocation of the threatened plants could reduce the
impact to one of MODERATE significance.
Impact 2 - Loss of reptile species of special concern

Cause and comment
The list of terrestrial reptiles of special concern in the back-of-port area is significant as it
includes five endemic species (two of which are endangered), eight CITES-listed species
whose international trade is controlled, one rare species, and four species at the periphery of
their range. Most threatened species are linked to sensitive habitats. Tasman’s girdled lizard
(Cordylus tasmani) and the Algoa dwarf burrowing skink (Scelotes anguineus) are relatively
common and widespread in the region. They are both present in the existing Addo Elephant
National Park. The proposed development is therefore unlikely to cause significant impact to
these species.
The Albany adder (Bitis albanica) is the most endangered vertebrate species in southern
Africa (Branch 1999b). It is endemic to the Albany region of the Eastern Cape Province,
from Port Elizabeth to near Committees, 25km northeast of Grahamstown. It has been found

in open regions in Mesic Succulent Thicket and Bontveld. Only eight specimens of this
seriously endangered species have been collected during the last 86 years, with the most
recent specimens (1985, 1995 and 1997) all being collected in areas adjacent to the Coega
IDZ. The Albany adder meets the criteria for inclusion as Endangered in the International
Red List as it occurs in very low numbers, has suffered a range contraction, and the only
known population is subject to obvious threats. Although no specimens have been collected
from the area directly affected by the back-of-port area, the species has been collected within
15-20km in similar habitat. Long term developments resulting from the Coega IDZ can be
expected to impact the whole area.
The small population of spotted geckos occurring on St Croix Island in Algoa Bay have
recently been shown to be genetically well-differentiated from spotted geckos (Pachydactylus
maculatus) on the adjacent mainland (Wieczorek, Branch and Channing, unpub.obs.). They
have for sometime been known to grow to a much larger size (Branch 1991). Studies are
currently underway to determine whether the St Croix population deserves recognition as a
separate species. If the population has diverged sufficiently for such recognition, the new
species will have the smallest distribution of any southern African vertebrate and will be of
the highest conservation concern. Even if the population has not diverged to specific status, it
is still likely that it could be recognised as an insular race, deserving of conservation
protection.
Project actions impacting on reptiles of special concern include the destruction and loss of
sensitive habitats, including Bontveld, Mesic Succulent Ticket and Dune vegetation.

Many of the species are described as relatively tolerant of disturbed environments, provided
migration corridors of suitable habitat are maintained to link pristine habitats. Particular
protection should be given to Bontveld habitat and the insular spotted gecko on St Croix
Island. Contractors and the Environmental Officer for the Coega IDZ should be aware of the
appearance and habitats of the endangered Albany adder. The discovery of a population
within the Coega region should be immediately brought to the attention of conservation
authorities. A captive breeding programme (CBP) could be initiated, ideally at the Bayworld
Snake Park, Port Elizabeth, where the species’ reproductive biology can be studied. The CBP
can act as an educational facilitator and secure a reservoir of breeding stock for re-
introductions to future rehabilitated areas. The initiative mentioned above should not be the
sole responsibility of the CDC or PAD, although they could provide logistical and financial
support.
Numerous project actions will probably result in a long term moderately severe impact at a
localised and national level. The environmental impact resulting from the loss of reptile
species of special concern will therefore be of HIGH significance. Compliance with the
suggested mitigation measures will reduce this to MODERATE significance. However, in
the absence of the Albany adder, the significance will be LOW.
Impact 3 - Loss of bird species of special concern

Cause and comment
Numerous birds of special concern occur in the back-of-port area. Although a number of
terrestrial birds of conservation concern may be occasional visitors to the region, no breeding
populations of these terrestrial species are known in the Coega region. Of more immediate
conservation concern are water and sea birds associated with the salt pans, coastal dune

habitat and seashore. Threatened seabirds utilising these habitats in the Coega area are well-
documented (e.g. La Cock and Cohen 1997; Wooldridge et al. 1997; Boshoff and Sigwela
1998; and references therein). Endangered species include Roseate (Sterna dougalli) and
Damara terns (Sterna balaenarum), whilst the African black oystercatcher (Haematopus
moquini) and Caspian tern (Hydroprogne caspia) are classed as Near Threatened. Roseate and
Damara terns are two of the most endangered coastal species in South Africa. The former
breeds on the offshore islands, but forages in the surf zone and has been observed roosting in
the dunes along the boundary of the port area. Damara terns breed in the coastal dunes and are
threatened by habitat loss and human disturbance.
Estuarine habitats are among the most threatened in southern Africa. Although the Coega
Estuary is now extensively modified from its natural condition due to the development of the
Coega Salt Works, it remains an important bird habitat, particularly for specialist salt-tolerant
species. Among these are a number of Near Threatened species (Barnes 2000), including
Chestnutbanded plover (Charadrius pallidus), Greater (Phoeniconaias ruber) and Lesser
(Phoeniconaias minor) flamingo.
La Cock and Cohen (1997) and Barnes (2000) reviewed knowledge of the Roseate tern in
southern Africa. Both reports considered the species to be Endangered, and to be conspecific
with fragmented populations in western Europe, western Atlantic Ocean, East Africa,
Madagascar, Asia and Australia. The world population ha s been recently estimated close to 40
000 pairs (Gochfeld et al. 1998). The present breeding population of Roseate terns in southern
Africa is currently estimated to comprise 210 to 220 pairs. Tree and Klages (2001) suggest
that on the available evidence, the South African population is reproductively isolated from
other populations and may represent a distinct species. The species remains the second rarest
seabird breeding in southern Africa. If the southern African population is isolated and
represents a valid species, then its current Red Data Book status as Endangered (Barnes 2000)
would have to be upgraded to the highest international rating of Globally Critically
Endangered.
Project actions during the construction of the harbour will disturb roost and breeding sites for
endangered terns on Jahleel Island; breeding and feeding sites for the Near Threatened
chestnutbanded plover in the salt pans; feeding grounds for both Near Threatened flamingo
species; and feeding, nesting and roosting grounds for the endemic African black
oystercatcher.
The Initial Environmental Assessment concluded that the predicted impacts associated with
the construction of the port on shorebird habitat would involve the total and irreversible
transformation of the site, and tha t no on-site mitigation measures were possible. Boshoff and
Sigwela (1998) concurred with this assessment. Although some feeding, roosting and
breeding habitat will be lost, this will be limited to a 2.5 kilometre stretch of shoreline. It was
concluded (CEN 1999) that there is probably sufficient habitat elsewhere on the shores of
Algoa Bay to accept the threatened birds (especially the black oystercatcher, Caspian tern and
Damara tern) which will be displaced. The construction and operation of the port was thus
likely to have a low impact on the shorebirds that use the site.

Mitigatory measures are limited and concern limiting the disturbance and access to the off-
shore islands as well as the maintenance of a functional salt pan environment after the existing
operation is closed down or relocated.

Project actions will definitely result in a long term very severe impact at a localised and
national level. The environmental impact resulting from the loss of bird species of special
concern will therefore be of VERY HIGH significance. Limiting access and disturbance to
the islands and maintenance of salt pan habitats could reduce this impact to one of HIGH
significance.
Impact 4 - Loss of mammal species of special concern

Cause and comment
Although the back-of-port area has a greatly reduced mammal diversity, a number of
threatened species may still occur in low densities within the region. The African wild cat,
Felis lybica (Vulnerable) is found throughout the Eastern Cape, has a wide habitat tolerance
(Smithers 1983) and may occur on the area demarcated for port development. Additional
wide-ranging mammals, listed as rare or vulnerable in the South African Red Data Book that
may occur in the study area are aardvark, Orycteropus afer (Vulnerable), honey badger,
Mellivora capensis and the African hedgehog, Atelerix frontalis, (Rare). Duthie’s golden
mole (Chlorotalpa duthiae) and the pygmy hairy-footed gerbil (Gerbillurus paeba exilis) are
endemic to the region. Both are restricted to dune habitats, the former in the dune woodland,
and the latter in the open dune sand where there is little or no vegetation (Van Teylingen et al.
1993).
Project actions impacting on mammals of special concern include the destruction and loss of
sensitive habitats, particularly Mesic Succulent Ticket and Dune vegetation, and the
construction of fences that inhibit the movement of wide-ranging species.

Protection from development and disturbance of dune vegetation, dense Mesic Succulent
Thicket and Bontveld habitats will help to maintain high mammal diversity. Where the loss
of habitat is unavoidable, linkages between habitat fragments should be maintained. Fences
should be constructed to allow passage of small and medium-sized mammals. Gaps in the
fences should be allowed for but must be regularly checked for snares. Single strand fences
should be used and all forms of mesh fencing should be avoided.
Project actions will proba bly result in a long term slight impact at a localised level on
mammals of special concern. The environmental impact resulting from the loss of mammal
species of special concern will therefore be of LOW significance.
Impact 5 - Loss of butterfly species of special concern

Cause and comment
In southern Africa the butterflies most at risk are the myrmecophilous (ant associated)
Lycaenidae. These species are often quite local and rare, as they require the presence of both
host ant and host plant as well as optimal climatic conditions. These species are particularly
vulnerable to any disturbance of their preferred habitat. Two such species occur in the Coega
region, although only one has an important breeding site in the back-of-port area. The small
blue lycaenid butterfly Lepidochrysops bacchus is known from widely-scattered localities in
the western and northern Cape, as well as from four localities in the Eastern Cape (Henning
and Henning 1989; CEN 1999). One of these is reported to occur in the “general area” of the
Coega IDZ, but not within the port area (Pringle 1999). Its preferred habitat is given as “well-
vegetated, rocky mountain slopes” (Henning and Henning 1989). There is no evidence that
this rare butterfly occurs in the back-of-port area, or that suitable habitat for it exists in the

port area. All three species are listed as Rare in the Red Data Book for Butterflies (Henning
and Henning 1989) and they are also recorded as rare in the IUCN Red Data Book.
The rare lycaenid butterfly Aloeides clarki inhabits coastal flats to the north of Port Elizabeth
and along the Sundays River. The species is rare, but is not strictly endemic to the Coega
region. Good colonies still exist near Barkley Bridge in the Sundays River Valley, and also in
Neptune’s Valley within the back-of-port area. There is an additional record from Avontuur,
but Pringle (1999 and pers.comm.) notes that this colony, although similar to A. clarki, may
be referable to the closely-related Aloeoides gowani and even represent a taxonomic novelty.
Moreover, the scientifically important type locality for the species (Aloes, Coega Flats, Cape
Province) may now be extirpated. The Neptune Valley site is therefore of critical importance
to this localised species.

It is essential that the known habitat of Aloeides clarki in Mesic Succulent Thicket in the
Neptune Valley region be fully protected. Development and the disposal of excavated
material at this site should be prohibited. The status of the population should be regularly
monitored by butterfly specialists to ensure that all aspects of the species’ complex life-cycle
are protected, including its food plant and ant host. Pringle (1999) recommends that the ridge
upon which the butterflies fly and the areas around the ridge are left undisturbed.
Development must not be allowed within 100 metres of the existing colony. He further
recommends that the valley below the ridge be left undisturbed. Fencing of the area should be
considered.
Project actions will definitely result in a long term severe impact at a localised and national
level. The environmental impact resulting from the loss of butterfly species of special concern
will therefore be of HIGH significance. Compliance with the suggested mitigation measures
will reduce this to MODERATE significance.
ISSUE 4: DESTRUCTION OF HABITATS IMPORTANT TO MIGRATORY

SPECIES
Impact 1 - Loss of habitats important to migratory species
Cause and comment
The salt pans and estuary are used as feeding and resting grounds by large numbers of
Palaearctic waders during the austral summer. Coega has been classified as the eighth most
important wetland in the Eastern Cape. Most species utilise both the estuary and the salt pans.
No mammal species are known to utilise habitats within the back-of-port area on a seasonal
basis. Migratory fruit bats may use some habitats during the fruiting season of some trees,
whilst insectivorous bats may also visit the region when invertebrate food is plentiful.

Effective mitigation for migratory birds inhabiting the Coega salt pans and estuary is not
possible due to the high levels of disturbance expected. Migrant waterbirds may find alternate
feeding and resting sites nearby, particularly in the Swartkops River estuary and associated
salt pans. Off-site mitigation involves the securing of suitable alternative sites in the general
vicinity. The potential sites include the Swartkops River estuary and associated salt pans, and
the new saltpans at Tankatara, near the Sundays River.

Disturbance and habitat loss for migratory species in the back-of-port area will probably
result in a medium to long term moderately severe impact at a local and regional level. The
environmental impact of this unmitigated action would be of LOW to MODERATE
significance.
ISSUE 5: INTRODUCTION OF ALIEN SPECIES

Impact 1 - Introduction of alien vegetation
Cause and comment
The high degree of invasion by exotic species decreases the conservation value of much of the
land within the back-of-port area. The most common exotic invader is Acacia cyclops. Dune
habitats are the most seriously impacted, with Dune Woodland having the highest number of
exotics and the highest percentage cover of exotics (50 – 90% cover). Ten percent of the
total cover of the grassveld within the Bontveld is covered by alien species. However, the
bushclumps of the Bontveld remain relatively pristine, with only a 1% cover of alien species.
Various project actions may increase the introduction of alien vegetation in the region. The
fragmentation of natural habitats due to site clearance, landscape gardening of developed
sites, and increased transport links into the region may all lead to the introduction and
establishment of alien plants.

Mitigation necessitates the continual monitoring of the remaining pockets of natural
vegetation for the presence of alien plants, and landscaping with indigenous plants.
The introduction of alien vegetation, resulting from increased fragmentation of natural
habitats, landscape gardening of developed sites, and increased transport links into the region,
will probably result in a long term moderately severe impact at a localised level. The
environmental impact of this unmitigated action would be of MODERATE significance.
Compliance with the suggested mitigatory measures could effectively reduce this to LOW
significance.
Impact 2 - Introduction of alien fauna 7

Cause and comment
A number of introduced alien bird species have become increasingly widespread in urban
areas in South Africa, including the house sparrow (Passer domesticus), European starling
(Sturnus vulgaris), Indian myna (Acridotheres tristis), and house crow (Corvus splendens).
The last two species are aggressive aliens that have recently been observed in the Port
Elizabeth region, and are likely to become established in industrial areas.
Some exotic species also hybridise freely with endemic species, leading to the decline of the
latter. Examples include the decline in pure wild populations of the African wildcat and black-
footed cat following hybridisation with feral domestic cats (Smithers 1986), and also
interbreeding between indigenous yellow-billed ducks and introduced mallards (De Moor and
Bruton 1988). Once introduced, alien species are often difficult and costly to eradicate.

Control of alien species requires continuous monitoring and eradication procedures. The
house crow was successfully controlled in Durban from 1989-1991, when control was
7
The introduction, resulting impact and management of rats and cats is discussed in Chapter 7 - Issue 5, Impact
2.

curtailed and crow numbers increased again rapidly. This has the potential to become a
human health hazard (Madge and Burns 1994).
The introduction of alien fauna will probably result in a long term moderately severe impact
at a localised level. The environmental impact of this unmitigated action would be of
MODERATE significance. Compliance with the suggested mitigatory measures will
effectively reduce this to LOW significance.
ISSUE 6: SUBSTANTIAL INCREASE IN ROAD TRAFFIC

Cause and comment
Over the life of the project, additional injuries and mortality to wildlife would be expected to
result from direct impacts with motor vehicles commuting to the project area and other
equipment travelling to and from the project area and the ancillary area. Experience from
other projects (e.g. Suikerbosrand Nature Reserve, Gauteng) suggests that measures to reduce
speeds on roads, such as posting reduced speed limits, to minimise inadvertent vehicle
impacts with wildlife are impractical to enforce.
Mortalities on roads, particularly in pristine areas, may impact significantly on long-lived,

wide-ranging species. Tortoises in North America occur in significantly lower numbers in
areas transected by busy roads than they do in comparable habitats with no roads (Nicholson
1978). Similarly, short-lived, explosive breeders, i.e. species that undertake mass migrations
to well-defined and long-established breeding sites (e.g. many amphibians), are very
susceptible to vehicles when crossing roads during their mass breeding migrations.
Populations can be easily decimated at such times, and massive road mortality can soon lead
to local extinction. Noise pollution and physical disturbance associated with road traffic can
also disturb many species. Increased fire risks are also associated with road traffic.
Impact 1 - Mortalities associated with an increase in traffic

Increased road traffic within the back-of-port area will definitely result in increased road
mortalities which will have a long term, slight to moderate impact at a local level. Mitigation
of this impact entails identification of sensitive areas and control of vehicle traffic at specific
times, which would probably decrease this impact to slight. The environmental significance
of this unmitigated impact would be LOW.
Impact 2 - Disturbance associated with an increase in traffic

The high volumes of road traffic expected during the construction phase will disturb many
species which will result in a severe, localised impact in the short term. Mitigation of this
impact entails identification of sensitive areas and control of vehicle traffic at specific times,
which would probably decrease this impact to moderately severe. The environmental
significance of this impact is MODERATE.
ISSUE 7: CHANGES IN HYDRODYNAMICS AND WATER QUALITY

Impact 1 - Changes in hydrodynamics and water quality
Cause and comment
Various construction activities may profoundly affect water flow dynamics and quality within
the back-of-port area. A diverse assemblage of amphibians, aquatic reptiles, and numerous
waterbirds and waders utilise aquatic habitats in the back-of-port area, particularly along
Coega River. Changes to flow dynamics in wetlands may reduce larval amphibian recruitment

and a local reduction in amphibian numbers as well as their reptile and avian predators may
therefore occur.

Mitigation of this impact entails identification of sensitive areas and control of drainage
patterns and flow to maintain normal regimes. This is essential during the interval between the
phased developments, to ensure that the salt pans and estuary continue functioning as normal
systems.
Changes in hydrodynamics and water quality within the back-of-port area will definitely
result in a long term slight to moderately severe impact at a local level. The environmental
significance of this unmitigated impact would be MODERATE and LOW after mitigation.
ISSUE 8: CHANGES IN FIRE REGIMES

Impact 1 - Increased incidences of fire
Cause and comment
Fire in many ecosystems is a natural phenomenon and prevents thicket development. Fire in
the Mesic Succulent Thicket and Bontveld is naturally infrequent. However, changes in water
flow dynamics may reduce the water table locally, drying vegetation to unnatural levels and
making it more susceptible to fire.
Construction and planning of facilities should anticipate a fire risk. Increased human
population growth in the area will occur as a consequence of increased prosperity resulting
from the industrial development. This will lead to an increase in accidental fires.

No fires should be allowed on site without the permission of the Technical Officer in
consultation with the Coega Environmental Officer. All approved fires shall be controlled by
the Contractor with a view to preventing “run away fires” and excessive smoke. During the
construction phase special attention to the fire risk must be taken to prevent particulate matter
spreading into the salt works area.
An increased fire risk within the back-of-port area will accompany the proposed
developments and will definitely result in a long term slight impact at a localised level.
Mitigation of this impact entails identification of sensitive areas and control of fire potential,
which would probably decrease this impact to slight. The environmental significance of this
unmitigated impact would be LOW.

Table 5.2a: Key environmental impacts on the terrestrial environment resulting from the construction of the back-of-port area.
WITHOUT MITIGATION WITH MITIGATION

ISSUE/IMPACT
RISK TEMPORAL SPATIAL CERT. SEVERITY SEVERITY SIGNIF.
ISSUE 1: LOSS AND FRAGMENTATION OF SENSITIVE HABITATS
Impact 1: Loss of the Foredune and Hummock vegetation Will occur Permanent Localised Definite Severe Moderately severe MODERATE
Impact 2: Loss of the Mesic Succulent Thicket habitat Will occur Permanent National Definite Mod-Severe Moderately severe MODERATE
Impact 3: Loss of Bontveld Will occur Permanent National Definite Severe Severe HIGH
Impact 4: Loss of salt pan and estuarine habitats Will occur Permanent Local-National Definite Severe Severe HIGH
Impact 5: Fragmentation of sensitive habitats Will occur Long term Localised Definite Severe Severe HIGH
ISSUE 2: LOSS OF BIODIVERSITY
Impact 1: Loss of amphibian diversity Will occur Long term Localised Probable Mod-Severe Slight MODERATE
Impact 2: Loss of reptile diversity Will occur Long term Localised Probable Mod-Severe Moderately severe MODERATE
MODERATE
Impact 3: Loss of bird diversity Will occur Long term Localised Probable Mod-Severe Moderately severe
– LOW
Impact 4: Loss of mammal diversity Will occur Long term Localised Probable Mod-Severe Slight LOW
ISSUE 3: LOSS OF SPECIES OF SPECIAL CONCERN
Impact 1: Loss of plant species of special concern Will occur Permanent National Definite Severe Moderately severe MODERATE
Impact 2: Loss of reptile species of special concern Will occur Long term Local-National Probable Mod-Severe Moderate MODERATE
Impact 3: Loss of bird species of special concern Will occur Long term Local-National Definite Very Severe Severe HIGH
Impact 4: Loss of mammal species of special concern Will occur Long term Localised Probable Slight Slight LOW
Impact 5: Loss of butterfly species of special concern Will occur Long term Local-National Probable Severe Moderately sever MODERATE
ISSUE 4: DESTRUCTION OF HABITATS IMPORTANT TO MIGRATORY SPECIES
LOW –
Impact 1: Loss of important habitats to migratory species Will occur Medium-Long Local-National Probable Mod-Severe Moderately severe
MODERATE
ISSUE 5: INTRODUCTION OF ALIEN SPECIES
Impact 1: Introduction of alien vegetation May occur Long term Localised Probable Mod-Severe Slight LOW
Impact 2: Introduction of alien fauna May occur Long term Localised Probable Mod-Severe Slight LOW
ISSUE 6: SUBSTANTIAL INCREASE IN ROAD TRAFFIC
Impact 1: Increase in mortalities Will occur Long term Localised Definite Slight Slight LOW
Impact 2: Disturbance of biota Will occur Short term Localised Definite Severe Moderately severe MODERATE
ISSUE 7: CHANGES IN HYDRODYNAMICS AND WATER QUALITY
Impact 1: Changes in hydrodynamics and water quality Will occur Long term Localised Definite Mod-Severe Slight LOW
ISSUE 8: CHANGES IN FIRE REGIMES
Impact 1: Increased incidences of fire Will occur Long term Localised Probably Slight Slight LOW

5.2.3 OPERATIONAL ISSUES

Introduction
The back-of-port area will encompass a customs secure Logistics Park, an E-commerce Park
and areas designated as Mixed Use Corridor, Electronic/Technical, and Port and Allied
Industries Clusters (Figure 5.2a). The operation of these industries will result in a number of
impacts relating to the terrestrial environment, including:
ISSUE 9: ELECTRICITY CONSUMPTION

ISSUE 10: WATER CONSUMPTION
ISSUE 11: DISPOSAL OF SOLID AND LIQUID WASTE
ISSUE 12: NOISE LEVELS
ISSUE 13: AIR QUALITY
ISSUE 14: LIGHTING
ISSUE 15: RISK OF EXPLOSIONS
These issues are discussed in more detail below and summarised in Table 5.2c.
ISSUE 9: ELECTRICITY CONSUMPTION 8

Impact 1 - Increased electricity consumption
Cause and comment
The development of the port and associated clusters will lead to an increase in the electricity
demand in the Port Elizabeth area. The Coega Development Corporation (CDC) aims to
provide a primary electricity reticulation at 11Kv and a secondary electricity reticulation
utilising underground cabling, including sub-stations. There are two scenarios for the
provision of these facilities:
1. Eskom to provide electricity for large consumers (>100 Megavolt Amps) from the
Grassridge sub-station using overhead lines; and
2. Port Elizabeth Municipality (PEM) to provide electricity for smaller consumers from
Motherwell.
The cumulative energy demand of Port Elizabeth must not exceed the supply capacity.
However, the total supply capacity could probably be increased if necessary. The CDC can
also ensure that the electricity demand for the back-of-port area does not exceed their
allocated supply by screening individual electricity demands during the tenant approval
procedure (TAP), which is being developed as part of their environmental management
system (EMS) (see Appendix B). The CDC can therefore control the electricity demand by
limiting industries with bulk energy needs, if this became necessary. The CDC could also
issue penalties for exceeding allocated energy demands.
The development of the port and back-of-port area will definitely result in an increase in the
electricity consumption in the area. This increased energy consumption will probably result
in a long term slightly severe impact of LOW significance at a sub-regional level. The
proposed mitigation will maintain the significance rating of LOW.
It should be noted that the issue of increased electricity consumption was assessed to be of
MODERATE environmental significance during the rezoning EIA. This was as a result of
heavy industry being incorporated into the core development area (CDA). No heavy industry
8
The positive spin offs associated with the economic returns of the industries utilising the electricity are difficult
to establish as the exact nature of the clients in the IDZ are not known.

is planned for the back-of-port area, thereby reducing the significance of the issue during the
initial phases of development.

Impact 1 - Increased water consumption
Cause and comment
Increased water consumption is an important issue that will result from the various
construction and operational activities in the back-of-port area. No large water consuming
industry (i.e. heavy industry) is planned for the back-of-port area.
The main principle for water provision is the development of a dual reticulation (“fresh” and
recycled water) system. The main aims are to provide primary and secondary potable water
and return effluent reticulation. This will involve the construction of the Coega Kop
reservoirs, the main bulk feeder line into the CDA and the distribution mains within the CDA.
Augmentation from the Nooitgedagt Treatment Works and the reservoir supply main off the
Grassridge-Motherwell pipeline will be required for the IDZ as a whole if a high water
demand industry is signed up in the metallurgical cluster.

The CDC will be given a water consumption budget by Port Elizabeth Municipality (PEM)
for the IDZ. The CDC must regulate the amount of water used in the back-of-port area and
this can be done in the TAP. All prospective tenants will provide the CDC with projected
water consumption requirements and the CDC must make sure that the cumulative demand
does not exceed the supply. The development of the dual reticulation system will also help
mitigate this issue. PEM are also investigating the implementation of a scheme to produce
approximately 20ML per day of treated effluent at the Fishwater Flats Treatment Works for
distribution to the Core Development Area.
Port and back-of-port activities will definitely result in an increase in the consumption of
potable water, which will probably result in a long term moderately severe impact at a sub-
regional level. After implementation of the proposed mitigation, this impact will probably be
reduced to one of LOW significance.
This issue was assessed to be of MODERATE environmental significance for the CDA
during the rezoning EIA. However, due to the reduced quantity of water needed for the back-
of-port area (because of no heavy industry and fewer clusters), the significance is reduced to
one of LOW significance.
ISSUE 11: DISPOSAL OF SOLID AND LIQUID WASTE

Impact 1 - Increased disposal of solid and liquid waste
Cause and comment
The increased disposal of solid and liquid waste is an important environmental issue that must
be considered. Domestic waste will be disposed of at the Arlington site while industrial waste
will be disposed at a new (hazardous) waste site that will be developed to serve the region.
The main aims for wastewater are to provide a primary and secondary sewerage reticulation
system including pumping stations that will allow for re-use of treated effluent for industrial
and irrigation purposes. There will be separate pipelines for effluent and sewage waste. The
effluent pipeline may incur heavy charges and will go to a central effluent treatment plant
where it will be treated before disposal/recycling. If marine effluent outfall is planned,
allowances must be made for a separate scoping study.


Mitigation for this issue includes:
1. Use of a licensed dump for domestic and industrial waste;
2. Design of wastewater disposal (see above);
3. Operators/contractors must ensure that stormwater or wastewater does not affect the
environment into which it is released, i.e. water must meet an acceptable discharge
quality standard as specified by DWAF before release. No chemicals, oils, process
effluent, factory wash water, etc. must be discharged into the stormwater drainage
system;
4. Regular monitoring by the CDC of groundwater, surface water and the nearshore
seawater, through a water-monitoring programme has already begun. Should there be
evidence of contamination, then the responsible person and the environmental manager
must agree on appropriate measures to be taken, which will be for the operator’s
account; and
5. A key opportunity of an industrial zone is the possibility of enacting ‘industrial
ecology’. Incoming tenants will be obliged to provide information on their material
inputs and outputs. It is envisaged that where this information is not confidential, a
register be made available to all companies within the IDZ so that opportunities for
material and waste exchange can be identified and utilised.
6. Waste storage sites should be carefully positioned so as to reduce the visual impact and
they should be placed in sheltered areas where refuse will not be carried by wind.
Volumes of solid waste produced will also be monitored.
Activities in the back-of-port area will produce solid and liquid wastes, which will need to be
disposed of in an environmentally acceptable manner. The disposal of these wastes will
probably result in a long term moderately severe impact at a localised level. Mitigatory
measures effectively reduce the significance of this issue to LOW.

Impact 1 - Increased noise levels
Cause and comment
Various operational activities in the back-of-port area will result in an increase in ambient
noise levels, and will probably have an impact on humans. Increased noise levels will also
reduce the abundance of many bird species, particularly shore and estuarine specialists.
Increased noise and motor vibrations in wetlands will also impact on amphibian breeding
choruses, but these will be very localised and many amphibian species are surprisingly
tolerant of urban noise.

Mitigation for this issue includes the development of noise guidelines and relocation of
residents in the IDZ. These are described in more detail below.
1. Noise guidelines have been developed as part of the EMS to manage noise and will be
enforced via the tenant approval procedure, ensuring that all operations meet the
requirements of the Environmental Conservation Act (Act 73 of 1989) and the SABS
Code of Practice 0103-1997 regulations.
2. Households in the entire IDZ will be relocated to Wells Estate in phase one. The CDC
in conjunction with the Nelson Mandela Metropole are currently constructing houses for
the Coega community at large (Koza pers. comm.).

The various industries and clusters in the back-of-port area will result in an increase in the
noise levels, which will probably result in a moderately severe impact at a localised level in
the long term. The noise guidelines developed for the EMS will probably reduce the overall
significance to LOW but the impact on the residents of St George’s Strand will probably be
of HIGH significance.

Impact 1 - Changes in air quality
Cause and comment
One of the most important environmental issues that will result from activities in the back-of-
port area is a change in air quality. Air quality by its nature affects a wide area and can have
an impact on a number of systems and/or parties. It should be noted that most of the industry
identified for the back-of-port area is “clean industry” (i.e. no scheduled process/heavy
industry).

Environmental principles and guidelines of air pollution have been formulated as part of the
EMS (see Appendix B), and include the following:
• Initially no industry may use a disproportionate amount of the total maximum capacity of
the atmosphere;
• Visible plumes are to be disallowed;
• All material stores must be fully enclosed or surrounded by a minimum of three retaining
walls opening away from prevailing winds;
• Industries must initiate monitoring programmes for their specific concerns at least three
months before commissioning;
• The list of substances subject to mandatory limit values must be expanded to include lead,
nitrogen oxides and ozone; and
• Compliance with air quality guidelines presented in Table 5.2b below.
Table 5.2b: Air quality guidelines recommended for the Coega IDZ.
Substance Averaging Source of air Guidelines Initial guidelines:

Period quality guidelines (µg/m3 ) 50% of limit value
or standards (µg/m3 )
TSP 24 hours US Secondary (pre- 150 (a) 75
1990) NAAQS
TSP Annual average US Secondary (pre- 60 30
1990) NAAQS
PM10 24 hours US Primary NAAQS 150 (a) 75
PM10 Annual average US Primary NAAQS 50 25
SO2 24 hours EU Standard 250 125
SO2 Monthly average DEAT Guideline 130 65
SO2 Annual average WHO Guideline 60 30
TSP: Total suspended particulate concentrators
PM10: Particulate matter with the aerodynamic diameter less than 10µg/m3 , which represents particles
of a size that would be deposited in and damaging to the airways of lower alveoli.
NAAQS: National Ambient Air Quality Standards
(a): Value not to be exceeded more than once per year
The CDC will monitor compliance with these guidelines with a thorough, comprehensive
real-time monitoring programme. A procedure is being developed to allocate pollution loads

to certain areas of the IDZ. A dynamic model will be used to screen prospective tenants in
terms of their predicted air pollution impacts against the recommended guidelines.
Environmental targets have also been formulated as part of the EMS (see Appendix B). The
following indicators will be monitored: number of exceedances of ambient air quality; SO2
ground level concentrations; particulate matter ground level concentrations; carbon monoxide;
particulate lead; nitrous oxide and ozone.
In addition, cumulative emissions will be regulated in the TAP. Prospective tenants will be
required to fill in a detailed form to ascertain potential environmental issues. One of the
focuses will be on emissions and odours.
Future operations in the back-of-port area will result in a decrease in air quality, which will
probably result in a long term moderately severe impact at a localised level. Since the CDC
has partial control or will be able to influence the various activities causing a potential change
in air quality, the suggested mitigatory measures included in the EMS will effectively reduce
impacts of MODERATE significance to LOW.
ISSUE 14: LIGHTING

Impact 1 - Increased lighting
Cause and comment
The establishment of industry in the back-of-port area and particularly along the N2 (i.e.
Mixed Use Corridor) may result in lighting issues. Increased lighting may create problems for
motorists along the N2 or may just have aesthetic impacts. There are few studies on the
impact of high intensity light on faunal diversity and abundance. The attraction of many
flying nocturnal invertebrates to urban lights can lead to concentrations of these organisms in
such areas. This, in turn, attracts predators, particularly bats, but also small owls, toads and
geckos. All can then suffer increased mortality from road traffic, predation by feral animals,
and collisions with power lines, etc.
Guidelines for lighting should be developed to minimise light scatter and pollution, thereby
reducing this potential impact. Guidelines could include restrictions on the number of
spotlights used, colour of light (orange bulbs should be used), overhead lights rather than
laterally orientated spotlights, which could impact on residential areas and road traffic. Where
possible, buffers of natural vegetation, especially along roads, should be put in place.
Increased lighting as a result of the various operations and security and safety measures could
result in visual impacts and could possibly be a nuisance to humans, resulting in a long term
moderately severe impact at a localised level. There are presently no guidelines to reduce this
potential impact and thus this impact remains of MODERATE significance. However, if the
above measures are implemented, the issue will be reduced to one of LOW significance.

Impact 1 - Increased risk of explosions
Cause and comment
The Port and Allied Industries Cluster will include the storage of bulk liquid and gas fuels.
Explosions may result from unforeseen upsets in industrial and shipping operations, leading
to impacts on human safety.


The main mitigatory measure involves the compliance with the Occupational Health and
Safety Act (Act 85 of 1993). All the necessary precautions to prevent explosions must be
taken by the tenant/operator, who must comply with the requirements of the Occupational
Health and Safety Act (Act 85 of 1993). Fires and smoking should also not be permitted near
any potential source of combustion and spot fines will be imposed on transgressors. Spillages
of flammable substances must be cleaned up immediately. Every possible precaution must be
taken when working with spark- generating equipment, especially close to potential sources of
combustion.
Explosions in the back-of-port areas are unlikely. However, if they do occur they will
probably result in a short term moderately severe impact at a localised level. Compliance
with the suggested mitigatory measures and adherence to legal specifications will effectively
reduce this MODERATE impact to LOW.

Table 5.2c: Key environmental impacts resulting from the operation of the back-of-port area on the terrestrial environment.

ISSUE/IMPACT
RISK TEMPORAL SPATIAL CERT. SEVERITY SEVERITY SIGNIF.
ISSUE 9: ELECTRICITY CONSUMPTION
Impact 1: Increased electricity consumption Will occur Long term Sub-regional Probably Slight Slight LOW
Impact 1: Increased water consumption Will occur Long term Sub-regional Probably Moderately severe Slight LOW
ISSUE 11: DISPOSAL OF SOLID AND LIQUID WAS TE
Impact 1: Increased disposal of solid and liquid waste Will occur Long term Localised Probably Moderately severe Slight LOW
Moderately
Impact 1: Increased noise levels Will occur Long term Localised Probably Moderately severe HIGH
severe
Impact 1: Changes in air quality Will occur Long term Localised Probably Moderately severe Slight LOW
ISSUE 14: LIGHTING
Impact 1: Increased lighting Will occur Long term Localised Probably Moderately severe Slight LOW
Impact 1: Increased risk of explosions Unlikely Short term Localised Probably Moderately severe Slight LOW

5.3 CONCLUSIONS
The ecological implications on the terrestrial environment that the construction and operation
phases will have can be grouped into 15 key issues (Tables 5.2a & c). These 15 issues are in
turn comprised of 28 specific impacts. All 28 impacts associated with the construction and
operational phases were found to be negative.
After mitigation no impacts were found to be of very high significance and thus no single
impact is thought to constitute a fatal flaw to the project. There were, however, a number of
impacts of high (4) and moderate (9) significance associated with the construction phase
(Figure 5.3a). The impacts of HIGH significance were orientated around two issues, viz. Loss
and fragmentation of sensitive habitats and the Loss of species of special concern.
Specifically, the impact that the construction phase would have on the Bontveld, and salt
pans were regarded as being of high significance after mitigation. The impact that
construction would have on endangered/rare or vulnerable birds was rated as being HIGH,
while the construction impacts on plants, reptiles and butterflies were rated as being
MODERATE.
The following construction issues were all found to have impacts of LOW significance after
mitigation: importance to migratory species (low- moderate), introduction of alien species,
substantial increase in road traffic, changes in hydrodynamics and water quality, and changes
in fire regimes.
The majority of issues and impacts associated with the operational phase, viz. electricity and
water consumption, air quality, waste disposal, lighting and risk of explosions were found to
be of LOW significance after mitigation. The impact that noise may have on people was rated
as being HIGH due to the proximity of St George’s Strand to the port operations. It must,
however, be noted that these ratings were made with limited information and on the premise
that the Environmental Management System outlined in Appendix B will be fully
implemented and audited.
Terrestrial Impacts
18%
Very High
High
50% Moderate
Low
32%
Figure 5.3a: Terrestrial impacts associated with the development of the port and back-of-port
areas.

CHAPTER 6:
MARINE DESCRIPTION
6. MARINE DESCRIPTIO N
6.1 GENERAL ALGOA BAY DESCRIPTION
Algoa Bay (Figure 6.1a) lies on the southeastern coast of Africa near the parallels 34°S and
26°E and is the easternmost and largest of a series of long-spiral bays along this coastline. It
faces the southwest Indian Ocean, where the dominant oceanic-scale feature is the Agulhas
Current, which flows polewards with its core close to the continental shelf edge (Pearce 1977;
Grundlingh and Lutjeharms 1979; Grundlingh 1983). Two headlands, Cape Recife and Cape
Padrone, separated by a distance of about 70km, enclose the Bay and form a wide mouth
which opens onto the eastern Agulhas Bank. The Bay extends for 90km, 80km of which
comprise surf-swept sandy beaches (McLachlan 1977).
Two major rivers, the Swartkops (15 kilometres north of the Port Elizabeth port) and the
Sundays (50km north of the Port Elizabeth port), flow into the Bay (McLachlan 1977; Baird
et al. 1988). The Coega River (approximately 20km north of Port Elizabeth) is utilised for the
production of sea salt for human consumption and the river water is prevented from flowing
into the Bay by earth impoundments.
The St Croix Island group, consisting of St Croix, Brenton and Jahleel, is located a few
kilometres offshore within the 30m depth contour.
6.2 HYDROLOGY AND CIRCULATION PATTERNS
Tides around South Africa are classified as semidiurnal microtidal, with a dominant M2 tide
(i.e. there are two high tides and two low tides per day) and amplitudes generally below 2m.
The tidal period is 12 ho urs and 25 minutes, with a slight diurnal inequality (Schumann, De
Ruyck and Rohwer 1996). Additionally, a substantial spring-neap variation exists, with
amplitudes as little as 0.5m at neap tides and on occasion over 2m at spring tides (South
African Navy Tide Tables). The tides propagate from west to east from an amphidromic
point in the Southern Ocean.
Longer-period water level variations also occur as a result of meteorological influences, in

particular wind. Coastal trapped waves occur along the south coast with amplitudes at times
in excess of 0.5m (Schumann and Brink 1990). The net water level variation may be impacted
on when the shorter-period tidal variations are superimposed on the longer-period coastal
trapped wave variations (Schumann, De Ruyck and Rohwer 1996).
Sea surface temperatures vary from greater than 22°C in summer to less than 14°C in winter.
However, considerable variability occurs on a day to day basis, particularly with the advent of
upwelling at Cape Recife which can cause large falls to below 10°C in that region (Goschen
and Schumann 1995).
Most of the swell around South Africa originates from storms in the Southern Ocean, to the
southwest of the continent (Rossouw 1984), as well as from strong, local westerly winds. The
city of Port Elizabeth was established in the lee of Cape Recife to obtain protection from these
storm waves. Nonetheless, waves can refract around Cape Recife, losing energy in the
process and with the extent of the refraction depending on the wave period.
Chapter 6: Marine Description 107

Cape Padrone
a)
Ngqura Port
St Croix Island
Group
Port Elizabeth -5 -10
b)
Metropole Coega Estuary
Algoa Bay N
-15
Coastline
Cape Recife
-10
0 500 m Jahleel
Island -17
Figure 6.1a: The study site (b) relative to Algoa Bay

(a), showing the major depth profiles and the position
of Jahleel Island relative to the Coega Estuary
(development site).
-18
108 Chapter 6: Marine Description

The most damaging waves are those originating in strong easterly winds, which can impinge
directly onto the western sector of Algoa Bay. Such waves have at times been responsible for
extensive damage to coastal structures and ships.
6.3 COASTAL SEDIMENT DYNAMICS
The beach state between the Swartkops, Coega and Sundays river mouths (Plate 6.3a) is
generally the intermediate type, transverse bar and rip subtype (Short 1987). This type of
beach is characterised by waves 1–1.5m high and small widely spaced rip currents every 150–
300m running oblique to the shoreline. The swash zone is generally shallow with low waves
breaking on the lee of or behind the terraces.
Plate 6.3a: A view of the beach stretching south from the Coega River mouth.
Wave driven longshore drift moves sand along the beach. The wave energy is moderate to
high; the prevailing swell is generated in the westerly gale belt and approaches the south coast
from the southwest (Schumann 1994). Net sand movement due to these waves/swells is in a
northward direction, although there is movement in both a northerly and southerly direction.
The volume of sediment transported northward and eastward by longshore drift around Algoa
Bay past the Coega River mouth is estimated to be in the order of 150 000 – 200 000m3 /yr
(Illenberger 1997).
The coast between North End and New Brighton Beach located 9km south of the Coega River
mouth has been subject to considerable beach erosion because the existing Port Elizabeth port
interrupts the longshore drift system along the Algoa Bay shore (Schumann, De Ruyck and
Rohwer 1996). Worries have been expressed about similar erosion occurring after the
construction of the Ngqura harbour.
The harbour basin will most likely be dredged in mainly unconsolidated material. Essential to

the location of the port is the existence of an asymmetric palaeo- valley, filled with
discontinuous layers of gravel, sand, silt and some clay. The quay walls have been oriented to
take advantage of this palaeo-valley.
6.4 THE ALGOA BAY ISLANDS

6.4.1 GENERAL DESCRIPTION
The Algoa Bay Island Nature Reserve comprises the Bird and St Croix (St Croix, Jahleel,
Seal and Brenton islands) Island groups. Both these island groups have been declared an
Important Bird Area (IBA), as they are inhabited by threatened and endangered species.
Formerly both island groups were under control of the Guano Islands section of the Division
of Sea Fisheries, but since April 1992 they have been managed by Eastern Cape Nature
Conservatio n.
These islands are formed by outcrops of super- mature, erosion-resistant Peninsula sandstone
of the Table Mountain group and are almost bare of any vegetation. St Croix has a maximum
elevation of 53m and is 12ha in size, while Brenton and Jahleel (Plate 6.4a) are considerably
smaller, having areas of 1 and 2ha respectively, and do not rise more than 20m above sea
level. There are derelict houses on St Croix, remnants from when guano scraping and egg
collecting used to occur, but the islands are now uninhabited by humans.
Plate 6.4a: A view of Jahleel Island showing its proximity to shore.
The seals and seabirds, which breed and rest on the islands, play an integral role in the
functioning of the marine ecosystem of Algoa Bay. The islands also play a national and

international role in the conservation of three seabird species, the Cape gannet, African
penguin and Roseate tern. The largest gannet colony in the world is at Bird Island, the largest
African penguin colony in southern Africa is at St Croix, and the only confirmed sites where
Roseate terns breed in South Africa are at Bird and St Croix islands, with a further possible
site being Jahleel Island.
The most easterly breeding colony of Cape Fur Seals, Arctocephalus pusillus, is situated at
Black Rocks in the Bird Island Group.
6.4.2 ISLAND BIOTA

Birds
Sixteen species of birds have been recorded at Jahleel Island. There are confirmed breeding
records for seven (African penguin, Cape cormorant, white-breasted cormorant, African black
oystercatcher, kelp gull, grey heron and black-headed heron) and a suspected record for
another (Roseate tern). Two of the species (African penguin, Cape cormorant) are endemic to
southern Africa and one of them (African penguin) is catego rised as Vulnerable. A third
species (Roseate tern) is categorised as Endangered.
Of the species known to breed at Jahleel Island, two (grey heron, black-headed heron) are
ubiquitous species mainly associated with terrestrial or freshwater/estuarine systems. The
numbers of a further two species, kelp gulls and African black oystercatchers, present on the
island are a small proportion of the South African and global populations of these species.
Similarly, the Cape and white-breasted cormorants do not regularly breed at Jahleel and the
island populations only represent a small proportion of the South African and global
populations of these species.
The African penguin (Plate 6.4b) and Roseate tern are amongst the four species of seabirds
listed in the Sout h African Red Data Book (Brooke 1984). The African penguin is also listed
in the International Red Data Book (Collar & Stuart 1985). Brooke (1984) lists the African
penguin as vulnerable and the Roseate tern as endangered. Cooper (1995) gives the
classification of the African penguin as near-threatened while Croxall et al. (1996) reclassifies
the African penguin as Vulnerable under the new IUCN categories of threat.
The Cape gannet

The Cape gannet colony at Bird Island is the largest gannetry in the world. The population is
estimated at 59 000 breeding pairs and 140 000 individuals. The breeding season runs from
the beginning of September to the end of March. Gannets are highly susceptible to
disturbance during the egg laying phase (East Cape Nature Conservation, 1996).
The Roseate tern

La Cock and Cohen (1997) and Barnes (2000) reviewed knowledge of the Roseate tern in
southern Africa. Both reports considered the species to be Endangered, and to be conspecific
with fragmented populations in western Europe, the western Atlantic Ocean, East Africa,
Madagascar, Asia and Australia. The world population has been variously estimated to be in
the order of 30 000 pairs (Croxall 1991), or between 25 000 and 50 000 pairs (La Cock and
Cohen 1997). However, these figures do not take into account recently discovered large
colonies in North Australia (R. Chatto, pers. comm. in Tree and Klages 2001), nor the present
status of many colonies in East Africa, Madagascar or southeast Asia, which have not been
fully assessed for many years. A more recent publication puts the probable size of the world
population closer to 40 000 pairs (Gochfeld et al. 1998).

The present breeding population of Roseate terns in southern Africa is currently estimated to
comprise 210 to 220 pairs. Adult birds from the chief breeding ground at Bird Island are
closest to their North Atlantic counterparts in wing, bill, total head length, tail and mass
measurements, suggesting common ancestry. Tree and Klages (2001) suggest that on the
available evidence, the South African population is reproductively isolated and may represent
a distinct species. In South Africa the largest breeding population is found on Bird Island
with a tiny outlier at Dyer Island in the southwestern Cape, where less than ten pairs are now
re-established (Crawford in Harrison et al. 1997). The species was formerly found breeding
on occasions at St Croix Island and at Cape Recife Point (Randall & Randall 1980), but these
records may have been brought about by severe human disturbance due to guano collecting on
Bird Island at the time. The recovery of the population of Roseate terns breeding in Algoa
Bay has been slow, with a total population of 118 pairs in 1977, 134 pairs in 1986 (Randall et
al. 1991), 152 active nests in 1996, 180 pairs in 1998, and 210 to 220 pairs in 1999. That the
population is increasing is also reflected in the number of immature visitors, with a peak of 70
counted on 23 July 1998 (Tree and Klages 2001). Nevertheless, after Leach’s Stormpetrel
(Whittington et al. 1999), the species remains the second rarest seabird breeding in southern
Africa. If the southern African population is isolated and represents a valid species, then its
current Red Data Book status as Endangered (Barnes 2000) would have to be up graded to the
highest international rating of Globally Critically Endangered.
The African penguin

African penguins (Plate 6.4b) are endemic to southern Africa, where they breed at 27
localities between Hollams Bird Island off central Namibia and Bird Island in Algoa Bay.
This represents the total global population of African penguins. There has been a marked
decrease in the total penguin population over their range (Klages et al. 2001). Breeding no
longer occurs at 10 localities where it was previously recorded or suspected. The latest
population estimate is 179 000 individuals. This population estimate is some 400 000 birds
fewer than at the start of the 20th century, indicating a decrease of approximately 70%.
The Algoa Bay penguin population (St Croix and the Bird Island Group) has been estimated
at 77 572 birds or 43% of the total global population. Crawford et al. (1995) estimate the St
Croix Island population at some 62 000 adults. This estimate indicates an increase of 30 -
40% over the 1979/1981 estimates. Estimates for Jahleel and Brenton islands seem to indicate
that the populations have been stable since the 1970s.
The south coast population (Algoa Bay Islands) was the only regional population to have
shown an increase in numbers (37%) between the 1976-1980 survey and the 1991-1994
survey, despite there being an overall decline in the total global population from 222 000 in
1976-1980 to 179 000 in 1991-1994. During a workshop (1999) to discuss the conservation
status of penguins, it was estimated that the Algoa Bay population has shown a decline of 15
000 birds over the past five years (Crawford pers. comm.).
Of the southern African islands, St Croix Island supports the highest population of 62 330 (44
781 in 1976-1980), whereas Jahleel has the eleventh highest population of 1 757.
Using stochastic modelling, Crawford et al. (2000) suggested that penguin colonies of 10 000
pairs have a 9% probability of extinction in 100 years, so that smaller populations should be
regarded as Vulnerable. However, in a period of prolonged food scarcity off southern
Namibia, the regional population decreased from some 40 000 pairs in 1956 to about 1 000
pairs in 2000, and many colonies numbering less than 1 000 pairs became extinct. The
minimum viable population for African penguins is considered to be greater than 40 000

pairs, of the order of 50 000 pairs, which is equivalent to its level in 2000. Survival of the
species through the 21st century is tenuous.
Plate 6.4b: The African penguin, whic h roosts and breeds on the St Croix Island group.
Reptiles
Two lizard species are present at St Croix Island, the spotted gecko Pachydactylus maculatus
and the girdled lizard Cordylus tasmani.
Recent genetic studies on the lizards of St Croix Island ind icate that significant genetic
divergence has occurred between spotted gecko populations on the island and adjacent
mainland (Branch and Channing unpub. obs.). It had already been noted that the St Croix
gecko exhibited gigantism (Branch 1991) and genetic studies support its evolutionary
divergence from the mainland population. The taxonomic status of the island population may
best be reflected by recognition as a unique insular evolutionary species. As the gecko would
then be endemic to the island, it is of higher conservation concern. Implementation of current
IUCN Red Data criteria may require that the species is categorised as Critically Endangered
due to its limited extent of occurence (<100km2 ) and because it is known from only a single
locality. However, the population size is unknown and its status (growing or declining in
numbers) is unknown.
Mammals
No indigenous mammals are found on the islands. The European rabbit, which formally
occurred on Bird Island was eradicated in 1990 and the only introduced mammal occurring on
Bird and St Croix islands is the house mouse Mus musculus. Cats have not been recorded for
any of the islands.
Insects
Bird Island is the only South African coastal island where wing reduction occurs in flies.
Information on the insects of the island is poor.

6.5 THE MARINE BIOTA

Algoa Bay is part of the transitional zone for marine animals between the warmer tropics and
the colder temperate zone, an important ecological position, and comprises open sandy
beaches, rocky capes and the Algoa Bay island groups (Emmerson, Watling and Watling
1982).
The beach and surf zones together are considered a functional ecosystem, which interacts with
the terrestrial environment through the movement of sand, and with the nearshore through the
activity of rip currents (McLachlan et al. 1984; McLachlan et al. 1981 and Talbot 1986). In
this semi-enclosed ecosystem, surf zone phytoplankton are the producers, macrofauna the
consumers and the interstitial meiofauna the decomposer.
6.5.1 MARINE PHYTOPLANKTON

Primary production in the surf zone is exclusively by phytoplankton and predominantly by the
diatom Anaulus australis (Campbell 1987). This diatom has been well studied in Algoa Bay.
Accumulations occur primarily from the Schelmhoek dunefield eastward toward the extensive
surf zone skirting the Alexandria dunefield. Although A. australis makes up 90% of the
diatoms in the surf zone, other diatom species such as Aulacodiscus kittoni, Sroederella sp.,
Asterionella sp., Thalassiothrix sp. and Navicula sp. occur.
A. australis fuels three distinct food chains, one associated with the interstitial system, the
microbial food chain and the macroscopic food chain (Brown and McLachlan 1990). Of the
total primary production by Anaulus along the Sundays River beach, about 40% enters the
microbial food chain, about 20% is consumed by the interstitial system, while macrofauna
account for 10–15%. Approximately 30% is exported to the marine nearshore, much of it as
detritus (Brown and McLachlan 1990).
6.5.2 MARINE FAUNA

The fauna consist of several components, namely;
(i) intertidal and surf zone macrofauna (>1mm in size);

(ii) meiofauna (<1mm) within the sediment;
(iii) surf zone zooplankton in the water column;
(iv) intertidal rocky shore macrofauna and macroalgae;
(v) fish; and
(vi) marine mammals.
Intertidal and surf zone macrofauna

The intertidal fauna is dominated by the filter feeding sand mussel Donax serra, with the
smaller D. sordidus dominating the surf zone (McLachlan and Bate 1984). Several cirolanid
isopod species occur across the intertidal moisture gradient (De Ruyck et al. 1992) with the
genus Eurydice being the most common and occurring lowest on the shore. The isopods
Excirolana natalensis and E. latipes occur in lower numbers above mid-tidal level.
Scavenging whelks such as Bullia rhodostoma are common in the intertidal zone while B.
pura and B. digitalis occur in the surf zone (McLachlan 1977). The surf zone swimming crab
Ovalipes punctatus preys on Donax and Bullia (Du Preez 1984) and the scavenging
polychaete worm Goniadopsis incerta is abundant seawards of the breaker zone (McLachlan
and Bate 1984). The bentho-pelagic mysid Gastrosaccus psammodytes is the most abundant
in the swash and surf zone of sandy beaches and occurs in densities of up to 55
individuals/m2 , forming an important link between the primary food supply and higher levels

of the macrofaunal foodweb (Wooldridge 1983). Their diurnal benthic distribution contrasts
with the nocturnal pelagic phase of males and juveniles, which occur behind the breaker line
as far as 250m from the shore during the night (Webb 1986). Of the macrofaunal biomass,
75% is intertidal and 25% subtidal (McLachlan and Bate 1984).
Meiofauna
Meiofaunal organisms are dominated by nematodes (38%) and harpacticoid copepods (38%),
with turbellarians (10%), mystacocarids (6%), archiannelids (3%), oligochaetes (2%) and
other minor groups (3%) constituting the rest (McLachlan et al. 1981). Nematodes dominate
where the sand is finer and the oxygen level lower while harpacticoid copepods prefer coarser
well-drained sands. In the surf zone of Algoa Bay the meiofauna concentrate in the upper 5cm
of the sediment but penetrate up to 90cm in intertidal sediment at the upper tide levels. Under
polluted conditions the nematode component of the meiofauna dominates and the diversity
decreases (McLachlan and Harty 1981). Meiofauna can thus be a good indicator of pollution
of the environment.
Surf zone zooplankton

The surf zone zooplankton is dominated by large motile crustaceans. The prawn
Macropetasma africana is associated with diatom accumulations inside the surf zone (Romer
1986) but Mesopodopsis slabberi appears to swarm just outside the breaker line after dark
(Wooldridge 1983) and migrate towards offshore bryozoan reefs during the day (Webb 1986).
Other members of the surf zone zooplankton community are siphonophores, chaetognaths,
ostracods, copepods, isopods, amphipods and decapod larvae (Romer 1986).
Intertidal rocky shore macrofauna and macroalgae

The 8km stretch of beach between the Swartkops and Coega rivers features a few low profile
rocky outcrops near the spring low water level. These outcrops are periodically inundated by
sand (Coetzee 1996). More extensive rocky shores are found about 3km northeast of the
Coega pipeline, opposite the abalone farm at Marine Growers (Pty) Ltd, Hougham Park. The
aeolian dune rock outcrops form a wave-cut platform in the intertidal zone. Northeast of the
abalone farm is a small beach, about 3km long, followed by more wave-cut platforms.
Macroalgae
The most conspicuous macroalgae are the small beds of Caulerpa filiformis, which cover the
rocks at the edges of the rocky platforms. The more exposed vertical rock faces at the
extreme spring low water level are covered by foliose algal mats of predominantly Hypnea
spicifera and Codium extricatum. C. platylobum and Plocamium corallorhiza are also found
at this level. The ubiquitous Gelidium pristoides and small foliose tufts of Ulva sp. occur
amongst the mussel beds. Coralline algae (Cheilosporum sagittatum and Corallina sp.) are
common in the shallow pools on the rocky platforms (Coetzee 1996).
Intertidal algal species do play an important role in the ecology of the rocky shore. Many
species, especially the algal tufts, support epifauna (Beckley 1980) which in turn fall prey to
fish and predatory invertebrates. The plantigrade larvae of mussels settle in foliose algae,
such as Gelidium pristoides (Beckley 1977). Macroalgae spores and phytoplankton are the
main food source for the filter- feeding mussels, whereas newly settled sporelings and the
already established macroalgae are food for the grazers, e.g. limpets, winkles and top shells.
Macrofauna
The rocky platforms support extensive beds of mussels, although predominantly the brown
mussel Perna perna, two other less common species are also to be found. Black mussels

Choromytilus meridionalis occur at the rock-sand interface, whereas the alien mussel Mytilus
galloprovincialis is found amongst the brown mussels.
Other common species on the rocky platform include whelks Burnupena spp., barnacles,
occasional tube mounds of Cape reef-worm (Gunnarea capensis) and the orange crumb-of-
bread sponge (Hymeniacedon perlevis). Limpets (Patella spp.) and top shells (Oxystele spp.),
a characteristic feature of typical Eastern Cape rocky shores (Coetzee 1992), are uncommon.
Fish
The fish fauna of Algoa Bay is typical of the eastern Agulhas Bank and is made up of both
South African endemics and wide-ranging southern African endemics. Being part of the
transition zone between the warmer waters of the northeast coast of Africa and the cool west
coast, the Eastern Cape is ichthyologically an important and unique region (Smale 1992).
Although more than 70 species of fish and elasmobranchs have been recorded in the surf zone
in Algoa Bay (Romer 1986), only 28 are common. The southern mullet Liza richardsoni
makes up 50% of the surf zone fish and grazes on surf phytoplankton accumulations, but also
consumes mysids and other zooplankton. Other species commonly found are the blacktail
(Diplodus sargus), steenbras (Lithognathus mormyrus and L. lithognathus), shoaling pinky
grunter (Pomadasys olivaceum), white stumpnose (Rhabdosargus globiceps) and strepie
(Sarpa salpa) (Lasiak 1982). The ray (Myliobatus aquila) and sandshark (Rhinobatus
annulatus) are the dominant benthic feeders. The sandshark is especially common in summer
when the females give birth in the surf (Rossouw 1983). The bronze whaler (Carcharhinus
brachyurus) and the dusky shark (Carcharhinus obscurus) frequently enter the surf zone at
Sundays River beach as evidenced by angling catches, while abundant blue stingrays occur
just behind the breaker line (Romer 1986).
The seventy-four, Polysteganus undulosus has been fished to commercial extinction in South
African waters, yet still maintains a nursery area around Bird Island, which needs urgent
protection from the relevant authorities.
Reptiles
The giant leatherback sea turtle (Dermochelys coriacea), the loggerhead sea turtle (Caretta
caretta) and the hawksbill sea turtle (Eretmochelys imbricata) have all been recorded feeding
in Algoa Bay. There are few records of any southern African sea turtles breeding on Eastern
Cape beaches, although nests of the leatherback turtle have been recorded from sandy beaches
in Port Alfred, Woody Cape and Oubostrand. Only the green sea turtle (Chelonia mydas)
utilises estuarine habitats, where it feeds on Zostera beds. It is known to occur in the Sundays
River estuary. The closed and degraded estuarine habitat of the Coega River is not suitable for
this species. The leatherback, hawksbill and green sea turtles are considered Endangered,
while the loggerhead sea turtle is considered Vulnerable in the International Red Data Book.
The yellow-bellied sea snake is a non-breeding vagrant in the Eastern Cape coastal waters and
coastal developments in the region will have no conservation impact on this wide ranging
Indo-Pacific species.
Marine mammals
The marine mammal fauna of South Africa comprise 35 whale, dolphin and seal species. Ten
species are relatively common in Algoa Bay, albeit some only seasonally (Table 6.5a).

Table 6.5a: Marine mammals commonly found in Algoa Bay.
Common Name Scientific Name

Southern Right whale Eubalaena australis
Bryde’s whale Balaenoptera edeni
Minke whale Balaenoptera acutorostrata
Humpback whale Megaptera novaeangliae
Humpback dolphin Sousa chinensis
Common dolphin Delphinus delphis
Bottlenose dolphin Tursiops truncatus
Striped dolphin Stenella coeruleoalba
Risso’s dolphin Grampus griseus
South African fur seal Arctocephalus pusillus
Southern Right whales use the shallow waters of Algoa Bay to give birth and nurse their
young (Plate 6.5a). These whales are presently making a slow recovery from intense whaling
(Greig 1983). Southern Right whales usually make their appearance in June and increase in
abundance to reach peak numbers in August to October, when up to 40 animals frequent the
Bay at any one time. As summer approaches, numbers decline and the last wha les usually
leave the Bay by January. Their size (12 - 15m), bulk (40 tons) and slow cruising speed (0.25
- 2.2 knots) make them vulnerable to collisions with ships. This species is protected in
Appendix 1 of the Bonn Convention on Migratory Species (CMS), of which South Africa has
been a member since 1991.
Two hundred to 400 humpback dolphins of southern Africa’s estimated population of less
than 1 000 animals, from False Bay through to Mozambique, live in Algoa Bay,
predominantly around inshore rocky reefs (Karczmarski 1996). The densest concentrations
are located west of the Sundays River. They are typical coastal dolphins, which occur in small
numbers and have low population growth. They use the surf zone extensively as a feeding
ground and for social interaction, both off the estuary and around the islands (Karczmarski
and Cockcroft, In press and Karczmarski et al. In press) and are known to be very sensitive to
development. This species is listed in Appendix 2 of the CMS and their current status of
insufficiently known in the 1990 IUCN Red Data Book is expected to change to Endangered.
Plate 6.5a: A Southern Right whale breaching.

Bottlenose dolphins are more abundant and their preferred sites are around Cape Recife, Bird
Rock and the section between the Swartkops River and Sundays River beach (Schumann, De
Ruyck and Rohwer 1996). Common dolphins on the other hand are less abundant and swim
close inshore during winter. Cape fur seals are commonly seen, even in the existing port
(Plate 6.5b), with their most northerly distribution being Black Rocks in the Bird Island
Group. The remaining cetaceans are usually encountered further offshore, but well within the
area under consideration (Wooldridge, Klages and Smale 1997).
Plate 6.5b: A Cape fur seal on Maitlands beach (courtesy of W.R. Branch).

CHAPTER 7:
MARINE IMPACTS
AND MITIGATION
7. MARINE IMPACTS AND MITIGATION
7.1 INTRODUCTION
The previous EIA studies on the port (Initial and Revised EIAs) concentrated specifically on the
marine impacts associated with their respective port proposals. This chapter has made extensive use
of these earlier works and CES fully acknowledges the input provided by the earlier CEN reports.
A number of specialist studies commissioned for the earlier EIAs were also of specific use and can
be found in Part 1 of the Specialist Studies Series. In particular, La Cock and Cohen 1997,
Wooldridge et al. 1997, Boshoff and Sigwela 1998, Kroese and Sauer 1998, and Sauer and Booth
1998 were of use in assessing the impacts on the biota of the region. The specialist studies
specifically commissioned for this, the Sub sequent EIA, were extensively drawn on. The reader is
encouraged to read the Risk Assessment (WSP 2001) and the Dredging, Excavation and Disposal
Reports (CES 2001). These reports can be found in the Specialist Studies Series – Part 2.
The impacts are grouped into a range of issues, with these issues being covered in separate
construction and operational sections. Some impacts may occur in both phases but are only
discussed in the phase in which they predominantly occur.
7.1.1 PROJECT ACTIONS OR ACTIVITIES ASSOCIATED WITH CONSTRUCTION

AND OPERATION OF THE PORT
During the construction of the port there are a number of project actions that could significantly
impact on the marine and nearshore environment. A detailed project description can be found in
Chapter 3 but the principal project actions or activities are:
1. the construction of the breakwaters and quay walls;

2. the dredging of the turning basin and approach channel;
3. blasting in the turning basin and approach channel;
4. the deposition of dredged material in the nearshore environment; and
5. the building and operation of the sand bypass system.
These project actions will involve significant disturbance to the marine environment. The
construction period will be approximately 3 years, with numerous activities being run in parallel.
The operational activities associated with the port are less defined as no confirmed clients exist for
the IDZ and thus the type of activities that will occur in the port have not been finalised. At present
it is envisaged that the port will handle three types of cargoes, viz. bulk, breakbulk and containers.
The products being moved could vary from various ores, cement, chemicals, refined petroleum
products, various iron products, vehicles and other containerised goods. For the present design, the
lowest ship movements are predicted at 258 per year and the highest at 557 per year. In the future
this may rise up to 1 047 ships per year (pers. comm. CDC and the Port Authority Division). The
operational activities at the port would involve the:
1. refuelling and general servicing of vessels;

2. unloading and loading of various cargoes; and
3. light repair and maintenance. 9
9
The CDC and PAD have indicated that no major ship breaking, refurbishment, building or painting will be allowed in
the proposed port.
Chapter 7: Marine Impacts and Mitigation 119

7.2 KEY ISSUES – CONSTRUCTION PHASE

ISSUE 1: SPECIFIC IMPACTS ON THE NEARSHORE ENVIRONMENT
The nearshore environment will, in the construction phase of the port, be impacted on by the
construction of the quay walls, breakwaters, container terminal and the sand bypass system. In
addition, occasional blasting but extensive dredging and offshore deposition of uncontaminated
dredge spoil will be required (see Chapter 3 for details on these project actions). Clear operational
guidelines (Appendix C – Section 3) have been proposed for dredging and blasting and these must
form part of a Construction Environmental Management Plan.
Impact 1 - Impact on soft sediment habitats (beach, intertidal, subtidal)

Cause and comment
The construction of quay walls and the breakwaters, along with the required dredging operations,
will result in the physical removal or destruction of sandy beach and soft sediment intertidal and
subtidal habitats. The construction of the hard structures of the port, e.g. quay walls and
breakwaters, will result in a permanent net loss of soft sediment habitat. This loss will, however, be
insignificant in terms of Algoa Bay. The impact on the soft sediment habitats within the dredge path
and immediate surrounds represents a significant pulse disturbance but recovery of the community
will begin soon after the operation ceases. This recovery will pass through a series of ‘successional’
stages before an ‘equilibrium’ community is established, which may take up to 2 – 4 years. The
‘equilibrium’ community may assume different characteristics compared to the initial community
present, due to natural variability in communities and/or modifications to key environmental
variables that structure them (e.g. slight changes in depth, light penetration, sediment
characteristics, slope etc).
Deposition of dredged material will smother organisms at the dumpsite 10 . Recovery of the
communities should occur relatively quickly (2 – 4 years). Available information suggests that the
bottom topography along the 30m depth contour at the proposed site is relatively uniform,
consisting of sand and finer material and very little reef. Although permanent changes to the
infaunal benthic community at the disposal site is possible, the apparent similarity of dredged
sediments compared to the sedimentary regime at the disposal site (sand dominated) would suggest
that the recovered community should ultimately not differ substantially from the community
presently there.

Limited mitigatory measures are available to ameliorate the impact on the soft sediment
communities but recovery of these habitats will occur. Adherence to the monitoring and deposition
programme outlined in the Dredging, Excavation and Disposal specialist study (Specialist Studies
Series – Part 2) as well as in Appendix C should result in the dredging impacts being contained to a
predetermined and assessed impact footprint.
The construction activities associated with the port will definitely result in the physical removal or
destruction of most of the benthic community within the footprint associated with the breakwaters,
quay walls, container terminal, turning basin and approach channel. In addition, the benthic habitat
at the dredge spoil disposal site will be smothered. This will definitely have a severe effect in the
short term on a localised scale. While mitigatory measures are limited and some of the soft
sediment habitat will be permanently lost under the port structures, the communities within the
dredge path and disposal site will recover over the short term, resulting in a slight impact in the
10
The impacts associated with disposal of dredge spoil were assessed assuming that the preferred ecological site
(inshore site) would be used. The Dredging, Excavation and Disposal report (See Specialist Studies Series – Part 2 )
investigated a number of sites and established that the inshore marine site was the most ecologically suitable.
120 Chapter 7: Marine Impacts and Mitigation

medium to long term. Adherence to the dredging and disposal guidelines should ensure that the
overall environmental significance of this impact is LOW (negative).
Impact 2 - Impact on fish

Cause and comment
Bony fish, sharks, skates and rays will be in the immediate vicinity of the dredging operations, and
may well be attracted to the disturbance area in search of food. It is probable that a percentage of
these may suffer mortality through hydraulic entrainment. Entrainment rates for fish tend to be low,
even for demersal species, but mortality rates of entrained fish are high. As a result of the low
entrainment rates, and the absence of rare and endangered species in the immediate vicinity
(Wooldridge et al., 1997), the impact will be limited. It is also probable that fish will be in the
immediate vicinity of the blasting operation, and that a percentage of these will suffer mortality.
While fish mortalities are expected to occur, no endangered species are likely to be found in the
blast area.
The dumping of dredge spoil may also result in the death of some sedentary or slow moving
species. However, this is expected to be limited to the disposal site and recolonisation of the area
should occur relatively quickly.

Mitigatory measures to reduce entrainment of fish are limited but adherence to the blasting
guidelines as well as the dredging and deposition guidelines outlined in Appendix C should reduce
the numbers of fish killed.
The impact of construction activities (dredging, disposal and blasting) will definitely have a
moderately severe impact on a localised scale over the short term. Mitigation though adherence to
the blasting as well as the dredging and deposition guidelines will result in a slight impact. The
overall environmental impact of this impact is LOW (negative).
Impact 3 - Impact on marine mammals

Cause and comment
The construction of the port will result in the loss of undisturbed nearshore habitat for feeding,
resting, nursing and social interactions for a variety of marine mammals. The loss will be the
greatest for the humpback dolphin and Southern Right whale, as the nearshore habitat off Coega
provides optimum habitat for these two species (Klages 1997 in CEN 2000). Klages (1997)
estimates that the development of Coega would exclude humpback dolphins from approximately
10% of their habitat in Algoa Bay (CEN 2000). A study by Karczmarski et al. in press did,
however, indicate that the prime habitat for humpback dolphins in Algoa Bay is from Port Elizabeth
Harbour towards Cape Recife and not towards the northeast sections of the bay. The study also
indicated that the dolphins were most frequently recorded 150 – 400m off shore (Karczmarski et al.
in press in CEN 2000).
Specific construction activities such as dredging, disposal and blasting will also impact on marine
mammals. It is highly probable that cetaceans will be present in the area of the dredging operations
on occasion but they are unlikely to be affected by the dredging operation itself. However, the
movement of the dredger to and from the disposal site will impact on their movements and pose a
risk of collision (see ISSUE 11). It is also possible that certain marine mammals may be in the area
prior to a blasting event and that they could suffer maiming or mortality as a result of the shock
waves. Cooper (1995) found that underwater blasts can cause air bladder, intestinal and organ
ruptures, lung haemorrhages and ruptured eardrums in mammals.


Mitigation of the loss of habitat is difficult but the proposed marine section of the Greater Addo
Park should provide protection for many of these species if the park goes ahead. A further dolphin
sanctuary area was proposed from Humewood Beach to Maitland River mouth by Karczmarski et
al. (In press) and this sanctuary would provide further protection. The development of these
sanctuary areas should be addressed in the implementation of the Algoa Bay Management Plan11 .
Adherence to the proposed blasting guidelines (Appendix C, Section 3), which regulates the
frequency of blasts as well as outlining the guidelines for monitoring mammals in the blast area,
should significantly decrease the possibility of injury or death. It should be noted that limited
blasting is expected to be needed as the sediments in the area are predominantly unconsolidated.
The construction of the port will probably result in a permanent localised loss of habitat for some
species of cetaceans e.g. humpback dolphins. Construction activities such as blasting could result in
a severe impact but adherence to the proposed blasting guidelines should reduce the probability of
injury or death, resulting in a slight overall impact. Due to the conservation status of a number of
cetacean species, the overall environmental significance of this impact is MODERATE (negative).
Impact 4 - Impact on birds

Cause and comment
The construction of the port will result in a permanent loss of approximately 3.5 kilometres of
beach. This loss has the potential to impact on a number of shorebirds that utilise this area (e.g.
black oyster catcher) but in terms of the available habitat in the bay, this loss of habitat will be
slight (CEN 2000).
Construction activities will involve dredging and blasting, which may affect birds in a number of
ways. Any seabirds in the vicinity of a blast will be vulnerable, whether they are underwater, e.g.
penguins, or on the surface, as their lungs and air sacs, which could be ruptured by the concussion,
are directly exposed to the effects of the blast (La Cock & Cohen 1997). The resultant sub- lethal
rupturing of tissues will probably result in mortality. Penguins are thought to be the most vulnerable
bird species as they are flightless and thus spend their whole sea time either on or below the surface
(La Cock & Cohen 1997). The direct impact of dredging on birds is thought to be limited 12 . During
maintenance dredging activities at Port Elizabeth, birds have been observed diving and feeding
adjacent to the dredging operation (Mike Cohen, personal observation).

A patrol of the area should be done to determine whether any seabirds are present in the water and
if any are detected, an effort should be made to scare them from the area. Adherence to the blasting
guidelines (Appendix C) should ensure that injury and deaths to birds are kept to a minimum.
If the Greater Addo initiative goes ahead, the sand beach ecosystem between the proposed harbour
and the Sundays Estuary will be conserved, which should ameliorate many of the loss of habitat
issues associated with the port. The CDC and the Port Authority Division (PAD) should collaborate
with the Addo initiative on aspects of mutual environmental concern.
11
The Algoa Bay Management Plan will need to be developed further by all stakeholders in Algoa Bay. The finalisation
and implementation of a Management Plan must be seen as a priority by all stakeholders in the Bay (e.g. the Nelson
Mandela Metropole, Port Authority Division (PAD), Coega Development Corporation, DEAT and other interest
groups).
12
The secondary impacts associated with dredging are assessed in other impacts, e.g. Impact of light and noise (ISSUE
9).

The construction of the port will involve a permanent loss of a small stretch of sandy beach habitat
and involve activities such as blasting, which will probably result in a severe localised short term
impact. Mitigation in the form of adhering to the blasting guidelines should result in a slight to
moderately severe impact, depending on the species impacted upon. The overall environmental
significance is LOW for most marine birds but HIGH for species of concern, such as the penguins.
Impact 5 - Impact on general ecology

Cause and comment
Increased levels of suspended solids (SS) during dredging and disposal means that turbidity plumes
will be evident in the immediate area throughout the dredging operation. The dynamics of these
plumes and the recommended SS levels and mixing zones are dealt with in detail under the
Monitoring Guidelines (Specialist Studies Series Part 2 – Dredging, Excavation and Disposal
Study). Elevated turbidity levels may negatively impact on phytoplankton production. This
reduction in the primary food source will in turn have a negative effect on the food web. Higher
than usual SS levels may also cause a disturbance and impact on the nearshore fish breeding
grounds. This in turn may impact on the availability of food for the birds utilising the area as a
feeding ground. The local fish communities are adapted to short term increases in turbidity levels,
for example, when rivers come down in flood. These episodic events are of short duration, whereas
the construction of the port and the associated turbidity levels will be sustained over a longer
period. This may result in changes to the local fish community structure and may reduce
recruitment.
Increased SS levels may impact on seabirds (e.g. penguins and cormorants) from the nearby St
Croix Island Group, which utilise visua l cues and diving in their feeding strategy, for example
penguins and cormorants. For bird species that are highly mobile and capable of finding alternative
feeding sites, the impact should be slight. Because penguins rely on vision for feeding and
orientation, an increase in turbidity may also increase predation on the penguins, which would be
unable to successfully avoid those predators that are not affected by the turbid water.
It is also possible that marine mammal species may be excluded from the disposal and dredging
areas depending on their ability to cope with higher turbidity. Certain species may avoid the area
due to increased risk of predation upon themselves or their young.
It must be noted that while general ecosystem functioning may be affected, the impact will be
confined to a very small proportion of the bay.

Environmental guidelines for dredging that address turbidity levels have been covered in detail in
the Dredging, Excavation and Disposal specialist study (See Specialist Studies Series – Part 2).
Adherence to these guidelines (See appendix C) should contain the majority of the impact to within
stipulated areas (dredge path including the mixing zone and the disposal site). In addition, much of
the dredging will take place within the basin and behind the breakwater, which removes some of the
risk associated with Jahleel Island. Furthermore it is recommended that the Trailer Hopper Suction
Dredge (TSHD) is equipped with a sub-surface overflow system which should ensure that surface
waters are not too adversely affected by elevated SS levels.

Increased SS levels will probably have a number of severe localised effects over the short term.
The higher suspended solids may affect primary productivity, feeding and escape responses of fish,
feeding in birds and utilisation of the area by marine mammals. Mitigation in terms of adherence to
the dredging and disposal guidelines (Appendix C), as well as the fitting of subsurface overflow
systems, should decrease the severity of these impacts. The overall ecological significance of this
impact is LOW at a ecosystem level but may be MODERATE for species of special concern, such
as the African Penguin.
ISSUE 2: THE EFFECT OF THE PORT ON THE PHYSICAL ENVIRONMENT

Impact 1 - Change in the bathymetry in the nearshore zone
Cause and comment
The dredging of the approach channel and turning basin as well as the reclamation works required
for the container terminal will result in a long term to permanent cha nge in the bathymetry of the
region.

The only mitigatory action available is to limit the amount of dredging to the minimum required for
the optimal functioning of the port. The immense cost of dredging should act as a self regulating
mechanism to ensure that no unnecessary disturbance occurs.
The bathymetry of the region will be severely altered over the long term on a localised scale. This
impact is of LOW environmental significance.
Impact 2 - The impact of port construction on the sediment dynamics of the dunes and
beaches around the breakwaters
Cause and comment
Coastal lands and sediments are constantly in motion. Breaking waves move sand along the coast,
eroding sand in one area and depositing it on an adjacent beach. Tidal cycles carry sand onto the
beach and move it back into the surf. Taken individually, each natural process of coastal transport is
complex. Taken collectively, they create an intricate system that attempts to achieve a dyna mic
balance. The wave energy in the vicinity of Coega is moderate to high; the prevailing swell is
generated in the westerly gale belt and approaches the south coast from the southwest. Even the
slightest angle between the land and the waves will create currents that transport sediment along the
shore. These longshore currents are the primary agent of sediment transport along the Algoa Bay
coast and are a major cause of sand migration along beaches. Sand is moved both northward and
southward along the beach, but net movement is northward (CEN 2000).
Solid structures constructed out into the sea impede the littoral drift of sand caused by longshore
currents. The beach then expands on the updrift side of the structure; however, the downdrift side of
the groin loses sand because of continuing longshore movement. A structure such as the breakwater
planned for Coega may lead to impressive retention of beach materials on the updrift side and
coastal degradation on the downdrift side (CEN 2000).
The construction of the breakwaters and construction related activities will also necessitate the
removal of some dune and beach area. These activities may cause a destabilisation of the dune area,
which could lead to erosion. The vegetated dune ridge as well as the mobile dune belt at Coega are
not actively involved in replenishing beach sand as they lie landward of the storm berm (Illenberger
and Burkinshaw 1996), unlike classical foredunes where there is regular exchange of sand between
the beach and dune with the adjacent dune occasionally being removed completely by storm waves,
and in the process helping to restore storm-eroded beaches as well as reducing the amount of

erosion. Illenberger (1997) states that the interruption of sand movement of the mobile dune belt
through a development that would intrude into the dune belt would be moderate on a local scale and
low on a regional scale, because the amount of sand movement here is negligible (approximately 1
percent) compared to the amount being moved by longshore drift. Illenberger (1997) further stated
that it would be possible to remove a 1km section of the dune ridge without a major impact on the
sediment dynamics because sand movement in this area is already limited due to the fixed nature of
the vegetated dune ridge. Along the Algoa Bay coastline there are approximately 20 kilometres of
this type of dune system and the impact of removing a small section of this dune ridge would be
high on a local scale, moderate on a sub-regional scale (Algoa Bay), and low on a regional scale
(Eastern Cape). The physical impact of constructing transport routes and possibly port walls and
channels through the vegetated ridge of the area designated for the port would also be minimal, as
discussed above (CEN 2000).

A sand bypass system has been incorporated into the design specifications for the port. The
proposed system will move sand from the root of the secondary breakwater and discharge it north of
the main breakwater. Sand will be collected on the southwestern side of the port on the outside of
the secondary breakwater. The collection of sand will be carried out using a sand bypass system.
The sand bypass system for collection of sand is envisaged to be a series of jet pumps mounted on a
fixed jetty across the surf zone on the southwest side of the breakwater. Localised sumps will be
excavated into the rock to provide sufficient storage for the systems. The sand in the form of a
slurry will be pumped via the pump-house at the base of the secondary breakwater. It will travel in
pipelines located in the service corridor around the back of the port. Booster pump stations along
the way will facilitate the movement of the slurry. The slurry will be discharged onto the beach on
the northeastern side of the breakwater for continued transport by natural means down the beach
(CEN 2000). Commissioning of the sand bypass unit will take place soon after the breakwater
construction is completed.
Additional recommendations include a beach and dune management and monitoring plan to assess
the effectiveness of the sand bypass system and to limit unnecessary disturbance of the dune
system.
The building of a breakwater will definitely change the longshore movement of sediment resulting
in a very severe permanent localised impact on the beaches around the harbour. The successful
implementation and operation of a sand bypass system (see Chapter 3) should result in a slight
impact. The removal of a small section of dune will have a moderately severe impact at a localised
scale. The overall environmental significance of the impact on sediment dynamics in the region is
LOW (negative).
ISSUE 3: THE EFFECT OF DREDGE SPOIL DUMPING AT SEA ON COMMERCIAL

AND RECREATIONAL FISHING ACTIVITIES
Impact 1 - The effect of spoil disposal on commercial and recreational fishing activities in the
area of operation
Cause and comment
More than 70 species of bony fish, sharks, skates and rays have been recorded in Algoa Bay (Romer
1986). The recommended disposal site will have a number of species associated with soft sediment,
including bony fish, skates and rays. The area is known to be a nursery site for Silver Kob, although
the disposal site only covers a small fraction of the available nursery area. The site is not
extensively used by either recreational or commercial fishermen (Dredging, Excavation and
Disposal Specialist Report). Two areas within the site have, however, previously been used as a

spawning ground for squid (Sauer & Booth 1998). Dumping will influence the activity of the
species regularly found in the area and will impact on the activities of squid vessels, although the
site occupies less than 5% of the area regularly fished.

Mitigation of this impact will be achieved by the dredger contractors being required to dump within
the inshore disposal site boundaries (See Dredging, Excavation and Disposal Specialist Report –
Specialist Studies Series - Part 2).
The disposal of dredge spoil at the disposal site will probably have a severe localised impact on
recreational and commercial fishing activities. Disposal of spoil within the predetermined disposal
site boundaries will result in a slight impact. The overall ecological significance of this impact is
LOW (negative).
ISSUE 4: THE EFFECT OF DUMPING AT SEA ON RECREATIONAL BOATING

(SAILING)
Impact 1 - Interference by dredgers with yachts in the vicinity of the St Croix island group
Cause and comment
The Port Elizabeth Yacht Club (PEYC) hosts two regattas a year, which incorporate daytime racing
in the vicinity of the St Croix Island Group. Both Brenton and St Croix are included in the race
course. A further race includes all three islands in the group and is a day/night event, although it is
not strictly an annual event. There is a risk that the disposal operation could interfere with the
running of these races and may result in a collision between yachts and the dredgers.

Communication and coordination between the dredging contractor and the PEYC should prevent
any collisions. Correct timing and course design can ensure that the trailer suction hopper dredge
(TSHD) is nowhere near the race area for those few times during the year.
A collision between the dredger and any yachts is unlikely but an accident could be severe in
nature. Correct management and course design of the yachting events and communication between
the organisers and the dredge operators should result in the probability of a collision being very
unlikely and hence the impact is of NO SIGNIFICANCE.
ISSUE 5: BIOLOGICAL CONTAMINATION THROUGH INTRODUCED ORGANISMS

Impact 1 - Impact of an introduced marine invasive organism
Cause and comment
The possibility of the introduction of exotic marine organisms by dredgers and ships will occur
throughout the life of the port and as such it is an impact that is found during both the construction
and operational phases. The probability of a release and successful colonisation of exotic organisms
is exceptionally difficult to predict or calculate (WSP 2001- Risk assessment) but the seriousness of
this issue should not be underestimated, as the introduction of a single invasive species could result
in a very significant permanent impact on the ecology of southern Africa’s coastal zone. This threat
is not unique to Coega and is a problem faced by all ports in the world. The main mechanisms by
which organisms could be introduced to Algoa Bay will be through ballast water of ships and
pockets of trapped sediment in the dredgers, which originate from their previous area of operation.

Ballast water can be dealt with in three general ways, viz. treating the water prior to release into the
harbour, transfer of ballast water to onshore tanks for treatment and offshore disposal.

Transfer of ballast water to onshore tanks for treatment eliminates the issue of ballast water being
released directly into the harbour. Treatment systems that can be applied could include oil
skimmers, and chemical or physical treatment, e.g. Chlorination or Ultra Violet irradiation as
applied to some European domestic or hospital wastes. Water to be returned after treatment can be
checked that no organisms are still alive in it. It is understood, however, that there are currently no
shore side treatments available in South Africa, and that none are planned for Coega (Nick van
Amstel, PAD, 2001, pers. comm.).
Treating the water whilst still on board and then releasing it is possible as is the offshore disposal
and re-ballasting of water (water exchange). Current practices in Port Elizabeth are for water
exchange and a certification process to check that this has been done. Independent validation of
this procedure is problematical and water exchange is weather dependent. Treatment of the ballast
water whilst still onboard and prior to release from the vessel would enable independent
verification. Since no onshore treatment tanks are to be provided, placing the onus on the vessel to
provide adequate facilities for onboard cleaning and treatment of ballast water would provide a
means to ensure release of only clean water.
It is essential that a ballast water plan be drawn up for both ports in the bay prior to the operational
phase of the Port of Ngqura.
In terms of the dredging operation, specific cleaning and ballast water specifications must be built
into the dredging tender. These specifications should include:
• Cleaning of the dredgers at sea, and cleaning and emptying of ballast while on route to, and
still outside of South African territorial waters.
• Upon arrival, the dredgers should still be considered a risk and inspected before dredging
commences in South Africa.
The introduction of an invasive exotic species to South African coastal waters is unlikely, but if it
occurs it will definitely have a permanent and very severe negative effect on native communities
and/or marine resource-based industries at the local, district, regional and national scale. The
environmental significance of the impact would be VERY HIGH. Mitigation in the form of a
rigorous ballast water plan and extensive cleaning of the dredgers only serve to reduce the
probability of occurrence but the impact will still be of VERY HIGH significance if it occurs.
Impact 2 - The potential impact of increased predation on the island biota

Cause and comment
The biota on Jahleel Island is very susceptible to an introduction of predators such as rats or cats.
The introduction of predators would impact on the birds that utilise the island as a roosting and
nesting site (limited nesting). While the breakwaters are 500m away from the island, there is a
chance that predators associated with ports (cats and rats) may reach the island.

The following mitigatory measures were recommended in the revised EIA (CEN 2000).
1) A detailed monitoring plan by Eastern Cape Nature Conservation should be implemented and a
management plan for rats should be devised.
2) A carefully planned and orchestrated eradication plan should be established if required.
3) A port de-ratting policy should be developed and form part of the Operational Management Plan.
This plan could include measures such as compulsory poisoned bait stations on ships, compulsory
fumigation, mooring rat guards and compliance inspections.
4) No infrastructure must be located on the eastern breakwater.

The introduction of predators to the offshore islands may occur and this would definitely result in a
severe localised impact in the long term. Mitigation could result in the probability of the impact
occurring being unlikely, and successful eradication would result in a slight impact. The overall
significance of this impact after successful mitigation is LOW (negative).
ISSUE 6: IMPACTS ON SITES OF MARINE ARCHAEOLOGICAL IMPORTANCE

Impact 1 - Impact on possible marine archaeology sites
Cause and comment
According to the Historical Shipwrecks Database maintained by the National Monuments Council,
264 vessels are listed as ha ving been lost in Algoa Bay. Three of these ships, the Oaklands (1860),
the Portsmouth (1866) and the Gerhardine (1888), are known to have been wrecked at the Coega
River mouth. These ships are all protected by legislation and may not be disturbed unless the
authority of the National Monuments Council has been obtained (CEN 2000).
Sonar scans of the dredge area were used to determine if any ships were present in the area (CEN
2000). A professional opinion (Dr Jenny Benny – Bayworld, PE) indicated that it was unlikely that
any ships were present in the area to be dredged.

The mitigation of this impact is covered by existing legislation that prohibits any unauthorised
damage to wrecks. The Port Authority Division (PAD), CDC and the dredging contractor will be
required to obey the National Heritage Resource Act (Act 25 of 1999). This Act stipulates the
protection of any vessel or part of a vessel that was wrecked in South Africa, whether on land, in
the internal waters, the territorial waters or in the maritime culture zone of the Republic. Any cargo,
debris or artefacts found or associated with the wreck, which is older than 60 years or which South
African Heritage Resources Agency considers to be worthy of conservation, receives protection
under the Act. The PAD and CDC will be required to get authorisation from the National Heritage
Association prior to proceeding with dredging. Correspondence with Mr John Gribble of the
National Heritage Association has indicated that further work on the issues may be required to fulfil
the legislative requirements prior to giving permission to start construction. It is recommended that
the PAD and CDC establish what additional work, if any, needs to be conducted prior to the
commencement of dredging or construction.
It is unlikely that wrecks will be found in the construction activities associated with the port. The
impact of dredging on wrecks could possibly have a very severe permanent impact as the wreck
would be destroyed by the dredger or covered by the breakwaters or dredge spoil. Mitigation would
involve an archaeological assessment of the site and the removal of any scientifically important
artefacts. The overall significance of this impact after mitigation should be LOW.
ISSUE 7: IMPACTS ON ADJACENT INDUSTRIES 13

Impact 1 - Effects on adjacent abalone farm
Cause and comment
Marine Growers Abalone Farm is located adjacent to the proposed port and will thus be influenced
by the construction and operation of the port. The construction and operational activities could
result in physical changes to water quality and sediment dynamics in the region.
13
The impact of the port on other industries (salt works, fishing industry) is further assessed and discussed in Chapter 9,
Issue 4. The abalone farm is addressed in this section due to the specific marine impacts that the port may have on the
farm.

Abalone are difficult to farm in that they have a relatively long grow out period and require high
water quality. An investigation done by Common Ground Consulting (2001) indicated that in terms
of marine impacts, the farm could be affected by the port in the following ways:
• Capital and maintenance dredging could result in high suspended load conditions and in
latter years of operation, the re-suspension of contaminants.
• The dredgers and ships could import pathogens and nuisance organisms into the region,
which could establish themselves in the farm.
• The seawater intake to the farm may be inundated by a change to the sediment processes in
the area.
• Acute pollution events such as oil spills, ship accidents and illegal waste dumping could
have severe impacts on the farm.
• Potential chemical contamination of the water by trace metals from the harbour or the ore
stockpiles in the IDZ could decrease production or kill the stock.
• During operation there could be a build up of biocides such as copper or TBTs and these
substances are particularly lethal to molluscs such as abalone.
Apart from the desktop assessment by Common Ground Consulting (2001), specific field studies to
investigate these issues have not been undertaken, or if they have, issues related to the abalone farm
have not received special attention. Any single or combination of the above impacts have the
potential to severely impact upon the abalone farm and in the absence of definitive studies, the
precautionary approach must prevail. By logical progression the land use option of abalone farming
immediately surrounding the port, including the 8CR property trust land on which the Marine
Growers Abalone farm is situated will also be significantly compromised (See Chapter 9 for further
discussion).

Many of the impacts outlined above can be mitigated through effective environmental management
of the port. This would involve establishing a thorough operating environmental management
system, which would include aspects such as a ballast water and dumping plan, oil spill contingency
plans, wastewater and stormwater plans etc. This system would need to be regularly updated and
have strict enforcement mechanisms. Unfortunately, abalone are sensitive organisms and there is
always the possibility of a catastrophic event occurring in the port e.g. an oil spill.
It is possible that the port will have a long term severe impact on the abalone farm. Until further
specialist studies are undertaken, the precise nature, magnitude and interaction of these impacts are
unknown. In addition, it may not be possible to quantify a decrease in market acceptance to a
product that is grown next to a port. Mitigation and management of the various impacts could be
implemented and have been shown to be successful in other ports, but in the absence of further
investigations specifically related to the Ngqura Port and the abalone farm, the overall significance
of the marine impacts are HIGH 14 (negative).
14
If the CDC or PAD do not undertake to successfully relocate or equitably buy out the abalone farm, then the required
studies to fully verify the impacts that the construction and operation of the port will have on the abalone farm must be
undertaken prior to authorisation.

Table 7.2a Construction phase impacts on the marine environment.

ISSUE/IMPACT
RISK TEMPORAL SPATIAL CERT. SEVERITY SEVERITY SIGNIFICANCE
ISSUE 1: SPECIFIC IMPACTS ON THE NEARSHORE ENVIRONMENT
Impact 1: Impact on soft sediment habitats (beach,
Will occur Short term Localised Definite Severe Slight LOW
intertidal, subtidal)
Impact 2: Impact on fish Will occur Short term Localised Definite Moderately severe Slight LOW
Impact 3: Impact on marine mammals Will occur Short term Localised Probable Severe Slight MODERATE
Impact 4: Impact on birds Will occur Short term Localised Probable Severe Moderately severe HIGH* (LOW)
MODERATE*
Impact 5: Impact on general ecology Will occur Short term Localised Probable Severe Moderately severe
(LOW)
ISSUE 2: THE EFFECT OF THE PORT ON THE PHYSICAL ENVIRONMENT
Impact 1: Change in the bathymetry in the nearshore
Will occur Long term Localised Definite Severe Severe LOW
zone
Impact 2: The impact of port construction on the
sediment dynamics of the dunes and beaches around Will occur Permanent Localised Definite Very severe Slight LOW
the breakwaters
ISSUE 3: THE EFFECT OF DREDGE SPOIL DUMPING AT SEA ON COMMERCIAL AND RECREATIONAL FISHING ACTIVITIES
Impact 1: The effect of spoil disposal on commercial
Will occur Short term Localised Probable Severe Slight LOW
and recreational activities in the area of operation
ISSUE 4: THE EFFECT OF DUMPING AT SEA ON RECREATIONAL BOATING
Impact 1: Interference by dredgers with yachts in the Localised NO
Unlikely Short term Possible Severe No effect
vicinity of the St Croix Island Group SIGNIFICANCE
ISSUE 5: BIOLOGICAL CONTAMINATION THROUGH INTRODUCED ORGANISMS
Impact 1: Impact of an introduced marine invasive
Unlikely Permanent National Definite Very severe Very severe VERY HIGH
organism
Impact 2: The potential impact of increased predation
May occur Long term Localised Definite Severe Slight LOW
on the island biota
ISSUE 6: IMPACTS ON SITES OF MARINE ARCHAEOLOGICAL IMPORTANCE
Impact 1: Impact on possible marine archaeology sites Unlikely Permanent Localised Possible Very Severe Slight LOW
ISSUE 7: IMPACTS ON ADJACENT INDUSTRIES
Impact 1: Effects on adjacent abalone farm May occur Long term Localised Possible Severe ? HIGH ?
* The higher ratings are due to impacts on species of special concern.

7.3 KEY ISSUES – OPERATIONAL PHASE

ISSUE 8: POLLUTION ASSOCIATED WITH THE OPERATION OF THE PORT
Impact 1 - Impact of general ship and port waste
Cause and comment
The present marine environment around the Coega River mouth and Jahleel Island is relatively
pristine. The operation of a port will result in the introduction of a range of waste into the marine
environment (e.g. solid ships’ waste, plastic, paper etc.). This waste will result from rubbish and
litter from the IDZ and from the ships arriving in the port. There will be an increase in litter on the
beaches and in the marine environme nt around the port. This litter (e.g. line, packing tapes etc.) will
cause a visual impact on the environment as well as impacting on some of the fauna in the region,
which may get entwined or ingest the litter.

The vast majority of this type of pollution can be prevented assuming an effective management
system is in place. It is recommended that an operational phase port management plan be compiled
and that litter control be incorporated into this plan. As required by MARPOL15 , adequate waste
reception facilities must be made available at the port to dispose of ships’ waste.
The incorrect operation of the proposed port will result in substantial amounts of pollution being
introduced into the environment, which will definitely have a severe localised impact on the fauna
and aesthetics of the area in the long term. The correct management of the port, which would
involve deterrents and effective enforcement, could result in the impact being slight. The overall
ecological significance of this impact is LOW (negative).
Impact 2 - Impact of ship associated biocides

Cause and comment
The fouling of ships’ hulls is a major problem in the shipping industry as it reduces the efficiency of
ships. The use of a variety of biocides on the hulls of ships has been standard practice for a number
of years. These biocides are specifically designed to kill organisms such as molluscs that attach
themselves to the hulls of ships. In recent years the accumulation of these biocides in ports and
marinas has been identified as a major problem and efforts are under way to curb the use of
biocides. The biocide treatments (e.g. antifouling paint) on the ship’s hull not only prevents the
successful attachment of organisms to the hull but unfortunately also leaches into the water column
and could result in decreased spawning success and larval development, and death of invertebrate
organisms in the port. The operation of the port has the potential to impact on invertebrate
organisms within and immediately around the harbour.

Portnet are presently investigating the reduction of biocide use in ports, and over the next few years
aim to prohibit the use of certain antifouling paints such as TBT. The stripping and repainting of
hulls has been identified in other ports as a major source of biocides entering the environment, but
these activities are not planned in the present port configuration.
While the issue of biocides in antifouling treatments is not unique to the Ngqura Port, the operation
of the port will definitely result in a severe long term impact to the organisms within the port, and a
moderately severe impact immediately around the port. The reduction of the use of biocide
15
The International Convention for the prevention of pollution from ships (1973) and its Protocol adopted in 1978
(MARPOL 1973/1978) place an obligation on parties to ensure that ports provide adequate waste reception facilities to
dispose of ships’ waste (CEN 2000).

treatment may reduce the severity of this impact in the future. The overall environmental
significance of this impact is MODERATE (negative).
Impact 3 - Impact of storm water runoff

Cause and comment
Large areas within the back-of-port (e.g. container terminal) and the IDZ will be hard surfaces and
will thus generate large quantities of stormwater runoff. This runoff could contain harmful
substances such as hydrocarbons (oils) and any of the various substances being stockpiled. As the
client base for the IDZ has not been ascertained, it is difficult to predict the nature of contaminants
that may enter the stormwater runoff.

As part of the EMS, the IDZ and port must develop a stormwater management plan. The tenant
approval system will require that individual tenants are responsible for the treatment and
management of stormwater generated on their sites and that any discharge must comply with
DWAF standards.
The poor management of stormwater originating from the IDZ and port could possibly result in a
severe localised impact over the long term. The efficient operation of a stormwater management
plan that regularly monitors and enforces discharge standards would probably result in a slight
impact. The overall ecological significance 16 of this impact is LOW (negative).
Impact 4 - Impact of material spill during cargo transfers

Cause and comment
The transfer of breakbulk, bulk and containerised cargo in the port will result in the occasional spill
during transfer. The risk assessment 17 (WSP 2001 – see the Specialist Studies Series - Part 2)
indicated that the majority of worldwide spills below 7 tonnes were associated with the routine
operations and loading and discharging within the port. In terms of the proposed port, the greatest
incidence of spills within Algoa Bay would be from operations within the port and these spills
would be less than 7 tonnes.
The proposed products (iron, ore, manganese ore, zinc concentrate, coke, coal, cement, H2 SO4 , wire
and rods, metal sheeting, scrap steel, vehicles and containers) vary greatly and so does the impact
that these products would pose if spilled. The risk assessment indicated that a liquid spill would
probably pose the greatest problem, and that spills of H2 SO4 and refined hydrocarbons would result
in the greatest impact on the environment. A spill of the more hazardous heavy fuels associated
with the recent MV Treasure accident was not thought to be as likely. The bulk ferrous materials
such as mild steel sheet, wire, rods and scrap are thought to pose a limited danger but fine bulk
powder products, e.g. cement, may have impacts due to the possible blanketing of the sea surface
when settled.

The fact that most pollution spills occur during transfers or normal port operations indicates that
these accidents should be able to be managed. The correct training programme and careful
management of port operations will be required. The enforcement of the health and safety
programmes and operational standards must all form part of the Operational Environmental
16
Readers are reminded that the overall significance assumes that the mitigatory recommendations will be implemented
and are effective. The pre-mitigation rating provides an indication of what the severity of the unmanaged impact may
be.
17
The precise risk values and their derivations are available in the Risk Assessment Study, which can be found in the
Specialist Study Series – Part 2.

Management System for the port. The sound management of the port should reduce the occurrence
of any spills but emergency containment plans must be drawn up in line with best practice standards
around the world so that, in the case of a spill, it can be contained within the port.
Spills of the various products that will be transferred through the port may occur. Depending on the
size and nature of the spills, they could result in a very severe impact in the short to medium term
within and possibly immediately surrounding the port. With correct management, significant spills
will probably be unlikely and if effectively contained, be of moderate severity. The overall
environmental significance is MODERATE (negative).
Impact 5 - Catastrophic oil spills 18

Cause and comment
The proposed deep water harbour will be visited by very large ships and the possibility always
exists that there could be a catastrophic oil spill such as was the case for MV Treasure in Table Bay.
The MV Treasure released 1 139 tonnes of heavy fuel and 56 tonnes of marine diesel into the sea
off Robben Island. A similar spill in Algoa Bay has the potential to impact on the Bird and St Croix
island groups as well as the entire coastline within and around the Bay. A spill of this magnitude
would impact significantly on various ecosystems within the Bay as well as a number of industries
such as tourism, fishing and mariculture.
While spills of this magnitude (>700 tonnes) are unlikely events, with approximately 7.3 occurring
worldwide every year, the possibility does exist that such a spill may occur (WSP 2001). The
overall risk is, however, regarded as being LOW (WSP 2001).

The correct management of the port can reduce the probability of a catastrophic event occurring,
and the availability of suitably trained people and the required equipment can significantly reduce
the impact of a spill. The following recommendations are proposed:
• Internationally, prevention has become the focus of oil spill management. As part of the oil
spill prevention programme, the National Department of Transport inspects all foreign
vessels calling on South African harbours. Further, all tankers entering South African waters
are obliged to have adequate insurance. However, non-tank vessels can also cause damaging
spills. At present there are no requirements regarding insurance for these vessels. The
international shipping community is promoting a move to broaden the base of ships, which
must carry insurance. Portnet should support these moves and encourage the responsible
state departments to support these international efforts (CEN 2000).
• A comprehensive oil spill contingency plan must be established for Algoa Bay. The plan
must address both containment and cleanup. The plan must adopt best practice techniques
and the necessary infrastructure must be adequately funded and regularly audited.
• A seabird and marine mammal rehabilitation and cleansing centre is required for both
catastrophic events and the day to day operation of the port. The CDC and PAD, as major
stakeholders, in conjunction with other concerned organisations, should provide the majority
of the infrastructure and funding for an appropriately sized and equipped centre. The CDC
in conjunction with PAD must initiate an investigation into the exact requirements of such a
facility and ensure that it is functional prior to the operational phase of the port. The
construction EMP must make provision for managing any impacts on seabirds and
mammals.
18

In the unlikely event of a major oil spill, the impact on the environment in Algoa Bay will be very
severe in the short to medium term. With sound management of the port and inspection of vessels,
the likelihood of occurrence should decrease. If adequate oil spill containment structures are in
place and are effectively deployed, the impact would probably be severe. While the potential risk of
such an occurrence is low (WSP 2001), the potential damage that a major oil spill could have on
sensitive areas such as the various island groups in the Bay results in the overall environmental
significance of this impact being VERY HIGH.
Impact 6 - Air-emissions associated with shipping

Cause and comment
The shipping in the proposed port will result in the emission of gases such as Carbon Dioxide
(CO2 ), Carbon Monoxide (CO), Sulphur Dioxide (SO2 ), Hydrocarbon Compounds (HC), Oxides of
Nitrogen (NOx ), and Particulates (PM) into the atmosphere. Predicted ground level concentrations
of all of the above did not exceed guideline limits (Highest hourly, Highest Daily, Annual Average)
during current or future proposed operations. Predicted concentrations are, however, seen to
increase when evaluating predicted future operations at the harbour site.
The emission of gases associated with the ships at the proposed port will probably result in a
slight, localised, long term impact. The overall significance of this impact is LOW.
ISSUE 9: DISTURBANCE OF FAUNA ASSOCIATED WITH THE OPERATION OF THE

PORT
General comments
The proposed port will result in disturbance to a number of animals e.g. whales, seals, fish and
birds. The largest impact will be on the birds, as the St Croix island group is immediately adjacent
to the proposed port. In particular, the birds that utilise Jahleel Island and the beach immediately
adjacent to the proposed breakwaters will be impacted upon. Jahleel Island and the other islands in
the St Croix group are known to be very important breeding and roosting sites for a number of rare,
vulnerable or endangered birds e.g. Roseate terns and African penguins. The proposed threats to
marine birds posed by the port are clearly outlined in the early specialists stud ies, e.g. La Cock and
Cohen 1997 and Boshoff and Sigwela 1998, and are summarised concisely in the Revised EIA
(CEN 2000). All of these studies can be found in the Specialist Studies Series - Part 1.
Disturbance of the bird communities will begin during the construction activities, when the
breakwaters are built and the dredging and blasting of the turning basin and approach channel will
take place. These operations will be done on a 24- hour basis and will involve flood lighting the
operational area and the generation of noise by the dredgers and breakwater construction. Blasting
should be infrequent but will occur occasionally. In addition there will be the continuous presence
of large numbers of personnel on the construction site. The disturbance created by construction will
be short term, < 5 years. While the individual operations, e.g. dredging, breakwater construction
etc., may not intrinsically be very noisy, and will occur some way off Jahleel Island and a long way
off other islands, the cumulative effect of all these operations being run in parallel will result in a
substantial and chronic disturbance in the area.
The operation of the port will result in disturbance to the area in the long term. Ports are naturally
busy areas as they tranship goods on a 24-hour basis. Noise will be created through the running of
ships, locomotives, vehicles, cranes etc., while the majority of the area will be flood lit.

The impact of the disturbances outlined above will vary from species to species. Sensitive species
will be affected most and any impacts on species of special concern are of importance. The
disturbance created by lights, noise and general activity may include decreased breeding success,
loss of habitat if the roosting or breeding sites are abandoned, and loss of feeding areas.
Impact 1 - Disturbance of birds of special concern

Cause and comment
The Jahleel Island penguin population, and specifically the breeding adult component, would be
severely impacted by the loss of the island as a suitable habitat (as have the populations at two other
islands been affected by port developments), primarily on account of their high fidelity to breeding
islands and reluctance to move when conditions deteriorate. Juveniles would be less impacted
because of a lower fidelity. The breeding performance of displaced penguins that settled elsewhere
would be impaired due to the associated disruption. Similarly their invasion would impact
negatively on the resident population where they settled. The most likely alternative locality for
displaced penguins is St Croix Island, where space is limited and, what is available, is marginally
suitable. This disturbance could be expected to have detrimental impacts on the overall productivity
of penguins in Algoa Bay. Bearing in mind the recently reported decline in the Algoa Bay penguin
population, the reduced productivity has regional as well as international implications (CEN 2000).
Roseate terns probably bred at Jahleel Island in 1983 and virtually the entire South African
population of less than 200 pairs breeds at islands in Algoa Bay, notably Bird and St Croix islands.
Roseate terns would be negatively impacted, primarily because they have already had to abandon
one breeding locality in Algoa Bay (Cape Recife) owing to human disturbance, and the loss of
Jahleel Island would reduce the number of potentially suitable sites to three (CEN 2000).
African black oystercatchers use Jahleel Island as a breeding, feeding and communal roost site. The
maximum count of 21 is 0.58 percent of the South African and 0.44 percent of the global
populations. Oystercatchers have a high fidelity to breeding islands and roost sites. Based on
examples elsewhere (e.g. Marcus Island, Saldanha Bay), they tend to stay on after an island
becomes unsuitable and would therefore suffer a population decrease. For oystercatchers, loss of a
roost site could be the most detrimental aspect of Jahleel Island becoming unsuitable for birds (CEN
2000).

Mitigation is limited but it recommended that:
• No activities are allowed on the eastern breakwater.
• Regular noise and lighting audits are conducted on the port and that lighting near the islands
is kept to a minimum.
• Port policy ensures that ship lanes are kept well away from the other isla nds in the St Croix
group.
• No unauthorised visits should be allowed to the islands.
The disturbance associated with the construction and operation of the port will definitely result in a
permanent severe localised impact on vulnerable bird species. Mitigation is limited and the overall
ecological significance of this impact is HIGH (negative).
Impact 2 - Disturbance of other marine birds

Cause and comment
White-breasted cormorants do not breed regularly at Jahleel Island. The maximum count of 30 pairs
is < 1.0 percent and < 0.01 percent of the South African and global populations respectively. The
loss of the island to this species would not be great on account of their wide distribution and

adaptability. Alternative breeding localities with space exist in the area but because of predation,
only St Croix Island is suitable (CEN 2000).
While Cape cormorants do not regularly breed at Jahleel Island, they would be negatively impacted
if Jahleel Island became unsuitable for them, primarily because the number of potentially suitable
sites for the species in Algoa Bay would be reduced to two (i.e. St Croix and Seal islands).
However, their low fidelity to site and mate means they have the behavioural traits to cope with
Jahleel Island becoming unsuitable. They would likely relocate to St Croix Island, with which
interchange almost certainly occurs and where suitable space is available (CEN 2000).
Kelp gulls are resident at Jahleel Island. The maximum count of 32 nests is 0.36 percent and < 0.01
percent of the South African and global populations respectively. Kelp gulls are highly adaptable
and shift breeding sites at times. A number of alternative breeding localities exist in the area and
interchange occurs. The impact that displaced kelp gulls will have on the resident populations of
other species is likely to be the most significant aspect of kelp gulls losing the use of Jahleel Island
(CEN 2000).

As for Impact 1.
The disturbance associated with the construction and operation of the port will probably result in a
permanent moderately severe localised impact on marine birds in general. Mitigation is limited and
the overall ecological significance of this impact is MODERATE (negative).
ISSUE 10: MAINTENANCE DREDGING

Impact 1 - Impacts associated with maintenance dredging
Cause and comment
Even though a sand bypass system will be installed in the port, a certain amount of maintenance
dredging will be required in the Ngqura Port. The maintenance dredging could result in a range of
impacts not encountered in the initial capital dredging programme, which will occur in a clean
sands environment (see Specialist Studies Series – Part 2). During operation, the Ngqura Port may
accumulate various contaminants in its sediments e.g. hydrocarbons and heavy metals. While the
projected dredge operations will be small, the suspension of any contaminants during dredging and
disposal can result in a range of impacts on the environment. One cannot predict the exact impacts
as the amount of material to be dredged and possible levels of contamination are unknown.

The London Convention and guidelines produced by DEAT clearly outline the requirements that
need to be met before dredging. Prior to any authorisation from DEAT for maintenance dredging,
these requirements will need to be met by the dredging contractor and thus the impact on the
environment should be low.
The dredging of contaminated areas could possibly result in a severe localised impact at both the
dredging and disposal sites. If the required permitting is obtained and the guidelines are adhered to,
the impact should be slight. The overall environmental significance of this impact should be LOW.

ISSUE 11: RISKS ASSOCIATED WITH INCREASED SHIPPING

Impact 1 - Increased risk of ship collision19
Cause and comment
The proposed port will result in a substantial increase in vessel traffic in Algoa Bay and as such
there is an increased chance of ship collision. The risk assessment (WSP 2001) indicated that with
the increased traffic, projected collisions of vessels of greater than 700 tonnes will be approximately
two incidents every ten years. Collisions between smaller vessels will be less than this.
The hydrographic and meteorological conditions normally prevailing in Algoa Bay, as well as sea
floor geology and currents, do not appear to be a major risk for collision, grounding or loss of
control. One possible exception is when wind and tidal conditions combine to give inshore drift,
with the wind broadside onto vessels as they approach the Ngqura Port. These conditions appear to
occur for a few days a year and additional measures such as the use of tugs will need to be taken
(WSP 2001).
Two areas of concern were identified in the risk assessment, viz. the fishing fleet and dredging
operation. The cargo, container and passenger fleet movements will all be controlled by pilotage but
it is unlikely that the fishing fleet would be. More important ly, the dredging operations for Coega
would probably not be under a pilot’s control. This is of concern as regular movements of this type
tend to become routine and mundane, and thus can become a higher risk (WSP 2001).

The following recommendations are made to reduce the likelihood of collisions:
• As the future approach lanes for Port Elizabeth and Coega will cross or interfere, the traffic
movement control system for the whole of Algoa Bay will need to be revised.
• All shipping in the bay should be under one authority.
• Training of port control tower personnel in the use of the VTS system in place must be
completed prior to the operation of the Ngqura Port.
• The dredging and fishing ship movements must be integrated into the traffic control of the
bay.
A co-ordinated approach to vessel traffic control by trained personnel will help to lower risks of
vessel collision in the approaches to the two harbours in Algoa Bay.
The risk of ship collision in Algoa Bay due to the building of the Ngqura Port will be higher.
Collisions could possibly occur and the impact on the environment may be very severe, depending
on the severity of the collision and the size of any resulting spill. With the correct traffic control
measures in place, collisions should be very unlikely. The large size of ships expected to berth at
the proposed port and the fact that large spills are usually associated with collisions (WSP 2001),
means that while being very unlikely, the overall environmental significance of a collision is HIGH
(negative).
Impact 2 - Increased risk of collisions with marine mammals

Cause and comment
Klages (1997, in CEN 2000) indicated that avoidance reactions by marine mammals and diving
seabirds to cavitation noise from ships’ propellers is not always effective in preventing collision
with vessels. Of the ten species of marine mammals that are regularly found within Algoa Bay, the
19

species at greatest risk of collision with vessels is the Southern Right whale, due to its slow speed
and limited visibility when swimming below the surface.
The probabilities of whales occurring in the defined shipping channels during their breeding season
was determined as well as the likelihood of collisions. The highest probabilities were found to be
during the dredging phase due to the repeated trips in shallow waters however the overall risk was
still regarded as being low WSP 2001 (See Specialist Studies Series – Part 2). The probabilities of
collisions between ships and whales in the design and future phases of operation for the Coega and
Port Elizabeth operations were found to be higher than the current operations at Port Elizabeth but
not nearly as high as the proposed dredging operation.

Mitigation factors that can be employed to reduce the risk of collisions are:
• A whale reporting system that reports whale sightings to the port control so that warnings
can be issued.
• Establishment of whale watches on ships entering the bay during whale breeding periods.
During the dredging period, when the risk of collision is highest, independent monitors
should be on the dredgers travelling to the disposal sites. During periods of high risk this
monitoring programme should be paid for by the contractors but administered by the Port
Environmental Officer.
• Suitable speed limits for vessel movements in the various regions of the bay should be
investigated.
The collision of ships or dredgers with marine mammals could occur and result in death or injury,
which would be a very severe impact due to the conservation status of many of these species. The
implementation of whale watches and effective traffic control may reduce the occurrence of
collisions. The overall significance of this impact is MODERATE (negative).

Table 7.3a: Operational phase impacts on the marine environment.

ISSUE/IMPACT
ISSUE 8: POLLUTION ASSOCIATED WITH THE OPERATION OF THE PORT
Impact 1: Impact of general ship and port waste Will occour Long term Localised Definite Severe Slight LOW
Impact 2: Impact of ship associated biocides Will occur Long term Localised Probable Severe Moderately severe MODERATE
Impact 3: Impact of storm water runoff Will occur Long term Localised Definite Severe Slight LOW
Impact 4: Impact of material spill during cargo
May occur Medium term Localised Possible Very severe Moderately severe MODERATE
transfers
Short to Medium
Impact 5: Catastrophic oil spills Unlikely Localised Probable Very severe Severe VERY HIGH
term
Impact 6: Air-emissions associated with shipping Will occur Long term Localised Unlikely Slight Slight LOW
ISSUE 9: DISTURBANCE OF FAUNA ASSOCIATED WITH THE OPERATION OF THE PORT
Impact 1: Disturbance of birds of special concern Will occur Permanent Localised Definite Severe Severe HIGH
Impact 2: Disturbance of other marine birds Will occur Permanent Localised Probable Moderately severe Moderately severe MODERATE
ISSUE 10: MAINTENANCE DREDGING
Impact 1: Impacts associated with maintenance
Will occur Long term Localised Possible Severe Slight LOW
dredging
ISSUE 11: RISKS ASSOCIATED WITH INCREASED SHIPPING
Impact 1: Increased risk of ship collision May occur Long term Localised Possible Very severe Very severe HIGH
Impact 2: Increased risk of collisions with marine
May occur Long term Localised Possible Very severe Severe MODERATE
mammals

7.4 CONCLUSIONS
The impacts associated with the construction and operation of the Port of Ngqura on the marine
environment are all negative. The after mitigation impacts are predominantly LOW but there are a
number of HIGH and VERY HIGH impacts (Figure 7.4a).
Marine Impacts
4% 8%
Very High
17%
High
Moderate
46%
Low
No significance
25%
Figure 7.4a: The post- mitigation construction and operational marine impacts of the proposed
harbour.
The construction of the Port of Ngqura is a considerable engineering undertaking. The construction
will take approximately 36 months, with many activities being run in parallel, many of which (e.g.
dredging) will be done on a 24-hour basis. The size, duration and nature of the construction has the
potential, if poorly managed, to impact significantly on the environment. The majority of pre-
mitigation construction impacts (Table 7.2a) are severe or very severe, which indicates that if the
process is poorly managed and the recommendations made in this EIA and the subsequent
Environmental Management Plan are not heeded, the impacts may well be significant. The impacts
are, however, generally short term and localised and if implementation of the recommendations are
successful, the overall environmental significance of the majority of the impacts will be reduced.
With successful mitigation, no impacts are regarded as fatal flaws to the project.
There is only one construction impact of VERY HIGH significance, viz. the impact of an
introduced marine invasive organism. The problem of alien invasives exists throughout the world’s
ports and is presently the focus of a large amount of research interest. The impact is rated as VERY
HIGH due to the tremendous damage that invasive organisms can have. Mitigatory measures such
as a strictly enforced ballast water plan must be implemented and the dredgers must be thoroughly
cleaned prior to arrival in South African waters. These measures will serve to reduce the possible
incidence but cannot assure that no invasives are introduced.
Algoa Bay is an important habitat to a number of bird species of special concern (e.g. African
penguins and Roseat terns). The overall significance of the impacts of construction will be LOW
for most marine species but due to the conservation importance of some birds, is rated as HIGH.
The only other impact of HIGH significance is the possible impact on the adjacent abalone farm.
The port and IDZ have the potential to impact on the abalone farm operations but as yet only a
desktop study identifying possible impacts has been undertaken. As the CDC have undertaken to
relocate or buy out the operation, the exact magnitude, probability and nature of the impacts have
not been fully established. Until an in-depth examination of the desktop assessed impacts is
undertaken, the impact is regarded as being HIGH.

The impact of construction on the general ecology of the region was MODERATE due to the
occurrence of species of special concern such as certain birds and cetaceans. For other aspects of
the ecology of the bay, e.g. benthic invertebrates and fish, the impact is regarded as being LOW.
The operation of the port will result in four main environmental issues, viz. pollution, disturbance of
fauna, maintenance dredging and risks associated with increased shipping. The only impact of
VERY HIGH significance is a catastrophic oil spill, which in turn is related to another impact of
HIGH significance, namely increased risk of ship collision. The possibility of a major oil spill is
unlikely but the significance is rated as being VERY HIGH due to the immense damage that a
large spill could have on the ecology of Algoa Bay. The correct management of the port, inspection
of inbound vessels and sound emergency capability may reduce the likelihood of a major spill and
attempt to contain a spill, but if an accident were to occur, the damage will in all probabilities be
severe.
The other impact of HIGH significance is related to the disturbance of birds of special concern.
Unfortunately the port is located next to Jahleel Island and close to other islands within the St Croix
group. These islands are important habitats for a number of birds with conservation importance and
the construction and operation of the port may well disturb the more sensitive species. All the
impacts associated with pollution during the operational phase are rated as being severe or very
severe prior to mitigation, which indicates that the poor management of the port and IDZ could
result in large amounts of pollution entering the harbour or atmosphere. These potential impacts
can, however, be managed and the significance of the impacts are MODERATE (cargo spills and
ship biocides) or LOW (general ship and port waste, polluted stormwater runoff, ship exhaust
emissions) after mitigation and management.

CHAPTER 8:
SOCIO-ECONOMIC DESCRIPTION
8. SOCIO-ECONOMIC DESCRIPTION
8.1 INTRODUCTION
This section of the report considers the socio-economic makeup of the proposed port and its
surrounds.
8.2 REGIONAL ECONOMIC OVERVIEW
The Eastern Cape is the second largest of the nine new provinces, has the fourth highest
population density and the second highest percentage of children under the age of 15. The
population is expected to grow rapidly in the coming decades. The nearest city to the
proposed Coega Industrial Development Zone (IDZ) is Port Elizabeth, South Africa’s fifth
largest city (CSIR 1997). The highest concentrations of people in the province occur in the
magisterial districts of Port Elizabeth and Uitenhage, which comprises the Port Elizabeth-
Uitenhage Metropolitan area. This metropolitan area houses approximately 1 166 345 people,
with 78% living in the Port Elizabeth area and 22% in Uitenhage.
The economy of the region has traditionally been relatively unbalanced, relying heavily on
manufacturing (CSIR 1997). The Port Elizabeth-Uitenha ge metropole is one of the country’s
major manufacturing centres, with particular focus on the motor industry. Although tourism is
not generally considered to be significant in economic reports of the region, SATOUR have
claimed that tourism brought in 5.5% of the region’s GDP in 1993. Recent years have shown
that this sector of the city has grown considerably. Port Elizabeth has considerable tourism
advantages (the diverse natural environment, good climate, sites of historical interest, nature
reserves, a variety of cultures, mountains etc.) and is being marketed as the ‘Gateway to the
Eastern Cape’. The fishing industry offers opportunities in the Eastern Cape as well, but is
regulated by the quota system that restricts the numbers of each type of fish that may be
harvested.
The economic boom of the 1920s came to an end with the withdrawal of the Ford and General
Motors industries, and the ensuing economic slump left a high level of unemployment in the
region, estimated at 39.8%. The Eastern Cape is one of South Africa’s most poverty stricken
and least developed areas. Sixty- four percent of the Eastern Cape’s population is reported to
be living in poverty (second only to the Northern Province with 69.3%). The poverty gap (the
difference between the income of each poor household and the poverty line) has been
estimated at 24%, the highest in South Africa. (South African Competitiveness Monitor 1996,
Provincial Comparison. WEFA Group. In: Tren 1999). The province also has a high Gini
coefficient, at 0.65, indicating that there is a large disparity in the distribution of wealth and
resources in the province (Tren 1999).
In the Port Elizabeth-Uitenhage metropole, 60% of the potentially economically active

population is employed. Forty- four percent are employed in the formal sector, and 16% in the
informal sector. However, these figures are unbalanced in terms of population structure: the
severity of unemployment in the township areas is estimated to be 50 – 60%.
Because of high levels of unemployment in the region, a large number of people are moving
into the city area to find work. There is a lack of housing, especially low- income housing, and
informal settlements have become a problem in the area (CSIR 1997). The existing house
stock in 1991 was reported to be 80 420 formal houses (housing structures with a life span of
20 years or more) and 53 000 informal houses (any housing unit over which tenure is held,
Chapter 8: Socio-economic Description 143

with access to at least basic services). Of these informal houses, the majority are the typical
shackland camps that continue to grow in accessible open land throughout the country.
In 1994, the Port Elizabeth area was serviced by seven public hospitals and three private
hospitals, as well as 21 clinics. The town of Coega has a small clinic.
There are considerable discrepancies in the standard of living of the different population
groups: the white and Asian communities live in conditions that could be described as first
world with adequate access to educational, recreational and health facilities, while black
communities live in third world conditions (CSIR 1997). The black community experiences
the highest levels of poverty and unemployment, with least access to facilities, particularly in
the Motherwell area.
The Human Development Index (HDI), which is a composite index of life expectancy,
literacy and income, has been determined by the Human Sciences Research Council for a
number of districts in the Eastern Cape. This index gives a good overall picture of the state of
development and the standard of living in an area. The value of the HDI varies between a
maximum of 1, indicating the highest level of human development, and a minimum value of
0. The Eastern Cape’s HDI was measured at 0.51 in 1991, an improvement from the 0.42
measured in 1980. This is South Africa’s second lowest HDI after the Northern Province and
captures the extent of poverty and deprivation in the province (South African Competitiveness
Monitor 1996, Provincial Comparison. WEFA Group In: Tren 1999). The HDI for Port
Elizabeth’s disadvantaged black community is 0.32 while the HDI for the white community is
0.94. Human Development levels of 0.90 and above equals the top 25 countries in the world.
The HDI of 0.32 is on a par with Rwanda at 0.33 (CEN 2000).
8.3 THE SUB-REGIONAL SOCIAL AND ECONOMIC ENVIRONMENT
8.3.1 SOCIO-ECONOMIC PROFILE

While the regional benefits of the successful implementation of the project should not be
overestimated, there is some potential for the Coega project as a whole to have negative local
impacts. These manifest themselves in the disruption of existing social networks and modes
of livelihood.
Current land use patterns in the port area indicate that the number of people likely to be
directly affected by the development of this aspect of the infrastructure is relatively low. At
present the port area and immediately adjacent land area that will fall under the Port Authority
is owned by private farmers and includes the communities located on the former King
Neptune Resort. It is estimated that there are 45 households in the greater port area (Table
8.3a). A further 43 households are located at Salnova, immediately to the north of the national
road. These communities, although adjacent to the port, are outside of the immediate area of
concern. The distribution of households within the port area is illustrated below.
Table 8.3a: Distribution of households.
Area Number Percentage

Hougham Park I (Crews) 10 22.2%
Swartkoppen (Potgieter) 1 2.2%
King Neptune 32 71.2%
Marine Growers 2 4.4%
Total 45 100.0%
144 Chapter 8: Socio-economic Description

The Coega Development Corporation commissioned a study to establish a baseline on the

prevailing social, economic and health conditions of people residing in the Coega
Development Zone. The purpose of that study (Rossouw et al. 1999) was to enable the
Implementing Authority to establish a baseline so as to be able to track changes that could be
attributed to the implementation of the project. This study has been further summarised in
CEN (2000).
The following information, extracted from the reports by Rossouw et al. (1999) and by CEN
(2000), illustrates selected social information for the area defined as the port.
According to CEN (2000), among the 45 households in the defined area, thirty-six households
(80%) are headed by males, with the remaining 9 (20%) being headed by females. Rossouw et
al. (1999) point out that households headed by a single head are typically disadvantaged in
terms of financial and social terms when compared with households headed by both a male
and a female household head. This is typical of households within the context of the
developing world, as better paid employment opportunities tend to be concentrated in the
hands of men and households are typically, although not inevitably, structured around the
primary breadwinner.
Almost 49 percent of the household heads are in the 35 to 49 year age group. Thirty-three
percent of the household heads are between 50 and 69 years of age. Eleven percent of the
household heads are younger than 29 years of age and almost 7 percent of the household
heads are older than 70 years of age. A population growth rate is difficult to predict. The
report entitled “Initial Social Assessment of the Proposed Coega Industrial Development
Zone and Port” (UPE 1997) indicates that Motherwell may well be growing at about 4.5% per
annum but that this is a very high growth rate. Other areas have growth rates as low as about
0.2% per annum.
The total population of the households resident within the port is 146 persons, giving an
average of 3.2 persons per household. The table below (8.3b) indicates the relationship of the
various community members.
Table 8.3b: Composition of households.
Relationship to Household Head Number Percentage

Head 45 30.8%
Spouse 29 19.9%
Child 45 30.8%
Parent 0 0.0%
Parent- in-law 0 0.0%
Grand child 11 7.5%
Other family 16 11.0%
Not family 0 0.0%
Total 146 100.0%
Perhaps the most critical data relates to the income available to the households and to
employment trends. In the area classified as port, 38 percent of the household heads are
employed on a full time basis, 27 percent on a part-time basis and 22 percent of household
heads are pensioners. Approximately 13 percent of the household heads are unemployed.

Sixty percent of the household heads obtain their income from salaries and wages, 13 percent
from old age pensions and 4 percent from their own business. Thirteen percent receive
disability and welfare grants and 9 percent no remuneration at all.
Of importance is that almost 42 percent of the household heads are employed within the area
covered by the proposed development zone. A further 10 percent are employed in the St
George’s Strand area and a further 14 percent are employed in the neighbouring Motherwell
and Markman industrial area. Fifty two percent of the household heads are employed either
within the area defined as development zone or within close proximity to their place of
residence. The income sources available to the household heads are outlined in Table 8.3c
below.
Table 8.3c: Source of income of household heads.
Source of Income for Household Heads Number Percentage

None 4 9.0%
Salaries & Wages 27 60.0%
Own Business 2 4.4%
Old Age Pension 6 13.3%
Maintenance 0 0.0%
Disability & Welfare Grant 6 13.3%
Interest on Investment 0 0.0%
Total 45 100.0%
The CEN (2000) report confines its study to the household heads. Rossouw et al. (1999)
looked at the general population in the Coega IDZ. According to their report, the
unemployment level among the employable sector of the community in the Coega IDZ area is
high, with only 18.1% having full- time employment and 30.8% of the community
unemployed. Interestingly this is lower than what is regarded as the provincial average. The
remainder have some form of income, or are students, scholars, pensioners, medically unfit
and housewives. Of those members of the community who are employed, a high number work
within the Coega IDZ (53.5%). A further 26.8% work in the immediate vicinity, including St
George’s Strand, Motherwell, Markman industrial area and Bluewater Bay.
Seventy-six percent of all earners have an income of less than R1 000 per month. The
majority of households have a disposable 20 income of between R100-R200 per month, while
some have a negative disposable income (<6%). Very little saving was detected in the
community.
Pension, welfare grants and disability grants are the main source of income for 5.9% of the
population in the Coega IDZ. Salaries and wages form the biggest source of income in this
community. This, and the fact that many people work within or in close proximity to the
Coega IDZ, implies that changes in the area need to consider how the employment situation
of these people may be affected, and alternative employment will have to be considered if
these people cannot be accommodated.
According to CEN (2000), of importance is that 66.4 percent of the household heads have
been resident in the area for longer than 10 years. Only 33.6 percent of the households have
been resident in the area for less than 9 years. As such a high degree of community stability
20
Disposable income is the total household income minus the total expenditure on essential commodities.

has been generated and homesteads are generally well established According to Rossouw et
al. (1999), the majority of dwellings are permanent structures and are in a reasonably liveable
condition. Dwellings are constructed out of a variety of substances, e.g. brick, mortar,
corrugated iron, wood, clay, manure and bricks (Plate 8.3a). Although liveable, more than half
the dwellings were found to have no ceilings, which is associated with weak insulation and
therefore ineffective in keeping out extreme cold or hot.
Given the degree of community integration, the issue of resettlement is likely to be a sensitive
one. As such “best practise” should be employed in terms of dealing with this issue. The best
guidelines for resettlement are those employed for World Bank projects. The major tenants of
these guidelines are the following:
• Involuntary resettlement should be avoided or minimised where feasible, exploring all
viable alternative project designs.
• Where displacement is unavoidable, resettlement plans should be developed. All
involuntary resettlement should be conceived and executed as development programmes,
with resettlers provided sufficient investment resources and opportunities to share in
project benefits. Displaced persons should be (i) compensated fo r their losses at full
replacement cost prior to the actual move; (ii) assisted with the move and supported
during the transition period in the resettlement site; and (iii) assisted in their efforts to
improve their former living standards, income earning capacity and production levels, or
at least to restore them. Particular attention should be paid to the needs of the poorest
groups to be resettled.
• Community participation in planning and implementing resettlement should be
encouraged. Appropriate patterns of social organisation should be established, and
existing social and cultural institutions of resettlers and their hosts should be supported
and used to the greatest extent possible.
• Resettlers should be integrated socially and economically into host communities so that
adverse impacts on host communities are minimised. The best way of achieving this
integration is for resettlement to be planned in areas benefiting from the project and
through consultation with the future hosts.
• Land, housing, infrastructure and other compensation should be provided to the adversely
affected population. The absence of legal title to land by such groups should not be a bar
to compensation.
Plate 8.3a: The old mission school settlement below Coega Kop.

Although the CEN (2000) report does not consider some of the other socio-economic aspects
of the population in the defined port area, Rossouw et al. (1999) consider the wider
population in the IDZ. The information provided for this population group may be
extrapolated to those in the port area, as the profiles are very similar.
From this study it may be deduced that Xhosa is the most important language of the people in
the area. According to Rossouw et al. (1999), Xhosa is the home language of 54.4% of the
people residing in the IDZ area, with 43.6% being Afrikaans. Other languages spoken include
English and Sotho, although less than 2% of the population regard these as home languages.
Of the 1 221 people living in the proposed Coega IDZ, more than 50% of the population is
functionally illiterate. The level of education in the Coega IDZ is similar for male and females
and is generally low, and the functional literacy rate needs to be improved. Almost half the
household heads (49.4%) have a level of education below grade 7 and can therefore be
classified as functionally illiterate. Only 13.2% of the household heads have a level of
education of grade 10 or above.
Within communities of this nature, roles and responsibilities are clearly defined along gender
lines. These definitions are rooted in people’s history and culture and, although sometimes
challenged in the urban areas, remain strongly intact. Women are responsible for the
reproduction of the household through low paid employment, child-rearing and domestic
activities. Men remain dominant in the organisation of civil society and are seen to be the
major breadwinners – even if only potentially.
8.3.2 SERVICES
For the population in the greater area there is at present water available from the Orange River
Scheme. The groundwater source currently in use within the area is the Uitenhage Artesian
System. This is one of the few artesian systems in southern Africa, and the only one of
practical importance. Part of the Coega IDZ lies over the Coega compartment of this system.
To date, industries have not impacted negatively on this groundwater resource (CSIR 1997).
The majority of households in the area have a water supply within 100m of them. Upgrading
of the water supply appears to be an issue for the community according to Rossouw et al.
(1999).
The city of Port Elizabeth currently disposes its general, non-hazardous waste at two solid
waste disposal sites. One of these sites, the salt pan near Struandale industrial area, serves the
eastern part of Port Elizabeth. However, this site has been ordered to be closed by the
Department of Water Affairs and Forestry. The other disposal site is at Arlington and it serves
the northern, central and western portions of Port Elizabeth.
The Arlington site is in the process of permit application for continuing operation (CSIR
1997), as peri- urban areas (including those within the port area) do not have the same levels
of service found in urban areas. As such the majority of the households burn their refuse,
while others take their refuse to a refuse site (10.1%), leave it as is (6%) or have a refuse
disposal service (6%) (Rossouw et al. 1999).
According to Rossouw et al. (1999), there is a lack of acceptable toilet facilities in the
households in the Coega IDZ area and this is a source of concern for the community. Some
households have no sanitation facilities (30.9%), others have pit toilets (38.9%), bucket toilet
systems (14.8%) and the rest have flush toilets (either septic tank or waterborne sewerage).

In general, ho useholds spend very little on fuel, with the exception of paraffin, which is the
most widely used energy source among households in the proposed Coega IDZ. Paraffin is
used for lighting, heating (water and household) and cooking. Electricity and candles are other
major fuels for lighting, and electricity is also used for heating and cooking. Wood is also
used by a number of households for cooking and heating.
The Coega area is serviced by the N2 national road, secondary roads and gravel roads. The
N2 is the major road link along the east coast and serves an important function in the
economy of the Eastern Cape region, facilitating the movement of commercial, industrial,
tourist and commuter traffic within the Eastern Cape. The N2 was designed to carry heavy
traffic and is in good condition. The old Grahamstown road (R435) within the Coega area
provides a linking road from the N2 for traffic travelling to Uitenhage. This road now mainly
serves the rural community in the Coega area and is in a fair condition. The Addo road (R450)
is the main access road for traffic from the Addo and Kirkwood agricultural hinterland to Port
Elizabeth. This road also provides access to Motherwell Residential Township and the
Markman Industrial Township. The R450 was constructed to carry heavy industrial traffic and
is still in good condition. The Coega-Uitenhage road (R460) carries traffic between Coega,
Motherwell and Uitenhage, and is in poor condition (CSIR 1997).
The main railway line from Port Elizabeth enters the Coega IDZ on the seaward side of
Markman Industrial Township, which is served from the Aloes Railway Station. Spoornet
stated that the maximum capacity for trains to and from Port Elizabeth on this line is 54 trains
per day (CSIR 1997).
The community is highly dependent on public transport. Taxis are the most commonly used
mode of transport (39.9%) in the Coega IDZ area. Other modes of transport include private
transport (27.5%) and buses (26.2%). Trains and bicycles are hardly ever used (Rossouw et
al. 1999).
The IDZ and the proposed port will reduce access to important commercial and recreational
fishing grounds and adjacent recreational areas. Of particular importance is Joorst Park.
According to CEN (2000), Joorst Park and St George’s Strand are popular recreation areas
serving the communities of north eastern Port Elizabeth. Joorst Park is adjacent to the area
covered by St George’s Strand/Wells Estate Coastal Structure Plan. According to the
Structure Plan, this area should be earmarked for recreational uses.
The coastline abutting the Joorst Park Resort (Plate 8.3b) is primarily a sandy beach area with
no significant rocky outcrops until approximately 1 kilometre north of the Coega River
mouth. Previous studies have indicated that the area is representative of an unpolluted coast,
reflecting the designated “beneficial uses”, namely natural environment and recreation.
The Joorst Park Resort provides camping, caravan, chalet and bungalow accommodation. The
resort contains 15 bungalows and 49 chalets, each sleeping six persons (384 bed nights). The
resort contains a parking lot with a path leading over the dunes to the beach. Outside the
resort a road leads through the dunes to a second parking lot, which is located directly on the
beach. Access to the dunes is unrestricted.
The resort also contains a community recreation hall and a restaurant. A swimming pool is
located close to the parking lot. Children’s play equipment is also provided within the resort.

Plate 8.3b: A view of the resort area at Joorst Park.
8.3.3 HEALTH PROFILE

The community in the proposed Coega IDZ area appeared to be healthy, but it was found by
Rossouw et al. (1999) that children were inadequately nourished (13.8%) and some were
severely malnourished (5.2%).
The most common diseases encountered in the area are mostly related to shack dwelling,
including tuberculosis (11.7% of households in the proposed IDZ suffer from this disease),
measles, meningitis, typhoid and gastro-enteritis (CSIR 1997). Within the Coega IDZ, the
bacteria Yersnia perstis is endemic. This bacteria is currently in a passive state and is being
monitored by the Department of National Health. Fleas carried by rats and mice transmit the
disease, and some species of wild rodents that occur in the Coega IDZ are potential carriers
(CEN 1997).
8.3.4 EXISTING ECONOMIC ACTIVITIES

In addition to an impact on communities within the area, there will also be an impact on
existing economic activities. Existing economic activities within the port area include the salt
works (Plate 8.3c) and farming operations. It is anticipated that the construction of the port
will have a high impact on the operations of the salt works. The salt works management have
indicated that they do not believe that they will be able to continue with the production of salt
for human consumption if the port proceeds. If the salt works closes or shuts down for the
duration of the construction period, about 100–140 jobs will be lost. The Coega Development
Corporation has stated that it would implement a policy that would ensure that no family
would be worse off as a result of the proposed developments. Implementation of this policy
will assist in reducing the impacts associated with a move.

Plate 8.3c: An aerial view of the Coega Salt Works.
A further concern is the Marine Growers Abalone Farm (Plate 8.3d); although this farm does
not fall directly in the port area, it may be impacted on by the port operation. Marine Growers
is located 2km northeast of the Coega River mouth and the proposed Ngqura Port (Common
Ground 2001). The area below the high water mark in the vicinity of the farm would fall
under the port limits (Government Gazette No. 19401 of 28 October 1998), allowing the Port
Authority to control all shipping and other activities in this region. Abalone farms by nature
take three to four years to become operational, and Marine Growers has recently reached this
stage, exporting its product overseas and producing abalone seed for other South African
farms. The Ngqura Port and IDZ may impact on Marine Growers in several ways, including a
deterioration in water quality, pollution associated with shipping accidents and illegal
dumping, importation of alien pathogens, accumulation of biocides such as TBT and
inundation of the farm’s seawater intake systems (Common Ground 2001). The possibility of
these impacts will also result in the loss of investor confidence and a doubt over the quality of
the product in markets. The CDC and Port Authority have investigated two possible
scenarios, either relocation of the farm or buyout and closure/continued operation. The
continued operation of the farm is preferable, as between 29 and 59 21 jobs are at stake,
although the CDC policy to ensure that no family is worse off due to the developpment should
go a long way to mitigate against the farm’s closure.
It is also expected that commercial farmers in the greater project area will be affected. While
loss of land may be mitigated through fair compensation, there are concerns that have been
expressed by these farming communities regarding the wider impact of the project. According
to UPE (1997), farmers are concerned about:
• The potential influx of workers into the area and the impact that this could have on the
security situation.
• Possible disruption of the labour force and loss of labour to short term construction
opportunities, which may pay higher wages in the short term but negatively affect labour
stability.
21
The exact number of employees varies according to source. The Common Ground report indicates 29
permanent staff but Mr Muller (Director of Marine Growers) indicated in personal communications with CES
that 59 people are permanently employed.

Plate 8.3d: Some of the grow-out tanks at the Marine Growers Abalone Farm.

CHAPTER 9:
SOCIO-ECONOMIC IMPACTS
AND MITIGATION
9. SOCIO-ECONOMIC IMPACTS AND MITIGATION
9.1 INTRODUCTION
The key issues identified in the socio-economic study can be divided into those with an economic
basis (Issues 1 – 4) and those with a predominantly social basis (Issues 5 – 14). The issues have not
been divided into separate sections according to the two dominant phases of the project
(construction and operational) as socio-economic issues do not often lend themselves to separation
on these grounds. Individual impacts can be orientated around certain phases and where this is the
case, it has been clearly stated. Readers are reminded that the economic issues discussed in this
report relate to the port and container terminal only and not to the Coega IDZ as a whole. The
economic implications of the proposed IDZ e.g. employment, direct and indirect economic
implications etc. are not discussed and fall outside the scope of this, the Subsequent Port EIA.
A range of reports were considered in the formulation of the issues outlined below but the most
informative texts were the Coega Rezoning EIA (CES 2000); the Revised Port EIA (CEN 2000);
various cultural sensitivity reports (Binneman & Webley 1997, Binneman 1998); the social impact
studies/surveys conducted by the Institute for Planning and Research – University of Port Elizabeth
(1997, Rossouw et al. 1999) and the Economic Cost Benefit study completed by MERIT (2001).
All monetary values, unless stated otherwise, are from the cost benefit analysis conducted by
MERIT and include the costs and benefits associated with expanding the port to meet the predicted
demand in containerisation traffic until 2019 (see Specialist Studies Series – Part 2).
The issues covered in this report are:
ISSUE 1 – EXPANSION OF THE SKILLS BASE

ISSUE 2 – DIRECT AND INDIREC T ECONOMIC IMPLICATIONS
ISSUE 3 – THE ABILITY OF THE PORT TO ACT AS A CATALYST FOR GROWTH
ISSUE 4 – IMPACT ON EXISTING BUSINESSES
ISSUE 5 – RESETTLEMENT
ISSUE 6 – DISRUPTION OF GRAVES
ISSUE 7 – CHANGES TO SOCIAL SYSTEMS AND STRUCTURES
ISSUE 8 – CLOSURE OF RECREATIONAL FACILITIES
ISSUE 9 – VISUAL IMPACTS OF THE PORT AREA
ISSUE 10 – INFLUX OF PEOPLE TO THE AREA
ISSUE 11 – AIR EMISSION IMPACTS ASSOCIATED WITH CONSTRUCTION TRAFFIC
ISSUE 12 – NOISE, AIR AND LIGHT POLLUTION
ISSUE 13 – SITES OF HISTORICAL OR CULTURAL INTEREST
ISSUE 14 – IMPACT ON THE PROPOSED GREATER ADDO NATIONAL PARK
9.2 ECONOMIC IMPACTS
9.2.1 BACKGROUND
The justification for the establishment of the Port of Ngqura at Coega depends upon the extent to
which the ensuing stream of benefits 22 will exceed the cost of the resources needed for its
construction and operation. These benefits must stem from the new cargo to be generated by the
location and specific features of the port, and from the savings in the use of resources which will be
achieved by the import or export of cargo that otherwise would move through ports elsewhere. A
22
The benefits and costs associated with the port include both social and economic aspects.
Chapter 9: Socio-economic Impacts and Mitigation 153

detailed cost benefit analysis (MERIT 2001) was conducted on the proposed port and can be found
in Part 2 of the Specialist Studies series. This report clearly out lines all the associated costs and
benefits associated with a range of port expansion options in South Africa.
In the revised EIA on the Ngqura Port (CEN 2000) it was stated that for the port to be feasible, it is
critical that sufficient volumes of cargo are generated by the industries in the IDZ and other bulk
product exports from inland. However, in the economic study undertaken for this, the subsequent
EIA, no bulk or breakbulk cargo for the port could be positively identified, although a variety of
potential cargoes mentioned in previous studies were considered. None of the schemes involving
the import or export of bulk commodities through the port by enterprises interested in establishing
industries in the Coega IDZ have resulted in a firm demand for its use. Furthermore, no reports or
other literature could be traced indicating the existence of deposits of ores or minerals in the
hinterland of the port that could be exported profitably. In any event, none of volumes of potential
bulk traffic mentioned in previous reports would be sufficient to justify the expense of building and
operating the port.
In the absence of a firm demand for the port from investors in primary industries, economic
justification for its establishment is limited to the function that it could fulfil within the South
African commercial port system. Again, there appear to be no bulk or breakbulk cargoes moving
through other ports that could be diverted through the proposed port without wasting resources or
negatively impacting on those ports. An in-depth analysis of future trends in containerisation, as
well as present and future capacities in other South African ports to handle the projected growth
did, however, indicate that a new container terminal is required within South Africa’s port system
(MERIT 2001). The only feasible location for such a terminal at one of the existing ports within the
requisite timespan is in the port of Richard’s Bay. The proposed Port of Ngqura provides an
alternative location to that of Richard’s Bay.
The economic study consequently investigated and compared the costs and benefits of constructing
the basic infrastructure required for the Port of Ngqura. A number of alternatives were assessed,
which involved various combinations of developments at Richard’s Bay and Durban. The results of
the economic analysis indicated that the construction of the Port of Ngqura and development of a
container terminal is economically justified and the preferred option23 . The results indicated that the
cost benefit ratios of the alternatives varied between 4.4 and 3.1 and the Internal Rate of Return
ranged between 1.04 and 1.30. It must be noted that in projects where substantial capital costs are
incurred in most years throughout the evaluation period, high Internal Rates of Return cannot be
expected.
The proposed container terminal at the port will serve mainly Gauteng, and the containers will have
to move through the port and terminal with the minimum of delay in order to reduce the cost effect
of the longer distances of inland transport, when compared with Gauteng traffic moving through
Durban. The main benefit stemming from the provision of a container terminal at Coega includes
savings for liner operators because ships from the West can be turned around earlier instead of
proceeding to Durban. Savings for cargo owners will also be accrued as containers will reach
destinations in Gauteng sooner than via Durban.
Some container traffic could be generated by industries in the Coega IDZ, but that is unlikely to
exceed 2% of the total throughput in 2019/20, which in any event could be handled at Port
Elizabeth. In effect, the development of the container terminal could be independent of the
development of the Coega IDZ. However, the provision of the port infrastructure for the purpose of
accommodating the terminal will enable berths for other purposes to be built and equipped at their
23
The economic justification was for the basic infrastructure and container terminal and does not include the costs of
the breakbulk and bulk berths.
154 Chapter 9: Socio-economic Impacts and Mitigation

marginal cost, in order to meet the demand for bulk and breakbulk imports and exports as the Coega
IDZ develops.
As the construction of the port will require foreign contractors to undertake the dredging, and the
breakwaters must necessarily be constructed in a capital intensive manner, not much of the
expenditure will enter the local economy. The container terminal will also be constructed in a
capital intensive manner while the cranes and most of the other equipment will be purchased
overseas. Thus, the project will result in a substantial outflow of foreign exchange. Nevertheless, it
is estimated that during each of the ten years in which construction will take place, some R233
million will be contributed to the gross regional product of currently R17.5 billion in the Port
Elizabeth – Uitenhage area.
The operation of the port for the purposes of the container terminal is unlikely to contribute much to
the local economy, as it will no doubt be operated at the outset as an adjunct to the existing port at
Port Elizabeth. However, the operation of the container terminal could result in the employment of
some 1 600 skilled and semi-skilled personnel by 2019/20 and their contribution to the local
economy at a multiplier of 2.27 is likely to be about R229 million in that year, at current prices 24 .
Furthermore, the functioning of the terminal will also require the services of firms concerned with
shipping and cargo services and although these services are likely to be supplied from Port
Elizabeth at the outset, the increase in container throughput will no doubt induce firms to establish
branches at or relocate to Coega. Most of the containers will be moved by rail to and from Gauteng
in order to save transport costs, but some will be carried by road in several hundred vehicles daily,
which will result in a local demand for vehicle maintenance, accommodation, food and
entertainment.
In conclusion, the establishment of the port and container terminal at Coega to accommodate the
needs of future South African containerisation means that its economic justification is independent
of both the Coega IDZ25 and the diversion of traffic from other ports.
9.2.2 KEY ECONOMIC ISSUES
ISSUE 1: EXPANSION OF THE SKILLS BASE

Impact 1 - The regional expansion of the skills base
Cause and comment
The Eastern Cape is a poor province with high unemployment, and associated with this there is a
limited skills base that is primarily centred around the motor vehicle industry. The expansion of the
skills base in the region is thus a high priority and any large project that uses state funding should
aim to produce as many jobs as possible. The construction of the port and associated infrastructure
will be capital intensive and foreign contractors will be used for dredging and the installation of
some equipment. Direct employment will depend upon the technique of construction and terms of
the contract, but direct employment is likely to be low. Initial figures indicate that the initial
construction will take up to 36 months and that at the peak, 800 people will be employed (See
Chapter 3). However, it is hoped that the fairly long construction period will be used to equip
aspirant emp loyees from the Eastern Cape with the requisite skills through training programmes,
and that the need to recruit staff in other centres or overseas will be limited.
24
The values quoted in the economic appraisal assume that the port will be expanded to include additional berths (See
Merit 2001 in the Specialist studies series – Part 2).
25
While the port can be economically motivated for independently of the IDZ, this does not mean that it should be
developed at Coega if the Coega IDZ is not developed, as other options for additional port infrastructure e.g. Richards
Bay do exist.

In terms of operating the container terminal it is likely that the concessionaire will be required to
employ at least 350 persons at the outset, of which 20 will be unskilled and drawn from the ranks of
the unemployed. Provision will also be required for training in order to create skills. Nevertheless, it
must be assumed that the majority of the 330 skilled workers will be recruited among the currently
employed in the domestic labour market. If the port and container terminal is a success and more
berths are opened, employment could rise to about 1 600 people at the terminal and 200 at the port
by 2019.
In terms of the capital investment required by the project, it is envisaged that the overall impact on
the skills base will be low. In terms of the overall Coega project it should be noted that the
expansion of the skills base is not expected to come from the infrastructure development such as the
port but from the industries in the IDZ. The numbers of jobs created and the expansion of the IDZ
will be dependant on the overall success of the IDZ.

Port Authority Division (PAD), CDC and any concessionaire must be required to invest in training
programmes and the construction contracts should, where possible, require labour intensive
techniques to be used. Recruitment policies were possible should favour local people and training
programmes that result in the phasing out of any expatriate expertise must be implemented.
It is probable that there will be a limited expansion of the skills base at the metropole and regional
level. This expansion will be slightly beneficial in the medium to long term. Optimisation involves
training local people, which may increase the beneficial nature of this impact. The overall
environmental significance of this impact will be LOW (positive).
ISSUE 2: DIRECT AND INDIRECT ECONOMIC IMPLICATIONS

Impact 1 - Direct economic impacts during the construction phase
Cause and comment
The construction of port infrastructure and development of the terminal will involve dredging and
the acquisition of equipment that will result in an outflow of currency (estimated at R2 548 million
at current prices) to foreign suppliers, and this expenditure will not benefit the local community.
Most of the work on the construction of the breakwaters and quay walls, as well as the surfacing of
the stacking areas, will be capital intensive and the employment, especially of unskilled workers,
will be limited. Much of the other work in the development of the stacking areas, especially the
installation of services and building construction, will be labour intensive, although most of the
expenditure will be on materials, of which some will be imported.
Notwithstanding the substantial amount to be spent on building the port and the container terminal,
both new employment and the multiplier effect in the local economy are likely to be low within the
context of the capital expenditure required. However, the development of the terminal will continue
with some interruptions over sixteen years, which should render the effect enduring. It is estimated
that of the R3 573 million required to develop the port infrastructure and terminal until 2019/20,
some R1 025 million will be spent locally at an average annual rate of R102.5 million during the
years that construction takes place. By applying a multiplier, the construction of the port could
contribute R233 million on average during those years to the regional economy, which is
insignificant in comparison with the gross regional product (R17.5 billion) of the Port Elizabeth –
Uitenhage area (MERIT 2001).
The construction of the port will definitely result in a slightly beneficial impact in the medium term
on the economy of the metropole. Limited optimisation can be implemented and the significance of

this impact will be LOW (positive).
Impact 2 - Direct economic impacts during the operational phase

Cause and comment
The operation of the terminal could contribute up to R229 million to the local economy in 2019/20.
Not much of that amount is likely to be saved apart from pension contributions and endowment
insurance premiums. Allowing for such savings, PAYE, other deductions from salaries and wages
and direct leakages, about R151 million is likely to be spent locally. Applying a multiplier of 2.27,
which is similar to that estimated for expenditure by port employees in Cape Town, the net effect
will raise the gross regional product by some R343 million at current prices, which will make only a
small contribution to the gross geographic product currently estimated at R17.5 billion in the Port
Elizabeth – Uitenhage area.
In terms of the national fiscus, if the container terminal is utilised on a concessionary basis it is
likely that the majority of the profits will be taken offshore and will not be spent in South Africa.
Another characteristic of the costs and benefits associated with ports is that they mainly accrue to
other participants in the trade rather than the Port Authority and thus the direct economic
implications for the Port Authority is probably low.
The operation of the port and container terminal will definitely result in a slightly beneficial impact
in the long term on the economy of the metropole. Limited optimisation can be implemented and
the overall the significance of this impact will be LOW (positive).
Impact 3 - Indirect economic impacts during the construction and operational phases
Cause and comment
Apart from direct employment, the operation of the terminal will require various material inputs,
but these are mainly power, fuel and spare parts, which will be imported into the region. Thus their
production will not constitute a regional benefit, although payment will no doubt be made to local
agents, which will have a slight multiplier effect. The main regional benefit from the establishment
of the port and terminal will be the indirect employment in many industries concerned with the
import and export of cargo as well as the transport of containers inland, and employment in the
industries likely to be attracted to the IDZ at Coega because of its proximity to the container
terminal. However, these benefits will only be realised quite far into the future, as virtually all the
services associated with shipping imports and exports are already being supplied at Port Elizabeth
and some spare capacity no doubt exists to extend that supply to Coega at the outset.
In general, there can be no doubt that the development of the container terminal will create at least
two to three thousand new job opportunities in the maritime industry at Coega/Port Elizabeth by
2019/20 and add indirectly to other employment. Remuneration will stem directly from the income
generated by the growth in imported and exported cargo and not from income redistributed from
other areas (MERIT 2001).

The optimisation of the indirect economic impacts of the proposed port and terminal can be assured
through the identification and support of small industries and businesses in the Port Elizabeth
metropole area that can provide the required services.
Secondary industries that service the needs of the port and container terminal will definitely result
in a beneficial impact in the long term on the economy of the metropole. This impact can be

optimised through the identification and support of small businesses in the Port Elizabeth metropole
region. The overall the significance of this impact will be MODERATE (positive).
ISSUE 3: THE ABILITY OF THE PORT TO ACT AS A CATALYST FOR GROWTH

Impact 1 - The impact of the port and container terminal on the Coega IDZ
Cause and comment
The CDC have stated that the Coega IDZ has been plagued by a chicken and egg scenario for a
number of years as no large industry would locate or commit to locating to the IDZ until the
required port infrastructure is in place, notwithstanding this it is pragmatic not to build a port until
you know that it will definitely be used. The CDC now maintain that the port should be seen as
enabling infrastructure that should be put in place if economic growth within the IDZ is to be
stimulated.
The economic cost benefit study (MERIT 2001) indicated that the existence of the port and
container terminal will not depend to any extent on traffic generated by the IDZ, although such
traffic may eventually add to the throughput. The number of containers that will arise from
industries in the IDZ in 2019/20 is projected to amount to only 2.0% of the container moves in that
year. In short, the port and container terminal are an economically feasible option without any input
from the IDZ. Notwithstanding this economic independence, the construction of a port and
container terminal will probably attract industries that can utilise the container terminal, and in this
manner the port and container terminal will have acted as a catalyst for growth within the IDZ.
The framework plan for the IDZ indicates that there will be a number of industries that will require
and produce break and breakbulk cargoes and thus berths able to handle this type of cargo are
required in the port. However, the economic study indicated that at present there is no need to build
a breakbulk or bulk terminal in the port, as these structures could not be economically justified
since no new throughput could be identified for them. The existence of the basic port and the
container terminal, as well as tax concessions or other subsidies that are likely to be granted by the
Government in the near future could, however, attract new industries to the IDZ. Certainly, the
marginal cost of adding bulk or breakbulk berths to the port should stimulate these types of
industries to locate in the IDZ.
While the provision of the port infrastructure and container terminal is independently warranted and
additional bulk and breakbulk berths can be added to the port at limited cost, the success of the IDZ
will be due to other factors such as location, tax concessions and labour. What should be noted is
that neither the port nor the IDZ are well located in relation to large markets or sources of raw
materials and it can readily be shown that the transport costs, including transhipment costs, for the
producers of bulky goods will impose a substantial penalty in delivered prices. Furthermore, the
prospect of attracting so-called footloose industries from abroad to the IDZ is hampered by the
labour and tax regimes, which are far less friendly than those of competing industrial development
or export processing zones elsewhere in the Indian Ocean Rim. No detailed feasibility studies
comparing the financial benefits and costs of location in the IDZ at Coega with location in
competing zones for particular industries are available, or have not been released, and without such
information, predictions of the development of the IDZ are difficult to quantify.
The provision of basic port infrastructure and a container terminal will probably stimulate
industries requiring containerisation to locate to the IDZ in the long term. The marginal cost of
adding breakbulk and bulk berths will possibly induce heavy industry to locate in the IDZ but other
factors such as labour, taxes and location will probably play a bigger role. The overall significance
of the impact that the provision of the port will have on stimulating growth in the IDZ is speculative
and will be UNKNOWN until the studie s outlined above are undertaken or made available.

Impact 2 - The impact that the Ngqura Port may have on other South African ports
Cause and comment
The provision of the basic port infrastructure and a container terminal has been shown to be
economically warranted without requiring the rerouting of existing containers from other ports
(MERIT 2001). The establishment of the container terminal will, however, result in a disturbance in
the containerisation industry in the short term as additional capacity comes on line and the industry
restructures. In the long term, however, the predicted growth in container traffic should result in
sufficient traffic for all existing operations.
At present the building of the breakbulk and bulk berths will, however, require the rerouting of
traffic from other ports to make their provision justifiable. If the breakbulk and bulk berths are built
prior to any traffic materialising from the IDZ and traffic was rerouted from existing harbours, the
impact on these harbours could well be high.

The proposed breakbulk and bulk berths should only be commissioned once definite traffic for these
berths has been established. If industries are serious about locating to the IDZ, then the provision of
the basic port infrastructure and container terminal, in conjunction with the fact that any further
berths will be at a marginal cost, should be sufficient to secure their tenure.
The building of a container terminal will possibly have a slight negative effect on some container
terminals in South Africa in the short term (e.g Durban) but probably no effect in the long term.
The building of the proposed bulk and breakbulk berths will probably have a severe to moderately
severe impact on the economic viability of some of the ports if no throughput is found or generated
by the IDZ. The overall significance of these national level impacts will be NONE for the former
scenario (in the long term) and MODERATE (negative) for the latter.
Impact 3 - Specific impacts on the Port Elizabeth Port

Cause and comment
Negotiations between the PAD and the CDC’s preferred private partner P&O Nedloyd regarding
the operational and financial agreements concerning the operation of the Port of Ngqura have not as
yet been finalised. Until these negotiations are finalised, it is difficult to evaluate the specific
impacts of the Port of Ngqura on the existing port at Port Elizabeth as the manner in which the two
ports are managed and rationalised will be significantly influenced by the agreement reached
between PAD and P&O Nedloyd. Obviously having two ports in the bay will result in new market
forces, which in conjunction with possible exclusive use agreements will result in changes
regarding who docks where and what cargoes are handled in the respective ports.
The container terminal at Port Elizabeth currently employs 309 people and any changes in the
containerisation traffic that jeopardise these jobs could be a severe impact on Port Elizabeth, as
would job losses associated with the rerouting of any breakbulk/bulk cargos.
In terms of assessing the impact of the Ngqura container terminal being operated exclusively it
should be noted that this does not preclude other carriers from continuing to utilise the Port
Elizabeth terminal. In future, the Port Elizabeth harbour could also concentrate on specific sectors
e.g. the automotive industry and the existing container facility should also benefit from the
projected increase in the overall containerisation traffic in the country.
While the viability of ventures such as waterfront development have still to be demonstrated for the
Port Elizabeth harbour, other land use options for the area should not be discounted.

The exact impact of the Ngqura Port on the Port Elizabeth Port will remain unclear until the final
operational structure of the Ngqura Port is established between PAD and P&O Nedloyd. What is
known is that if this operational agreement results in the closure of the Port Elizabeth container
terminal or reroutes significant components of the existing operation, resulting in the loss of jobs
and economic externalities then there may be a long term severe impact of HIGH 26 significance on
the Port Elizabeth metropole, assuming that no alternate land use option or shipping trade, which is
economically equivalent to the present land use, is found.
ISSUE 4: IMPACT ON EXISTING BUSINESSES 27
General comment
The principal aim of the Coega IDZ is to stimulate growth in the Eastern Cape and thus any loss of
jobs in establishing the IDZ must be viewed in a serious light as it detracts from the overall
objective. There are a number of industries which may be directly negatively affected by the
establishment of the port. These industries are Marine Growers, which is an abalone farm; National
Salt, which operates a salt production and processing operation in the Coega Estuary; and the
offshore recreational and commercial fishery. It is the policy of National Government to acquire the
land for the IDZ on a “willing buyer/willing seller” principle.
However, since the Coega project is of national importance, Government retains the right to
expropriate land in the national interest. If the land is expropriated, then the land must be held by
Government and cannot be sold freehold to developers. If the expropriation route is followed, it can
be generally assumed that the willing buyer/willing seller approach did not succeed and the real
impact of this course of action on the land owner is difficult to assess. The option of challenging
any expropriation in court will be available to the land owner.
The manner in which the relocation or buyout of the various businesses is handled has significant
implications for the present stakeholders in the businesses: CDC, PAD, Transnet shareholders and
the South African taxpayer. The way forward on the acquisition of these businesses should be
mutually agreed upon as this will limit the negative impacts associated with the buyout or
relocation. The negotiations surrounding these businesses must be resolved prior to the construction
of the port and should be treated as a matter of urgency.
Impact 1 - Impact on Marine Growers Abalone Farm
Cause and comment
An evaluation of the proposed Ngqura Port on the Marine Growers Abalone Farm was undertaken
by Common Ground Consulting (January 2001), where it was established that the infrastructure of
the Marine Growers Abalone Farm is well established and the farm is in a presently unpolluted
environment. In terms of production, the farm has reached the point where it has started to export its
products and is also selling seed abalone to other farms in South Africa. Although none of the
abalone farms in South Africa have yet proven to be a long term profitable business, this farm
certainly has the potential of achieving this (Common Ground 2001).
There will be a number of positive and negative impacts28 associated with the development of the
port and the IDZ on the abalone farm, but the negative impacts outweigh the positive ones. The
positive impacts are generally regarded as being of convenience to the existing operation rather than
necessities. They are: improved infrastructure associated with establishing the port and IDZ as well
as a larger pool of skilled labour. The only significant positive impact would be the provision of a
new international airport in the IDZ but this benefit may only be realised in 20 years’ time. The
26
As negotiations have not been finalised the impact rating is provisional and precautionary.
27
Impacts associated with the building of the Ngqura Port on other ports and related industries are covered in Issue 3.
28
The impacts identified in the Common Ground Report were based on a desktop assessment. The precise severity of
some of these impacts will require further studies. Until these studies have been completed, a precautionary approach
has been adopted in the assessment of these impacts.

negative impacts relate to: limitations on the expansion of the farm, investor confidence being
eroded, a deterioration in water quality, pollution associated with shipping accidents and illegal
dumping, importation of alien pathogens, accumulation of biocides such as TBT, possible blocking
of the farm’s seawater intake systems due to the dumping of excavated sands on the beach during
construction and a negative customer perception of the product (Common Ground 2001).
It can thus be concluded that while advantages of the port and IDZ for the farm are minor, there are
very significant negative implications for the farm, ranging from impacts that could potentially
compromise the quality of the products to impacts that could affect productivity. The most
significant impacts, however, are those that affect investor confidence. On the basis of this
assessment it was concluded that the farm is not viable as an ongoing business in its present
location, given the development of the port and IDZ (Common Ground 2001). If the port and IDZ
go ahead and the current operation/ownership situation prevails, the impact on the stakeholders of
the abalone farm could be very severe.
The recognition of the majority of the impacts that the port and IDZ may have on the abalone farm
have resulted in two major options being explored, viz. relocation of the abalone farm and buyout.
Both of these options have a number of subtle variations within them. For example, relocation may
involve partial relocation, phased relocation or closure and reopening, while buyout may involve
buyout and closure or buyout and operation. These different options have a suit of different social
and economic impacts, which are clearly outlined in the evaluation undertaken by Common Ground
Consulting (2001).
Scenario 1 – Relocation
This would require the CDC and PAD to cover all costs associated with relocation (relocation costs,
capital costs, running costs, loss of potential earnings). The primary impact associated with this
scenario is the possible loss of employment for the present employees 29 . This could be mitigated by
the CDC retraining and employing these workers and/or relocating the employees. On a macro-
economic level it should be noted that a similar number of people will need to be employed at the
new site and thus there should be no nett loss of jobs. The cost of relocation will, however, be
expensive and it will be borne by the CDC, and therefore by the taxpayer or PAD and its
shareholders.
The building of a port and IDZ could probably have a severe to very severe impact on the existing
abalone farm and its stakeho lders over the long term. The local impact of the proposed
developments can be mitigated against if a successful relocation programme is implemented. This
relocation programme must be agreed to by all parties and must be monitored to ensure that Marine
Growers is no worse off after the relocation. If the relocation programme is successful, the impact
should be of NO SIGNIFICANCE but if it is poorly managed then the overall impact could well
be VERY HIGH (negative) 30 .
Scenario 2 – Buyout and operate

If relocation is not feasible then buyout of the assets should be investigated. This will require a
formal evaluation of the business and mutual agreement on the sale price. The impact on the present
stakeholders in the farm can be successfully mitigated against if an agreed buyout package can be
established, which compensates both shareholders and workers. The principal macro, social and
economic impacts associated with buyout and closure are the loss of jobs and economic input of the
29
The exact number of employees varies according to source. The Common Ground report indicates 29 permanent staff
but Mr Muller (Director of Marine Growers) indicated in personal communications with CES that 59 people are
permanently employed.
30
In order for the impact to have NO significance on the stakeholders, it is imperative that an amicable relocation
package is agreed upon. If this relocation is not amicable to the stakeholders, the impact could be VERY HIGH.

business into the Eastern Cape fiscus. Mitigation in the form of the CDC or PAD then running or
setting up a SMME scheme to run the operation will negate any losses in the short term. The buyout
and operate scenario does not, however, negate the negative impacts associated with the port and
IDZ; it simply means that the new owners will be prepared to take those risks. If the abalone farm
and port are proven to be mutually exclusive in the long run, then the loss of jobs and economic
input into the Eastern Cape still stand.
The building of a port and IDZ could probably have a severe to very severe impact on the existing
abalone farm and its stakeholders over the long term. The buyout and closure of the farm could very
severely impact on the present stakeholders if a mutually acceptable buyout package is not agreed
upon. If an agreed buyout package is negotiated, the overall significance of the impact on the
stakeholders could range from LOW negative to LOW positive.
The impact on the macro-economic and social environment of a buyout will be moderately severe
at the metropole level as jobs will be lost. This impact could probably be mitigated against in the
short term by the continued operation (different ownership) of the abalone farm, which would result
in NO SIGNIFICANCE at the macro-economic and social level. However, if the port and IDZ are
proven to be incompatible with the abalone operation in the medium to long term, the overall
significance of the impact will be HIGH negative as the possible closure will result in a loss of jobs
and input into the local economy.
Impact 2 - Impacts on National Salts (production and processing)

Cause and comment
National Salt Limited (NSL) has a large salt works in the Coega Estuary that will be impacted upon
by the establishment of the port and IDZ. A study was commissioned in 1998, which investigated
the potential impacts related to air and water pollution that the IDZ and port may have on the
existing salt works. The results of this report are clearly summarised in the Revised Port EIA (CEN
2000). In short, it was found that there is a real risk of contamination in both the construction and
operational phases of the port and IDZ, and that the production of salt for human consumption
would be jeopardized in the medium to long term. In subsequent negotiations between National
Salt, the CDC and PAD, it has been established that the long term co-existence of the port and IDZ
with the salt works is not viable.
The options available to the salt works are relocation or buyout and closure. In terms of the aims of
the Coega Development which is to economically and socially uplift the region the loss of jobs and
revenue (direct and indirect through associated industries) associated with the closure of an existing
large business within the port footprint should be avoided were possible. To date no specialist study
specifically investigating buyout and closure of the salt works has been undertaken and therefore a
precautionary approach should be taken when evaluating the impacts associated with closure. Any
closure of the salt works must also take into consideration the knock-on effect that this may have on
the entire NSL national operation, the packed salt industry as a whole and associated industries
(suppliers and clients), as the Coega site is a integral component of the NSL operation and produces
a significant portion of total national salt production. The NSL Coega site is an important part of the
whole NSL operation which incorporates other production sites and depots around the country.
Any option which can preserve the jobs and revenue associated with salt works should be
thoroughly investigated prior to buyout and closure being considered as an option. Relocation is
such an option but should only be considered if an environmentally (ecological, economic and
social) sound site can be found. Any phased withdrawal of the salt works must take cognisance of
the impact of particulate dust during the construction phase (see the Air Quality Impact Assessment,
Specialist Studies Series – Part 2).

Scenario 1 – Relocation
The salt works currently employs in excess of 140 permanent staff and contributes significantly to
the local economy, and thus any measures that can result in the continued operation of this industry
should be investigated and encouraged. National Salt’s preferred site for relocation is to its existing
operation near the Sundays River Estuary. This location has, however, had a number of
environmental problems related to the seepage of saltwater onto an adjacent farm, Tankatara,
particularly on the north-western boundary fence. The relocation of the salt works to any site will
require the stipulated environmental regulations to be followed and studies such as an EIA or
EMPR to be undertaken.
The development of a port and IDZ will definitely have a very severe impact on the stakeholders in
the salt works in the Coega Estuary. The negative impacts associated with the Coega development
will result in the long term incompatibility of the salt works with the IDZ and port, which would
result in the loss of approximately 140 permanent jobs and a significant source of revenue into the
area. Mitigation in the form of relocation may be possible but as yet this has not be ascertained,
which places the operation at risk as it might not be re-established. If relocation is successful, the
overall significance of this impact will be LOW (negative). Relocation to an environmentally sound
site is the preferred option.
Scenario 2 – Buyout and closure

If relocation is not viable then the CDC or PAD will be required to buy out the shareholders and
compensate the stakeholders of the Coega salt works operation. This would involve mutual
agreement on a buyout package that includes both the owners and workers of the salt works. The
impacts associated with this are the loss of an important component of a large established business
in the Port Elizabeth region as well as the loss of over 140 jobs.
Significance statement (Individual stakeholders)

Under the closure scenario, the development of a port and IDZ will definitely have a very severe
impact on the stakeholders in the salt works in the Coega Estuary. The negative impacts associated
with the Coega development will result in the long term incompatibility of the salt works with the
IDZ and port, which would result in the loss of over 140 permanent jobs. Mitigation in the form of a
mutually acceptable buyout package (which would include retraining and employment of many of
the present workers) will result in an impact that could range in significance from LOW positive to
LOW negative for the present stakeholders.
Significance statement (Macroeconomic)

The loss of the salt works at the macro-economic and social level cannot be mitigated against and
the loss of 140 jobs and economic input (direct and indirect through the multiplier effect) from the
salt works to the regional and local economy will result in an overall impact of VERY HIGH
negative significance. This impact is of particular significance, as the Coega Initiative as a whole is
aimed at job and wealth creation.
Impact 3 - Impacts on the fishing industry in Port Elizabeth

Cause and comment
An investigation into the interaction between the proposed port and the fishing industry in Port
Elizabeth was undertaken by Sauer and Booth (1998, See Specialist Studies Series – Part 1). Sauer
and Booth (1998) indicated that there were a number of fishing activities in the Bay, viz. inshore
trawling, purse-seining, squid jigging and line fishing, but that the ma jority of commercial fishing
was undertaken outside of the Bay (west of Bird Island and east of Cape Recife).

Of the impacts identified by Sauer and Booth (1998), none were found to be of high significance or
moderate negative significance after mitigation. The principal impacts on the recreational and
commercial fisheries were the effect of shipping lanes on trawling, oil spills, increased access to the
islands and a deterioration in water quality and ecosystem functioning.

A number of mitigatory measures can be applied to reduce the impact of the port on the fisheries:
• No fishing vessels (recreational or commercial) should be permitted to operate from the
port.
• The new shipping lanes must be planned so that they do not interfere with existing squid
fishing areas in the Bay.
• Water quality must be regularly monitored and targets met.
• Contingency plans and equipment to deal with oil spills must be made mandatory. The port
must regularly maintain and update any oil spill emergency equipment.
The proposed port could probably have a moderately severe impact on the fishery in a localised
area in the bay in the long term. Mitigatory measures in the form of limiting access to the islands,
oil spill contingency plans and the management of water quality will probably result in a slight
impact. The overall significance of this impact is LOW (negative).
Impact 4 - Impact on other business and land owners

Cause and Comment
There are a number of other property owners whose land will need to be bought. The financial
impact on the owners of these properties could range from positive to negative depending on
whether agreement is met on the selling price and whether the land is expropriated or not. If the
properties are sold on a willing buyer/willing seller basis and agreement is met on price, the overall
impact on the owners should be positive. If no agreement is reached over price and the land is
expropriated, then the impact on the owners will obviously be perceived as being negative. The
exact significance/extent of the negative impact on the owner will be difficult to establish as in most
cases there will be disagreement around perceived versus actual opportunity costs. For the above
reasons, forced expropriation should only be used as a last resort and the various parties should try
to resolve their differences through mediation and/or arbitration.
The future land use options of adjacent landowners such as PPC cement may be impacted upon.
While PPC have a current mining venture with an approved EIA and EMPR the business also has
plans for land based and sea based tourism ventures. As with other such conservation and tourism
ventures e.g. the Greater Addo Park initiative, the port and Coega Project as a whole will have a
sense of place and visual impact on such an initiative. These impacts could limit the land use
options available to adjacent landowners and hinder the economic sustainability of such a venture.
The specific impacts associated with the Addo initiative which has similar characteristics (tourism
& conservation) occurs in the same region but is on a far larger scale is dealt with in detail in Issue
14. As with any large industrial development certain land use options in the surrounding areas will
be impacted upon. The suitability of the Coega site for a port was determined by the need for an
international transport network for the IDZ. The location and suitability of an industrial land use
option for the area is outside of the scope of this EIR and is more suited to an SEA. An SEA was
completed on the project by the CSIR (1997).
The overall significance of this impact is UNKNOWN.

Impact 5 - Impact on future mariculture landuse options

Cause and Comment
No specific study on the impact of the port on general mariculture in the region has been undertaken
however a desktop study by Common Ground Consulting (2000) on the existing abalone farm
indicated that the port could significantly compromise the activities at the abalone farm. In the
absence of any detailed studies to further elucidate this issue the precautionary principal must
prevail and the impact on the farm was rated as being HIGH. By logical extension of this principal
any abalone venture (present or planned) would face the same difficulties and thus this land use
option is unavailable or highly risky in the immediate port area. One such landowner is the 8CR
property trust. The exact economic impact on the stakeholders in this enterprise is difficult to
ascertain as the valuation of any damages would revolve around an opportunity cost.
The land use option of abalone farming will possibly be severely impacted upon in the area around
the port in the long term. The economic significance of this impact on the stakeholders is
UNKNOWN.
9.3 SOCIAL ISSUES
ISSUE 5: RESETTLEMENT OF PEOPLE IN THE PORT AREA

Impact 1 - Impact on local people having to be resettled
Cause and comment
The CDC and PAD intends to purchase all the land in the core development area of the IDZ below
the N2. As residential land use is incompatible with the activities planned for the Coega
development a relocation programme has been implemented. The CDC and Nelson Mandela
Metropole has come under criticism for the relocation of the Coega Communities which culminated
in an submission to the Human Rights Commission. In order to establish what the impacts on the
relocated community within the Ngqura Port were an addition specialist study was commissioned as
part of the Subsequent Port EIA (see Appendix E – Forensic Audit of the Coega Resettlement
Process and its Impact on Affected Parties). The aims of this forensic audit were to provide:
• A description of the resettlement process as it has unfolded to date.
• A description of the impacts of the resettlement on the resettled communities.
• An assessment of the resettlement process and impacts according to World Bank Guidelines.
The reader is encouraged to read the specialist study to get a thorough understanding of a process
which has had numerous stakeholders and has taken place over a number of years.
The study established the following:

The Coega resettlement process as it unfolded has resulted in some positive impacts for the resettled
communities. Many of the resettled households now have access to housing and facilities (such as
water, sanitation, transport), which are of a better quality than in their original communities. An
Integrated Development Plan, has been prepared by the NM3 for their resettlement area, which is
expected to address their needs for services, hopefully in the medium term future. There are also
some benefits associated with the relocation package e.g. one job per family (see appendix E).
However, the absence of a comprehensive relocation and compensation plan prior to the
commencement of the resettlement process has resulted in certain negative impacts on the resettled
communities and has left the organising agencies vulnerable to criticism.
The following negative impacts were identified:

• People, with an economically weak status (a high percentage of unemployed people) have been
relocated from a rural area, where they had developed a survival strategy, to an urban
environment. This may result in a loss of access to certain resources such as land, firewood,
livestock, vegetables and social support. In the urban area, the households will incur new costs
such as water and electricity charges. This change in live style, coupled with a lack of financial
means to survive in an urban setting, may lead to marginalisation of the resettled people,
resulting in feelings of disempowerment and in decreased physical and mental well-being. It
needs to be acknowledged however that due to the contributions of CDC people were relocated
in Phase I Wells Estate, instead of Phase II or III, which provided them with benefits, above
those provided in the Phase II and III developments.
• From the survey it is clear that the quality of the houses that were built for the resettled people
do not meet the people's expectations. They demonstrate many of the problems associated with
low cost housing. The CDC did however provide R 3000 to upgrade the houses.
• The controversy that has arisen around the resettlement between CDC, the Municipality and
various interests groups has led to social disarticulation amongst the affected people, breaking
up the Coega community and leading to various tensions within the resettled community.
• Due to the absence of a survey of the impacts on each household, it is impossible to assess the
degree of impact for each of the households. As a result some families may have benefited
more, and others less from the resettlement.
The process of resettlement has definitely result in a socio-economic disruption which will vary
from individual to ind ividual and household to household in the short, medium and long term at the
local level. The exact impact on individual households cannot be established but the positive
aspects of the relocation are that many of the people now have access to housing and facilities (such
as water, sanitation, transport), which are of a better quality than in their original communities and
the impact on them is slightly beneficial. Unfortunately for sensitive sectors of the community such
as the young and elderly there are negative aspects of the relocation which have resulted in a
moderately severe impact on their well being. While the relocation has been completed there are a
number of mitigatory recommendations which must be implemented and which should improve the
well being of the translocated communities:
• In order to ensure that people are not worse off after the relocation an authority approved
process needs to be established with the stakeholders (resettlers, CDC and NM3), which will
involve establishing their current needs and expectations. On the basis of this information an
ongoing development plan should be established, which ensures that people's quality of life is
equal and or better than before the resettlement. Economic upliftment needs to be an important
focus of such plan. The implementation of the plan should be the responsibility of both the CDC
and NM3 and should be independently audited.
• Continued consultation and negotiation with the relocated communities is needed.
• The controversies between the various interest groups should be resolved, without further
polarising groups within the affected people.
• A plan to monitor and evaluate people's living conditions and to address unforeseen problems
should be set up.
If the following mitigatory actions are meaningfully implemented and successful the overall
significance will probably be LOW to MODERATE (positive) for the majority of the people.
However for certain individuals and the sensitive sectors of the community (young and old) the
impact may still be LOW (negative)

ISSUE 6: DISRUPTION OF GRAVES

Impact 1 - Physical removal or relocation of graves
Cause and comment
Graves are an integral part of many communities and contribute to issues of individual and family
identity. Graves and cemeteries can be very sensitive issues and must be handled with the reverence
they deserve. No registered graves are found within the port limits but there are two grave sites on
the farm at Hougham Park (outside of the port limits), both of which are unregistered.

The CDC has undertaken to ensure that every possible effort will be taken to avoid disturbing
graves. Graves will be properly fenced and will not be tampered with. Any graveyards will be fully
integrated into the land use plan and access to these sites will be allowed.
If in exceptional circumstances graves are to be moved, the following recommendations must be

followed:
• The relocation of graves should take place with full participation of affected families and
communities.
• All the costs of the relocation must be covered by the developers.
• Costs associated with the relocation of graves could include coffins or blankets, the services
of healers or religious leaders, food, traditional alcohol and animals for slaughter.
• The developer, in conjunction with the affected communities, should jointly decide where
graves are to be relocated, and the timing and procedure for relocation and ritual activities.
The relocation of graves is highly unlikely but this activity will definitely have a moderately severe
impact on the local communities in the short term, if it were to occur. Mitigation in the form of
undertaking the right ceremonies and compensation to the families may reduce the severity of this
impact but it must be noted that in some cases no form of mitigation may suffice. The overall
significance of this impact is LOW (negative).
ISSUE 7: CHANGES TO SOCIAL SYSTEMS AND STRUCTURES

Impact 1 - Conflict between settlements and relocated communities
Cause and comment
The relocation of people from the port limits and the rest of the IDZ may well result in tensions
between them and their new host communities. This could be aggravated by the fact that in an area
of high unemployment the relocated people will be preferent ially treated in terms of training and
jobs. The establishment of the port and IDZ may alter existing power relationships and thereby
increase the potential for conflict between settlements and relocated people. As the area to which
the people are being moved (Wells Estate) is a new development, this impact will probably be low.

A comprehensive public participation programme that includes all affected communities will help
to reduce this impact, as people will be more informed about the project.
It is possible that there could be conflict between people in the short to medium term, which could
have a slight impact on the social structures and systems in the region. The overall significance of
this impact is LOW (negative).
Impact 2 - Conflict between local residents and expatriates brought in for construction
Cause and comment

The building of the port will require an expatriate workforce that will be involved in the dredging
operation and the building of the breakwaters and quays. This may result in conflict as the Eastern
Cape is economically depressed and many people from a range of economic groupings have
expectations of employment.

In order to deal with this impact, the developer must adhere to decisions reached through an
inclusive process – particularly with reference to employment policies – and limit their employment
of expatriate workers and non- local labour.
It is probable that there will be conflict between the local workforce and expatriates in the short to
medium term. This conflict may have a slight impact on the social structures and systems in the
region. The overall significance of this impact is LOW (negative).
Impact 3 - Increased incidence of sexually transmitted diseases

Cause and comment
HIV/AIDS is seen as a critical issue in southern Africa with disastrous consequences. It is well
known that the disease follows transport corridors, and ports have a steady influx of foreign workers
and are targeted by the sex industry.

Mitigation for the potential spread of HIV/AIDS is difficult and complex. All mitigation measures
should be a joint effort between the Port Authorities, Concessionaire, CDC, the various tenants in
the IDZ, health authorities and community leadership. The following recommendations are made:
• All workers should undergo thorough AIDS awareness and education programmes.
Industrial theatre and health workshops are some ways of raising awarene ss and educating
people about the risks.
• Ongoing, accessible and culturally appropriate awareness programmes with visiting sailors,
local residents and workers around the dangers of STDs and the risks of AIDS could be
implemented.
• Condoms must be provided to all workers.
• It would also be beneficial for the developer to support initiatives to design culturally
appropriate strategies to healthcare, based on integrated concepts of health, rather than
taking a purely biomedical approach.
Significance stateme nt
The building and operation of the port will definitely contribute to an increased incidence of STDs
and AIDS. This will result in a severe impact in the medium to long term, at the individual
household, and regional levels. Successful implementation of mitigation measures as outlined
above could possibly reduce the severity of this impact. The overall significance of this impact is
MODERATE (negative).
ISSUE 8: CLOSURE OF RECREATIONAL FACILITIES

Impact 1 - Loss of recreational facilities
Cause and comment
The closure of the Joorst Park Resort and beaches may have a significant impact on the population
of the northern areas of Port Elizabeth. Occupancy of the resort is low, with the exception of the
December and January periods, but it does provide a resource for the communities living in the
areas to the north and east of Port Elizabeth. The beaches at St George’s Strand and Wells Estate
will still be available to the public and the additional pressure on the beaches is not considered to be
problematic. The carrying capacity of the St George’s and Wells Estate beaches has been estimated

to be 160 000 people. Anglers see the closure of the beaches as a moderate impact especially as a
number of beaches under the jurisdiction of the Port Elizabeth Municipality have been closed to off-
road vehicles (CEN 2000).
Access to the beaches surrounding the proposed harbour should be not be unduly denied. The exact
demarcation of the public access limit must were possible take into consideration the needs of
recreational anglers and beachgoers. Access issues must form part of both the construction and
operational environmental management plan of the proposed port.
The closure of various recreational facilities will probably have a moderately severe impact on the
population in the northern area of Port Elizabeth over the long term. The overall significance of this
impact is MODERATE (negative).
ISSUE 9: OVERALL VISUAL IMPACTS OF THE PORT AREA

General comments
The visual impacts associated with the proposed port were assessed in the Revised EIA (CEN
2000). However, a change in the design of the port required an updated report to be commissioned
(Anderson 2001- See Specialist Study Series part 2 ) and this updated visual impact assessment
report can be found in Part 2 of the Specialist Studies series.
The visual sensitivity of the area in which the proposed port will be built is moderate to high. The
30-40m high dunes and embankments found in the area provide a certain degree of visual enclosure
and absorption capacity for the proposed harbour but the sea and coastal platform are visually
exposed. They offer little visual absorption capacity and are therefore visually sensitive.
Mitigation of the visual impacts is possible and the following measures are recommended:
• All slopes should be re-vegetated and shaped to blend in with existing slopes.
• Landscaping of all cut slopes should be undertaken.
• The various components of the transport corridor should be planned so that they have as
small a visual impact as possible, e.g. the pipeline and conveyor structure should be
combined.
• Careful attention must be given to the siting and design of all buildings.
• Screening vegetations should be used wherever possible.
• Temporary roads and construction sites must be clearly demarcated and rehabilitated.
• Architectural finishes should be used, e.g. colour should attempt to blend into the landscape
rather than stand in contrast.
• The eastern headland spoil site must be landscaped and re- vegetated.
In reviewing the impacts it should be noted that the severity of visual intrusions varies significantly
from one person to another, with some people appreciating the visual spectacle of big developments
such as ports.
Impact 1 - Visual impact of the maritime infrastructure

Cause and comment
The visual impact of the proposed breakwaters, quays, sand bypass facilities and spoil sites will be
moderate to high. The breakwaters will be visible from a short section of the N2 and coastline,
albeit from a distance. The visual impact of placing excavated material on the eastern headland will
be high but can be mitigated if the area is landscaped and re-vegetated.

The maritime infrastructure associated with the port will have a permanent severe visual impact.
Mitigatory measures, if successfully implemented, could reduce the severity of this impact,
resulting in an impact with an overall significance of MODERATE (negative).
Impact 2 - Visual impact of the main land based developments

Cause and comment
The visual impacts associated with the main land based developments are in general moderate to
high and are related to the transport corridor, cut and fill embankments, the tank farm, the levelling
of the western dunes and container handling area. Limited mitigation is possible to reduce the
impact of the tank farm and container handling area.
The main land based developments associated with the port will have a permanent severe visual
impact. Mitigatory measures, if successfully implemented, could reduce the severity of some of the
impacts, however the overall significance remain high due to the visual impact of the tank farm and
container handling area HIGH (negative).
Impact 3 - Visual impact of the construction activities

Cause and comment
A number of access and haul roads will be built to service the construction of the port. Two main
construction sites will also be constructed. The visual impact of the haul and access roads and the
construction camps will be very high during the construction period.
The building and operation of a number of access roads and construction camps will result in a
severe impact in the short term. As the impact is for a limited period, mitigation in the form of
reducing dust levels associated with construction activities as well as the successful rehabilitation of
these areas after the construction phase will probably result in an impact of LOW (negative)
overall significance.
Impact 4 - Visual impact of port ope rations

Cause and comment
Ships entering and leaving the proposed port will probably be visible from along the coastline
between Port Elizabeth and the Sundays River, and from some vantage points along the N2 between
Port Elizabeth and the Sundays River. The unloaders and ships will be visible from the N2 as it
passes through the Coega Valley. The terminals will be floodlit 24 hours a day, 365 days a year and
will result in a significant visual impact.
The operation of the port will result in a permanent moderately severe impact. Mitigation is limited
and the overall significance of this impact is MODERATE (negative).
ISSUE 10: INFLUX OF PEOPLE TO THE AREA

Impact 1 - Creation of unmanageable in-migration
The creation of job opportunities (real or perceived) in an area experiencing poverty and
unemployment will lead to in- migration. People will be drawn to the Coega area seeking
employment, which is a problem experienced by most big developments. Squatter camps will grow
and deve lop and there is also the possibility that existing informal camps will want to move closer
to the development. The existing infrastructure is already under pressure in this area and in-
migration could result in a number of social problems such as crime, vandalism, conflict, poverty,
malnutrition etc. (Initial Social Assessment of the proposed Coega IDZ and Port 1997).


The only way to mitigate this impact is to be proactive and realistic. Measures must be taken to
limit in- migration but areas for squatter camps must also be set aside. Land use around the
development must be confirmed and infrastructure prepared for that in- migration which cannot be
prevented. It is of great importance to involve local leaders and the authorities in all planning
exercises.
The nature and content of all press releases must be monitored to prevent any unrealistic
expectations of employment being created, which has already taken place.
The expectation of work at the port will definitely result in an in- migration of people in the short to
medium term. This in- migration could result in a very severe impact on local resources and
infrastructure. Some mitigation is possible but within the context of the economic environment in
the Eastern Cape, in- migration will occur and will be of MODERATE to HIGH negative
significance.
ISSUE 11: AIR EMISSION IMPACTS ASSOCIATED WITH CONSTRUCTION TRAFFIC

Impact 1 - Changes to air quality from particulate emissions
Cause and comment
Very high levels of dust will be generated by the traffic associated with construction work. Dust
will be generated through the hauling of rock from the quarry and the excavation and transport of
excavated material to disposal sites. While the main haul road is tarred, the other construction roads
are not. The Air Quality Impact Assessment (See Specialist Study Series Part 2) indicated the
following:
a) The main contributors to fine particulate matter (PM10) ground level concentrations are the
unpaved roads linking the breakwaters and dumpsites.
b) The frequency of exceedance of the DEAT daily guideline of 180µg/m3 in the entire area is
>30% of the year without control measures in place and higher around the construction
activities.
c) The introduction of control mechanisms to limit 90% of the particulates originating from the
unpaved roads, substantially improves the ground level concentrations of fine particulate
matter predicted for the area, but the DEAT guidelines will still be exceeded at times.
d) The impact will be the highest in the winter months.
Various impacts result from increased dust levels, including: visual impacts, the need for artificial
illumination and heating; soiling of buildings; delays, disruption and accidents involving traffic; and
vegetation growth reduction associated with reduced photosynthesis. Following long term exposure,
human health problems may also arise. High dust levels settling in the salt pans of the Coega salt
works can also be expected to have a significant commercial impact.

A number of mitigatory measures have been recommended. The unpaved stockpile access roads
were identified as a source of fugitive dust due to vehicle-entrainment. A variety of measures may
be taken to reduce emissions from unpaved roads. They include measures aimed at reducing the
extent of unpaved roads (e.g. paving); traffic control measures aimed at reducing the entrainment of
material by restricting traffic volumes and reducing vehicle speeds; and measures aimed at binding
the surface material or enhancing moisture retention, such as wet suppression31 and chemical
stabilisation. The introduction of windbreaks may also limit the impact of particulate concentrations
from dump sites on adjacent sensitive areas. Fuller details of potential mitigatory measures are
31
The use of saltwater is only advised for the temporary construction road along the upper reaches of the beach.

given in Burger and Watson (2001, See Air Quality Impact Assessment, Specialist Studies Series –
Part 2). It is recommended that all reasonable measures be investigated in the Construction
Environmental Manageme nt Plan and that specific dust suppression measures and targets
(maintenance of dust levels below DEAT guideline levels) be stipulated in the construction
contracts.
Changes to air quality from particulate emissions will accompany construction of the proposed
developments, and will result in a short term severe impact at a localised level. Successful
mitigation of this impact would probably decrease this impact to moderately severe. The overall
environmental significance of this impact would be MODERATE (negative).
Impact 2 - Impact of other fugitive emissions

Cause and comment
The construction traffic will result in various emissions from the truck engines e.g. Carbon dioxide
(CO2 ), Carbon monoxide (CO), Hydrocrabon compounds, Sulphur Dioxide (SO2 ), Nitrogen Oxides
(NOx ), Particulate matter (exhaust) and lead. The large traffic volume associated with the
construction phase will result in exceedance of DEAT guidelines for Nitrogen Oxides (average
hourly limit) and particulate matter (daily and annual limits). These exceedances are, however, very
localised and are contained within a few hundred metres of the roads.
Chronic exposure to high levels of the various emissions e.g. NOx generally results in decreased
lung functioning.

The only feasible mitigatory action is to keep the diesel engines in good working order. Regular
inspections and emission tests must be conducted on the vehicles. The construction EMP must
include a testing system that can be imp lemented and fleet emission targets must be built into any
haulage contracts.
Engine emissions associated with the vehicles used in the construction of the port will result in a
short term moderately severe impact at a localised level. Mitigation of this impact is limited to
good maintenance of the diesel engines. The overall environmental significance of this impact will
be MODERATE (negative).
ISSUE 12: OPERATIONAL NOISE, AIR AND LIGHT POLLUTION

General comments
The impacts of noise, air and light pollution associated with the operation of the port are covered in
Chapter 5, Issues 12 – 14.
ISSUE 13: SITES OF HISTORICAL OR CULTURAL INTEREST

Impact 1 - Sites of historical or cultural interest
Cause and comment
Two specialist reports (Binneman and Webley 1997; Binneman 1998) were compiled on important
culturally significant sites in the vicinity of Coega. Archaeologists from the Albany Museum
excavated and sampled most of the important in situ features in the vicinity of the Coega Estuary.
A number of shell middens were located 0.5km east of the Coega River mouth towards the
boundary of the IDZ. Binneman (1998) states that “In general the results were disappointing when
compared with other areas along the Eastern Cape coast. No ‘new or unique’ features or material
were found during the survey. The shell middens were small with little depth of deposit, dominated
by one shellfish species and with virtually no cultural or food remains. No Khoekoen pastoralist

sites were found or any significant ceramic remains. The stone tools were in secondary context and
consisted mainly of quartzite flaked cobbles”. However, important sites may be covered by dunes
and vegetation and may be exposed during the removal of the dunes for the development of the
port.
The reported shell middens fall mainly outside the development area, and are likely to be directly
affected only during the possible disposal of excavated material on the eastern headland. This
project action will cover but not destroy possible archaeological sites.

In terms of the National Heritage Resources Act (Act No 25 of 1999), if an artefact or any other
object of possible cultural or historic significance is uncovered during an excavation, all work on
the site will have to be terminated and the advice of an expert must be obtained. Any suspected site
or object located during construction should therefore be reported immediately to the National
Monuments Council. All construction site staff must be briefed to immediately report any sites that
are located during the construction of the facility. The contractors and the Coega Environmental
Officer must be informed of the sensitive areas and be fully briefed on what archaeological remains
may be encountered.
Project actions may impact on a few sites of scientific interest. Disturbance of these sites will
probably result in a permanent moderately severe impact at a localised or international level. The
environmental impact will therefore be of HIGH significance. Compliance with the suggested
mitigatory measures and adherence to legal specifications will effectively reduce this to LOW
significance.
ISSUE 14: IMPACT ON THE PROPOSED GREATER ADDO NATIONAL PARK

General comments
The building of a port and more significantly the Coega project as a whole will have an impact on
future eco-tourism land options in the area around the proposed development. The largest current
initiative is the Proposed Greater Addo National Park.
Kerley and Boshoff (1997) drafted a proposal for the expansion of the Addo Elephant National
Park. Their proposal suggested the amalgamation of two large existing conservation areas and their
expansion to create a Greater Addo National Park (GANP), thereby providing an opportunity for a
viable regional and national development and conservation initiative. The proposal is based on 11
recognised criteria and on national and international environmental legislation and treaties.
The proposed park would be some 398 000 ha in size, consisting of a 341 000 ha terrestrial zone
and a 57 000 ha marine zone. The terrestrial zone includes the Darlington Dam and almost 90
kilometres of the Sundays River, and the marine zone includes the Bird and St Croix island groups.
The proposed park, which would form a continuous conservation area of over 200 kilometres in
length, would be the third largest in South Africa.
The proposed park would be geomorphologically and botanically the most diverse conservation
area in South Africa and probably one of the most diverse in the world. In addition it would create
the potential for socio-economic development in the economically depressed Eastern Cape.
In terms of its conservation value, the proposed park will contribute significantly to South Africa’s
conservation requirements. It would be unique through the inclusion of examples of six of the seven
biomes that occur in South Africa, as well as a diverse marine component. Major landscapes

included are the Zuurberg Mountain range, part of the former African land surface, the Alexandria
coastal dunefield, fossil dune ridges and karstic landforms. The Alexandria coastal dunefield is the
largest, most impressive and least degraded coastal dunefield in South Africa, and one of the most
spectacular in the world. The park will also offer some protection to fragile and threatened river
systems, with the Sundays River estuary being of particular conservation significance.
The Bird and St Croix island groups are of conservation value, in that they support the largest
population of the threatened African penguin and the largest gannet colony in the world, as well as a
range of other species of special conservation significance, for example Cape fur seals.
The marine zone also supports populations of threatened and ecologically and economically
important species, such as reef and game fish, bottle-nosed and humpback dolphins, Southern Right
and Bryde’s whales, and great white sharks, all of which are also important ecotourism resources
(CEN 2000).
The proposed park and its surrounds have an important and interesting paleontological record,
consisting of a range of plant and animal fossils. These include dinosaur bones and unique fossil
fish deposits.
The report by Kerley and Boshoff (1997) discusses a number of issues relating to the establishment,
management and potential for success of the proposed park. Their report raises the issue of a
potential conflict between the proposed Coega harbour and IDZ development on the proposed park
in terms of visual pollution, air pollution, toxic waste as well as the impact on various species of
special concern. Additional points were raised during the review of the Revised EIA and included
the impacts that the port will have on the marine and coastal sections of the proposed park (oil
pollution, visual impact of harbour from the seaward side).
Impact 1 - Visual impact

Cause and comment
The visual impact of the proposed port can be broken down into two main facets, which include the
visual intrusion of the port and port related structures, and the night glow associated with the
continuous floodlighting of the port. The port structures will be highly visible from the marine and
coastal sections of the reserve and this will be exacerbated at night as the port will be floodlit. The
port and associated structures may be visible from other areas of the park e.g. the Zuurberg
Mountains and some areas on the coastal plain. A glow associated with the lighting of the IDZ and
the port will be visible at night from many regions within the park.

Mitigation in the design of harbour buildings, limited lighting and the use of screening vegetation
will help to minimise the visual impact of the harbour (see issue 9). Unfortunately the sea and
coastline have a limited visual absorption capacity and the breakwaters, quays and other
infrastructure will always be visible (Anderson 2001, Specialist Studies Series – Part 2).
The construction of the port and associated facilities will have a permanent severe visual impact on
the coastal sections of the proposed park. The port and associated structures will also have a
moderately severe impact on the terrestrial portion of the park. The overall significance of this
impact after mitigation (see Issue 9) is MODERATE negative for the terrestrial areas in the park
and HIGH negative for the marine areas.

Impact 2 - Impact of air pollution on the proposed park

Cause and comment
The area bounded by the port limits has no heavy industry but will contain some industries that will
result in air emissions. As the exact tenants of the IDZ are not known as yet, air pollution will be
controlled by the Environmental Management System (EMS) and targets will be set and enforced
(See Appendix B). The standards set by the EMS and the implementation of the Tenant Approval
Procedure (TAP) should limit emissions to below legislated levels. Comment on possible air
pollution from the development zone is outside the brief of this study.

All tenants will be obliged to obey the EMS and TAP systems, which will enforce emission levels.
Air emissions from the port could be severe and have a permanent impact in a localised area around
the Coega IDZ. The implementation of the TAP and EMS systems will probably ensure that the
impact is slight. The overall significance of this impact on the proposed park is LOW negative.
Impact 3 - Impact of general port operations on the marine park

Cause and comment
The operation of the port will result in some pollution e.g. plastics, biocides and oil which could
impact on species of special concern such as certain marine birds. These impacts can be managed
but even after strict controls, there will be an increase in this type of pollution along a presently
pristine piece of coast. Catastrophic events such as oil spills could occur but are regarded as being
unlikely. Oil spill contingency plans, if properly implemented, should contain these spills but will
be unable to prevent all of the impacts. Collisions of marine mammals and ships are also possible
but regarded as being unlikely (WSP 2001, See Specialist Studies Series – Part 2).
With correct management the impacts associated with general port operations can be contained to a
limited portion (western section) of the proposed park. Mitigatory actions limiting the ports
intrusion into the park must e.g. ecologically suitable shipping lanes should be investigated as part
of the construction and operational environmental management plans.

Mitigation in the form of adequate oil spill contingency plans, strict operating procedures pertaining
to ship speed, ballast water, dumping, plastic pollution etc. must be established and be enforced
within the port. A port Environmental Management Plan must be written, enforced and clearly
communicated to all ship captains entering the port.
Significance statement 32
The general operation of the port could result in severe impacts in the long term to western sections
of the marine park. Impact on the eastern sections towards the Sundays River and Seal Island are
expected to be limited. If the port is managed properly and mitigatory actions are implemented
successfully, the severity of the impacts may decrease. The overall significance of this impact on
the entire marine park is MODERATE negative.
Impact 4 – Overall loss of sense of place and subsequent loss of wilderness experience
Cause and comment
A loss in sense of place is a personal judgement and as such is hard to quantify, as people perceive
the environment around them differently. There is no doubt that a large game park that wishes to
32
The effect of catastrophic impacts e.g. oil spills and the establishment of an invasive species while being unlikely
could have a VERY HIGH impact on regions of the park if they were to occur. The effect of oil spills, collisions with
marine mammals and pollution are further assessed in Chapter 7 - Marine Impacts and Mitigation.

market a wilderness experience will benefit from reduced urbanisation and industrialisation around
its perimeters but in order to evaluate a change in the sense of place, the exact impact of existing
and proposed developments needs to be established. The question concerning the compatibility of
the Coega IDZ and port and the Greater Addo National Park should be broken down into two
sections. Firstly, what is the present level of urbanisation and industrialisation around the park and
how does that impact on the wildlife experience or sense of place of the park, and secondly what
impact will the Coega development, and in particular the port, have on the proposed expansion.
The Addo Elephant Park is situated within half an hour of one of South Africa’s largest cities and
any visitor from Port Elizabeth is required to drive through heavily industrialised areas and/or
townships to reach the park. This approach presently detracts significantly from any wilderness
experience and a trip to the park is viewed within the context of it being adjacent to the Nelson
Mandela Metropole. The tremendous conservation and tourism potential associated with an
expansion to the park has been recognised and has taken into consideration the present impacts of
the industrial and township areas. The question is how this potential will be impacted upon by
further industrialisation through the Coega development.
The Coega development will definitely add to the industrialisation and urbanisation around the
proposed park, which will result in a reduction of a sense of place or wilderness nature of the
proposed park, but this impact cannot be viewed as a simple relationship of “increasing
industrialisation results in decreasing sense of place”. The existing park is already viewed within
the context of being near industrial and township areas and the expanded park will not be able to
change this.
The marine infrastructure and port operations will specifically impact on the sense of place of the
marine component of the park, as the present area is relatively pristine with few visual intrusions.
Due to the low visual absorption capacity of sea and dunes, the breakwaters, quays and ship traffic
will detract from the experience offered by the marine park.
The loss of sense of place as well as the visual intrusion may well have an opportunity cost to the
proposed GANP development. At this stage no quantitative stud y on the economic impacts has been
commissioned. This type of analysis would be more suited to a strategic rather than a project
specific EIA as it would address long term land use options and policies for the region.

Mitigation of this impact can be implemented by both the CDC and the South African National
Parks. The structures in the port must be designed in such a manner as to reduce their visual impact
(Anderson 2001, Specialist Studies Series – Part 2). When designing the expanded park, the SANP
should take cognisance of the Coega development and suitably site wilderness areas, camps, roads
and viewing sites in positions that do not have commanding views of the proposed port and IDZ.
The proposed port and associated structures and operations will possibly result in a permanent and
severe impact on the sense of place experience offered by the expanded park. Limited mitigation
can be implemented, and the overall significance of this impact will vary from person to person, but
is probably MODERATE to HIGH negative. The impacts are serious but do not result in the
projects being mutually exclusive.

Table 9.3a: Key socio-economic impacts associated with the Ngqura Port.

ISSUE/IMPACT
ISSUE 1: EXPANSION OF THE SKILLS BASE
Impact 1: The regional expansion of the skills base Will occur Medium-Long term Regional Probably Slight beneficial Slight beneficial LOW (+)
ISSUE 2: DIRECT AND INDIRECT ECONOMIC IMPLICATIONS
Impact 1: Direct economic impacts during the construction
Will occur Medium term Metropole Definite Slight beneficial Slight beneficial LOW (+)
phase
Impact 2: Direct economic impacts during the operational
Will occur Long term Metropole Definite Slight beneficial Slight beneficial LOW (+)
phase
Impact 3: Indirect economic impacts during the construction
Will occur Long term Metropole Definite Beneficial Beneficial MODERATE (+)
and operational phases
ISSUE 3: THE ABILITY OF THE PORT TO ACT AS A CATALYST FOR GROWTH
Impact 1: The impact of the port and container terminal on
May occur Long term Regional Probably DON’T KNOW
the Coega IDZ
Impact 2a: The impact that the Ngqura Port may have on
Will occur Long term National Probably No effect No effect NO SIGNIFICANCE
other South African ports (Container terminal)
Impact 2b: The impact that the Ngqura Port may have on Severe –
Will occur Long term National Probably Moderately severe MODERATE (-)
other South African ports (Bulk and breakbulk berths) Moderately severe
Impact 3: Specific impacts on PE harbour May occur Long term Metropole Unsure Severe Severe HIGH (-)
ISSUE 4: IMPACT ON EXISTING BUSINESSES
Impact 1a: Impact on Marine Growers Abalone Farm Severe – Very
Will occur Long term Local Probably No effect NO SIGNIFICANCE*
(Relocation) severe
Impact 1b: Impact on Marine Growers Abalone Farm (Buyout
Will occur Long term Metropole Probably Severe No effect NO SIGNIFICANCE#
and operate)
Impact 2a: Impacts on National Salts (Production and
Will occur Long term Metropole Definite Very severe Slight LOW (-)
Processing) (Relocation)
Impact 2b: Impacts on National Salts (Production and
Will occur Long term Regional and Local Definite Very severe Very severe VERY HIGH (-)
Processing) (Buyout and closure)
Impact 3: Impacts on the fishing industry in Port Elizabeth Will occur Long term Local Probably Moderately severe Slight LOW (-)
Impact 4: Impact on other business and land owners DON’T KNOW
Impact 5: Impact on mariculture land use option May occur Long term Local Possibly Severe DON’T KNOW
ISSUE 5: RESETTLEMENT
Slightly beneficial
Impact 1: Impact on local people having to be resettled Has occurred Short – Long term Local Probably Beneficial - Slight LOW (-)$ to MOD (+)
to severe$
ISSUE 6: DISRUPTION OF GRAVES
Impact 1: Physical removal or relocation of graves Unlikely Short term Localised Definite Moderately severe Slight LOW (-)


ISSUE/IMPACT
ISSUE 7: CHANGES TO SOCIAL SYSTEMS AND STRUCTURES

Impact 1: Conflict between settlements and relocated Short – Medium
May occur Regional Possible Slight Slight LOW (-)
communities term
Impact 2: Conflict between local residents and expatriates Short – Medium
May occur Regional Probably Slight Slight LOW (-)
brought in for construction term
Impact 3: Increased incidence of sexually transmitted Individ., Household
Will occur Medium – Long term Definite Severe Moderately severe MODERATE (-)
diseases and Regional
ISSUE 8: CLOSURE OF RECREATIONAL FACILITIES
Impact 1: Loss of recreational facilities Will occur Long term Regional Probably Moderately severe Moderately severe MODERATE (-)
ISSUE 9: VISUAL IMPACTS OF THE PORT AREA
Impact 1: Visual impact of the maritime infrastructure Will occur Permanent Localised Probably Severe Moderately severe MODERATE (-)
Impact 2: Visual impact of land based developments Will occur Permanent Localised Probably Severe Severe HIGH (-)
Impact 3: Visual impact of the construction activities Will occur Short term Localised Probably Severe Slight LOW (-)
Impact 4: Visual impact of port operations Will occur Permanent Localised Probably Moderately severe Moderately severe MODERATE (-)
ISSUE 10: INFLUX OF PEOPLE TO THE AREA
MODERATE to
Impact 1: Creation of unmanageable in-migration Will occur Short – medium term Localised Definite Very severe Moderately severe
HIGH (-)
ISSUE 11: AIR EMISSION IMPACTS ASSOCIATED WITH CONSTRUCTION TRAFFIC
Impact 1: Impacts from particulate emissions Will occur Short term Localised Probably Severe Moderately severe MODERATE (-)
Impact 2: Impact of other fugitive emissions Will occur Short term Localised Probably Moderately severe Moderately severe MODERATE (-)
ISSUE 12: OPERATIONAL NOISE, AIR AND LIGHT POLLUTION
Impact 1: Noise, air and light pollution See Chapter 5
ISSUE 13: SITES OF HISTORICAL OR CULTURAL INTEREST
Impact 1: Sites of historical or cultural interest May occur Permanent Local/International Probably Moderately severe Slight LOW (-)
ISSUE 14: IMPACT ON THE PROPOSED GREATER ADDO NATIONAL PARK
Impact 1a: Visual impact (coastal) Will occur Permanent Localised Probably Severe Severe HIGH (-)
Impact 1b: Visual impact (terrestrial) Will occur Permanent Localised Probably Moderately severe Moderately severe MODERATE (-)
Impact 2: Impact of air pollution on the proposed park Will occur Permanent Localised Probably Severe Slight LOW (-)
Impact 3: Impact of port operations on the marine park Will occur Long term Localised^ Definite Severe Moderately severe MODERATE (-)
Impact 4: Overall loss of sense of place and subsequent loss MODERATE to HIGH
Will occur Permanent Regional Possibly Severe Moderately severe
of wilderness experience (-)
* NO SIGNIFICANCE – This impact will only have no significance if the compensation offered to all the stakeholders in the operation is satisfactory.
# NO SIGNIFICANCE – This impact will only be of no significance if the farm is not significantly impacted upon by the port.
$ The negative impacts will be primarily associated with the sensitive sectors of the community.
^ The impact on the marine park will decrease as one moves away from the port and is probably negligible in the eastern sectors of the park.

9.4 CONCLUSIONS
The socio-economic impacts associated with the development of the Ngqura Port are both positive
and negative (Table 9.3a). The main positive impacts are related to the expansion of the regional
skills base and the direct and indirect economic benefits of the construction and operation of the
facility. The benefits associated with the port were, however, found mainly to be of LOW
significance (Figure 9.4a), when put into context of the capital expenditure of the project. The main
reasons for the LOW significance is that the facility will not generate large numbers of jobs during
construction or operation, and the impact of the port on the regional economy will be negligible. In
addition, a significant portion of the construction budget will leave the country, as foreign
companies will be involved with large sections of the construction (e.g. dredging) and the preferred
private partner is also an international company. The MODERATE economic impact is related to
the indirect economic impact that the port may have. The main regional benefit will be from the
indirect employment in industries concerned with the import and export of cargo and in the
industries attracted to the IDZ because of the proximity of a container terminal. It must be noted,
however, that the port is only the transport infrastructure for the IDZ and that the IDZ should be
regarded as the vehicle to create jobs and economic growth for the entire Coega development. As
stated in the introduction (Section 1, Chapter 1), the economic viability and the potential for the
Coega initiative to create wealth falls outside of the scope of this EIA.
The ability of the port to act as a catalyst for growth in the IDZ is presently unknown but there will
be some induced economic growth around the provision of services for the container terminal.
While the port may provide the IDZ with the transport infrastructure required for an internationally
competitive IDZ, characteristics of the IDZ itself (e.g. location, labour, tax regimes, political
stability etc.) will determine whether it is a success. The most important finding of the economic
cost benefit analysis (MERIT 2001) was the existing and future need for a container terminal in the
South African port system, and that the Port of Ngqura can be economically justified to fulfil this
role. The fact that the proposed port can be justified independently to the IDZ is important to note
when considering the viability of the Coega development as a whole. It must, however, be
emphasised that no existing need was identified for the proposed bulk and breakbulk berths and that
these berths are presently not economically viable without having a significant effect on other ports.
Positive Impacts
Very High
40% High
Moderate
60%
Low
Figure 9.4a: Positive impacts associated with the Port of Ngqura (3 impacts were rated as Do Not
Know).

In terms of relocation the lack of an integrated Resettlement and Compensation plan has resulted in
it being impossible to assess individual or household impacts however the survey indicated that
many of the people now have access to housing and facilities (such as water, sanitation, transport),
which are of a better quality than in their original communities and the impact on them is slightly
beneficial to beneficial. If meaningful and successful mitigatory actions are implemented as soon as
possible, which should go a long way in ensuring that no parties are worse off after the move, then
the overall impact may well be LOW to MODERATE (+). There will however be a number of
individuals particularly in the sensitive sectors of the community who will still experience a
negative impact on their livelihoods. If the correct mitigatory measures are implemented this may
be reduced to one of LOW (-) overall significance.
There are a number of negative impacts (Figure 9.4b) associated with the building and operation of
the port and back-of-port area, quite a number of which are of HIGH or VERY HIGH significance
(Table 9.3a). The negative impacts of VERY HIGH significance revolve around the impact that the
port may have on existing businesses in the region. These impacts must be considered in a serious
light in that the aim of the Coega development is to bring economic growth to the region and any
job losses associated with the proposed port and back-of-port area must be carefully considered. In
particular, the possible impacts that the port will have on the salt works and abalone farm are rated
as being severe or very severe before mitigation, and while the two scenarios associated with the
abalone farm have the potential to be amicably resolved and thus be of NO SIGNIFICANCE, no
agreements have been reached thus far. The possible buyout and closure of the salt works is a
VERY HIGH negative impact and every effort should be made to relocate the salt works, provided
that an environmentally suitable site can be found. The port and IDZ may also impact upon the
future land use options immediately adjacent to the port and IDZ. The exact economic impact on
the shareholders in these properties is undetermined due to the difficulty in appraising future plans
rather than actual losses or impacts associated with existing operations.
While negotiations have not been finalised regarding the operational arrangements between P&O
Nedloyd and PAD and thus the specific impacts of the new port on the existing port at Port
Elizabeth remain unclear. Any arrangement which jeopardises the current operations viz. rerouting
of container traffic or bulk and break bulk cargoes has the potential to be a severe impact of HIGH
significance.
Negative Impacts
12% 4%
19% Very High
High
Moderate
31% Low
No significance
34%
Figure 9.4 b: Negative impacts associated with the Port of Ngqura (3 impacts were rated as Do Not
Know).

The loss of recreational facilities is of MODERATE significance while the visual impact that the
port will have on the surrounding areas is of MODERATE to HIGH significance. The possible
influx of people into the region is also regarded as a significant negative impact and the authorities
and CDC must make provision for this eventuality, as a project of this size is bound to elicit an
influx in a poor province such as the Eastern Cape. The impacts associated with hauling of vast
quantities of material in the construction area could result in very severe impacts if the required
mitigatory measures are not put in place. If dust suppression is successful then the impact will be of
MODERATE significance.
The last issue of HIGH or MODERATE significance is the impact that the port may have on the
proposed Greater Addo National Park. The most severe impacts are related to the visual intrusion
that the proposed port will have on the marine park and the associated loss of sense of place that the
entire park will experience. These impacts are rated as being of MODERATE to HIGH
significance but must be viewed in the context of the park currently being located in close proximity
to townships and industrial areas. The port will also have a MODERATE impact on the park in
terms of general port operations as species of special concern will be impacted upon. In conclusion,
the Eastern Cape is a poor province and while in an ideal world it would be better to have as little
industrialisation close to the park as possible, this luxury cannot be afforded and the two initiatives,
while not being in harmony, are not mutually exclusive.

CHAPTER 10:
FINAL DISCUSSION
AND CONCLUSIONS
10. FINAL DISCUSSION AND CONCLUSIONS
10.1 INTRODUCTION
It is essential that the Coega Development Corporation (CDC), Port Authority Division
(PAD), National and Provincial authorities and the interested and affected parties (IAPs)
recognise the issues that this EIR addresses and, equally importantly, what it does not. The
entire Coega Project is a large, multifaceted, capital intensive undertaking and as such has
elicited very polarised views. In a multiracial, multicultural and economically unbalanced
society such as that found in South Africa, any large, primarily government-funded project
will always result in divided opinions as to the project’s need, approach, scale, locality and
who the expected beneficiaries should be. In the age of transparency and accountability, the
Department of Trade and Industry, CDC and PAD must be expected to answer questions
relating to the rationale of the Coega Project as a whole. The rationale behind spending
billions of taxpayers’ rands must be sound and must carefully have weighed up the benefits
and costs of the project. This Port EIR is part of this process in that it examines the
environmental33 impacts (positive and negative) associated with the proposed port, which is
one component of the overall development. This EIR does not, however, make comment on,
or evaluate, the rationale behind the Coega Project as a whole. It is nevertheless important to
note that the provision of infrastructure as capital intensive as that of the proposed port should
only be authorised if the authorities are fully informed regarding the sustainability of the
Coega Project as a whole. What should also be recognised is that a final decision to support
and fund the Coega Project will most likely not only be based on a purely economic best
return basis, but also include aspects such as the strategic development of a previously and
presently economically marginalised area of South Africa. This decision, as with most
“business” decisions, will include a margin of calculated risk. The process and the
information used by the government to come to a final decision must nevertheless be
transparent to ensure that accountable and responsible development occurs.
The complexity of the Coega Project and its assessment has also been exacerbated by a
number of changes in design and preferred partners or anchor tenants. These changes have
resulted in a multitude of reports that are either totally or partially outdated, e.g. the initial
cost benefit analysis surrounding the IDZ (KPMG 1997) and the initial feasibility study on the
port (CEN 1997). This EIR has been informed by the relevant aspects of previous reports but
is not bound by previous recommendations made on now outdated concepts and designs. This
EIR has followed the authority approved plan of study and has re-examined all of the impacts
outlined in the outdated Revised Port EIR (CEN 2000 – See Specialist Study Series Part 1). In
addition, a range of specialist studies were commissioned to build on the existing data
available, and to answer questions raised in the scoping stage (e.g. the cost benefit analysis).
As mentioned, the Coega Project has resulted in very polarised views on many aspects,
including the whole assessment process. CES distances itself from, and this EIR does not
comment on, the procedural issues surrounding the building of the haul road. The EIR does,
however, make application for construction roads (below the N2) as one of the many project
actions associated with the building of the port. To this end, the building and operation of
roads has been included in the overall impact assessment process.
Public comment on this EIR should be constrained to port issues. Any further comments that
IAPs may have on other aspects of the Coega Project are welcomed but should be addressed
separately to the authorities and/or the CDC.
33
Environmental in this context includes the biophysical, social and economic environments.
Chapter 10: Final Discussion and Conclusions 183

10.2 SIGNIFICANT ISSUES / IMPACTS ASSOCIATED WITH THE

PROPOSED PORT
10.2.1 BACKGROUND
The following sections aim to crystallise the main positive and negative issues associated with
the proposed port, for the reader to weigh up the pros and cons of the development. In order to
do this, issues of low or no significance are generally not covered 34 . It must be noted that the
final significance attached to impacts assume that the mitigation and optimisation
recommendations will be successfully implemented 35 .
In order to fully assess a project, the possible future impacts of expansion of the project
should be assessed. These possible future scenarios are very difficult to assess with any
confidence but the potent ial environmental issues surrounding the expansion of the port are
discussed.
Prior to weighing up the positive and negative impacts associated with the proposed port, it is
important to acknowledge that the proposal is to build a large port that will serve as the
primary infrastructure to an industrial development zone. The port is to be built in a region in
Algoa Bay (marine and intertidal) that would be best described as pristine. Any development
of this size that has major construction activities such as dredging is bound to have negative
biophysical and social impacts. The questions to be answered are whether the negative
impacts are outweighed by the positive impacts, and whether the project is sustainable in the
long term.
10.2.2 NEGATIVE IMPACTS

There are a number of significant biophysical impacts associated with the construction and
operation of the port and back-of-port areas (see Tables 5.2a and c, 7.2a, 7.3a, 9.3a). The
terrestrial impacts of HIGH or MODERATE significance are associated with the construction
phase of the back-of-port infrastructure, with all the impacts in the operational phase being
rated as being of LOW significance with the exception of noise. It should be noted that the
rating of the operational impacts assumes that the Environmental Management System (EMS)
designed for the IDZ will be operational and applied to all areas of the IDZ and port.
The issue of loss and fragmentation of sensitive habitats had a number of significant impacts.
The loss of foredune vegetation and mesic succulent thicket in particular was rated as being of
MODERATE significance, while the loss of Bontveld and saltpan habitat was of HIGH
significance. In terms of species of concern and the loss of biodiversity, the impact of
construction will be HIGH on birds, and MODERATE on reptiles (Albany Adder), butterflies
(Aloeides clarki) and certain plant community types (Bontveld). While these impacts are
significant in that they are severe and either long term or permanent in nature, none are
thought to be fatal flaws to the project.
The building and operation of the port will result in a number of negative impacts on the
marine environment that are of HIGH or VERY HIGH significance 36 . The two impacts of
VERY HIGH significance, viz impacts of an introduced marine invasive organism and a
catastrophic oil spill, are both very difficult to predict but are regarded as being unlikely to
occur. Their VERY HIGH significance is due to the severe nature of these impacts, should
34
The reader is directed to the summary tables in Chapters 5, 7 and 9 if they would like to analyse all of the
impacts.
35
The reader is reminded that the various impact chapters (5, 7 and 9) include pre-mitigation assessments.
36
In some cases, impacts of VERY HIGH significance can be regarded as being fatal flaws to a project.
184 Chapter 10: Final Discussion and Conclusions

they occur. Neither of the impacts are specific to the Port of Nqgura and both are problems in
the general shipping industry. While the potential catastrophic nature of these impacts is
recognised, they are not regarded as fatal flaws to the project as long as the correct
management measures are in place (See Appendix C).
The construction and operation of the port will not significantly impact upon soft sediment
habitats and fish in the long term but could have a severe to moderately severe impact upon
certain birds of special concern (e.g. penguins and terns) as well as some cetaceans. These
impacts are primarily due to the long term disturbance that the port will have on the nearby
islands (in particular Jahleel) as well as the possibility of increased collisions between marine
mammals and ships. The impact of this disturbance on birds of special concern is of HIGH
significance.
The early initiation and continual monitoring and upgrading of the environmental
management system governing the port must be an integral part of the construction and
operational phases of the port. If the recommendations stipulated in this EIR and those
developed in a construction and operational environmental management plan are adhered to,
there should be no impacts that could be regarded as fatal flaws to the project. It must,
however, be noted that the severity of many of the impacts is far higher if the correct
management procedures are not followed. As with most large projects, the construction and
operation of an environmentally unmanaged or unmonitored port will most likely have very
severe impacts on the environment.
In terms of the socio-economic environment, there are a number of negative impacts

associated with the building and operation of the port and back-of-port area. The negative
impacts of VERY HIGH significance revolve around the impact that the port may have on
existing businesses in the region. These impacts are considered in a serious light in that the
aim of the Coega development is to bring economic growth to the region, and any job losses
associated with the proposed port and back-of-port area must be carefully considered. In
particular, the possible impacts that the port will have on the salt works and abalone farm are
rated as being severe or very severe before mitigation, and while the two scenarios associated
with the abalone farm have the potential to be amicably resolved and thus be of NO
SIGNIFICANCE, no agreements have been reached thus far. The possible buyout and closure
of the salt works is a VERY HIGH negative impact and every effort should be made to
relocate the salt works, provided that an environmentally suitable site can be found. The port
and IDZ may also impact upon the future land use options immediately adjacent to the port
and IDZ. The exact economic impact on the shareho lders in these properties is undetermined
due to the difficulty in appraising future plans rather than actual losses or impacts associated
with existing operations.
One of the more topical impacts of the port and the Coega Project as a whole has been the
possible impacts that it may have on the Greater Addo National Park initiative and other such
tourism and conservation land use options in the area. This issue has been rated as being of
HIGH or MODERATE significance, with the most severe impacts being related to the visual
intrusion that the proposed port will have on the park and the associated loss of sense of place
that the park will experience. These impacts must, however, be viewed in the context of the
park currently being located in close proximity to townships and industrial areas. In short, the
Eastern Cape is a poor province and while in an ideal world it would be better to have as little
industrialisation close to the park as possible, this luxury cannot be afforded and the two
initiatives, while not being in harmony, are not thought to be mutually exclusive. The IDZ and
Port may also have a MODERATE impact on certain species of concern and hence the
conservation aims of the marine park. The impact that the port and IDZ will have on species

of special concern will be HIGH close to and adjacent to the port but far lower in the other
regions of the marine park thus resulting in a MODERATE overall impact.
The other HIGH or MODERATE socio-economic negative impacts relate to the possible
impact on PE harbour, loss of recreational facilities, dust associated with the hauling of
material, influx of people into the area and the visual impact that the port will have on the
surrounding areas.
In terms of relocation the impacts are both positive and negative. The lack of an integrated
Resettlement and Compensation plan has resulted in it being impossible to assess individual
or household impacts however a survey (Appendix E) indicated that many of the people now
have access to housing and facilities (such as water, sanitation, transport), which are of a
better quality than in their original communities and the impact on them is slightly beneficial
to beneficial. If meaningful and successful mitigatory actions are implemented as soon as
possible, which should go a long way in ensuring that no parties are worse off after the move,
then the overall impact may well be LOW to MODERATE (+). There will however be a
number of individuals particularly in the sensitive sectors of the community who will still
experience a negative impact on their livelihoods. If the correct mitigatory measures are
implemented this may be reduced to one of LOW (-) overall significance.
10.2.3 POSITIVE IMPACTS

The construction and operation of the port and back-of-port area are not thought to have any
significant positive impacts on the natural environment. The positive impacts associated with
this project are limited to three issues, viz:
• The expansion of the skills base.
• Direct and indirect economic implications.
• The ability of the port to act as a catalyst for growth.
The positive impacts associated with the port are thought to be LOW or MODERATE, with
no HIGH or VERY HIGH impacts. The LOW impacts are the expansion of the regional skills
base, as well as the direct economic impacts during the construction and operational phases.
The only MODERATE positive impact gained is through the induced or indirect economic
spin-offs. The modest nature of these impacts is primarily due to the very high capital
expenditure of the venture, against which these positive impacts have to be measured. This
modest return on investment in the port is not unexpected, as the rationale behind building the
port is that it is enabling infrastructure that will service the IDZ and South Africa as a whole.
While the cost benefit analysis (MERIT 2001) indicated that the port could be sustainable on
its own if it concentrated on the container market, the port will also act as a crucial transport
corridor in the IDZ. Unfortunately the exact benefits that the port may accrue due to the IDZ
are unknown as no tenants have yet been secured. While the port could provide the required
infrastructure for an internationally competitive IDZ, characteristics of the IDZ itself (e.g.
location, labour, tax regimes, political stability etc.) will determine whether it is a success. If
the IDZ is feasible and tenants are found once the required infrastructure is in place, then the
growth (economy, jobs, skills, standard of living) in the region may be very significant and
the port will be a key activity in the entire Coega Project. Prior to taking a decision on the
port, the authorities must avail themselves of all the facts regarding the feasibility and
sustainability of the Coega Project as a whole.
One of the more important aspects concerning the economic sustainability of the port is the
effect that it may have on other ports in the country. In short, present predictions (excluding
the potential traffic produced by the IDZ) indicate that only the container sector of the market
warrants additional port capacity to be built in South Africa. If the Ngqura Port builds a

container terminal only, there should be no significant impact on other ports in the long term.
Immediately after the new container terminal comes on line there will, however, be some
rerouting of traffic, which may result in a negative impact in the short term. If, however,
breakbulk and bulk berths are also built, this may result in a diversion of traffic from other
ports to make the Ngqura operation sustainable. This diversion of traffic would probably have
a moderately severe negative impact on other ports. The IDZ may, however, produce the
required break and breakbulk traffic that is needed to warrant the additional berths, in which
case these could be added at a marginal cost. The specific impacts that the Port of Ngqura will
have on the Port Elizabeth port will be unclear until the negotiations between P&O Nedloyd
and PAD are finalised, as these negotiations will influence the manner in which the port is
managed. Port management and market pressures will in turn influence which carriers and
liners will dock where in Algoa Bay, and what traffic is routed through the different ports.
10.2.4 FUTURE IMPACTS

Depending on the development of the IDZ and the future growth in the regional and national
economies, the Port of Ngqura may expand from the existing 5 berths to a total of 34 berths.
The details of each phase will depend on the needs of the existing and anticipated users at that
time. Future berthing areas will be created by extending the south western and north eastern
quay walls of phase 1 inland, and constructing separate quay walls in the outer basin (Figure
3.4a). In order to fully weigh up the pros and cons of the present development, one needs to
have an idea of the long term plans of the port. As no detailed design has been undertaken,
and one does not have a clear idea as to what the environment (social and biophysical) will be
in the future, or what technological innovations regarding the mitigation of impacts may be
available, it would be inappropriate to try to rate any impacts, since no acceptable levels of
certainty could be attached to the predictions. Instead, the possible issues of significance
associated with the expansion have been identified (Table 10.2a).
10.3 FINAL CONCLUSION
In order to aid the decision- making authorities, who need to decide on the desirability of the
proposed Ngqura Port from an environmental perspective, it is important to consider the
concepts of sustainability, equit y and efficiency. In order to do so, these concepts are first
defined below.
10.3.1 CONCEPTS OF SUSTAINABILITY, EQUITY AND EFFICIENCY

Sustainability
Sustainability can be defined as “meeting the needs of the present generation without
compromising the needs of future generations”. It addresses the complex factors that
determine whether the economies of the world, a nation or region can be perpetuated and
adapt to changing needs and opportunities (CSIR Environmental Services 1993). This can be
traced to the concept of self-sustaining ecosystems, where the forces of nature balance each
other so that equilibrium is maintained over long periods. For example, ecosystems in which
hunter-gatherers subsisted without degrading the natural resources that they exploited would
be sustainable, as would the harvesting of other resources at a rate not exceeding the capacity
of the ecosystem to replace the harvested resources.
Present thinking on sustainability admits that development can be designed to be compatible

with environmental protection, and indeed that environmental protection is not attainable
without development (World Bank 1992).

Equity
The concept of equity deals with the fair distribution of benefits among people. For
development to be sustainable in the broad sense, it must be equitable. In other words, the
benefits arising from development must be distributed fairly among all people who rightly
have a stake in the development.
Efficiency
Efficiency means the choice between alternative development strategies or projects, taking
into account which of the alternatives will return the greatest present and future benefits for a
given cost in resources. Efficiency is usually described by translating costs and benefits into
monetary terms.
The National Environmental Management Act, NEMA (Act no 107 of 1998) lists a number of
principles that should be used to guide the interpretation, administration and implementation
of the Act, and any other law concerned with the protection or management of the
environment (CEN 2000). The NEMA states that environmental management must place
people and their needs at the forefront of its concern, and serve their physical, psychological,
developmental, cultural and social interests equitably. It further states that “Development
must be socially, environmentally and economically sustainable” (CEN 2000).
10.3.2. CRITERIA EVALUATION

Sustainability
In terms of sustainability, one of the key findings of the cost benefit analysis is that the
proposed port, if constrained to the container terminal, is economically weakly sustainable
without the IDZ. It is, however, not recommended that the port be built if the IDZ is not
viable, as expansion of the container handling capacity in South Africa could be undertaken
through the expansion of the existing Port of Richards Bay37 . Nevertheless the port can be
regarded as being warranted without the IDZ, and as such can only benefit from being part of
a successful industrial zone. If the IDZ is a success, the port will be an economically
sustainable project. However, as mentioned before, the overall decision to go ahead with the
port is inextricably linked to the viability of the IDZ.
In terms of ecological sustainability, the project will impact on a number of species of special
concern and threatened habitats. Many of the impacts can be mitigated against and no
biophysical impact is thought to be severe enough to curtail the project provided they are
correctly mitigated. In terms of social sustainability, the project has the potential to provide
(in the context of the capital expenditure) limited direct jobs and economic input into the
regional economy. The project will, however, possibly result in a greater impact through
induced or secondary inputs into the regional fiscus. Again it should be noted that the project
is providing the infrastructure for other businesses to utilise, and thus the main economic and
social benefits should be derived from the IDZ and other industrial centres utilising the port.
If the IDZ is a success then the port, as a pivotal component of the IDZ, will contribute
significantly to the social and economic sustainability of the region.
The Coega and other industrial development zones are seen as one of the mechanisms of the
GEAR policy of creating social and economic sustainability in South Africa.
37
While the MERIT report indicates that the proposed port and container terminal (excluding bulk and break
bulk berths) would be sustainable at Coega, the rationale behind not recommending the building of the port,
should the IDZ not be viable, is linked to the initial reason for the building of the port in the first place, which
was to provide an international gateway for the Coega IDZ. This is not to say that future investigations by PAD
may not find this site to be suitable. However, any future investigations would be subject to an independent EIA
process.

Table 10.2a: Possible issues of significance associated with the expansion of the port.
POTENTIAL SIGNIFICANT ISSUES COMMENT
Terrestrial issues (construction and operational phases)
1) Loss and fragmentation of sensitive habitats The construction of future phases of the port may result in further removal of foredune and hummock vegetation and any
remaining saltpan or estuarine environments below the N2. The removal of foredune and saltpan habitats was regarded as being
of MODERATE and HIGH significance in the initial construction phase, and a further removal of these habitats will probably
result in a more severe impact.
2) Loss of biodiversity and species of special The construction could result in a further reduction in the natural diversity of the region and will impact on species of special
concern concern that utilise the estuarine and foredune habitats.
3) Operational impacts (noise, lighting, air The operation of a larger port has the potential to increase the impacts associated with the various operational impacts identified
quality, electrical consumption, water for the initial phase. While these impacts were assessed as being slight in the initial phase, they may be more severe in the future
consumption, disposal of wastes etc.) phases.
Marine issues (construction and operational phases)
4) Impacts on the nearshore environment The construction of the new turning basins and quays will require a large dredging operation as well as the construction and
alteration of breakwaters. These project actions will result in impacts on various soft sediment environments, fish, marine
mammals and birds. The impacts would most likely be highest on any species of special concern, e.g. certain bird species.
5) Biological contamination through the A second round of capital dredging, most probably using foreign dredgers, could result in the introduction of an invasive marine
introduced organisms organism. The capital dredging programme, in conjunction with the increased shipping associated with a 34-berth port, would
increase the chances of a foreign organism being introduced.
6) Impact on adjacent industries It is not known what industries will have started up near the port but the expansion of the port may be an issue to such industries.
7) Pollution If the size of the port reaches 34 berths, then the whole port will be a significantly larger operation that could generate far more
pollution (general ships’ waste, ship associated biocides, stormwater runoff and material spill during cargo transfers). This
increase in pollution, if not correctly managed, could result in a significant impact on the marine environment.
8) Disturbance of fauna associated with the The operation of a 34-berth port would create a considerably larger disturbance (general movements, noise, lights, ship traffic)
operation of the port that the 5-berth operation. This disturbance could well have a significant effect on the utilisation of Jahleel Island as a roosting or
nesting site for birds. The additional port area, as well as movements of ships, would also impact on certain cetaceans.
9) Maintenance dredging A larger port would most likely require a larger and more frequent maintenance dredging programme.
10) Increased shipping One of the most significant issues of a larger port will be the increased shipping that will result from it. This increased shipping
would result in an increased risk of collision and associated spills. The increased shipping would also result in increased risk of
collisions with marine mammals.
Socio-economic issues (construction and operational phases)
11) Visual impacts of the port area The expansion of the port would result in it having a far greater visual impact. The larger breakwaters and greater number of
quays will increase the visual intrusion that the port has on the marine and nearshore environment. The larger port will also
produce more light pollution.
12) Impact on any conservation or tourism based If initiatives such as the Greater Addo National Park are successful, they will be in opposition to the expansion of the port or the
industry IDZ.
13) Creation of jobs and expansion of the skills If demand exists to warrant expansion of the port to up to 34 berths there will be concomitant increase in the number of jobs that
base the port provides. A 34 berth port would be a significant employer in the region.
14) Impact on the economy Depending on who is awarded the engineering contract the expansion of the port to 34 berths could be a significant economic
input into the region.

Equity
The concept that a project should be equitable is to ensure that all stakeholders in a
community should derive the benefits from the project. The benefits associated with the
construction of the port (jobs and contracts) are not entirely equitable, in that components of
the capital expenditure will be spent on foreign contractors (e.g. dredging). The jobs and
contracts that are available will be equitably distributed, as the CDC and PAD have equitable
labour and materials procurement policies. The distribution of jobs will also favour those
stakeholders that have been negatively impacted by the project through actions such as
resettlement. The specific aim of the Coega Project as a whole is to uplift the region, socially
and economically.
Efficiency
The question of whether the proposed port is an efficient use of taxpayers’ money is
fundamentally linked with the Coega Project as a whole. In order to answer this question, one
needs to examine the viability and rationale behind the entire Coega Project.
On the basis that government has already taken an ‘in principle’ decision to proceed with its
Spatial Development Initiatives, and in some cases their associated industrial development
zones, a policy decision was taken by the Ngqura Environmental Committee (NEC) not to
consider alternative land uses. Indeed the evaluation of alternative land uses is more suited to
a Strategic Environmental Assessment (SEA), as was initially done (CSIR 1997), and falls
outside the scope of this EIA.
10.4 RECOMMENDATIONS
If the construction and operation of the port is to go ahead, then it is recommended that the
approval be conditional on the PAD and CDC implementing the following:
1. The Environmental Management System designed for the IDZ must be completed.
Any additional outstanding tasks must be completed prior to the start of the phase of
operations that they are applicable to (e.g. the construction EMP must be completed
prior to construction while the operational EMP must be completed prior to the
operational phase). While it is recognised that the EMS is a dynamic tool, details on
its various mechanisms must be produced in an integrated form and approved by the
authorities, after which it should be regularly updated and reviewed.
2. The co- management structure between PAD and the CDC should be formalised to
ensure a compatible approach to managing the entire project. The management of the
ports should be guided by the structures and mechanism being developed for the IDZ.
3. Construction and operational EMPs must be completed prior to the implementation of
the various phases of the port. Specific recommendations to be included in these
EMPs are made in Appendix C.
4. An oil spill contingency plan must be commissioned and implemented prior to the
operation of the port.
5. The construction and operational Environmental Plans must be authority approved and
include monitoring activities. These monitoring activities must be clearly defined in
the environmental management plans and be rigorously audited. It is recommended
that an independent Environmental Site Officer be appointed for the construction
phase of the Coega Project as a whole.
6. No significant modifications to the project, as described in the project description,
may be made. Any such modifications will be reported to the authorities and will be
subject to their approval.

CHAPTER 11:
REFERENCE LIST
11. REFERENCE LIST

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Development Zone and the Ngqura Port Development. Coastal and Environmental Services,
Grahamstown.
CES. 2001. Specialist report on the environmental impacts and monitoring guidelines for the
land excavation and disposal, marine dredging and marine disposal operations at coega port.
Report for the Subsequent Environmental Impact Assessment on the Coega Industrial
Development Zone and the Ngqura Port Development. Coastal and Environmental Services,
Grahamstown.
MERIT. 2001. Economic Evaluation of the Proposed Port of Ngqura and Development of a
Container Terminal. Report for the Subsequent Environmental Impact Assessment on the
Coega Industrial Development Zone and the Ngqura Port Development. Coastal and
Environmental Services, Grahamstown.
WSP Environmental. 2001. Coega Harbour Risk Assessment. Report for the Subsequent
11.3 SPECIALIST STUDIES UNDERTAKEN FOR THE INITIAL

ENVIRONMENTAL IMPACT ASSESSMENT AND THE STRATEGIC
ENVIRONMENTAL ASSESSMENT
Annegarn, H.J., Burger, L.W. and Scorgie, Y. 1997. Air quality study for the Coega
Industrial Development Zone. Report for the Coega Industrial Development Zone SEA.
Annegarn Environmental Research (PTY) Ltd., Sandringham.
Binneman, J. and Webley, L. 1997. Coega Industrial Development Zone: cultural sensitivity
report. Report for the Coega Industrial Development Zone SEA. Albany Museum,
Grahamstown.
Brits, M. 1997. Visual assessment for the Coega Industrial Development Zone and Coega
harbour. Report for the Coega Industrial Development Zone SEA and Coega harbour EIA.
Marius Brits Landscape Architects, Cape Town.
Coastal and Environmental Services, 1997a. Coega Port study: environmental impacts of a
quarry at Coega Kop. Report for the Coega harbour EIA. Coastal and Environmental
Services, Grahamstown.
Coastal and Environmental Services, 1997b. Strategic Environmental Assessment of the

Coega Industrial Development Zone - specialist report on the ecological impacts of the

proposed conveyor route. Report for the Coega Industrial Development Zone SEA. Coastal
and Environmental Services, Grahamstown.
Coastal and Environmental Services, 1997c. Strategic Environmental Assessment of the

Coega Industrial Development Zone - Terrestrial Ecology Specialist Report. Report for the
Coega Industrial Development Zone SEA. Coastal and Environmental Services,
Grahamstown.
Cohen, M. 1997. Environmental permissions and permitting requirements for the Coega
harbour and Industrial Development Zone initiative with comments on other relevant
legislation. Report for the Coega harbour EIA. CEN, Integrated Environmental Management
Unit, Port Elizabeth.
Cohen, M. and La Cock, G. 1997. Report for the Environmental Impact Assessment of the
proposed harbour on the St. Croix Island group and their associated fauna: (Penguins and
roseate terns). Report for the Coega harbour EIA. CEN, Integrated Environmental
Management Unit, Port Elizabeth.
Illenberger, W.K. 1997. Potential impact of the proposed Coega harbour on coastal sediment
dynamics. Report for the Coega harbour EIA. SAB Institute for Coastal Research, University
of Port Elizabeth, Port Elizabeth.
Institute for Development Planning and Research, 1997. Preliminary social assessment of the
proposed Coega Industrial Development Zone and port. Report for the Coega Industrial
Development Zone SEA and Coega harbour EIA. Institute for Development Planning and
Research, University of Port Elizabeth, Port Elizabeth.
Pakes, T. and Nel, H. 1997. Coega Industrial Development Zone and port - preliminary
economic assessment. Report for the Coega Industrial Development Zone SEA and Coega
harbour EIA. University of Port Elizabeth, Port Elizabeth.
Schumann, E.H. 1997. Catchment drainage and water circulation. Report for the Coega
harbour EIA. SAB Institute for Coastal Research, University of Port Elizabeth, Port Elizabeth.
Van Zyl, H. 1997. Potential economic implications of the establishment of an export

processing zone at Coega, Port Elizabeth. Report for the Coega Industrial Development Zone
SEA. University of Cape Town, Rondebosch.
Wooldridge, T.H., Klages, N.T. and Smale, M.J. 1997. Nearshore marine flora and fauna.
Report for the Coega Industrial Development Zone SEA and Coega harbour EIA. SAB
Institute for Coastal Research, University of Port Elizabeth, Port Elizabeth.
11.4 SPECIALIST STUDIES UNDERTAKEN FOR THE REVISED

ENVIRONMENTAL IMPACT ASSESSMENT
Binneman, J. 1998. Coega Industrial Development Zone: Cultural Sensitivity Phase 2 Report.
Department of Archaeology, Albany Museum, Grahamstown
Boshoff, A.F. and Sigwela, A. 1998. The Predicted Impacts of the Construction and
Operation of the Proposed Coega Harbour on the Birds of the Coega Estuary and Jahleel
Island. Terrestrial Ecology Research Unit, University of Port Elizabeth, Port Elizabeth.

Campbell, E.E. 1998. The Vegetation of the Coega Harbour Area and Wells estate:
Importance of the Vegetation Types. Report submitted to CES Integrated Environmental
Management Unit.
Kroese, M.K. and Sauer, W.H.H. 1998. Impacts of Marine Traffic and the Coega Harbour on
Marine Mammals in Algoa Bay. Department of Ichthyology and Fisheries Science, Rhodes
University, Grahamstown.
OVP Associates and Megan Anderson. 1999. Coega Industrial Development Zone Harbour
and Back of Port Development. Complementary Visual Impact Assessment Report. OVP
Associates.
Sauer, W.H.H. and Booth, A.J. 1998. Impact Assessment of the Coega Harbour on the
Fishing Activities, Estuaries and Phytoplankton Production in Algoa Bay. Department of
Ichthyology and Fisheries Science, Rhodes University, Grahams town.
Schumann, E.H. 1999. Ocean Circulation Update. Report for the Revised Port EIA on the
Port of Ngqura. SAB Institute for Coastal Research, University of Port Elizabeth, Port
Elizabeth.
11.5 OTHER SPECIALIST STUDIES UNDERTAKEN FOR THE COEGA

DEVELOPMENT
Jongens Keet Associates. 1999. Coega Development Zone Ambient Noise Guidelines.
Jongens Keet Associates. 1999. Application of the Noise Pollution Guidelines for the Coega
Development Zone.
Rossouw, A.M.M., Potgieter, F.E. and Venter, D.J.L. 1999. Social Baseline Report. Summary
Report: Coega Socio-economic and Health Survey of Households. Report produced for the
Coega Development Corporation as part of a Social Baseline Report.

APPENDIX A:
PLAN OF STUDY FOR THE
SUBSEQUENT ENVIRONMENTAL IMPACT STUDY
FOR THE PORT OF NGQURA
CEN INTEGRATED ENVIRONMENTAL MANAGEMENT
UNIT
Environmental and Rural Development Specialists
Plan of Study for the

Subsequent Environmental
Impact Study for the Port of
Ngqura
Plan of Study for the Subsequent
Environmental Impact Study for the
Port of Ngqura
 CEN Integrated Environmental Management Unit

36 River Road
Walmer, Port Elizabeth. 6070
South Africa
Phone (041) 581-2983 • Fax (041) 581-2983
E-mail: steenbok@iafrica.com
This project was undertaken on behalf of:
Portnet
101 DeKorte Street
Braamfontein
Johannesburg
Environmental Management Programme Report
2
TABLE OF CONTENTS
Table of Contents ............................................................................ 3

Chapter 1: Chapter 1: Introduction to the Plan of Study.......... 5
1.1 1.1 Background ..................................................................... 5
1.2 Motivation for the Development of a Port at Coega......... 6
1.3 Approach to the Environmental Studies ............................ 8
1.3.1 Initial Environmental Assessment......................................... 8
1.3.2 Revised Environmental Assessment ..................................... 8
1.3.3 Second Revision of the Environmental Assessment (This

Study) ............................................................................................... 9
Chapter 2: Description of the Activity ...................................... 10

2.1 Name of Applicant .............................................................. 10
2.1.1 Identified Activities Requiring Authorisation in Terms of the
Environmental Regulations .............................................................. 11
2.1.2 Location of the Port............................................................. 12
2.1.3 Port Limits........................................................................... 12
Chapter 3: Description of the Tasks to Be Conducted in

Compiling the Subsequent Environmental Impact Assessment .
.................................................................................... 13
3.1 Plan of Study........................................................................ 13
3.2 Authority Consultation ....................................................... 13
3.2.1 Pre Application meeting...................................................... 13
3.3 Process for the Revised EIR .............................................. 14

3.4 Port Designs......................................................................... 14
3.5 Issues and Concerns .......................................................... 14
3.5.1 Identified by Authorities...................................................... 14
3.5.2 Additional Issues................................................................. 15
3.5.3 Evaluation of Impacts.......................................................... 21
3.6 Alternatives ......................................................................... 23
Plan of Study for the Revised Environmental Assessment of the Port of Ngqura
3
3.7 Public Participation Process ............................................. 23
3.7.1 Releasing of the Coega Documentation.............................. 23
3.7.2 Public Participation Process ............................................... 23
Chapter 4: Consultants............................................................... 24
4
1
Chapter
CHAPTER 1: INTRODUCTION TO THE PLAN OF

STUDY
1.1 BACKGROUND
The construction of a new port to serve an Industrial Development Zone (IDZ) was
proposed for the Coega area near Port Elizabeth, in the Province of the Eastern Cape.
In order to ensure that important environmental issues were addressed at an early
stage in the planning and decision-making process, the Coega Development
Corporation on behalf of Portnet commissioned a series of Environmental Impact
Assessments (EIA's) for the proposed new port. The Initial Environmental Impact
Assessment or Phase 1 study was undertaken from June 1996 to June 1997.
During September 1997 the Minister of Environment Affairs and Tourism

promulgated regulations under Sections 21, 26 and 28 of the Environmental
Conservation Act (Act No 73 of 1989). In terms of the new legislation Portnet was
required to obtain a permit or an authorisation to undertake certain listed activities,
which may have a detrimental impact on the environment.
During June 1998, Portnet decided to proceed to the detailed design phase of the new
port. CEN Integrated Environmental Management Unit (CEN IEM Unit) was
appointed to undertake the necessary revision of the Initial Environmental Impact
Assessment, co-ordinate EIA related activities locally in Port Elizabeth and manage
any necessary additional specialist studies.
The revision of the Initial Environmental Impact Assessment was undertaken to

ensure that Portnet complied with the Regulations promulgated under Section 21 (1)
of the Environmental Conservation Act (Act 73 of 1989). The revision also allowed
for an assessment to be made of impacts associated with changes in design and
location of the proposed port.
5
In order to obtain the necessary authorisations in terms of the Environmental
Conservation Act (Act 73 of 1989), CEN IEM Unit proposed a particular approach to
the relevant authorities, namely, the National Department of Environmental Affairs
and Tourism and the Eastern Cape Department of Economic Affairs, Environment
and Tourism. The proposed approach was accepted with minor adjustments.
During June 2000 the Coega Development Corporation indicated that their preferred
private partner, P&O Nedlloyd, had indicated that they were interested in establishing
a container terminal at the proposed port of Ngqura.
The establishment of a container terminal will require the configuration of the

proposed port to be adjusted. The new configuration of the proposed port may alter
the impacts as assessed during the revised impact assessment.
In order to determine the approach that should be taken with regard to the changes in
port configuration and the necessary revision to the environmental impact assessment,
the Coega Development Corporation and their consulting engineers, Prestedge Retief
Dresner Wijnberg, presented a series of concept port designs to the Ngqura
Environmental Committee (NEC) in order for them to understand the magnitude of
the proposed changes and to allow them to maker a recommendation on how to
proceed with the environmental studies.
At their meeting of 22nd June 2000, the NEC concluded that the Environmental
Impact Report (EIR) that had been compiled for the Port of Ngqura had to be adjusted
to reflect the proposed changes and that all impact associated with the new design and
port related activities reviewed.
Based on the decision of the NEC the national and provincial authorities called for a
meeting on July 6th 2000. The purpose of this meeting was to decide on a way forward
which would be acceptable to Portnet, he Coega Development Corporation, the
National Department of Environmental Affairs and Tourism and the Provincial
Department of Economic Affairs, Environment and Tourism.
MOTIVATION FOR THE DEVELOPMENT OF A PORT
AT COEGA
Soon after the democratic elections of 1994 the Government of South Africa initiated
its Spatial Development Initiative (SDI) Programme The SDI programme is a short-
term investment strategy that aims to unlock inherent economic potential in specific
spatial locations in Southern Africa. It uses public resources to leverage private sector
investment.
The initiatives aim to create jobs and opportunities for the empowerment of
previously disadvantaged communities by encouraging economic growth. Through
the SDI's it is hoped to generate employment and to provide for the development of
skills in the previously disadvantaged communities. They are the practical
6
implementation of the Government's economic strategy as set out in its Growth,
Employment and Redistribution (GEAR) policy.
The SDI programme consists of eleven SDI's at varying stages of delivery. The
Department of Trade and Industries has indicated the possibility of Industrial
Development Zones being linked to five of the SDI's. These are Gauteng, Richards
Bay, East London, Coega outside Port Elizabeth and Saldanha (Jennifer Smith Pers
Comm.). New industrial development with a view to beneficiation of raw materials
and export of higher value added products is the main focus of the proposed Coega
Industrial Development Zone.
A key to attracting industry to the proposed Industrial Development Zone is the

provision of an effective bulk transport operation for imports to and exports from
industries located in the zone. The existing port at Port Elizabeth by way of
extensions and a new industrial port situated at the mouth of the Coega River were
identified as possible sites capable of providing the port facilities required by the
zone.
The Initial studies concluded that the industrial harbour should be located at Coega
for the following reasons:
¯ Lower capital costs

¯ Greater potential for future expansion at a lower marginal cost
¯ Closer to the IDZ, allowing more effective cargo linkages
¯ Has the potential to allow for the release of prime land within the Port at Port
Elizabeth for redevelopment
In addition to the cargo flows associated with industry in the Zone it is anticipated
that exports of dry bulk materials and imports of liquid bulk will also occur in the
future. (The relocation of the bulk ore handling facility and oil tank farm from Port
Elizabeth is part of Portnet's long-term strategy.)
The maritime infrastructure for the proposed first phase port development comprises a
dredged channel, a main and secondary breakwater enclosing a dredged basin,
approximately 600 metres of continuous quay providing 2 berths and a separate berth
of approximately 300 metres. A sand bypassing system will be provided to manage
littoral drift.
Further development of the port will be considered in response to demand.
The success of the Development Zone and the port are inextricably linked. The port
represents the basic infrastructure development required to provide a conduit for
cargo flows into and out of the Development Zone.
7
APPROACH TO THE ENVIRONMENTAL STUDIES
INITIAL ENVIRONMENTAL ASSESSMENT
Traditional environmental impact assessments usually describe and assess
environmental impacts using criteria such as:
¯ Extent, Duration, Intensity and Probability.
The above are then evaluated in terms of:
¯ Significance (Low, Medium High), status of the impact, and degree of

confidence in predictions.
The above procedure, which is ideal, can only be applied when it is possible to
quantify those activities that are likely to interact with the environmental components
or processes and to define their expected range. This can only take place when the
project is fully described or defined. Because the Coega project evolved so rapidly
and under an extreme time frame all of the necessary detail was not available during
the initial study period.
The lack of detail about the development precluded a quantitative assessment being
made and created uncertainty about the potential environmental effects of some of the
project actions. To overcome these limitations, a worst-case scenario was accepted
and the precautionary principle adopted throughout the initial impact assessment.
As a further precaution, all of the key issues addressed by specialists, which could not
be quantified, were accepted as being of a high significance prior to any mitigation
being proposed and as being an impact of a high probability of occurrence.
This approach resulted in more stringent conditions being placed on the development
than may have been the case had the project been fully described.
Knowledge gaps were acknowledged throughout the study and recommendations

made for additional studies.
REVISED ENVIRONMENTAL ASSESSMENT
With the move to detailed design phase of the project, many of the issues had been
clarified and it was possible to make more accurate assessments of the potential
impacts. In the light of the improved project description and more certainty on many
of the issues, as well as the inclusion of environmental specifications in the project
descrip tion it was possible to review and revise a number of the recommendations
made in the initial environmental study. It was also possible to illustrate the extent
and duration of most of the predicted impacts and to rate them in terms of
significance.
8
Where necessary, the additional studies recommended in the initial impact assessment
were undertaken. The results of these additional studies were included in the revised
environmental impact report.
The Draft Environmental Impact Report was submitted to the Coega Development
Corporation on 14th December 1999 in order for them to make the necessary
application to the authorities and to feed the document into the public participation
process.
SECOND REVISION OF THE ENVIRONMENTAL ASSESSMENT (THIS
STUDY)
After the submission of the first revised environmental impact report (December
1999) Government ratified the recommendation of the CDC of selecting, P&O
Nedlloyd as their preferred private partner for the development of the proposed IDZ.
The consortium’s proposal includes the development of a container terminal and
transhipment hub in the Port of Ngqura, associated with an industrial park, logistics
centre and electronic commerce (e-commerce) business park. The construction of a
container terminal would necessitate several structural changes to the port
configuration as well as changes to the back of port structures and activities.
The proposal to change the port configuration was presented to the Ngqura
Environmental Committee at their meeting of June 22 1999. At that meeting the NEC
recommended that the relevance of the Draft Environmental Impact Report compiled
for the proposed Port of Ngqura needs to be reviewed and revised to reflect the
changes resulting from the involvement of P&O Nedlloyd’s request for a container
terminal. They recommended that the CDC conduct the subsequent environmental
assessment in accordance with the process as stipulated in the regulations.
9
2
Chapter
DESCRIPTION OF THE ACTIVITY

A detailed description of the proposed port is provided in Chapter 5 of the "Draft
Environmental Impact Report for the Proposed Port of Ngqura, Port Elizabeth" which
was submitted to the Coega Development Corporation on 14th December 1999 and
which has subsequently been distributed to the members of the Ngq ura Environmental
Committee (NEC).
The description of the activity is not repeated in the Plan of Study and readers are
referred to the Draft EIR for details of the proposed project.
The consulting engineers for the port, Portnet and P&O Nedlloyd are meeting on July
11 to discuss details of the port design and it is not possible to include a detailed
description of the proposed port at this stage. Details of the changes to the port have
also been included in the Scoping Report.
NAME OF APPLICANT
The environmental investigation will be undertaken for Portnet through the Coega
Development Corporation.
Contact persons.
Portnet
Mr Nick van Amstel
Deputy Chief Engineer
Portnet
P O Box 32696
Braamfontein
Johannesburg
2017

Mr Themba Koza
10
Environmental Specialist
Postnet Suite No 35
Private Bag X13130
Humewood
6013
IDENTIFIED ACTIVITIES REQUIRING AUTHORISATION IN TERMS OF
THE ENVIRONMENTAL REGULATIONS
In terms of the regulations the Minister of Environment Affairs and Tourism
identified a number of activities as potentially having a substantial detrimental effect
on the environment. This environmental impact assessment makes application to
undertake the following listed activities:
1. The construction or upgrading of:
a) Transportation routes and structures, and manufacturing, storage,

handling or facilities for any substance, which is dangerous or hazardous and
is controlled by national legislation; (Access routes in the area proposed for a
port) (Portnet ha s indicated that they will consider the relocation of the ore
dumps and tank farm currently located within the Port Elizabeth harbour).
This environmental assessment will not consider the relocation of the ore
dumps and the tank farm.
b) Roads, railways, and associated structures outside the borders of town
planning schemes; (Roads and railway lines within the area designated as port
area)
c) Marinas, harbours and all structures below the high-water mark of the
sea; (Proposed Ngqura Port)
d) Canals and channels, including diversions of the normal flow of water
in a river bed and water transfer schemes between water catchments and
impoundments; (Diversion of the Coega estuary)
e) Dams, levees or weirs affecting the flow of a river; (Port Structure in
the Estuary)
2. The reclamation of land below the high water mark of the sea and in inland water
including wetlands.
3. The environmental report will not make application for any permits required
under the national Water Act
11
LOCATION OF THE PORT
The Port of Ngqura will be situated at the mouth of the Coega River near the southern
corner of the proposed Development Zone. The area to the north and west of the Port
has been set aside for port related activities, whilst to the north west the area is
occupied by a saltworks. A quarry lies to the northwest at a distance of approximately
10 km.
PORT LIMITS
The area enclosed by the Port limits is described in the following paragraphs
(Government Gazette No. 19401 of 28 October 1998).
The seaward area of the port is bounded by a line commencing at the extreme point on
the east bank of the Swartkops River thence due east (true) for a distance of one
nautical mile (1609 m) to a point in the Indian Ocean; Then from that point to a
second point in the Indian Ocean one nautical mile due east (true) from Cape Recife;
then from that point to a third point in the Indian Ocean one nautical mile south east
(true) from the extreme point on the east bank of the Sunday’s River; then along the
high water mark between the extreme point of the east bank of the Sunday’s River
and the extreme point of the east bank of the Swartkops River, excluding the Islands
of Jahleel, St Croix and Brenton, and the 500 m marine reserve surrounding each
island. This enables the Port authority to control all shipping activities within the
defined area.
The land area of the port is bounded to the north west by the N2 national road; to the
north east by the boundary between Hougham Park and Sonop Farms; to the south
west by the line joining a point on the N2 National Road and the high water mark,
which will become the boundary between St George’s Strand and the Coega IDZ; to
the south east by the high water mark between these two boundaries. This area will be
vested in the port authority, presently Transnet.
12
3
Chapter
DESCRIPTION OF THE TASKS TO BE

CONDUCTED IN COMPILING THE
SUBSEQUENT ENVIRONMENTAL IMPACT
ASSESSMENT
PLAN OF STUDY
This Plan of Study will be submitted to both the national and provincial authorities.
While the national Department of Environmental Affairs and Tourism is the
designated authorising authority, it is suggested that the contact point for all
submissions should be the provincial Department of Economic Affairs, Environment
and Tourism. This will allow for easy contact on a day-to-day basis if and when
necessary.
AUTHORITY CONSULTATION
PRE APPLICATION MEETING
In the light of the NEC decision that a revision of the Environmental Impact Report
was required to accommodate the changes resulting from the incorporation of a
container terminal at the proposed Port of Ngqura an authorities meeting was
convened on July 6th 2000 to establish the requirements of the revised investigation.
The meeting was attended by:
Representative Department / Organisation

National Department of Environment Affairs and
Gottlieb Arendse
Tourism
National Department of Environment Affairs and
Flora Mokgohloa
Tourism
Provincial Department of Economic Affairs
Andries Struwig
Environment and Tourism (Chairman)
Jannie van As Department of Mineral and Energy Affairs
Themba Koza Coega Development Corporation
Mpumi Mabula Coega Development Corporation
Nick van Amstel Portnet
Mike Cohen CEN IEM Unit
13
The meeting stipulated the process that needs to be followed during the revision of the
environmental impact assessment and conducted a preliminary identification of the
additional assessments that would be required for the revised assessment.
PROCESS FOR THE REVISED EIR
The meeting stated that the legal framework as set by the EIA regulations
promulgated in terms of section 26 of the Environment Conservation Act, 73 of 1989,
should be followed as closely as possible. The following process was agreed upon.
¯ Meeting to discuss revision of the port EIR.

¯ Submission of a plan of study for scoping for the revision of the port EIR to
DEAT with a copy to DEAE&T. This plan of study determines the broad
Terms of Reference for the investigation.
¯ Approximate time frames for the investigation must be illustrated.
¯ An application form must be submitted with the plan of study for scoping.
¯ A second Consultation Meeting might be required. The authorities will decide
on the necessity for a second consultation meeting.
¯ A scoping report must be compiled. The scoping report should include a
section that sets out the background and the need for the revision of the port
EIR, a new project description as well as all the additional issues/concerns that
will be investigated/reviewed.
¯ Specialist studies that are necessary for the revision of the EIR must be listed.
¯ Compilation of the EIR
¯ Release of the revised port EIR for public comment.
The need for adequate public participation was stressed.
PORT DESIGNS
The consulting engineers, Portnet and P&O Nedlloyd are currently considering two
configuration options for the port. These design options provides for approximately
600m of berth length for container handling. The requirement as stipulated by P&O
Nedlloyd was for an initial 1100m of berth length with a long-term requirement of
1300m of berth length.
The environmental assessment will determine the impacts associated with the two
preferred port configurations unless the consulting engineers, Portnet and P&O
Nedlloyd table a firm proposal for one port configuration.
The two configurations do not include the long-term configuration for the port. A
master plan for a final port configuration will be designed and the environmental
impacts associated with the “Master Plan” assessed.
ISSUES AND CONCERNS

IDENTIFIED BY AUTHORITIES
The following issues/concerns were identified at the authority meeting and during
scoping as the minimum requirements that need to be assessed during the revision of
the port EIR.
14
¯ Increased shipping in Algoa Bay
- Increased risk associated with increased shipping
¯ Larger back of port area
¯ Water quality
¯ Transportation related to activities
¯ Links to harbour
¯ Stockpiles etc.
¯ Additional material needed from Coega Kop
- Rock
- Stone. This needs to be conveyed to Coastal Environmental Services in
order for them to consider the implications for the Coega Kop Quarry
EMPR.
¯ Impacts on other harbours notably Port Elizabeth and Durban. This must
include an assessment of the potential economic and social impacts
¯ Increased shipping speeds
¯ Visual impact – including the increased lighting
¯ Noise impact – increased noise levels
¯ Increased impact on foredunes
¯ Waste disposal related to construction – excavation material
¯ Ballast water
¯ Bio- monitoring – relation to port construction and operation
¯ Impact on the Coega Salt Works and mariculture operation
¯ Duration of construction
¯ Sustainability of the harbour. The investigation must consider the
sustainability / viability of the current designs linked to the assessment of the
potential impacts on other harbours as well as the potential impacts of the long
term requirements that would need to be accommodated at the Coega harbour.
The authorities indicated that the revised EIR must include an assessment of the two
designs presented at the meeting but must take into account the requirements of P&O
Nedlloyd, namely, a container berth length of 1300m. If a final option has been
decided on by the engineers, Portnet and P&O Nedlloyd prior to the commencement
of the environmental investigation this will be the only option considered. Options
raised during the public participation phase of scoping will be commented on.
The revised EIR must also include a section on the long-term development potential
and the impacts that could be associated with it.
ADDITIONAL ISSUES
Desktop Review
During scoping the environmental consultant reviewed the December 1999
Environmental Impact Report to ensure that all issues addressed in the report are
revised to accommodate any change related to the changed configuration of the
proposed port. The following table extracted from the scoping report illustrates the
revisions, which will be necessary for the subsequent EIR.
15
Ø Table 1: Summary of Impacts Relating to the Construction of the
Redesigned Port of Ngqura
Actions and Environmental Aspects with Low Significant Adverse Impacts
Construction Phase of the Port Development
Reassessment
Action and Environmental Concern Notes
Required
The removal of additional beach and dunes may

Archaeological and Paleontological Yes impact on archaeological sites of importance not
yet studied
Disturbance and Loss of Habitat
The initial assessment called for an investigation

Estuarine Birds – if alternative habitat is
Yes of available habitats in the vicinity of the pans.
available in Algoa Bay
This study has not been undertaken
The additional shoreline development may
Shorebirds Yes
reduce the area of habitat available to shorebirds
Vegetation
The additional development will cause the

Salt marshes, Dune woodlands, Yes removal of more dune and salt marsh area than
initially estimated.
Terrestrial Herpetofauna, Mammals,
Avifauna and Invertebrates
The increased back of port area and the long term
development of the port will reduce the area of
Herpetofauna, Mammals, Avifauna Yes available habitat for most species occurring in the
area defined as port. This may have implications
for the Albany Dwarf Adder
Actions and Environmental Aspects with Moderate Significant Adverse Impacts
Reassessment
Action and Environmental Concern
Required
Biophysical Impacts
Disturbance and Loss of Habitat
16
Reassessment
Required
The initial assessment called for an investigation

Estuarine Birds – if no alternative habitat is
Yes of available habitats in the vicinity of the pans.
available in Algoa Bay
This study has not been undertaken
Terrestrial Herpetofauna, Mammals,
Avifauna, Invertebrates
The additional long term development of the land
Aloeides clarki Yes side infrastructure may impact on the population
of Aloeides clarki
Social Impacts
The loading and unloading of containers and the

Noise Yes movement of containers from the port may cause
additional impacts not previously considered
Actions and Environmental Aspects with a Moderate Significant Beneficial Impact
Reassessment
Economic Impacts
Required
The construction of a container terminal may
Generation of jobs Yes have an impact on the number of construction
jobs that will be generated for the development
Actions and Environmental Aspects with a High Significant Adverse Impact
Reassessment
Required
Vegetation
The increased back of port activities may cause

Foredune and Hummock Communities, Mesic
Yes additional impacts to the dune, thicket and
Succulent Thicket, Bontveld
bontveld communities
Social Impacts
Economic Impacts
The change in configuration to the port may

Coega Salt Works Yes cause additional impacts to the salt works
operation
17
Ø Table 2: Summary of Impacts Relating to the Operation of the
Redesigned Port of Ngqura
Actions and Environmental Aspects with Low Significant Adverse Impact
Operation Phase of the Port Development
Reassessment
Required
Biophysical Impacts
Vegetation
Salt marshes, Foredune and Hummock

The port operation may cause additional impacts
Communities, Mesic Succulent Thicket, Yes
to the vegetation of the zone identified as port
Bontveld
The additional developments and activities in the
Herpetofauna, Mammals, Avifauna and
Yes port zone may cause impacts not considered in
Invertebrates
the previous assessments
Fishing Grounds
The impacts related to increased shipping related

Shipping lanes Yes to the container terminal will have to be
reassessed
The impacts related to increased shipping in the
Shipping on squid Yes
Bay will need a reassessment
The impacts related to increased shipping in the
Purse seining Yes
Bay will need a reassessment
Actions and Environmental Aspects with a Low Significant Beneficial Impact
Reassessment
Economic Impacts
required
The construction of a container terminal may
Generation of jobs Yes have an impact on the number of construction
jobs that will be generated for the development
Actions and Environmental Aspects with a Moderate Adverse Significant Impact
Reassessment
Action and Environmental Concern Required
18
Biophysical Impacts
Herpetofauna, Mammals, Avifauna and

Invertebrates
The increased back of port activities may impact
Aloeides clarki Yes
on the population of Aloeides clarki
Social Impacts
The increased development of the port and the

Visual Yes back of port activities may have additional
impacts on the visual aspects
Actions and Environmental Aspects with a High Adverse Significant Impact
Reassessment
Required
Economic Impacts
Additional impacts may be created through the

Coega Salt Works Yes
increased back of port activities
Ø Table 3: Areas Requiring a Risk Assessment
Increased Shipping
Accidents Risk assessment required Reassessment
Collision with whales Moderate Risk Reassessment
Risk assessment and contingency

Pollution and Oil Spills Reassessment
plan
Risk assessment and national
Ballast water and release of alien organisms Reassessment
policy and guidelines
The identified issues, which may be affected by the change in the port configuration,
will be re-evaluated in terms of the new proposal. Where possible, the specialists who
conducted the initial surveys / investigations will be requested to review their
19
conclusions and evaluation of the identified impacts in the light of the proposed
changed design and configuration to the proposed port. If the specific specialist who
undertook the initial investigation is unavailable for the reassessment, a new specialist
will be appointed to conduct the re-evaluation based on the initial specialist report.
All specialists will be requested to assess the potential impacts related to the full
development as illustrated in the proposed master plan for the port.
Specialist Review
The environmental consultant appointed for the revised environmental assessment
should request all of the specialists who undertook investigations for the first revised
impact assessment to review their specialist reports in the light of the changed port
configuration and in terms of the proposed final development.
The findings of the specialists will be incorporated into the revised impact
assessment.
The environmental consultant will also review the full draft environmental impact
report (December 1999) and ensure that all issues identified are updated to address the
new port configuration and the long-term perspective.
Additional Specialist Studies
The inclusion of a container terminal in the Port of Ngqura will necessitate that
additional specialist investigations are undertaken. The potential costs and benefits of
a container terminal on the existing Port Elizabeth Port, East London Port and on the
Port of Durban will need to be assessed. This assessment should also consider the
viability of a container hub in Port Elizabeth, as opposed to the proposed Durban Hub
and the proposals for a Port in Southern Mozambique, which may become a major
entry and exit port for goods and products to and from Gauteng. Consideration of the
suitability of the transportation network from Port Elizabeth to the hinterland should
be commented on.
A further study on the economic viability of the phase-one port development of the
Port of Ngqura will need to be undertaken.
These studies will allow the relevant authorities to make an informed decision on the
sustainability of a container terminal at Coega and to ensure that if the port proceeds it
will be ecologically, socially and economically sustainable after completion of the
first phase of the development.
This plan of study does not define the Terms of Reference for the studies and the
environmental consultants will determine the Terms of Reference for the specialists
and make the necessary appointments. The Terms of Reference will be submitted to
the authorities for approval before the appointments are made.
Full Development
The assessment will cover both the phase 1 development and the full development.
The revised environmental impact assessment (December 1999) only considered the
phase 1 development, but included a diagram of what the potential full development
would incorporate. The revised EIR will address the full development and include the
20
landside developments. As it is unlikely that the detail of the landside development
will be available at this early stage of planning a model, which speculates, on the
configuration of the full landside development will be used to make an assessment of
the environmental impacts.
EVALUATION OF IMPACTS
In order to keep the various reports produced as part of the various assessments for
the proposed Coega post consistent the same methods of assessment will be used for
the second revision. There are summarised below.
Impact Measurement and Significance
It is normal practice in environmental impact assessments to use a set of criteria for
the description and assessment of environmental impacts. The criteria suggested by
the Department of Environment Affairs, in their draft document on Guidelines for
Comprehensive Environmental Impact Reports (Department of Environment Affairs
and Tourism 1997) include the following:
Extent:
Ø Whether the impact will occur on a scale limited to the immediate areas or site
(Port area) of the development activity or will the impact occur on a regional
(Algoa Bay) and or national scale.
Duration:
Ø Whether the lifetime of the impact will be of a short duration (0-5 years); medium
term (5-15years); long-term (>15 years, with the impact ceasing after the
operational life of the development); or considered permanent where mitigation
either by natural process or by human intervention will not occur in such a way or
in such a time span that the impact can be considered transient.
Intensity/Magnitude:
Ø Whether the intensity (magnitude / size) of the impact is high medium, low or
negligible (no impact). Where possible the intensity of impacts will be quantified.
Probability:
Ø The probability of the impact actually occurring as either improbable (low
likelihood); probable (distinct possibility); highly probable (most likely) or
definite (impact will occur regardless of preventative measures)
Legal Requirements:
Ø The specific legislation on permit requirements, which potentially could be
infringed upon by the proposed project, including reference to the procedures
required to obtain them.
The above are evaluated in terms of:

Significance 1:
Ø The significance of impacts of the proposed project are assessed with the
mitigation measures which will be included in the contract as well as with the
additional mitigation measures recommended in this report being implemented.
The significance of the identified impacts on the components of the affected
environment (and where relevant, with respect to potential legal infringement) are
described as:
1
The modified ratings of significance are based on the sy stem proposed by the Department of Environment Affairs and Tourism
21
No Impact
Ø Where the project action will not cause any adverse or beneficial changes to the
natural (biophysical), and/or social environment.
Impact of Low Significance
Ø Where the project actions will result in minor short-term changes to the
biophysical and/or socio-economic environment. The impacts will usually be
restricted to the immediate area of the project action. The affected system should
return to its natural or almost natural state in a short period of time (0 – 5 years).
The impacts on human populations will be of a short duration and will not have
any lasting consequences.
Impact of Moderate Significance
Ø Where the project actions will result in moderate short-term or medium term
changes to the biophysical and/or socio-economic environment. The effects of the
impact could be experienced outside of the project action area and may be evident
at a sub-regional or even a regional level. Minor indirect impacts may arise from
the project action. The system should recover but it is unlikely that it will return to
its natural state. Recovery would only take place in the medium term (5-15 years).
Impacts on the human population will be felt after the project action is completed
but are not severe and/or disruptive to their quality of life or economic well being.
Impacts of High Significance
Where the project actions will result in major long-term changes to the biophysical
and/or socio-economic environment. The effects of the impact will be experienced
outside of the project action area and may be evident at a regional, nationa l and even
at the international level. Secondary or indirect impacts may arise from the project
action. The system may recover over the long-term (>15 years) but will not revert to
its natural state. Impacts on human populations will be felt after the project action is
completed. The impacts are of a long-term nature and are disruptive to the previous
life style of the affected population.
- Determination of significance is made only after the specialist study

reports have been completed and other available information reviewed, and
- On the assumption that any mitigation measure which is recommended
will be implemented.
Mitigating Environmental Effects
Mitigation measures are technically and economically feasible measures that will
mitigate a project's likely environmental effects. Mitigation is the elimination,
reduction, or control of a project's adverse environmental effects, including restitution
for any damage to the environment caused by such effects through replacement,
restoration, compensation, or any other means.
Mitigation is used to address all adverse environmental effects, whether or not

subsequent analysis determines that the effects are significant. The development of
the mitigation measures commenced during the initial impact assessment and ma ny
have become part of the project design. Relevant mitigation measures should form
part of any contract for the project.
Status of the impact:
Ø This describes whether the impact is positive (a benefit) or negative (a cost), or
neutral.
22
Degree of confidence in predictions:
Ø The degree of confidence in the predictions, based on the availability of
information and/or specialist knowledge.
ALTERNATIVES
The initial environmental investigation reviewed a number of alternatives. Additional
alternatives were mentioned during the scoping phase for the subsequent
environmental assessment. The report will comment on the various alternatives.
PUBLIC PARTICIPATION PROCESS
RELEASING OF THE COEGA DOCUMENTATION
The Draft EIR (December 1999) was released to the public during August 2000 and
served as a base line study that could be referenced during the review of the revision
of the EIR. The Draft Port EIR was released together with the Environmental Scoping
Report for the subsequent environment assessment. Comment made on the draft EIR
and the scoping report will be considered in the subsequent EIR.
The consultants appointed by the CDC for the Public Participation Process (PPP) will
be requested to compile a detailed programme, which allows adequate time for public
participation and for comments on the subsequent EIR. This programme will be
submitted to the authorities before work commences on the subsequent EIR.
23
4
Chapter
CONSULTANTS
Consulting Engineers Environmental
Prestedge Retief Dresner Wijnberg CEN Integrated Environmental
Marina Centre Management Unit
West Quay Road 36 River Road
Victoria and Alfred Waterfront Walmer
Cape Town Port Elizabeth
6070
Contact Person.
Dr Allan Wijnberg Contact Person
Telephone: (021) 418-3830 Dr Mike Cohen
Fax: (021) 418-3834 Telephone: (041) 581-2983
E- mail: awijnberg@prdw.co.za Fax: (041) 581-2983
E-Mail:
steenbok@iafrica.com
CEN Integrated Environmental Management Unit has been appointed to compile the
Plan of Study and the Scooping Report. An environmental consultant needs to be
appointed for the revision of the environmental impact assessment. The CDC will
inform the authorities once this appointment has been made.
24
This document remains the property of CEN Integrated
Environmental Management Unit, subject to its use by the client
for the particular project to which this appointment relates.
APPENDIX B:
COEGA DEVELOPMENT CORPORATION
ENVIRONMENTAL MANAGEMENT
SYSTEM AND POLICIES
BACKGROUND TO APPENDIX B
The vast majority of Appendix C comes from the Coega Rezoning EIA (CES 2000). The
environmental policies, guidelines and systems outlined below are subscribed to by the Coega
Development Corporation. The back of port area assessed in this EIR report was undertaken with
limited information and were assuming that the principals and mechanisms outlined below will be
implemented and adhered to.
1) ENVIRONMENTAL POLICY
The CDC subscribes to principles intended to guide the development in a manner that is
ecologically sustainable, socially acceptable and economically viable.
Furthermore, regarding environmental management of the Coega DZ and Core Development Area,
the CDC will:
• apply world-class management practices;

• ensure sustainability;
• conform to legislative and regulatory requirements;
• develop, implement and maintain an (ISO 14001) Environmental Management System;
• establish baseline data with integrity; and
• maintain an integrated monitoring system.
The Environmental Policy is the instrument by which the CDC, custodian of the DZ, states its
commitment to these and other principles and establishes the framework by which the principles are
turned into actions. The Environmental Policy is outlined below:
The Coega Development Corporation aims to apply world-class environmental management

practices to DZ activities, and in so doing, to become the model for similar developments
throughout Africa. To achieve this aim and develop the Coega DZ in a manner that is economically,
ecologically and socially acceptable and sustainable, the Coega Authority undertakes to:
1. Ensure ongoing opportunities for public and stakeholder involvement throughout all stages of
DZ development.
2. Provide beneficial economic and employment opportunities for businesses and communities in
the region.
3. As a minimum, require adherence to all legislation and government policy relevant to the
development of the DZ and pertaining to the environment and to the health, safety and well-
being of the public and stakeholders.
4. Establish and maintain an Environmental Management System to:
• determine aspects of the DZ development which may significantly impact on the environment;
• plan actions to mitigate negative impacts and enhance positive impacts;
• set responsibilities and timelines for implementing these actions;
• periodically audit and review progress
in order to achieve a continual improvement in the:
• environmental performance of individual tenants and the zone as a whole;
Appendix B: CDC – Environmental Management Policies and System 1

• efficient utilisation of resources such as water and waste within the network of the
development;
• prevention of waste and pollution where feasible
throughout all phases of the development.
5. Work with companies operating within the DZ and harbour to ensure appropriate
environmental management of the terrestrial, nearshore and marine environments.
6. Within the scope of our authority, prevent conditions that compromise the health and safety of
people within and in the vicinity of the DZ.
7. Limit potentially detrimental effects of the DZ development, including:

• economic loss or disruption to communities due to establishment of activities within the DZ
• nuisance due to noise or odours
• visual impact due to structures or activities associated with the DZ
8. Maintain environmental integrity and protect those species within the DZ that are:
• found in the Red Data List of endangered species
• deemed conservation-worthy by the relevant authority
9. Follow a phased planning and development approach, and integrate planning of the DZ with
that of the Port Elizabeth-Uitenhage-Dispatch region.
This policy will be reviewed on an annual basis, and is available to any interested party on request.
2) ENVIRONMENTAL MANAGEMENT SYSTEM

The Environmental Management System (EMS) for the Coega DZ is the overarching instrument by
which the CDC intends to ensure that those activities which can either have a significant beneficial
or detrimental effect on the environment are properly managed (see Figure B.2a). The EMS has
been developed in accordance with the requirements of the internationally recognised standard for
environmental management, ISO 14001.
The EMS encompasses all activities related to the design, construction and operation of the DZ and
which occur within the boundary of the proposed DZ, excluding port or marine-related operational
activities that fall under the responsibility of Portnet. However, due to the interdependence of the
DZ and harbour, some activities within the realm of Portnet control will be given management
priority within the CDC EMS.
Roles and responsibilities

The key role-players in the Coega EMS are: the CDC, Concessionaires and Tenants and the
Ngqura Environmental Committee (NEC).
(i) CDC
The CDC is the body responsible for management of the DZ and related activities. As such, the
CDC provides the framework for activities within the zone, co-ordinates development, provides
resources and ultimately carries some accountability for the consequent outcomes, be they
beneficial or detrimental. The CDC is the custodian of and driving force behind the EMS, and has
appointed an Environmental Manager to ensure the effective implementation of the EMS. The
CDC’s primary task is to provide an enabling environment for investme nt. This is mainly an
administrative function, but it also includes activities such as: installation and maintenance of
infrastructure (e.g. roads, rail links, telecommunications); maintenance of common areas.
2 Appendix B: CDC – Environmental Management Policies and System

ALGOA BAY
TENANTS APPROVAL
PROCEDURE
MANAGEMENT
PLAN
OPEN SPACE
MANAGEMENT
PLAN
STAKEHOLDER
MONITORING
& REVIEW
ENVIRONMENTAL
COMMUNICATION MANAGEMENT SYSTEM ENVIRONMENTAL
DESIGN
MANUAL
ENVIRONMENTAL
ENVIRONMENTAL GUIDELINES
1. Noise
TARGETS Guideline
s
…………
………….
2. Air
Quality
EMP FOR …………..
………….
CONSTRUCTION
Figure B.2a: Aspects of the EMS designed to ensure that activities, which can either have a
significant beneficial or detrimental effect on the environment, are properly
managed
The entire spectrum of activities within the DZ has been considered in the development of the EMS.
Key activities which can be detrimental to the environment have been identified, and the CDC has
set environmental objectives and performance targets in consideration of these key activities. These
objectives and targets will establish a framework for all activities within the DZ, both for the CDC
as well as for tenants and concessionaires. The CDC will assess and regularly report on
environmental performance against these performance targets, and act in order to rectify breaches of
these targets.
(ii) Tenants and Concessionaires

Whereas the activities of the CDC are primarily administrative in nature, those of tenants and
concessionaires are not. Following the installation of basic infrastructure, tenant activities will
comprise the bulk of sub sequent activities, and therefore require appropriate management to prevent
undue detrimental impact on the environment. Tenants must retain first- line responsibility for these
environmental management actions, and may choose to employ their own EMS for this purpose.
Over and above these first- line actions, the CDC will be able to transfer requirements of its
overarching EMS onto specific tenants via a contractual agreement.

(iii) Ngqura Environmental Committee (NEC)

A third key role-player in the EMS is a committee representing governmental departments (at all
levels) which have a stake in the environmental management of the zone. This committee, the
Ngqura Environmental Committee (NEC), fulfils a triple role within the EMS, namely:
• acting as an ‘independ ent watchdog’ over the activities of the CDC, and regularly reviewing
the environmental performance of both the CDC and other activities within the DZ;
• for those members of the NEC who represent departments with a specific jurisdiction over
activities (e.g. Department of Water Affairs and Forestry, Department of Environmental
Affairs and Tourism), initiating when necessary any enforcement actions with respect to
breaches of legal requirements;
• providing a streamlined mechanism for decision making with respect to incoming activities
proposed for the zone. This decision- making process is guided by the Tenant Approval
Procedure.
Relationships between the various role-players

In terms of concessionaires and tenants within the zone, the EMS is based on the premise that their
relationship with the CDC is analogous to a tenant/landlord relationship. In simple terms the CDC
(the landlord) screens prospective tenants (using the Tenant Approval Procedure, see section 4), and
upon acceptance, enters into a contractua l agreement with the tenant. This agreement contains the
conditions under which the tenant may legally conduct operations within the zone, and these
conditions may include, for example, stipulations on environmental performance or conformance
with specific requirements outlined in EMS documentation. Conditions which the CDC wishes to
impose on the tenant which are over and above existing legal requirements (e.g. if water discharge
is to conform to a level more stringent than the General Standard) must explicitly form part of this
contract. Contracts will include a provision for duly authorised representatives of the CDC to enter
the premises of the tenant for the purpose of verifying compliance with the terms of the contract.
Thus the CDC will fulfil a role similar to that of a local authority.
In terms of the various government departments (as represented by membership on the NEC), the
EMS is based on the premise that routine interactions of these departments with specific tenants and
concessionaires will be on an indirect basis, through the CDC. In this non-traditional, indirect
model, the primary onus and responsibility for routine management and monitoring of tenant and
concessionaire activities shifts away from the relevant department toward the CDC. The CDC is
thus empowered to establish minimum criteria for environmental performance, as well as facilitate
the resolution of problems should non-conformance with these performance targets occur.
However, in compliance with current South African legislation, the minimum acceptable level of
environmental performance for the DZ will meet or improve upon the current requirements of the
relevant authorities, and these departments will retain their legislated responsibilities in terms of:
granting permits or authorisations in terms of various environmental management legislation (e.g.
Environmental Conservation Act, Atmospheric Pollution Prevention Act), enforcing the legal
requirements as stipulated in any legislation or authorisations under their jurisdiction, including
conditions contained in any such authorisations.
EMS mechanisms for environmental control in the DZ

Within the scope outlined above, a comprehensive set of CDC activities with the potential to cause
environmental impacts has been identified. The potential environmental aspects and associated
impacts for each activity has been noted, and the relative importance of these environmental aspects
and impacts rated according to criteria agreed by both the CDC and NEC. The resulting set of
significant aspects and impacts forms the basis for the CDC environmental objectives contained in
the environmental policy (see section 1), as well as specific performance indicators and targets (see
section 3). The significant aspects and impacts also form the basis for determination of control and

monitoring measures which form the core of any environmental management system. The control
measures are discussed in detail later in this section. Table B.2a below contains examples of some
key activities, their associated environmental aspects and potential impacts, and the EMS control
measures that have been established in order to manage the environmental aspects.
Table B.2a: Examples of activities, some environmental aspects and related control measures.
Activity Environmental Possible Environmental Control Measure

Aspects Impacts
Operation of • Selection and siting • Cumulative impacts • Tenant Approval
industry or of activities • Degradation of air and procedure (&
commerce within • Emissions to air, water quality associated
tenant or water guidelines)
concessionaire areas
Design of • Decisions regarding • Visual impacts • Environmental
infrastructure and the nature and • Effects on traffic Design Manual
operations within location of • Noise • Environmental
DZ structures Guidelines
Construction • Operation of • Employment • EMP for
activities within the earthmoving • Noise Construction
DZ equipment Degradation of water
• Establishment of quality
construction sites • Disturbance to
conservation- worthy
species
Maintenance of • Type of plant species • Water consumption • Open Space
open spaces used (indigenous vs. • Encroachment of alien management plan
non- indigenous) species • Environmental
• Labour requirements • Employment Guidelines
3) ENVIRONMENTAL TARGETS
Environmental targets for the Coega DZ have been formulated as part of the development of the
EMS. The CDC has set targets, the proposed indicators of which will be measured are available,
although they have not yet been approved. The indicators are presented here as an indication of the
comprehensive suite of factors that will be monitored to ensure effective environmental
management within the DZ.
(a) Communication Indicators
1. Number of communications to public per year
2. Number of communications from the public per year
3. Incorporation of communications into decision making
(b) Economic and Employment Indicators
1. Capital investment per year within the DZ
2. Number of business registrations per year
3. Foreign exchange generated per year by companies in the DZ
4. Number of people employed in companies in DZ
(c) Compliance with Government Legislation & Policy: Indicators
1. Number of incidents of non-compliance with relevant legislation per year
2. Adherence to government policy
3. Number of public nuisance complaints per month

(d) EMS Indicators

1. Progress towards implementatio n of EMS
2. Number of non-conformances in the EMS
(e) Integrated Planning Indicators
1. Progress towards an integrated plan
(f) Tenant Indicators

I. Ambient air quality
Number of exceedances of ambient air quality targets
SO2 ground level concentrations (µg/m3 )
Particulate matter (PM10 and TSP) ground level concentrations µg/m3
Carbon monoxide
Particulate lead
Nitrous oxide
Ozone
II. Water quality and quantity
PH Electrical conductivity
Chemical oxygen demand (COD)
Groundwater quality
pH
Electrical conductivity
COD
III. Land: waste
Tons of hazardous waste generated per annum
Volume of waste disposed per annum
IV. Flora and fauna
Adherence to landscaping practices
Total open space area
V. Marine Water quality
Contaminants in sediments
Bio indicator species
Water column chemistry
Number of breeding pairs Roseate terns
(g) Limit Detrimental Effects: Indicators
Increase in informal settlements in DZ per year
Displacement of communities (welfare indicators - used in social study)
(h) Health and Safety Indicators
Lost time (or disabling) injury rate
Number of lost time injuries
Occupational health-related diseases in workers in DZ
Traffic accidents
(i) Maintain Ecological Integrity & Conserve Rare Species: Indicators
I. Change in species habitat
Total open space area in ha
II. Species richness
Sustainability of butterfly population
Sustainability of Coega Kop flora
Sustainability of Roseate terns on the islands
% cover of alien plant species in open space areas

4) TENANT APPROVAL PROCEDURE

The Tenant Approval Procedure (TAP) is presently being developed to help the CDC screen tenants
and to assist prospective tenants within the Coega DZ to meet requirements to comply with South
African environmental legislation and current best practice. The TAP aims to:
• assist the applicant with the identification of permit requirements associated with proposed
activities in accordance with the relevant environmental legislation.
• assist the applicant by streamlining the process for applying for the necessary permits.
• communicate to the applicant the environmental requirements (emission levels etc.) according
to the environmental legislation and the CDC’s requirements.
• identify key aspects of the applicant’s proposed activities that require further assessment or
further information to enable a decision to be made by the decision- making authorities.
• collect information required by the CDC to facilitate the effective environmental management
of the CDZ e.g. to assist in the long term planning of the CDZ, emergency response and the
provision of environmental services to tenants.
• assist the CDC and relevant authorities to assess the desirability of accepting proposed activities
in the Coega DZ.
Prospective tenants are required to fill in a detailed form designed (in part) to ascertain potential
environme ntal issues. The form focuses on:
• nature of the activity

• proposed timing (planning, construction, commission, operation, decommission, closure)
• employment potential
• land requirements: site location and size
• activities listed in the EIA regulations
• emissions and odours
• hazardous materials
• noise
There is also a separate technical component of the TAP concerned with infrastructure
requirements. It is possible that certain proposed tenants will not be admitted to the Coega DZ,
although the main objective of the TAP is to assist prospective tenants.
5) EIAs/ SCOPING
Activities identified in Government Notice No. R. 1182 of 5 September 1997 under Section 21 (1)
of the Environment Conservation Act, No 73 of 1989, require a Scoping Study and/or
Environmental Impact Assessment (EIA). No identified activities are permitted in the Coega DZ
unless approved by the relevant authority - usually the Department of Economic Affairs,
Environment and Tourism (DEAE&T) in the Eastern Cape.
It is expected that a number of tenants wishing to locate in the DZ will undertake activities which
invoke the EIA regulations. Scoping studies/EIAs can be time-consuming exercises, but it is likely
that Scoping Reports/ EIAs for activities in the Coega DZ will be expedited by existing baseline
information about the Coega area. Furthermore, it is proposed that a protocol will be developed and
agreed with DEAE&T, to allow for a streamlined procedure. This protocol will be based on the
TAP and other guidelines, and will highlight areas of non-compliance. However, tenants locating in
the DZ will not be exempted from the EIA regulations.

6) ENVIRONMENTAL DES IGN MANUAL

An Environmental Design Manual (Appendix B – Coega Rezoning EIA CES 2000) is intended as a
guide to the Coega Implementing Authority (IA), tenants, developers, consulting engineers,
architects, contractors and other parties likely to invest in or assist with the development of the
Coega DZ. These environmental guidelines are intended as an addendum to the guidelines that
typically apply in the engineering, architectural, construction, landscaping and other relevant
professions. They do not replace the (technical) guidelines that are used as standard industry
practice in most professions. The purpose of these guidelines is to provide a reference source of
guidelines to assist professionals working in the DZ to perform their work with due regard for
environmental issues.
The guidelines are presented to reflect the anticipated phasing of development within the DZ, and
are as follows:
• Planning and Zoning Guidelines.

• Infrastructure Guidelines.
• Building / Architectural Guidelines.
• Landscaping Guidelines.
7) EMPs FOR CONSTRUCTION

The Construction Environmental Management Procedure (EMP) incorporates specifications to
minimise negative environmental impacts and enhance the positive environmental impacts during
the construction work within the CDZ (Appendix C – Coega Rezoning EIA CES 2000). The EMP is
intended for dissemination by the CDC to approved concessionaires/tenants or persons responsible for
the infrastructure works who shall ensure that it is included in the Tender Document(s) issued to the
prospective contractors. The contractors shall incorporate the requirements of the EMP in their
submissions to the concessionaires/tenants.
The EMP incorporates specifications designed to limit impacts associated with the following
activities/facilities:
• demarcation of environmentally sensitive areas

• location of camp and depot
• demarcation of the site
• access to beach
• toilets
• domestic waste water
• refuse
• protection of the fauna and flora
• defacement of natural features
• protection of archaeological and palaentologial sites
• effluent and stormwater management
• dust control
• noise control
• materials use, handling, storage and transport
• emergency procedures
• social issues
• site clearance
• site rehabilitation
The EMP includes a system for internal and external monitoring of the implementation of the EMP
and for corrective action.

8) ENVIRONMENTAL GUIDELINES
Environment guidelines (and principles) have been formalised for air pollution and noise and are
presented here:
Air Pollution Guidelines

Key guidelines to manage air pollution within the Coega DZ include:
• initially no industry may use a disproportionate amount of the total maximum capacity of the
atmosphere
• visible plumes are to be disallowed
• create a 1 000m buffer zone around heavy industry in which no residential development occurs
• all material stores must be fully enclosed or surrounded by at least three retaining walls opening
away from prevailing winds
• industries must initiate monitoring programmes for their specific concerns at least three months
before commissioning
• expand list of substances subject to mandatory limit values to include lead, nitrogen oxides and
ozone
• compliance with air quality guidelines presented in Table B.8a below.
Table B.8a: Air quality guidelines recommended for the Coega DZ.
Substance Averaging Period Source of air quality Guidelines Initial guidelines:

guidelines or (µg/m3 ) 50% of limit value
standards (µg/m3 )
TSP 24 hours US Secondary (pre- 150 (a) 75
1990) NAAQS
TSP Annual average US Secondary (pre- 60 30
1990) NAAQS
PM10 24 hours US Primary NAAQS 150 (a) 75
PM10 Annual average US Primary NAAQS 50 25
SO2 24 hours EU Standard 250 125
SO2 Monthly average DEAT Guideline 130 65
SO2 Annual average WHO Guideline 60 30
TSP: Total suspended particulate concentrators

PM10: Particulate matter with the aerodynamic diameter less than 10µg/m3 which represents particles of a size that
would be deposited in and damaging to the airways of lower alveoli.
NAAQS: National Ambient Air Quality Standards
(a): Value not to be exceeded more than once per year
Compliance with these guidelines will be monitored by the proposed air monitoring programme. A
procedure is currently being developed to allocate pollution loads to certain areas of the DZ. A
dynamic model will be used to screen each prospective tenant in terms of their predicted air
pollution impacts against the recommended guidelines.
Noise Guidelines
Key guidelines to manage noise within the Coega DZ include:
• any noise from a source, or a combination of sources, measured in accordance with the
SABS 0103, must not cause a rating of level of ambient noise, measured on the boundary, to
exceed the maximum permissible rating level for the zone
• a noise impact investigation for certain activities will be necessary in certain circumstances,
as indicated in the noise impact procedure (Jongens Keet Associates 1999)

• aim for a “zero dB” increase in ambient noise level

• buffer zones should be established around zones with large in- zone noise levels
• noise emitted from a source should not exceed the maximum permissible rating levels of
outdoor noise for land-uses within and surrounding Coega, as indicated in Table B.8b.
Table B.8b: Maximum permissib le rating levels of outdoor noise for different zones.
MAXIMUM Lr (dBA)
ZONE Day Evening Night
Industry 70 70 70
Business; commercial 65 60 55
Residential; education 55 50 45
institute; hospital
Rural; recreational 45 40 35
Nature reserve 35 30 25
9) STAKEHOLDER COMMUNICATION
Thus far, most communication with the public around environmental (and other) issues about the
Coega Project has been through various public participation programmes designed for the SEA and
other EIA’s. In addition, the formation of a stakeholder committee representing a number of organs
of government has kept the authorities informed of developments at Coega.
In order to engage proactively with the broader public and I&APs, the Coega IA is developing a
communications strategy which will:
• determine the discreet target audiences for communication in terms of geographic spread,
appropriate communications medium, and society
• outline the core messages (including environmental) to be communicated to target audiences
• develop a programme of communication
As regards environmental information, it is proposed that a regular newsletter be distributed to

I&APs. This strategy is in its formative stages and will be revised regularly to respond to the
demands of the target audience.
10) OPEN SPACE MANAGEM ENT PLAN

A proportion of the DZ will be retained as Open Space. The boundaries of the designated Open
Space were determined during the SEA and confirmed for the Core Development Area in a
subsequent site verification exercise in 1997 and 1998. Open Space boundaries were delineated,
taking the following factors into consideration:
• vegetation
• rare and endangered species
• slopes
• aesthetics
• traffic
• dust
• noise
• proximity to sensitive features, e.g. wetlands
• Coega fault exclusion zone
• social impacts, e.g. community disruption

Open Space will have to be managed. At this stage it is premature to commence management of this
Open Space, but Terms of Reference (ToR) have been prepared for this task. The purpose of the
Open Space Management Plan (OSMP) is to formulate a plan for the management of the already-
identified open space and other non-developable areas – notably servitudes - within the Coega DZ.
These spaces have been defined in the Development Framework Plan (DFP) for the Coega DZ,
although it should be noted that precise boundaries will be determined during the development of
the OSMP. It is probable that there will also be smaller “islands” of open space within the industrial
clusters identified in the DFP, the management of which will also need to be incorporated into the
OSMP. The OSMP should also link with other plans governing land-use surrounding the DZ.
The OSMP should comprise baseline information, management goals and principles, appropriate
guidelines/manual, and the institutiona l arrangements required to implement and manage the plan,
including organisational structures, responsibilities and timing. The OSMP will be commissioned
once the formal go-ahead for the rezoning of the Core Development Area has been given.
11) ALGOA BAY MANAGEMENT PLAN

An Algoa bay Management Plan has been completed and was available to the public for comment.
The management plan produced was however a first draft and numerous activities were
recommended to be undertaken in order to implement the plan. The CDC recognises the importance
of co operative management of the Bay and negotiations will begin shortly to ensure that this plan is
fully developed and that all major stakeholders have input and are tasked with the required
responsibilities.
12) MARINE RISK ASSESSMENT AND MANAGEMENT

It is probable that marine risks will increase once construction of the Ngqura port commences,
continuing through into the operational phase. Portnet will assess these risks once approval for the
project has been received (Portnet letter, 19 May 1999). The approach to risk management will be
as follows:
• a hydrodynamic model will be commissioned once a decision to construct the port at Coega is
taken
• an oil spill contingency plan will be completed once more quantitative information about port
operations is available and the relevant risk assessment has been undertaken. This plan will also
be completed and implemented before operation of the port commences
13) MONITORING AND REVIEW

The traditional approach to environmental management in South Africa is the regulation of
environmental performance through legislation, policed by the appropriate authorities. In contrast,
an EMS is a self-regulating systems in which the organisation sets its own performance targets
(which, as a minimum, must comply with local legislation) and monitors its own performance. As a
result, an important component of the EMS is regular monitoring and review of environmental
performance in order to identify non-conformance and direct corrective and preventive action.
In the DZ, the following key environmental issues will be monitored:
• air quality, through a comprehensive real-time monitoring programme

• surface water, groundwater and nearshore seawater quality, through a water monitoring
programme
• water use
• volumes of solid waste produced
• changes in social conditions

• economic and employment impacts

• flora and fauna
There will be annual public report-backs on (monitored) environmental performance against targets.
In addition, regular internal and externa l reviews will be conducted to ensure that the EMS is being
effectively implemented. Furthermore the EMS will be the subject of regular management review,
where the CDC will evaluate the performance of the EMS and make appropriate revisions (to
targets) in order to ensure continuous improvement.

APPENDIX C:
SPECIFIC RECOMMENDATIONS
FOR INCLUSION IN THE CONSTRUCTION
ENVIRONMENTAL MANAGEMENT PLAN
1. BACKGROUND
Specific recommendations were made in the project description chapter of the Revised EIR (CEN
2000). This EIR has provided additional recommendations and included and updated the existing
recommendations in this Appendix. It must be noted that the recommendations outlined below are
meant to guide the formulation of the comprehensive construction and operational management
plans. In no way are the following guidelines a substitute for the development of the above
management plans.
This appendix has been broken into two main sections, i.e. general recommendations and dredging
recommendations. The section on general recommendations has several sub-sections; the first deals
with recommendations that apply to the entire development, while the second gives
recommendations on specific faunal and floral groups or specific habitats. The remaining sub-
sections deal with the recommendations to reduce the impacts associated with ship collisions, the
socio-economic impacts, visual impacts, the development of an Environmental Management
System (EMS) and recommended future studies. The dredging recommendations section is
similarly broken into three sub-sections viz. suspended solid guidelines, recommendations for
underwater blasting and deposition guidelines.
2. GENERAL RECOMMENDATIONS
2.1 GENERAL
2.1.1. Reporting structure
Environmental Reporting Structure
CDC
Environmental
Manager
Project Manager
Routine liaison and decision making
Local
Routine liaison and environmental decisions
Technical Officer PAD
Environmental Manager
Contractor Compliance Monitoring; Audits and work stoppage
Routine liaison
Environmental representative
The preliminary internal reporting structure outlined above will need to be finalised in the authority
approved Environmental Management Plans once the exact environmental interaction between the
CDC and PAD is finalised and the authorities indicate what independent monitoring requirements
they may require. The approved structure should be contractually sound and regularly reviewed to
ensure that it is effective.
Appendix C: Specific Recommendations 1

2.1.2 Access and traffic control

The Contractor shall provide 24-hour access control to the construction sites. Construction and
public traffic shall be duly separated and where necessary controlled by flagsmen. Road safety
regulations shall be imposed on site and actively monitored to the satisfaction of the Technical
Officer.
2.1.3 Access roads

Access roads should be limited in order to minimise disturbance to sensitive habitats. Specific
recommendations for different habitat types include the following:
• Access roads should, where possible, run parallel to the dune system, preventing
encroachment into this habitat.
• Access roads should be designed so that as little disturbance as possible occurs within the
Bontveld patches.
2.1.4 Areas identified as requiring protection

All areas, excluding those identified as construction sites, haul and access roads, and their
associated servitudes, shall be considered as protected areas. The Contractor shall only be allowed
to use additional areas subject to the approval of the PAD environmental officer.
Should areas within the identified construction sites require special protection, in the opinion of the
Technical Officer and/or the PAD environmental officer, the Contractor shall provide the necessary
facilities. These areas would include, but not be limited to, the following sites:
i) Archaeological sites
ii) Sites containing rare and endangered fauna and flora
iii) Steep slopes
iv) Areas below the high water mark
v) Areas below the 1:10 year flood line
vi) Offshore islands
2.1.5 Site clearing and stabilisation

a) The Contractor shall, prior to commencing with the clearing of any area, undertake a survey to
identify potential protected sites. On the identification of any potential sites, the Contractor shall
immediately inform the Technical Officer who shall ensure, in consultation with the PAD
environmental officer, that the necessary instructions are given to proceed.
b) The Contractor shall give special attention to preventing the remobilisation of dunes, exposure of
large areas of unconsolidated fine sands and unnecessary removal of ground cover.
c) Sand or sandy soil areas shall be stabilised against erosion by wind or rainfall runoff.
d) Immediately subsequent to exposure of erodable surfaces, the Contractor shall stabilise the
surfaces at slopes not steeper than 1:1.5.
2.1.6 Rehabilitation
The Contractor shall, subject to the approval by the Technical Officer and PAD environmental
officer, undertake the rehabilitation of the site using appropriate indigenous vegetation. All
temporary works shall be removed and disposed of. Prior to commencing with this work, the
Contractor shall submit a plan in accordance with the Environmental Management Plan, for
approval by the Technical Officer in conjunction with the PAD environmental officer.
2 Appendix C: Specific Recommendations

2.1.7 Dust control

The Contractor shall maintain dust control over the entire construction site. This shall be
undertaken by providing immediate cover to exposed areas and by implementing mechanisms to
suppress dust under all expected working conditions on site. The Contractor shall undertake special
measures in areas immediately adjacent to the salt works to prevent dust dispersion. Failure to
comply with this requirement shall empower the Technical Officer and/or the PAD environmental
officer to stop the works until compliance is achieved.
2.1.8 Waste disposal

No disposal of waste will be allowed on site. The Contractor shall, prior to the commencement of
the works, submit a detailed waste management programme for the construction site to the
Technical Officer. This programme shall address the following issues:
i) Inventory of expected wastes
ii) Category of waste
iii) Plan of dealing with waste
iv) Compliance with local authority requirements
v) Auditing and monitoring
vi) Dealing with accidental spillages and clean-up
The Contractor shall maintain a clean and tidy site at all times. The Technical Officer and/or the
PAD environmental officer shall impose spot fines of up to R1 000 per incident on the Contractor
for staff found littering.
2.1.9 Fires
No fires shall be allowed on site without the permission of the Technical Officer in consultation
with the PAD environmental officer. All approved fires shall be controlled by the Contractor with a
view to preventing “run away fires” and excessive smoke. The Contractor shall pay special
attention to prevailing wind conditions and its potential to transport particulate matter into the salt
works area.
2.1.10 Handling, storage and disposal of hazardous substances

The Contractor shall comply with the legislated requirements for the handling, storage and disposal
of hazardous substances. An inventory of all hazardous substances on site shall be submitted to the
Technical Officer, PAD environmental officer, CDC environmental officer and the Provincial
Environmental Authority. The Contractor shall ensure that all relevant personnel are familiar with
the proper use, hand ling and disposal of hazardous substances.
2.1.11 Emergency procedures

The Contractor shall submit a detailed Emergency Plan to the Technical Officer for the site, prior to
the commencement of the works. Issues addressed in this document shall include:
i) Fires
ii) Flooding
iii) Accidents on site
iv) Spillage of hazardous substances
v) Storm events
The Contractor shall appoint a responsible person for the management of emergency situations, who
shall report to the Technical Officer at all times.
2.1.12 Stormwater management

Stormwater on site shall be collected from disturbed surfaces such as roads and cleared areas, and
suitably conveyed to discharge points in natural watercourses in a manner that does not cause

erosion and is to the satisfaction of the Technical Officer, the PAD environmental officer and the
Department of Water Affairs and Forestry. The Contractor will be required to comply with all
existing South African legislation.
2.1.13 Compliance with South African environmental legislation

The Contractor shall comply with all applicable legislation pertaining to the protection of the
environment. The cost of compliance will be deemed to be included in the rates and prices in the
Contract. The Contractor shall, in particular, comply with the following acts:
i) The Environmental Conservation Act (1989)

ii) The National Environmental Management Act (1998)
iii) The Sea Shore Act (1935)
iv) The Minerals Act (1991)
v) The National Water Act (1998)
vi) The Dumping at Sea Control Act (1980)
vii) International Convention for the Prevention of Pollution from Ships Act (1986)
viii) Prevention and Combating of Pollution of the Sea by Oil Act (1981)
ix) The Shipping General Amendment Bill (1996)
x) The Sea Fishery Act (1988)
xi) Sea Birds and Seals Protection Act (1973)
xii) National Heritage Resource Act (1999)
xiii) Occupational Health and Safety Act (1993)
Where permits have been provided by Portnet, the Contractor shall ensure compliance with the
conditions thereof.
2.1.14 Environmental awareness and control on site

The Contractor shall ensure that all personnel on site, including those of sub-contractors, be
adequately informed of environmental issues. For this purpose, a minimum of 3 hours, prior to the
commencement of the contract, shall be set aside for a workshop arranged by the Technical Officer
and run by the PAD environmental officer. The Contractor is to provide required facilities for this
task to be undertaken.
2.1.15 Water use and waste management

The CDC will have to regulate water use in the back-of-port area and this can be done in the Tenant
Approval Procedure. Other recommendations include:
1. The use of a licensed dump for domestic and industrial waste;
2. The design of a wastewater disposal plan;
3. Operators/contractors must ensure that stormwater or wastewater does not affect the
environment into which it is released. No chemicals, oils, process effluent, factory wash
water, etc. must be discharged into the stormwater drainage system;
4. Regular monitoring by the CDC and PAD of groundwater, surface water and the nearshore
seawater, through a water monitoring programme will take place. Should there be evidence
of contamination, then the responsible person and the environmental manager must agree on
appropriate measures to be taken, which will be for the operator’s account;
5. A key opportunity of an industrial zone is the possibility of enacting ‘industrial ecology’.
Incoming tenants will be obliged to provide information on their material inputs and outputs.
It is envisaged that where this information is not confidential, a register be made available to
all companies within the IDZ so that opportunities for material and waste exchange can be
identified and utilised; and

6. Waste sites should be carefully positioned so as to reduce the visual impact and should be
placed in sheltered areas where refuse will not be carried by wind. Volumes of solid waste
produced will also be monitored.
2.1.16 Air and noise pollution

Environmental principles and guidelines of air pollution have been formulated as part of the EMS
(see Appendix B). The CDC will monitor compliance with these guidelines with a thorough,
comprehensive real- time monitoring programme. A dynamic model will be used to screen
prospective tenants in terms of their predicted air pollution impacts against the recommended
guidelines. Environmental targets have also been formulated as part of the EMS (see Appendix B).
The following indicators will be monitored: number of exceedances of ambient air quality; SO2
ground level concentrations; particulate matter ground level concentrations; carbon monoxide;
particulate lead; nitrous oxide and ozone. In addition, cumulative emissions will be regulated in the
TAP. Prospective tenants will be required to fill in a detailed form to ascertain potential
environmental issues. One of the focuses will be on emissions and odours.
Recommendations for the reduction of noise impacts include noise guidelines, which have been
developed as part of the EMS to manage noise. These will be enforced via the tenant approval
procedure, ensuring that all operations meet the requirements of the Environmental Conservation
Act (Act 73 of 1989) and the SABS Code of Practice 0103-1997 regulations.
2.2 RECOMMENDATIONS FOR THE PROTECTION OF SPECIFIC FAUNA AND

FLORA AS WELL AS SPECIFIC HABITATS
2.2.1 Vegetation
The impact to threatened plants can be mitigated by identification and protection of the Red Data
listed species prior to vegetation clearing. If vegetation clearing is to take place, the species of
special concern should be relocated to patches of similar vegetation in the surrounding area.
The development should be placed so that as little disturbance as possible occurs within the
sensitive vegetation types. Recommendations specific to habitat types include:
• The protection of Foredune and Hummock habitat from Joost Park to St George’s Strand,
pending possible removal during future phases of the port development.
• All undisturbed Bontveld patches should be fenced and actively protected from illegal
dumping and infestation with alien vegetation. The development of the tank farm and
industrial precinct in the eastern section of the back-of-port area must ensure that viable
corridors are maintained between Bontveld habitats.
• The development in dense Mesic Succulent Thicket habitat on the steep slopes on both
banks of the Coega River should be kept to a minimum.
• The population of Syncarpha recurvata, which is primarily located just behind the eastern
headland, and the vegetation immediately surrounding the population should be fenced to
prevent disturbance during the construction phase.
2.2.2 Invertebrates
It is essential that the known habitat of Aloeides clarki in Mesic Succulent Thicket in the Neptune’s
Valley region be fully protected. Development and the disposal of excavated material at this site
should be prohibited. The status of the population should be regularly monitored by butterfly
specialists to ensure that all aspects of the species’ complex life-cycle are protected, including its
food plant and ant host. Pringle (1999) recommends that the ridge upon which the butterflies fly and
the areas around the ridge be left undisturbed. Development must not be allowed within 100 metres
of the existing colony. He further recommends that the valley below the ridge be left undisturbed.
Fencing of the area should be considered.

2.2.3 Amphibians
Recommendations for the protection of amphibians include:
• The protection and maintenance of water quality in the back-of-port area.
• The presence of a planned system of linked habitat corridors, particularly around water
sources.
• The construction of permanent water sources with vegetated margins may have a beneficial
impact, creating additional breeding sites for amphibians.
2.2.4 Reptiles
Linkages between habitat fragments should be maintained at all times. All field personnel involved
in the construction phase should be aware of the appearance and habitats of the endangered Albany
adder. The discovery of a population within the Coega region should be immediately brought to the
attention of conservation authorities, who should initiate a captive breeding programme (CBP)
where the species’ reproductive biology can be studied.
2.2.5 Birds
Estuarine species utilising the saltpans at the Coega Salt Works cannot be protected on-site in the
long term. Off-site mitigation involves the active protection by nature conservation and other
interested parties, of other possible sites for these birds, including the Papenkuils River, various
saltpans in the Swartkops Valley, Sundays River estuary, and new saltpans at Tankatara, near the
Sundays River. Although the roosting and feeding habits of many of these species have not been
studied for over twenty years, the suitability of these sites will still have to be investigated.
The beaches to the east of the port, designated for “Low Intensity Recreation” in the urban plan for
the CDA, could be set aside as a protected reserve for displaced wildlife. The area lies adjacent to
the Algoa Bay islands, and its control and management may best be integrated with protection of
these regions.
A seabird and marine mammal rehabilitation and cleansing centre is required for catastrophic events
and day to day port activities. The CDC and PAD, as major stakeholders, in conjunction with other
concerned organisations, should provide the majority of the infrastructure and funding for an
appropriately sized and equipped centre. The CDC in conjunction with PAD must initiate an
investigation into the exact requirements of such a facility and ensure that it is functional prior to
the operational phase of the port. The construction EMP must include but not be limited to the
monitoring of bird populations for injured or oiled birds, rehabilitation at a suitable centre for any
damaged birds, catastrophic event planning and the prior approval for the release of funds by PAD
should a major event occur.
2.2.6 Mammals
Terrestrial mammals
Protecting a variety of vegetation types will help to maintain mammal diversity in the port region.
Where the loss of habitat is unavoidable, linkages between habitat fragments should be maintained.
Marine mammals
The proposed Greater Addo National Park should provide some protection for affected marine
mammals. Karczmarski et al. (in press) proposed a further dolphin sanctuary area from Humewood
beach to Maitland River mouth and this sanctuary would provide further protection. The
development of these sanctuary areas should be addressed in the implementation of the Algoa Bay
Management Plan.

2.2.7 Control of alien species

Terrestrial
Control of alien species requires continuous monitoring and eradication procedures. All feral dogs
and cats should be removed from the project area by animal control experts. Weed control measures
should be implemented so that introduced plants will not become established within the project
area. Manual or mechanical means of control shall be the preferred method employed. Use of other
methods (e.g. herbicides) should be cleared with the Department of Agriculture. The weed control
measures should be implemented within six (6) months of when noxious weeds are visually
identified within the project area.
The following recommendations for reduction of rat infestation and the protection of Jahleel Island
from rat infestation were made in the revised EIA (CEN 2000).
1) A detailed monitoring plan by Eastern Cape Nature Conservation should be implement ed and a
management plan for rats should be devised.
2) A carefully planned and orchestrated eradication plan should be established if required.
3) A port de-ratting policy should be developed and form part of the Operational Environmental
Management Plan. This plan could include measures such as compulsory poisoned bait stations on
ships, compulsory fumigation, mooring rat guards and compliance inspections.
4) No infrastructure must be located on the eastern breakwater.
Marine
Prevention of alien organisms introduced through ballast water can be dealt with by treating the
water prior to release into the harbour, transfer of ballast water to onshore tanks for treatment or
offshore water exchange. In terms of the dredging operation, specific cleaning and ballast water
specifications must be built into the tender. These specifications should include:
• Cleaning of the dredgers at sea, and cleaning and emptying of ballast while on route to, and
still outside of South African territorial waters.
• Upon arrival, the dredgers should still be considered a risk and inspected before dredging
commences in South Africa.
It is essential that a ballast water plan for both Port Elizabeth and Ngqura ports be in place prior to
the operational phase of the port.
2.2.8 The offshore islands

Recommendations are limited and concern limiting the disturbance and access to the offshore
islands. Additional recommendations include:
• The protection of the insular spotted gecko on St Croix Island through limiting access to the
island.
• Conducting regular noise and lighting audits on the port, and keeping lighting near the
islands to a minimum.
• Develop a port policy to ensure that ship lanes are kept well away from the other islands in
the St Croix group.
• Do not allow unauthorised visits to the islands.
2.2.9 Sandy beach habitat

A beach and dune management and monitoring plan is recommended, to assess the effectiveness of
the sand bypass system and limit unnecessary disturbance of the dune system.
2.3 PREVENTION OF SHIP TO SHIP AND SHIP TO WHALE COLLISIONS
The following recommendations are made to reduce the likelihood of collisions:

• As the future approach lanes for Port Elizabeth and Coega will cross or interfere, the traffic
movement control system for the whole of Algoa Bay will need to be revised.

• All shipping in the bay should be under one authority.

• Training of port control tower personnel in the use of the VTS system in place must be
completed prior to the operation of the Ngqura Port.
• The dredging and fishing ship movements must be integrated into the traffic control of the
bay.
A co-ordinated approach to vessel traffic control by trained personnel will help to lower risks of
vessel collision in the approaches to the two harbours in Algoa Bay.
Recommendations that can be employed to reduce the risk of ship collisions with whales are:
• A whale reporting system that reports whale sightings to the port control so that warnings
can be issued.
• Establishment of whale watches on ships entering the bay during whale breeding periods.
• During the dredging period, when the risk of collision is highest, independent monitors
should be on the dredgers travelling to the disposal sites. This monitoring programme should
be paid for by the contractors but administered by the PAD Environmental Officer.
• Suitable speed limits for vessel movements in the bay should be investigated.
2.4 RECOMMENDATIONS TO AMELIORATE SOCIO-ECONOMIC IMPACTS
2.4.1 Local economic opportunities

Labour intensive techniques should be utilised wherever possible during the construction to allow
employment of as many local people as possible. The PAD and CDC will be required to invest in
training programmes to allow employment of local people.
2.4.2 Social impact reduction
The CDC has undertaken to ensure that every effort will be taken to avoid disturbing graves. Graves
will be properly fenced and will not be tampered with. Any graveyards will be fully integrated into
the land use plan and access to these sites will be allowed. If in exceptional circumstances graves
are to be moved, the following recommendations must be followed:
• The relocation of graves should take place with full participation of affected families and
communities.
• The developers must cover all the costs of the relocation.
• Costs associated with the relocation of graves could include coffins or blankets, the services
of healers or religious leaders, food, traditional alcohol and animals for slaughter.
• The developer, in conjunction with the affected communities, should jointly decide where
graves are to be relocated, and the timing and procedure for relocation and ritual activities.
The following recommendations are made to attempt to limit the potential spread of HIV/AIDS:
• All workers should undergo thorough AIDS awareness and education programmes.
Industrial theatre and health workshops are some ways of raising awareness and educating
people about the risks.
• Ongoing, accessible and culturally appropriate awareness programmes with visiting sailors,
local residents and workers around the dangers of STDs and the risks of AIDS could be
implemented.
• All workers should be provided with condoms.
It would also be beneficial for the developer to support initiatives to design culturally appropriate
strategies to healthcare, based on integrated concepts of health, rather than taking a purely
biomedical approach.

2.4.3 Relocation mitigation

While the relocation of people has already been completed there are a number of mitigatory
recommendations which must be implemented and which should improve the well being of the
translocated communities:
ongoing development plan should be established, which ensures that people's quality of life
is equal and or better than before the resettlement. Economic upliftment needs to be an
important focus of such pla n. The implementation of the plan should be the responsibility of
both the CDC and NM3 and should be independently audited.
• A plan to monitor and evaluate people's living conditions and to address unforeseen
problems should be set up.
2.4.4 The impact of the port on fisheries

A number of mitigatory measures can be applied to reduce the impact of the port on the fisheries:
• No fishing vessels (recreational or commercial) should be permitted to operate from the
port.
• The new shipping lanes must be planned so that they do not interfere with existing squid
fishing areas in the bay.
• Contingency plans and equipment to deal with oil spills must be made mandatory. The port
must regularly maintain and update any oil spill emergency equipment.
• Water quality must be monitored regularly and targets met.
2.5 VISUAL ASSESSMENT RECOMMENDATIONS
Several recommendations were made on completion of the Visual Impact Assessment, and are
mentioned below:
• Excavation and resulting cut faces should be shaped so that the new cut face is similar to the
existing dune formation, with undulations and slope variety. Typical dune vegetation should
also be re-established on disturbed areas.
• Cut and fill slopes of transport corridors should be shaped to blend into the existing adjacent
slopes and re-vegetated with typical indigenous vegetation.
• "Foreign" geometric forms in the natural landscape should be combined (i.e. the pipeline
included in the conveyor structure), and the architectural detail, form and colour attended to.
• The height and footprint of the harbour control building is unknown, but careful attention
must be given to architectural style and siting of the building in the allocated area.
• Disturbance by access roads and services must be limited and rehabilitated on completion of
construction/installation.
• The extent of area denuded for the construction of the road and camps must be minimised
and the area not required for operation, but cleared for construction, must be rehabilitated.
On completion of the port construction, the road and camp should be rehabilitated.
• Architectural finishes, e.g. colour, should attempt to blend into the landscape rather than
stand contrast.
• The eastern headland spoil site must be rehabilitated so that it looks like it is part of the
existing and adjacent landscape. Prior to spoiling, vegetation and topsoil must be collected,
stripped and stockpiled, the spoiled material landscaped to undulating slopes typical of the

surrounding dune morphology, and thereafter the bare area stabilised and re-vegetated with
existing indigenous vegetation from the area.
• All development should be planned/designed in view of reducing the extent of disturbance.
Landscape master plans/sketch plans indicating rehabilitation proposals and visual impact
mitigation measures should be produced.
2.6 DEVELOPMENT OF AN ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)
Many of the impacts discussed in this EIR can be mitigated through effective environmental
management of the port. This would involve establishing a thorough operating Environmental
Management System, including aspects such as:
• A ballast water and dumping plan;
• Oil spill contingency plans;
• Wastewater and stormwater plans;
• Adequate waste reception plan for ships’ waste;
• A litter control plan; and
• A visual impact plan containing necessary actions, guidelines and requirements for reducing
the visual impact of any construction.
This system would need to be updated regularly and have strict enforcement mechanisms.
2.7 RECOMMENDED FURTHER STUDIES
Economic assessment studies

It is also recommended that a model be developed and maintained for use, taking into account liner
operations, terminal capacity and throughput, inland transport arrangements, and the costs and
prices of the services for the purpose of prediction. This model would help for planning purposes
for any future developments at the Ngqura Port.
3. MONITORING GUIDELINES FOR THE DREDGING AND DEPOSITION

OPERATION AT COEGA PORT
Three major aspects of the Coega dredging operation will need to be monitored, viz. suspended
solids (turbidity), blasting and dispersion of disposed material.
3.1 SUSPENDED SOLID MONITORING

Four sampling techniques may be employed to monitor turbidity plumes originating from dredging
and disposal practises, namely in situ sampling, acoustic monitoring, remote sensing and dye tracer
studies (Puckette 1998). Each of these techniques was assessed by Probyn (2000), and we concur
that in situ collection of water samples for the determination of SS levels would be the most
appropriate 1.
3.1.1 Equipment specifications

A contractor shall be appointed who will undertake monitoring measurements to ensure that SS
concentrations as a result of dredging and disposal operations adhere to the criterion that turbidity
levels do not exceed the specified maximum concentration above ambient. The contractor shall
make a vessel, crew and all necessary instrumentation available. The vessel should be capable of
sampling during adverse weather conditions to determine ambient SS concentrations under these
circumstances. All SS measurements shall be taken once daily by the contractor in the presence of
the PAD Environmental Officer or a designate for the duration of the dredging operation. The
1
In situ determination of SS levels will be correlated to NTU for measurement by the prescribed probe.

vessel shall be equipped with a GPS capable of fixing the monitoring positions to an accuracy of
5m. Measurements shall be taken with a Grant YSI or OBS turbidity probe with data logger (must
be an up-to-date model) or similar approved instrumentation. The cable shall be long enough to
allow for measurements in 50m water depth if the first choice disposal site is approved (If the
secondary site is utilised, cable for measuring in 70m of water should be sufficient). Additional
probes shall be provided to measure salinity and temperature at the same time. The turbidity probe
shall be calibrated once per week, or as directed by the PAD Environmental Officer, to allow
accurate correlation of the NTU measurements of the probe with the SS concentrations (mg/l) of the
dredged material at Coega. The responsibility for accurate calibrations and measurements rests with
the contractor but must be done to the Environmental Officer’s satisfaction.
3.1.2 Monitoring and reference sites
For the purposes of this report, a monitoring site refers to any site at which sampling takes place to
determine the total SS levels above ambient, and a refe rence site refers to any site at which
sampling takes place to determine the ambient SS level.
All monitoring and reference sites shall be sampled on a daily basis for the first three months. The
Ngqura Environmental Committee (NEC) may review this procedure every three months and make
amendments as to the frequency of sampling depending on the operational levels of SS during that
stage of the operation. For dredging in the approach channel, six monitoring sites shall be evenly
spaced along both sides of the line demarcating the 500 m mixing zone. There should be a single
site on each of the southern- most corners at the extreme of the mixing zone, with two on both the
shoreward and seaward sides of the zone line lying parallel to the approach channel. For dredging
within the harbour basin, the monitoring sites shall be fixed at 500 m from the mouth of the
breakwaters at either side on the limit of the mixing zone. These positions will be independent of
the progress of breakwater construction at the time of sampling. The coordinates of the mixing zone
must be established before dredging begins, i.e. the precise position of the dotted line in Figure 3.1
must be established for the dredging operation. Daily SS concentrations must also be collected from
two fixed reference sites on either side of the dredging site, which are unaffected by the dredging
operation for determination of natural ambient SS concentrations. These reference sites should be
approximately 3.8 km from the edge of the mixing zone to the northeast and southwest. Two other
monitoring sites will be situated 150 m from Jahleel and Brenton islands. The recommended
monitoring and reference sites are presented in Figures 3.1 and 3.2. The waypoints for each of these
sites are presented in Table 3.2. Measurements at the dredging monitoring sites should be taken
while the dredgers are operational, and at the monitoring site at Brenton Island within an hour of
disposal. However, at spring tides during harbour basin dredging, whenever possible the monitoring
must be done at mid-tide during the ebb tide. It is the responsibility of the PAD Environmental
Officer to check that the contractor is following the correct procedure and ensure that measurements
are taken at the correct monitoring and reference sites each day. Monthly reports indicating daily
results, mitigatory actions implemented, guideline exeedances and subsequent remedies must be
submitted to the NEC. The Department of Economic Affairs, Environment and Tourism should also
regularly ensure that the guidelines are being adhered to by conducting spot checks and audits.
3.1.3 Turbidity concentrations and mitigatory actions
Due to the design of the subsurface 2 overflow on the TSHD and the disposal method, it is unlikely
that the sediment plume will reach the surface, and will move closer to the bottom with distance
from the dredging/disposal site. Taking cognisance of Probyn’s (2000) analysis, where the
recommendation is that absolute turbidity levels should not be above 80 mg/l, the normal practice
of a depth averages SS concentration could allow values much greater than 150 mg/l to occur at the
seabed, when the expected low values at the surface and mid-depth are considered. Consequently it
is recommended that profiles of turbidity, temperature and salinity be measured at all monitoring
2
The specialists study undertook the appraisal assuming the trailer suction hopper dredgers would be fitted with a subsurface release
mechanism.

sites. A maximum value can then be established, and this maximum value should not be more than
150 mg/l above the maximum concentration along the depth profiles at the fixed reference sites that
measure the ambient situation. These maximum values may differ with depth at the respective
monitoring and reference sites. It must be clear that 150 mg/l above ambient is the absolute
maximum we recommend and any exceedance of this value at any individual monitoring site must
result in the suspension of dredging/disposal operations.
Due to the highly sensitive nature of the environment associated with Jahleel and Brenton islands, it
is recommended that a maximum of 80 mg/l above ambient be allowed at the islands’ respective
monitoring sites. The site at Jahleel is far beyond the mixing zone boundary, and the site at Brenton
is almost 3 km from the northeast edge of the disposal site. Exceeding the 80 mg/l (above ambient)
maximum should not be a concern, but it is included as a backup failsafe due to the sensitivity of
the region. It is our opinion that if 80 mg/l is exceeded at these sites, then a serious problem already
exists at the disposal site or at the dredging site and its relevant monitoring sites at the edge of the
mixing zone.
In an attempt to prevent instituting serious mitigatory measures (cessation of activities) due to the
150 mg/l (above ambient) maximum being exceeded, a graded system of turbidity concentrations is
recommended. Instead of relying on a single turbidity concentration maximum at the daily
monitoring sites on the edge of the mixing zones, an SS concentration of 100 mg/l (above ambient)
should be used as an early warning indicator. The contractor would thus be in more of a position to
initiate mitigatory measures to avert exceeding the 150 mg/l (above ambient) threshold if he has
sufficient warning that this level is being approached. Once the 100 mg/l (above ambient) level is
attained or exceeded, the contractor should ensure that the necessary mitigatory steps are taken and
documented to prevent a further increase in SS concentration, which could lead to suspension of the
operation when 150 mg/l (above ambient) is exceeded. Mitigatory steps that have been proposed for
other dredging operations include slowing cutter head speed, a slower rotational speed of the CSD,
a different cutter head, a slower rate of progress for the TSHD (slower drag rate of suction head
along the bottom means less disturbance), a slower rate of hopper loading to control the overflow,
moving the dredger to another sediment type, and disposal over wider area within the disposal site
(sediment plume will be more diffuse and diluted from the start). If 150 mg/l (above ambient) is
attained or exceeded, there should be no debate and dredging operations must be immediately
suspended until levels are reduced to below the threshold mark. A report on the exceedance incident
should be prepared and only after the environmental officer is satisfied that the situation has been
rectified should the operation be resumed.
Approach
1) At each of the monitoring and reference sites, measurements shall be collected from three
different locations (replicates) in close proximity to each other. The measurements shall be in the
form of a profile, with the replicate readings averaged at each depth. The highest average value is
the ruling ambient or monitoring value for that site (see Table 3.1 for an example).
2) The daily ambient value is the higher of the two ambient ruling values from sites C & D.
3) If any of the monitoring sites’ (6 sites around approach channel and sites A & B) ruling value
exceeds 150 mg/l above the ambient value for that day, operations should be stopped.
4) If any of the island monitoring sites’ (sites E and F) ruling value exc eeds 80 mg/l above the
ambient value for that day, operations should be stopped.

Table 3.1: An example of how the averaging should be done and reference values should be
calculated.
Monitoring Site or Reference Site
Depth3 Profile Replicate 1 Profile Replicate 2 Profile Replicate 3 Average
1 0 0 0 0
4 5 7 9 7
7 13 22 19 18
10 16 28 20 21.33
13 20 36 25 27
16 26 49 32 35.66
19 30 65 38 44.33
22 38 70 47 51.66
25 55 73 54 60.66
28 78 80 73 (Ruling Value) 77
31 65 67 60 64
Continue in 3m intervals
While mitigatory actions associated with the release of dredge spoil at the deposition site are
limited, the selection of the deposition site for each load should take into consideration the approved
deposition plan (see below) as well as the prevailing conditions to ensure that the spoil deposited
settles within the site and buffer area. In other words, if a strong current is running towards Brenton
Island, that load should be deposited in the southern reaches of the disposal site.
3
Care should be taken that the deepest station reading is clear of the substrate.

D
10m
Jahleel 15m
1km Island
N E
150m boundary
around Jahleel
A Island
B
el
hann
nce c
Entra
20m
10m
15m
Mixing zone
limit
20m
Figure 3.1: Monitoring stations for the dredging operation at Coega Port. The dotted line represents
the extent of the 500 m mixing zone either side of the approach channel along which the 6
monitoring sites for the approach channel must be located. A & B are the fixed monitoring sites for
the basin dredging operation, C & D are the fixed reference sites to the NE and SW respectively,
and E is the fixed monitoring site on the 150 m boundary around Jahleel Island.

Table 3.2: Waypoints for the monitoring and fixed reference sites to be used for the dredging
operation at Coega Port (excluding approach channel sites). 4
Site Latitude (S) Longitude (E)

A 33 49.20 25 41.06
B 33 49.40 25 41.72
C 33 53.29 25 38.86
D 33 48.10 25 43.38
E 33 48.50 25 42.30
F 33 49.15 25 45.82
15m 20m
Coega River 30m
2km
St Croix
N
Jahleel
Brenton
F 150m boundary
15m around Brenton
31
15.8
20m Site 1
35
Swartkops River
46
44
Site 2
50m
20m
46
15m 30m
Figure 3.2: Fixed monitoring site (F) 150 m from Brenton Island to the NE of offshore disposal site
1.
4
The approach channel sites will be fixed once the precise approach channel is decided upon.

Turbidity concentration measured at

monitoring and reference sites.
Monitoring sites located on Fixed reference sites on 150 m

the edge of the 500 m boundary surrounding Jahleel
mixing zone surrounding the and Brenton.
Reference sites for
dredging and disposal sites. ambient SS levels
located 3.8 km NE and
SW of dredge sites.
< 80 mg/l
< 100 mg/l
Maximum replicate average

value from reference sites will Continue with normal
be taken as daily ambient SS operations.
Continue with normal concentration value (see table
operations. 3.1).
80 mg/l
100 – 150 mg/l
Mitigation to be considered by contractor, e.g. slowing

cutter head speed, a slower rotational speed of the CSD, a
Absolute limits exceeded – immediately
slower rate of progress for the TSHD, a slower rate of
suspend operations. Contractor to
hopper loading to control the overflow, moving dredger to
another sediment type, disposal over wider area within explain reasons for exceeding limits.
Environmental officer to authorise
disposal site.
dredging/disposal once he/she is
convinced that mitigatory measures will
be implemented and adhered to.
> 150 mg/l
100 – 150 mg/l < 80 mg/l
Mitigation to be considered
by contractor (see above).
< 100 mg/l Resume normal operations.
Figure 3.3: Flowchart for monitoring SS concentrations and mitigation (all concentrations are
above ambient SS concentrations).

3.2 BLASTING MONITORING

If hard rock is encountered, this shall be removed using underwater drilling, blasting and dredging.
Hard material shall be drilled and blasted to obtain a size distribution that can be removed by the
dredging equipment mobilised for the contract. Blasting shall use delay elements to ensure that a
Peak Particle Velocity (PPV) of 25 mm/s is not exceeded.
Underwater blasting shall only be permitted once per day during daylight hours, preferably between
12h00 and 14h00. A visual survey of the area shall be done 30 minutes before the blasting is to
commence to determine whether marine mammals are within 2 kilometres of the blast. Permission
to blast must be delayed until all cetaceans are outside of the 2 km limit. Marine mammals may not
be disturbed in terms of the Sea Fisheries Act. Any marine birds in the area must be scared off prior
to the blast. A member of the Department of Economic Affairs, Environment and Tourism should
observe all blasts and permission to blast can only be given by the PAD Environmental Officer or
his/her designate.
A visual survey of marine mammal and bird casualties shall be carried out after each blast and
reported to the PAD Environmental Officer. In addition, the beaches surrounding the port should be
inspected for casualties on a weekly basis.
A dredging method statement shall be submitted with the tender, and shall include specific
reference to blasting and provide calc ulations in this regard. Each blast shall be designed and
submitted to the Technical Officer for approval before blasting is to take place. Blast monitoring
shall include a detailed account of layout of blast, charge, delays and PPV measurements of the
blast.
3.3 MATERIAL DISPERSION AND MONITORING AT THE DISPOSAL SITE

The distribution of the deposited sediment must be monitored to avoid any build up beyond the 2 m
cap expected. The even distribution of material is the contractor’s responsibility and detailed
hydrographic surveys to confirm the dredging results along with the even deposition of spoil
material should be undertaken by the contractor and be subject to review by the Port Authority
Division (PAD).
To ensure an even spread of materials, the contractor must submit to the NEC, on a quarterly basis,
a detailed deposition plan. This plan must contain the following.
1) A clear grid pattern that divides the deposition site into 6 equal size areas.
2) The previous quarter’s dumping statistics (e.g track plots, exact amounts, location and date).
3) The results of the latest surveys.
4) The proposed deposition plan which takes cognisance of the results of the previous quarter.
The contractor should keep daily records and submit a monthly report to the PAD Environmental
Officer, outlining how the objectives stipulated in the quarterly report are being met. The PAD
Environmental Officer and/or the NEC must be authorised to stop dumping activities if the
deposition plan is not being adhered to.

APPENDIX D:
FINAL PUBLIC PARTICIPATION
REPORT FOR THE SUBSEQUENT
ENVIRONMENTAL IMPACT REPORT FOR
THE PROPOSED PORT OF NGQURA
FINAL PUBLIC PARTICIPATION REPORT
For The
FINAL SUBSEQUENT ENVIRONMENTAL IMPACT REPORT

SEPTEMBER 2001
Prepared by:
Sandy & Mazizi Consulting cc.

PO Box 23088, Port Elizabeth, 6000
120 Diaz Road, Adcockvale, Port Elizabeth 6001
Prepared for:

Postnet Suite No. 35
Private Bag X13130
Humewood
Port Elizabeth
6013
Final Public Participation Report for the Subsequent EIR for the Port of Ngqura
INDEX
CHAPTER 1: INTRODUCTION 1
1.1 BACKGROUND 1
1.2 PRESENT STAGE 2
1.3 LIMITATIONS AND CHALLENGES 2
1.4 REPORT STRUCTURE 3
2. PUBLIC PARTICIPATION PROCESS 4

2.1 OVERVIEW OF THE PUBLIC PARTICIPATION PROCESS 4
2.2 NOTIFICATION AND DISTRIBUTION OF THE SUBSEQUENT 6
DRAFT EIR FOR THE PORT
2.3 PUBLIC MEETINGS AND CONSULTATIONS WITH I&APS 6
2.3.1 Consultation Meetings 6
2.3.2 Open Day and Public Meetings 7
2.3.3 Issues and Response Trail 8
2.2.1 Final Report 8
3. ISSUES AND RESPONSE TRAIL 9

3.1 INTRODUCTION 9
3.2 SUMMARY OF THE KEY ISSUES AND CONCERNS RAISED 9
3.2.1 Existing and Adjacent Businesses 9
3.2.2 Impact on the Addo National Elephant Park 9
3.2.3 Monitoring and Management of Impacts 10
3.2.4 Algoa Bay Management Plan 10
3.2.5 Economic Impacts 10
3.2.6 Ongoing Public Participation/Involvement 10
3.2.7 Training and Employment Opportunities 10
3.2.8 Wells Estate Relocation 11
3.2.9 Pollution 11
3.2 ISSUES AND RESPONSE TRAIL 12
4. CONCLUSION AND RECOMMENDATIONS 53

4.1 INTRODUCTION 53
4.2 CONCLUSION
4.3 RECOMMENDATIONS 53
4.3.1 Newsletter 54
4.3.2 Discussion Group/Forum 54
DIAGRAMS
Diagram 1: Public Participation Process
TABLES
Table 1: Report Structure
Table 2: Consultation Meetings
Table 3: Open Day and Public Meetings
Table 4: Issues and Response Trail
Sandy & Mazizi Consulting cc. (August 2001)

APPENDIX A
• Report Distribution List - The Executive Summary of the Subsequent Draft
Environmental Impact Report was distributed to the following I&APs.
• Briefing Paper containing a map of the proposed Port layout
• Input presented at Public Meetings and at most networking meetings
• Copy of the Advertisement placed to advertise Public Meetings and notifying I&APs to
register their interest in the project.
APPENDIX B
• Notes taken at networking meetings
• Issues and concerns raised at public meetings
• Issues noted in comment forms
APPENDIX C
• Comments in response to the 50/50 Programme
• Letter of explanation in response to 50/50 comments
APPENDIX D
• Detailed written comments submitted by I&APs
• Second written submission, dated 21 August 2001, by the Mandela Metropolitan
Sustainability Coalition(MMSC)
• Response by Merit to the second MMSC submission, dated 21 August 2001
APPENDIX E
• Database of interested and affected parties
Sandy & Mazizi Consulting cc (August 2001)

1. INTRODUCTION
1.1 BACKGROUND
The Coega Development Corporation (Pty) Ltd (CDC) has been mandated by the South
African Government to investigate the possible implementation of the Coega Industrial
Development Zone (IDZ) and Port in the vicinity of Coega. It is proposed that a new
deepwater port will be built and operated by the Port Authority Division (PAD) of Transnet to
act as the primary transport facility for the IDZ. The proposed Port is located at the mouth of
the Coega River in Algoa Bay and falls within the Fish River Spatial Development Initiative
(SDI).
Since 1996 the environmental assessment of the establishment of a Port in the vicinity of
Coega has undergone a number of iterations. (See Coastal & Environmental Services,
Subsequent Port EIR Augus t 2001, Chapter 2 for a detailed discussion of the EIR Process).
The present stage in the process is the Subsequent EIR for the Port of Ngqura which takes
into account the change in the Port configuration associated with the establishment of a
container terminal as required by the preferred private partner, P&O Nedlloyd/TCI
consortium. The Coega Development Corporation has appointed Coastal & Environmental
Services (CES) to undertake the Subsequent Environmental Impact Report for the Port of
Ngqura and Sandy & Mazizi Consulting have been appointed to facilitate the process of
public participation.
This process has been implemented in two phases, namely:
Phase 1: Draft and Final Scoping Report for the Proposed Port of Ngqura: Subsequent Impact
Assessment (August 2000 - December 2000 by CEN Integrated Environmental Management
Unit)
This phase entailed the identification of impacts associated with the construction and
operation of the Port. The Draft Scoping Report together with the comments received from
interested and affected parties were submitted to the authorities for their consideration and
approval of the Plan of Study for the Subsequent Port Environmental Impact Report.
Phase 2: Subsequent Draft Environmental Impact Report for the Port of Ngqura (March 2001
- August 2001 by Coastal & Environmental Services)
The Draft EIR assesses the socio-economic, and bio-physical implications of the construction
and operation of the Port. Specialist studies that have been conducted as part of the EIR
include an Economic Cost Benefit Study, Air Quality Impact Study, Marine Risk Assessment,
a review of the possible impact on Bontveld, Visual Impact Analysis, as well as a Dredging,
Excavation and Disposal Impact Study.
In accordance with the regulations governing EIAs public participation forms an integral part
of the environmental impact assessment process. This report outlines the process of public
participation that has been implemented for Phase 2 of the Subsequent EIR for the Port of
Ngqura.
Sandy & Mazizi Consulting cc (August 2001) 1

This report does NOT address the public participation process that was implemented for
Phase One. Details of this process can be found in the following report; Final Public
Participation Report for the Coega IDZ and Port, Draft Environmental Impact Reports
Including EMPR, Volume 1, December 2000 by Sandy & Mazizi Consulting cc.
1.2 PRESENT STAGE

P&O Nedloyd/TCI Consortium have been identified as CDC's preferred private partner and
have expressed their interest in establishing a container terminal at the proposed Port. The
Port has been designed to handle containers and various bulk and break bulk cargos and to
take account of projected business opportunities as well as changes in world shipping and
logistics operations.
The EIA and Public Participation Process follow an authority approved plan of study. This
report provides an overview of the process implemented for Public Participation, the approach
to consultation with I&APs and the opportunities for raising issues and concerns. It further
highlights key issues that have emerged through Public Participation and makes
recommendations for ongoing dialogue and interaction with I&APs.
1.3 LIMITATIONS AND CHALLENGES
The proposal for the development of an Industrial Development Zone and Harbour at Coega
has evolved over a period of time since 1996. The Port has undergone a process of intensive
public involvement associated with the various Port options and design phases.
This would be the third round of public participation associated with the proposed Port at
Coega. The first process being in 1996 with the SEA and Initial Port EIR, and the second
being in 2000 with the release of the Revised EIR and Subsequent Scoping Report for the Port
of Ngqura.
As with any process that evolves over a period of time a key challenge has been to maintain
the interest of I&APs and contextualise the various stages of the public participation process.
That is, to communicate the importance of each stage of the public involvement process and
the changes that has necessitated a revision of the environmental impacts and therefore further
public consultation. Stakeholder fatigue and a potential lack of interest are phenomenon that
can be experienced by processes that are implemented over a period of time.
Despite the potential for stakeholder fatigue it has been the experience of the public
participation consultants that the level and depth of understanding on the project and the
Environmental Impact Assessment process has increased. This is evident in the level and
depth of issues and concerns that have been identified and raised through the public
participation process by a broad cross spectrum of I&APs with various interest in the project.
The reader's attention is drawn to the issues and response trail in support of this statement.
The following could have attributed to the increased levels of understanding on the project
and the process:
• Protracted and ongoing public participation over a period of time has increased the level
of understanding on the project and the EIA process
• Recent extensive media coverage has contributed towards broad public awareness on the
project
2 Sandy & Mazizi Consulting cc (August 2001)

The second challenge in the process is that television coverage was given on the project
through the programme 50/50. The contact details of the public participation consultants
were provided without supporting information on the EIA or public participation process.
Comments have thus been received from interested parties that have not been a part of the
Public Participation or EIA process to date. Below are some of the comments that have been
received:
• I would like to express my deep concern about the destruction of yet another piece of
habitat on account of the harbour project at Port Elizabeth. Please let me know if there
is anything I can do. And thank you for providing us with a channel to register our
protests.
• We wish to record a resounding NO vote to the (already illegally commenced)Coega
harbour development
In order to distinguish between the issues and concerns raised by I&APs that have been a part
of the process over a period of time and are informed about the development, the issues raised
in response to the 50/50 programme are contained separately in this report. (See Appendix C
For comments in response to the 50/50 Programme) These I&APs will be sent a copy of the
Executive Summary of the Draft EIR, Impact and Mitigation Table and a covering letter
explaining the process that has been implemented. (See Appendix C For a copy of this letter)
1.4 REPORT STRUCTURE
The following table summarises the Chapter contents and structure of the Public Participation
Report.
Table 1: Report Structure

CHAPTER BRIEF DESCRIPTION
Chapter 1: Provides the reader with background
Introduction information on the project, limitations and
challenges of the process and the structure of
the report.
Chapter 2: This chapter provides the reader with an
Public Participation Process overview of the Public Participation Process,
communication mechanisms and information
sharing, and opportunities for comment and
participation.
Chapter 3: Chapter four lists in tabular format the issues
Issues and Response Trail and concerns raised through the public
participation process and the response
provided by the relevant specialist or other
relevant parties. It further summarises the key
issues raised through the public participation
process.
Chapter 4: The last chapter provides concluding remarks
Conclusions and Recommendations and makes recommendations for ongoing
information sharing and participation of
I&APs.

2. PUBLIC PARTICIPATION PROCESS

2.1 OVERVIEW OF THE PUBLIC PARTICIPATION PROCESS
This chapter provides information on the process of Public Participation as implemented by

Sandy & Mazizi Consulting cc. for the Subsequent Environmental Impact Report for the Port
of Ngqura. The process as detailed below, follows an authority approved plan for public
participation. (See diagram 1 overleaf)
The following provides a brief overview of the various stages of the Public Participation
Process:
Stage 1: Notification and Distribution of the Subsequent Port EIR for Comment
• Reports placed in libraries
• Notification letter, Briefing Paper and comment form sent to all I&APs
• Newspaper advertisements notifying I&APs of the time to comment and further
opportunity to register interest in the project
• Initiate networking process
Stage 2: Consultation with I&APs and Public Meetings

• Networking meetings with I&APs
• Open Day and Public Meetings
• Increased understanding and information distribution on the project and process
Stage 3: Issues and Response Trail

• Development of the Issues and Response Trail by specialist consultants and other relevant
parties
Stage 4: Public Participation Report

• Development of Final Public Participation Report including Issues and Response Trail
Stage 5: Submission to Aut horities

• Submission of the Final Participation Report to the Authorities for their consideration
2.2 NOTIFICATION AND DISTRIBUTION OF THE SUBSEQUENT

DRAFT EIR FOR THE PORT
As agreed with the Authorities the Subsequent Port EIR and information sharing around its
availability would take place as follows:
• Reports in Libraries - The report was placed in the following libraries in the Nelson
Mandela Metropolitan Municipality area - Govan Mbeki Avenue, Newton Park, Walmer,
Motherwell, New Brighton, Uitenhage and Despatch; University of Port Elizabeth; Port
Elizabeth Technikon and the following national libraries - University of Cape Town; and
Rhodes University
• Report Distribution - Distribute Subsequent Port EIR to relevant authorities and key
I&APs. Distribute Executive Summary of the Subsequent Draft Port EIR to other
identified I&APs (See Appendix A for a report distribution list)

Diagram 1: Public Participation Process
Networking Distribution of Draft Coega Port EIR

17 July 2001
and Consultation
Notification Letter to I&APs to Comment
Meetings with I&APs Newspaper Advertisements
Report in Libraries
Briefing Paper & Comment Form
Public Meeting, Raymond Mhlaba Sports Centre Motherwill, 31

July 2001, 5:30pm
Open Day, PE City Hall, 1 August 2001, 10am-6pm
Public Meeting, Centenary Hall, New Brighton, 2 August 2001,
5:30pm
Interaction with Specialist Consultants
Closure for Comment

14 August 2001
Submission to Consultants
17 August 2001
Issues & Response Trail
Submit to Authorities
24 August 2001
Final Port EIR

• I&AP Notification - Notify all I&APs in writing of the availability of the Subsequent
Port EIR. A notification letter of the availability of the Subsequent Draft Port EIR, time
to comment and the Briefing Paper was sent to ALL 980 I&APs on the database. (See
Appendix E fo r the updated database of I&APs) Although a period of 21 Days was agreed
to with the Authorities for public comment 28 days was provided. The Briefing Paper
outlined the process to be implemented for public participation and gave I&APs
background information on the project and EIA process. (See Appendix A for a copy of
the Briefing Paper)
• Advertisements - Advertisements notifying I&APs of the availability of the Subsequent
Report and encouraging I&APs that had not yet registered their interest in the project
were placed in the following newspapers. Sowetan, Business Day, Daily Despatch,
Herald and Die Burger (See Appendix A for a copy of the Advertisement placed).
• Loudhailer Announcements - In order to create awareness in the disadvantaged
community of the Public Meeting at Centenary Hall a loudhailer was used.
2.3 PUBLIC MEETINGS AND CONSULTATIONS WITH I&APS
The following opportunities were provided for I&APs to raise issues and concerns on the
Subsequent Port EIR for Coega.
2.3.1 CONSULTATION MEETINGS
In order to accommodate a wide range of I&APs with different interests and to ensure key
I&APs were consulted through the public participation process a series of networking
meetings were held. The purpose of the meetings was to provide I&APs with background
information on the Subsequent Draft EIR for the Port and the public participation process as
well as engage them in discussion on issues, concerns and recommendations that they may
have with regards to the Subsequent Draft EIR. (See Appendix B For notes taken at these
meetings)
The following table outlines I&APs met through the networking and consultation process.
Table 2: Networking and consultation meetings
Meeting Attendance
Consultation Meeting - Zwide 12
Consultation Meeting - Addo 17
Kwazakhele Alliance 18
Uitenhage Consultation 7
Motherwell Community Development Forum 72
Bethelsdorp Alliance 8
KwaNobuhle Alliance 41
SA Trade & Allied Workers Union 7
SANCO PE 20
Missionvale Alliance 4
PE Fishing Forum 2
Northern Areas Alliance 7
Motherwell Councillors Forum 9
Langa Alliance 11
Wells Estate Leadership 7
Despatch Alliance 15
Valencia Ward Councillor 1
SACP/Cosatu 1
KwaDwesi Alliance 42
SANP 1
Marine Growers 1
8CR Property Trust 1
National Salt Limited 2
Democratic Alliance 1
Wildlife & Environment Society 1
Nelson Mandela Metro 1
EP Shore Anglers 1
TOTAL 310
In addition to the I&APs noted above other I&APs such as the Sundays River Citrus Co-
operative, PE Regional Chamber of Commerce and Industry, East Cape Africa Chamber of
Commerce and the Zwartkops Trust were contacted telephonically and encouraged to submit
their comments in writing.
2.3.2 OPEN DAY AND PUBLIC MEETINGS
The following Open Day and Public Meetings were held:
Open Day
• 1 August 2001, 10am - 6pm, Port Elizabeth City Hall
Public Meetings
• 31 July 2001, 5:30pm, Raymond Mhlaba Sports Centre, Motherwell
• 2 August 2001, 5:30pm, Centenary Hall, New Brighton be held at the PE City Hall.
The Open Day provided I&APs with the opportunity to view information presented in the
Draft Subsequent EIR, engage with Specialist Consultants and note issues of concern and/or
additional recommendations. This meeting was advertised in local and regional newspapers
and all I&APs were invited to attend.
While only the Open Day was planned for and approved by the Authorities four additional
Public Meetings were held, all in the disadvantaged community, see table 3. Two of these
meetings, Motherwell and New Brighton, were planned for and advertised in the local media
together with the Open Day. The public meetings in Veeplaas and Wells Estate were held as
part of the networking and consultation phase of public participation.
The additional public meetings were held in order to access and provide information to the
disadvantaged community, key I&APs as well as to ensure a cross spectrum of interest groups
are informed on the project and are provided with the opportunity to raise issues and
concerns. The public meetings provided I&APs with the opportunity to further their
understanding on the Subsequent Draft EIR for the Port, the impacts and proposed mitigatory
measures and raise issues and concerns. I&APs at these meetings were provided with copies

of the impact and mitigatory measures table from the Subsequent Port EIR and the Briefing
Paper. (See Appendix A for a copy of the input presented at Public Meetings)
The following table outlines the attendance figures for the Open Day and Public Meetings.
Table 3: Open Day and Public Meetings
Public Meeting/Open Day

Open Day - PE City Hall 46
Public Meeting - Motherwell 74
Public Meeting - New Brigton 183
Public Meeting - Veeplaas Alliance (non-advertised) 44
Public Meeting - Wells Estate (non Advertised) 114
TOTAL 461
Appendix B contains a list of the issues and concerns raised at public meetings.
2.3.3 ISSUES AND RESPONSE TRAIL
The issues, concerns and recommendations raised by I&APs through the public participation
process has been summarised into an Issues Trail.
The issues raised by IA&Ps are submitted to the specialist consultant and other parties for
their response and/or amendment of the Final Subsequent Port EIR. The Issues and Response
Trail is a mechanism to indicate to I&APs how the issue they have raised are addressed in the
Final EIR or will be addressed in future e.g. through the Environmental Management Plan. It
further provides the authorities with an overview of the issues raised through the public
participation process and areas of concern.
The Issues and Response Trail is dealt with in detail in Chapter 3.
2.3.4 FINAL REPORT
The last stage in the public participation process is the submission of the Final Public
Participation Report together with the Final Subsequent Port EIR to the Authorities for their
consideration.
Once a decision has been made on the project all I&APs will be notified in writing of the
Record of Decision (ROD).

3. ISSUES AND RESPONSE TRAIL

3.1 INTRODUCTION
This Chapter of the report addresses the issues and concerns raised and highlights the key
areas of concern that emerged through the public participation process. The purpose of this
chapter is to provide the reader with a summary of the issues and concerns raised by I&APs.
Issues have been identified and raised in the following manner:
• Through networking meetings

• Submission of the comment form
• Submission of detailed written comment
• Through public meetings
• Telephone contact
It is important to note that the Issues Trail should not take the place of detailed written
submissions. The Issues Trail is a summary of the issues raised and in certain instances it is
necessary to refer to the detailed submission for the full comment raised by certain I&APs.
(See Appendix D for the comments submitted)
3.2 SUMMARY OF THE KEY ISSUES AND CONCERNS RAISED
The following provides an overview of the key issues and concerns that have emerged
through the public participation process.
3.2.1 EXISTING AND ADJACENT BUSINESSES
The Subsequent Port EIR states that if successful relocation or an amicable buyout package is
not achieved, the impact on the Abalone farm will be VERY HIGH or very severe for the
present stakeholders. With regards to the Salt Works at Coega the Subsequent EIR report
states that environmentally sound relocation is the preferred option and that the pre-
mitigation impact is very severe for the stakeholders of the salt works. The impact has been
rated as VERY HIGH negative due to the loss of jobs, impact on the national NSL operation
and the loss of direct and indirect economic input into the regional economy.
Despite the very negative high impact identified for both the Mariculture and the Salt
operations an amicable agreement is yet to be reached with these two businesses. This issue
has been addressed in the Final EIR but is again highlighted here as part of the public
participation process.
3.2.2 IMPACT ON THE ADDO NATIONAL ELEPHANT PARK
Concerns have been raised with regards to the impact of the Coega Port and Industrial
Development Zone on the existing and proposed Greater Addo National Elephant Park. Some
of these impacts are rated as high. The Addo National Elephant Park is presently undertaking
a Strategic Environmental Assessment for the expansion of the Park. The Final EIR makes

recommendations to manage and mitigate the potential impacts on the existing and proposed
Park.
3.2.3 MONITORING AND MANAGEMENT OF IMPACTS
A number of I&APs have raised their concern with regards to the monitoring and
management of the impacts associated with the development. Specific areas of concern are
with regards to the capacity that Government has to monitor and manage the impacts and
accountability for environmental degradation.
The proponent will be required to meet all aspects of the conditions of approval set out in the
Record of Decision. This ROD will probably include the requirement that a comprehensive
construction and operational environmental management plan be developed and approved by
the authorities. The proponent will be required to adhere to this approved plan and the
proponent will be required to fund the required mitigatory actions. The CDC and PAD also
aim to be ISO 14001 compliant, which will require independent auditing at their own
expense. The authorities will however be the responsible body to ensure that the
recommendations and conditions of approval are met.
3.2.4 ALGOA BAY MANAGEMENT PLAN
A number of I&APs have expressed their concern that the Algoa Bay Management Plan
(ABMP) contains many of the mitigatory measures for the Port, many of which need to be
implemented prior to initiation or construction of the Port. It is therefore crucial that the
ABMP is workshopped with all the relevant role players and amended, and a relevant
Authority is set up to drive the implementation of the Plan before construction of the Port
commences.
3.2.5 ECONOMIC IMPACTS
Concern around the potential negative economic impacts of the establishment of the Port has
been raised by certain I&APs, with regards to the impact on existing businesses, the viability
of the Port and the impact on the Port of Port Elizabeth. The viability of the establishment of
the Port has been questioned and a critique of the MERIT report has been submitted by the
Nelson Mandela Metropolitan Sustainability Coalition. It is not the role of the Public
Participation Report to discuss this issue but to note it as an area of concern that has been
raised. The reader's attention is drawn to the second submission dated 21 August 2001 by the
Mandela Metropolitan Sustainability Coalition (MMSC) and the response provided by
MERIT. Due to the specific nature and focus of this submission the submission and response
by MERIT is contained separately in this Report in Appendix D.
3.2.6 ONGOING PUBLIC PARTICIPATION/INVOLVEMENT
A broad cross spectrum of I&APs with various interests have raised the need for some form
of ongoing public participation and information sharing on the project. The need for ongoing
public communication has been a recommendation in two previous Public Participation
Reports. The establishment of a mechanism for broad information sharing and more detailed
discussion on the project needs to be given serious consideration.

3.2.7 TRAINING AND EMPLOYMENT OPPORTUNITIES
The almost unanimous question raised by I&APs from the disadvantaged community is
receiving information on the process for training and employment opportunities. It is
important that the opportunities for training and job creation are clearly communicated to this
sector in order to bring in line expectations for job creation and the capacity the project has to
meet these expectations.
3.2.8 WELLS ESTATE RELOCATION
The relocation of the Coega Community to Wells Estate received prominence in the media
during the public participation process and was raised at various meetings. The reader is
referred to the additional specialist investigation in the Final Subsequent EIR with regards to
this issue.
3.2.9 POLLUTION
The impact of air and water pollution and the protection of people from pollution was raised
by certain I&AP groupings. It is noted that CDC is currently conducting baseline monitoring
for water and air pollution and will continue to do so as this will assist in monitoring potential
pollution.

3.2 ISSUES AND RESPONSE TRAIL
The following section of the report lists in tabular format the issues and concerns raised by various I&APs. The issues contained in the Issues and
response trail have been identified in the following manner:
• Networking Meetings
• Written Submissions
• Comment Forms
• Public Meeting
The Issues trail is a summary of the issues identified and as such does not contain the full text of each submission. The reader is referred to Appendix
B and D, which contains the detailed comments, raised throughout the process.
TABLE 1: Issues and Response Trail
ISSUE/CONCERN RAISED BY RESPONSE

1. Existing & Adjacent Businesses
1.1 The maps in the Subsequent Draft Port EI R are confusing and Marine Growers The concerns of Marine Growers and the 8CR Property Trust are noted and in
misleading for decision makers as it does not indicate the proximity order to clarify the issue, a cadastral map has been included in Chapter 1 of the
of the abalone farm to the port. Marine Growers and 8CR Property Final EIR. This map clearly outlines the property in question (Portion 8 of the farm
Trust are the closest businesses to the port. Marine Growers has also Coega River Mouth 303). The map clearly shows that the property has been
been excluded from the IDZ and this is not indicated on any of the excluded from the proposed IDZ area.
maps. The Final Port EIR should include the Addendums submitted
by Marine Growers and the A5 maps in colour to indicate these
businesses in relation to the IDZ.
1.2 In Part 2 (page 18) of the Specialist Studies reference is made to sand Marine Growers The impact on the abalone farm (Chapter 9 - Issue 4 Impact 1) has been updated
that would rise 1 meter on the northern beaches. This point has been and includes the statement that one of the impacts of the port may be “possible
excluded from the Subsequent Draft EIR and will have a significant blocking of the farm’s seawater intake systems due to the dumping of excavated
impact on Marine Growers. The rising of sand will cover the pumps sands on the beach during construction”. The overall impact remains the same (as
required for pumping seawater, which is vital to the survival of the in the Subsequent Draft EIR) and includes the following statement “On the basis
abalone on the abalone farm. Any changes to the beach profile, of this assessment it was concluded that the farm is not viable as an ongoing
erosion or attrition is going to impact on the abalone farm. This is a business in its present location, given the development of the port and IDZ
very high impact. (Common Ground 2001). If the port and IDZ go ahead and the current
operation/ownership situation prevails, the impact on the stakeholders of the


abalone farm could be very severe”. The impact statement clearly states that if
successful relocation or an amicable buyout package is not achieved, the impact
will be VERY HIGH or very severe for the present stakeholders.
1.3 CDC needs to be aware that relocation of the abalone farm is now not Marine Growers The Madiba Bay development may result in complications for relocation to the
an option. Relocation would take two years before any preferred site however other sites could probably be identified along the coast. It
commencement of the harbour and IDZ could begin. The initial area should be noted that relocation of the abalone farm is the preferred environmental
identified for relocation is now included within the Madiba Bay option as the associated jobs and nett input that the abalone farm has to the
development. The EIA must not be approved until this situation is regional fiscus will then not be lost. The primary aim of the Coega development is
amicably resolved, as this will lead to legal action being taken to to uplift the area economically and socially. As recommended in the draft EIA
protect the abalone farm, which will lead to further delays. (Chapter 9 Issue 4 – General comment), “The negotiations surrounding these
businesses must be resolved prior to the construction of the port and should be
treated as a matter of urgency”. The impact statement clearly states that if
successful relocation or an amicable buyout package is not achieved, the impact
will be VERY HIGH or very severe for the present stakeholders.
1.4 The 8CR Property Trust raises serious concerns that they have been 8CR Property Trust The 8CR Property Trust is within the gazetted port boundaries, which defines an
excluded from the EIR. (Portion 8 of the farm Coega River Mouth area within which a port may be developed. PAD has within those limits (as
303). The Trust's property is included within the port limits but defined in the Act) decided on the boundaries where the Port will be built. The
excluded from the IDZ, and is approximately 800m from the current plans do not require the 8CR Property Trust land and as such the land has
proposed harbour wall and shares a common boundary with the not been included in the area required for the port and IDZ. The justification for
proposed harbour and core development area. exclusion of this piece of land is outside the scope of this EIA. The port and IDZ
will however have an impact on the possible land use options available to this
property.
1.5 Chapter 7 Issue 7 - 8CR Property Trust has not been considered 8CR Property Trust The 8CR Property Trust concerns have been included in Chapter 7 – Issue 7 -
under impacts on adjacent industries. Chapter 9 Issue 4 - 8CR Impact 1. The following statement is made “Apart from the desktop assessment by
Property Trust has not been considered under impacts on existing Common Ground Consulting (2001), specific field studies to investigate these
businesses. 8CR must be considered and included in this report in issues have not been undertaken, or if they have, issues related to the abalone farm
both Chapters 7 and 9. The Final Po rt EIR must include all have not received special attention. Any single or combination of the above
comments submitted by 8CR and the maps must be in full colour. impacts have the potential to severely impact upon the abalone farm and in the
The issues as submitted by Marine Growers also relate to the Trust. absence of definitive studies, the precautionary approach must prevail. By logical
progression the land use option of abalone farming immediately surrounding the
port, including the 8CR Property Trust land on which the Marine Growers
Abalone farm is situated, could be significantly compromised (See Chapter 9 for
further discussion).
1.6 The 8CR property was acquired with the specific intent and use for 8CR Property Trust The following impact statement has been included in the Final EIR:
development of five (5) abalone farms. The property has very
limited pre existing land use as abalone farms and was successfully Impact 5 - Impact on mariculture land use options
marketed as that. This was already stated in the first preliminary Cause and Comment
14 Sandy & Mazizi Consulting cc (August 2001) Sandy & Mazizi Consulting cc.
(August 2001)

economic assessment. Due to the Harbour and IDZ development, No specific study on the impact of the port on general mariculture in the region has
proposed transactions have lapsed and the best land use option for the been undertaken. However, a desktop study by Common Ground Consulting
area has been affected. (2001) on the existing abalone farm indicated that the port could significantly
compromise the activities at the abalone farm. In the absence of any detailed
studies to further elucidate this issue, the precautionary principle must prevail and
the impact on the farm was rated as being severe. By logical extension of this
principle, any abalone venture (present or planned) would face the same
difficulties and thus this land use option is unavailable or highly risky in the
immediate port area. One such landowner is the 8CR Property Trust. The exact
economic impact on the stakeholders in this enterprise is difficult to ascertain, as
the valuation of any damages would revolve around an opportunity cost.
The land use option of abalone farming will possibly be significantly compromised
in the area around the port in the long term. The economic significance of this
impact on the stakeholders is UNKNOWN.
1.7 NSL have to date been under the impression that their business will National Salt Limited As no specific specialist studies on the salt works formed part of the authority
be relocated. Recommendations in previous Assessments and agreed plan of study none were undertaken. A precautionary approach to the
planning within NSL have focused on relocation. The release of the impacts was adopted and the following recommendations are made:
Subsequent Draft Environmental Impact Assessment for the Port of 1) Ecologically sound relocation is a preferred option to buyout and closure.
Ngqura notes buyout and closure as a mitigatory measure. According 2) Buyout and closure should only be considered if relocation is not
to NSL this option has not previously been discussed or considered environmentally suitable (ecological, social and economic suitability).
by NSL and is not a mitigatory option. The impact of the buyout or
closure option would have far-reaching local and national socio- Environmental suitability includes ecological, social and economic suitability.
economic impacts, which are not adequately reflected in the Draft Economic suitability would need to weigh up the costs to the proponent and the
EIA report. The existing business of NSL within the Coega Estuary existing stakeholders of relocation versus buyout and closure.
provides infrastructural and other support to the Tankatarra,
Swartkops and Berg River Saltworks. The closure would further The impact statement (Chapter 9 – Issue 4 – Impact 2) has been amended to state
indirectly impact on other industries such warehouses and depots in that no specialist studies have been undertaken to assess the impacts of closure,
Durban, Johannesburg and Cape Town. The closure of the Saltworks and that the precautionary approach has been adopted. The impact is rated as
at Coega and the potential impacts thereof cannot be viewed in VERY HIGH, which is the only socio-economic impact of such severity. In terms
isolation. of the entire project it is probably the single most negative impact, with the other
two VERY HIGH impacts being catastrophic oil spills and the impact of marine
invasive organisms, both of which are unlikely and not project specific.
The proponent maintains that the negotiations between CDC and NSL always
looked at various options for acquisition and buy-out and closure was one of the
options.


1.8 The Draft Subsequent Port EIR draws conclusions about buyout and National Salt Limited Detailed specialist studies on all impacts of the project would be ideal. However,
closure, which have not been discussed with NSL. There is still no detailed studies have been undertaken and as such the precautionary principle
enough time to relocate the Saltworks and avoid the negative socio- has been adopted. The imp act has been rated as VERY HIGH negative due to the
economic impacts that would be associated with closure. Relocation loss of jobs, impact on the national NSL operation and the loss of direct and
may be the more expensive short term option but it is the more cost- indirect economic input into the regional economy.
effective long term socio-economic alternative. In order for buyout
or closure to be assessed as an option or even be considered as part of It is stated in both the draft and final EIR that “The manner in which the relocation
the decision making process as a mitigatory measure, a detailed or buyout of the various businesses is handled has significant implications for the
assessment of the impacts of this option must be considered. present stakeholders in the businesses: CDC, PAD, Transnet shareholders and the
South African taxpayer. The way forward on the acquisition of these businesses
should be mutually agreed upon, as this will limit the negative impacts associated
with the buyout or relocation. The negotiations surrounding these businesses must
be resolved prior to the construction of the port and should be treated as a matter
of urgency.”
The recommendation in the final EIR is that environmentally sound relocation is

the preferred option and that the pre-mitigation impact is very severe for the
stakeholders of the salt works.
1.9 What are the implications for the Cerebos workers? SANCO PE/ Wells The Cerebos workers are part of the stakeholders of the salt works and the pre-
Estate mitigation and post mitigation implications of the two scenarios considered for
stakeholders is covered in Chapter 9 - Issue 4 -Impact 2. Further, all workers
impacted on by the demarcated IDZ and Port development will be given preference
for skills development, training and employment in the IDZ and Port.
1.10 Why were PPC not considered to be an Interested and Affected Party PPC The consultants followed an authority approved plan of study for the EIR, which
(IAP) in the study? We are the biggest neighboring landowner and was based on a scoping study completed by CEN. No issues regarding PPC were
intend investing over one billion Rand in the area. PPC have done included in the plan of study.
numerous EIAs and have an approved EMPR. Our plans include the
following: a. Mining Venture b. A Cement Manufacturing Plant c. A No specialist investigation into this matter has been undertaken but the following
Rare Game Breeding Programme d. Land based Tourism Venture statement has been included in the EIR. “The future land use options of adjacent
and e. Marine based Tourism Venture landowners such as PPC Cement may be impacted upon. While PPC have a
current mining venture with an approved EIA and EMPR, the business also has
plans for land based and sea based tourism ventures. As with other such
conservation and tourism ventures e.g. the Greater Addo Park initiative, the port
and Coega Project as a whole will have a sense of place and visual impact on such
an initiative. These impacts could limit the land use options available to adjacent
(August 2001)

landowners and hinder the economic sustainability of such a venture.
The specific impacts associated with the Addo initiative which has similar
characteristics (tourism & conservation), occurs in the same region but is on a far
larger scale and is dealt with in detail in Issue 14. As with any large industrial
development certain land use options in the surrounding areas will be impacted
upon. The suitability of the Coega site for a port was determined by the need for
an international transport network for the IDZ. The location and suitability of an
industrial land use option for the area is outside of the scope of this EIR and is
more suited to an SEA. An SEA was completed on the project by the CSIR (1997).”
With regards to Public Participation for the Draft Environmental Reports for
Coega including the EMPR, PPC has been registered as an interested and affected
party (I&AP) from the outset of the process. PPC is also registered as an I&AP
for the Subsequent Draft Port EIR, as such they have been kept informed of all
public meetings, availability of information and deadlines for comment from the
outset of the process. As a registered I&AP the comments submitted by PPC have
been submitted to the Environmental Consultants for their consideration (see
response above).
1.11 The impact on existing and potential industries does not seem to have MMSC The negative impact on existing industries was stated in section in 10.2.2. of the
been considered in the conclusions of the EIR. conclusions in the draft EIR and is repeated here: “In terms of the socio-economic
environment, there are a number of negative impacts associated with the building
and operation of the port and back -of-port area. The negative impacts of VERY
HIGH significance revolve around the impact that the port may have on existing
businesses in the region. These impacts are considered in a serious light in that the
aim of the Coega development is to bring economic growth to the region, and any
job losses associated with the proposed port and back -of-port area must be
carefully considered. In particular, the possible impacts that the port will have on
the salt works and abalone farm are rated as being severe or very severe before
mitigation, and while the two scenarios associated with the abalone farm have the
potential to be amicably resolved and thus be of NO SIGNIFICANCE, no
agreements have been reached thus far. The possible buyout and closure of the salt
works is a VERY HIGH negative impact and every effort should be made to
relocate the salt works, provided that an environmentally suitable site can be
found.”
In addition, the conclusions discuss the impact on future developments such as the
Addo initiative and other existing operations such as the PE harbor (see section
10.2.2). The impact on the fishing industry is rated as LOW (-) and in order to


highlight the significant negative impacts, those of low significance are not
discussed in the conclusions.
2. Shore Angling
2.1 The recommendations made in the draft Scooping Report re shore EP Shore Anglers The final public participation report for the IDZ (Sandy & Mazizi 2000) which
angling must be included as part of the final EIR and stated. This involved the Revised Port EIR (not the Subsequent Port EIR) states that “ The
issue affects approximately 200 affiliated anglers, which represent fencing of the harbour will limit access for anglers below the high water mark, this
only a percentage of the angling population. fencing should be placed as close as possible to the proposed harbour. It is
suggested that the fence be placed along the high water mark or even behind the
primary dune.”
The following statement has been included in the EIR (Chapter 9 - Issue 8 -
Impact 1). Access to the beaches surrounding the proposed harbour should not be
unduly denied. The exact demarcation of the public access limit must, where
possible, take into consideration the needs of recreational anglers. Access issues
must form part of both the construction and operational environmental
management plan of the proposed port.
The port will be secured by fencing from south of the sand bypass to north of the
eastern breakwater. This is required to ensure port security and to prevent access
to the breakwater, which is a recommendation of the EIR. Unless required by
other Authorities or for operational reasons the Port Authority will not be
preventing access to the beaches outside of the area enclosed by the fencing
described above.
The final public participation report also states that “ The area zoned for low
intensity recreational use should include shore angling as a recreational sport.”
This request will only be considered if fishing does not conflict with the proposed
GANP, which will probably, include or be immediately adjacent to the seaward
section of this area.
3. Swartkops River
3.1 The health of the whole of Algoa Bay will be adversely affected by any Swartkops Trust The consultants regard the Bay as an inclusive ecosystem, which would include the
deterioration of the Swartkops River. Likewise, the health of Algoa estuaries entering into it. The consultants have in-house estuarine expertise and
Bay will affect the river. In other words, there is an ongoing cycle of these systems have been considered in the overall functioning of the Bay.
cause and effect.
3.2 Developments can no longer be seen in isolation and regarded as a Swartkops Trust The cumulative nature of impacts is of concern and for that reason a holistic plan
small increment. These increments, if allowed to continue, will to manage all users of the Bay (Algoa Bay Management Plan) was completed but
eventually destroy the habitat entirely. The Coega IDZ and Port are in needs to be updated and implemented. The EIR clearly recommends that “The
(August 2001)

any event massive by any measure. The cost of re-establishing this Algoa Bay Management Plan will need to be developed further by all stakeholders
wetland will be prohibitive. in Algoa Bay. The finalisation and implementation of a Management Plan must be
seen as a priority by all stakeholders in the Bay (e.g. the Nelson Mandela
Metropole, Port Authority Division (PAD), Coega Development Corporation,
DEAT and other interest groups).” See below for discussion on cumulative
impacts.
4. Holistic Approach to Assessment & Cumulative Impacts
4.1 Although the report states that it does not address the Coega IDZ in SANP The comment has some validity and the lack of a holistic approach is a
its entirety and that this falls beyond the scope of the port EIR, in shortcoming of a project, which has evolved over a period of time. It is also a well
essence the IDZ activities are inextricably linked to the activities of recognised shortcoming of project level EIAs, and has led to the development of
the port and vice versa. E.g. the quarrying of Coega Kop, the SEAs to provide more holistic assessments of cumulative impacts. In an attempt to
construction of the haul road and the water provision pipelines are all rectify the piecemeal approach, an integrated overview document on the Coega
activities which are linked to the construction of the port but are Development was produced in 2000 (Integrated Environmental Summary Report)
taking place in the IDZ and their impacts have not been considered but this obviously does not include the Subsequent Port EIR.
here. Consequently SANParks still finds it unacceptable that there
has been no attempt by the CDC or the respective consultants to The subsequent Port EIR followed an authority approved plan of study. The
review the development of the port and indeed the IDZ in a holistic approach of having a separate Port EIR was taken prior to the initial Port EIA in
fashion. These developments and the impacts associated with them 1997.
need to be assessed in a coordinated manner and not in parallel
isolation. Once again the concern is that the impacts associated with
a small component of the development may appear to be of little
significance but when viewed in combination with the impacts of
associated developments may indeed be of greater significance.
4.2 CDC and PAD plan for the relocation of the Tank Farm and ore SANP The exact operating nature of the PE Port and Port of Ngqura has not been
dumps and the impacts thereof should be considered by this established. The relocation of the tank farm and ore dumps from Port Elizabeth and
assessment. other facilities related to future cargo flows through the Port of Ngqura are
identified for the future to give insight into the possible future development of the
port. The move will not occur immediately and as such should be subject to
environmental approval at the time of relocation. The facilities are viewed as
possible future tenants and, as with all future tenants, will need to undergo an EIA
prior to approval being granted.
4.3 It is difficult to assess the impacts of the proposed development when SANP The approach taken to the back-of-port area was a precautionary one in terms of
one has no indication of the types of activities that will ultimately be the environment. The impacts were rated assuming that significant impacts would
undertaken. Merely listing a range of broad scale activities (e.g. occur on the biophysical environment.
mixed use) provides little information on the scale and degree of
potential impacts in the area, specifically the back of port area, which The lack of information on the back-of-port area and the Rezoning EIA is a
will be impinging on the sensitive foredune and hummock habitats. difficulty with this type of assessment where little information on future tenants is
The vague nature of the assessment of potential impacts has been a available. In order to overcome this limitation an EMS system has been developed


problem throughout the suite of EIA/Rs that have been forthcoming which includes aspects such as the tenant approval procedure, which should limit
for the proposed development. and manage impacts. One of the key recommendations in the EIR is that: “The
Environmental Management System designed for the IDZ must be completed. Any
additional outstanding tasks must be completed prior to the start of the phase that
they are applicable to. While it is recognised that the EMS is a dynamic tool,
details on its various mechanisms must be produced in an integrated form and
approved by the authorities, after which it should be regularly updated and
reviewed.”
The Rezoning EIA clearly identifies the likely activities within the broadly defined
clusters. Any new activities will have to be assessed for compliance with agreed
land uses and may require project specific EIA’s as required by legislation.
5. Addo
5.1 The port will reduce the economic success of the GANP, as well as MMSC The scope of work for the EIR called for an in-depth examination of the economic
threatening a number of its conservation goals. The reduction in the implications of the port on other ports. The plan of study did not require a specific
economic success of the park must be factored into the port study on the economic implications on a future development such as the Greater
evaluation. Addo Initiative. No specialist study has been commissioned by the client to
specifically look at the economic implications of the port or the Coega
. Development on the Addo Initiative.
However, the general assessment of the effect that the port will have on the Addo
initiative is assessed in Chapter 9 Issue 14. The following impacts were covered:
1) Visual Impact
2) Impact of air pollution
3) Impact of general port operations
4) Overall loss of sense of place and subsequent loss of wilderness experience.
It should be noted that the expansion of the Addo National Elephant Park is not an
approved project and is currently undergoing a Strategic Environmental
Assessment (SEA). The GANP, the regeneration of the NMMM and the immense
regional wide opportunities for tourism are all activities within the Government’s
macro-economic strategy.
5.2 The marine protection zone proposed for the expansion of the park is SANP As with all impacts the rating system gives a pre and post severity rating for
85 000 ha and extends right up to the Coega River Mouth. It is a maintenance dredging. The pre-mitigation rating is severe for maintenance
continuous area and not just a reserve around the islands. If you dredging, but if mitigatory actions such as compliance with the London Dumping
don’t know what the contaminants are going to be in the maintenance Convention are attained and the dredging is authorised and fulfills DEAT
dredging, the rating of the impacts may be high and not low. guidelines, then it is assumed that the procedure proposed for the maintenance
(August 2001)

dredging will have mitigated any impacts such as those associated with
contaminants. The London Dumping Convention, along with other guidelines such
as PIANC, clearly outlines how contractors deal with contaminated sediment
disposal e.g. land based disposal or capping.
This comment does serve to highlight the importance of the pre-mitigation severity
scale used in this study.
5.3 SAN Parks and CDC need to meet to mitigate the visual impacts on WESSA Agreed. If both projects are authorized, they should actively work together to
the park. The proposed bridge across the Coega River could be minimise any impacts that they may have on one another. It is the intention to
visually intrusive. submit the design of the bridge to national and international competition in order to
achieve world class design standards.
5.4 The impact that the proposed port would have on the greater Addo SANP The effect that the port will have on the ecology (marine and terrestrial) was
Elephant National Park is listed as being high or moderate with the assessed in detail in Chapters 5 and 7. In those chapters impacts on species of
most severe impacts being related to the visual intrusion. SANParks special concern such as birds was rated as being of HIGH (-) significance. In
does not necessarily agree with this conclusion, as the impacts are not terms of the impacts on the Greater Addo Park it is recognised that conservation is
solely related to aesthetics. The expansion of the Addo Elephant a key activity and objective of the park. The port is however located on the edge of
National Park is centered on the conservation of the region’s unique the proposed marine park and as such the biological impacts of both the port
biodiversity, which includes some 6 biomes. Although the construction and operation is predominantly limited to a small portion of the
enhancement of eco-tourism is one of the primary focal areas, proposed marine park.
ultimately conservation is of critical importance. As such, because
the expanded park will also be negotiating a marine protected area The impact statement has however been amended to incorporate the concerns
(which includes both offshore island groups) which overlaps with the expressed by the SANP and reads as follows in the final EIR :
port control area, SANParks is particularly concerned about the
potential impacts to the fauna and flora of the marine and island Chapter 9 – Issue 14: Impact 3 - Impact of general port operations on the marine
habitats, particularly species of special concern (African penguin, park
Roseate tern, Damara tern, Duthie’s golden mole, southern right Cause and comment:
whale etc.). Although some of these are listed in the subsequent EIR, The operation of the port will result in some pollution e.g. plastics, biocides and
it should be noted that these should also be seen as impacts oil, which could impact on species of special concern such as certain marine birds.
associated with the greater Addo Elephant National Park and should These impacts can be managed but even after strict controls, there will be an
therefore be listed as HIGH (currently listed as LOW, pg. 174) increase in this type of pollution along a presently pristine piece of coast.
Catastrophic events such as oil spills could occur but are regarded as being
unlikely. Oil spill contingency plans, if properly implemented, should contain these
spills but will be unable to prevent all of the impacts. Collisions of marine
mammals and ships are also possible but regarded as being unlikely (WSP 2001,
See Specialist Studies Series – Part 2).
With correct management the impacts associated with general port operations can
be contained to a limited portion (western section) of the proposed park.


Mitigatory actions limiting the port’s intrusion into the park (e.g. ecologically
suitable shipping lanes) should be investigated as part of the construction and
operational environmental management plans.

Mitigation in the form of adequate oil spill contingency plans, strict operating
procedures pertaining to ship speed, ballast water, dumping, plastic pollution etc.
must be established and be enforced within the port. A port Environmental
Management Plan must be written, enforced and clearly communicated to all ship
captains entering the port.
The general operation of the port could result in severe impacts in the long term to
western sections of the marine park. Impacts on the eastern sections towards the
Sundays River and Seal Island are expected to be limited. If the port is managed
properly and mitigatory actions are implemented successfully, the severity of the
impacts may decrease. The overall significance of this impact on the entire marine
park is MODERATE negative.
5.5 The scale of these impacts cannot necessarily be equated to those that SANP The scale of the visual impacts of the proposed port on the proposed Greater Addo
exist at present. The present impacts are of a known scale (small National Park (GANP) are rated as being HIGH and MODERATE (-), and are
scale industry) whereas the potential impacts from developments that therefore significant impacts. The impact statement outlines that the present
would take place from activities within the IDZ (HEAVY industry) situation in and around Port Elizabeth and the existing Addo Park is not a pristine
as well as port area are undefined and as yet undetermined. There is environment and therefore there is an existing visual and sense of place impact.
therefore potential for these impacts to be of much greater
significance. Furthermore, with the envisaged expansion the access The HIGH rating for marine visual intrusion takes into consideration the fact that
to the park is likely to change which will re-route potential tourists the marine park will be extensive and the fact that the port will be located on the
around unsightly developments and/or industrial areas. Mitigation of one boundary. The visual absorption capacity as well as the location of the port has
the loss of sense of place as a result of the visual impact of the resulted in a moderate terrestrial impact (See visual impact Study – Specialist
proposed port is based on SANPark’s undertaking developments in Study Series Volume 2).
areas, which would be out of sight of the proposed developments.
However, given the extent of the park expansion it is unlikely that The GANP is not surrounded by pristine environment and consequently the
there will be many areas where the port would not be visible to some visitors to the park are presently confronted with unsightly industry in and around
extent. It may be necessary for SANParks to forgo preferred sites for PE the main entry point for tourists. Whilst heavy industry may form part of the
rest camps and/or private concession areas purely based on the visual Coega IDZ, it is probable that environmental aspects of this industry will be more
impact from the port and IDZ developments. The impacts of such carefully managed than that of existing industry and therefore the premise that
requirements on revenue generated by the park are undetermined. future industry will be more visually and environmentally detrimental than existing
industry (the majority of which was designed and operational before the current
(August 2001)

environmental legislation was passed) is not necessarily entirely valid.
It is appreciated that the mitigatory measures suggested by SANParks might have

some opportunity costs for the development but as yet no specific study has been
commissioned to quantitatively look at the exact economic costs that the project
may have on the GANP. The following statement has been inserted in the final
EIR, indicating as much: “The loss of sense of place as well as the visual intrusion
may well have an opportunity cost to the proposed GANP development. At this
stage no quantitative study on the economic impacts has been commissioned. This
type of analysis would be more suited to a strategic rather than a project specific
EIA as it would address long term land use options and policies for the region.”
6. Air Emissions
6.1 Air emissions may be low for the port but taken into account with the SANP The air emissions for the entire IDZ and back-of-Port will be managed as one and
IDZ, it may be high. targets will have to be met as part of the EMS. Once limits are reached the Tenant
Approval Procedure will be unable to admit any further air polluting industries.
7. Monitoring
7.1 It is essential that a proper monitoring body be put in place to SAMREC From an environmental point of view, the whole IDZ including the Port will be
monitor the management of the port and IDZ and to ensure the ISO: 14001 certified. Further, all enterprises will have to comply with these
mitigating factors are implemented. The body should have powers to environmental requirements. This is the authorities decision more especially the
impose sanctions if the measures are not properly implemented. This National Department of Environmental Affairs. Monitoring and management must
monitoring body should contain representatives from interested be a subsection of the authority approved EMP and EMS for the Port.
NGOs as well as government bodies.
8. Management
8.1 Furthermore, although threats to the environment are identified in Swartkops Trust It is the authorities’ responsibility to enforce legislated limits and guidelines.
environmental impact reports, in practice nothing or very little is done A number of I&APs have raised their concern with regards to the limited capacity
about this. Moreover, the resources, both financial and material, which of the relevant Authorities to manage and monitor the mitigatory measures
are made available to agencies enjoined with the responsibility of proposed in the Subsequent Port EIR. It is important that the relevant Authorities
protecting the environment, are hopelessly insufficient and most of the take note of this concern and where necessary take this into account in their
environmental protection measures fail dismally in the application. budgeting and planning.
8.2 It is optimistic to expect that the full range of mitigatory measures MMSC The proponent will be required to meet all aspects of the conditions of approval set
can be implemented and maintained throughout the construction and out in the Record of Decision. This ROD will probably include the requirement
operation of the port. Guarantees need to be put in place that the full that a comprehensive construction and operational environmental management
range of mitigatory measures will be enforced. Who will pay for plan be developed and approved by the authorities. The proponent will be required
these? This should form part of the authorisation process. to adhere to this approved plan and the proponent will be required to fund the
required mitigatory actions. The CDC and PAD also aim to be ISO 14001
compliant, which will require independent auditing at their own expense.
The Port Authority will develop an EMP to ensure that the mitigation measures


attached as conditions of approval in the Record of Decision are implemented.
Further to this the Port Authority is developing an EMS in accordance with ISO
14001 for the construction and operational phases. The Port Authority has
established its own environmental management section that would be responsible
for ensuring compliance.
The authorities have got a constitutional mandate to oversee and monitor for
compliance in dealing with projects of this nature.
8.3 Appendix B outlines some of the measures that have been put in SANP The conclusions of the EIR state that “The Environmental Management System
place for the EMS but falls short in addressing all of the issues designed for the IDZ must be completed. Any additional outstanding tasks must be
identified. This has to be rectified, as one of the conditions before completed prior to the start of the activities they pertain to. While it is recognised
construction can proceed is that there is an adequate EMS in place. that the EMS is a dynamic tool, details on its various mechanisms must be
As an example, the section detailing the environmental targets produced in an integrated form and approved by the authorities, after which it
section (i) gives no mention of the African penguin and the impacts should be regularly updated and reviewed.” In addition a port construction EMP
associated with this population. Furthermore, the report states that will need to be completed prior to activities that pertain to construction on the
the list of targets set has not yet been approved by the CDC which is port.
cause for concern as this provides the public with no guarantee that
such measures and targets will actually be used in the operational
phase of the port and IDZ.
8.4 Will there be measures in place to monitor activities? Will there be SANP The construction and operational EMPs for the port and back-of-port activities will
any independent monitoring that is undertaken to see that the need to develop the exact monitoring guidelines, which will be required. A clear
activities adhere to or comply with national and international recommendation of the report is for such EMPs to be developed. All activities will
standards? be monitored by the CDC and PAD environmental officers. It is recommended
that an independent environmental site officer (ESO) be utilized throughout the
construction phase of the project.
A number of I&APs have raised their concern with regards to the capacity of the
relevant authorities to monitor the development. The Authorities should ensure
that they have the necessary capacity to monitor this project as they have a
mandate and responsibility to do so.
8.5 There are no significant problems with the mitigating measures WESSA This report is an EIR, which identifies and rates impacts as well as providing
proposed but more concern about how they will be managed. There possible mitigatory measures. The next stage in the process is the development of
are a number of mitigating measures that affect the Metropole, authority approved construction and operational environmental management plans.
Province and National government. The report does not indicate who
will manage this and whether government will be provided with The construction and operational EMP’s for the port and back-of-port activities
additional capacity to manage and monitor the mitigating measures. will need to develop the exact monitoring guidelines, which will be required. A
The government can support the project but they also need to be clear recommendation of the report is for such EMPs to be developed.
(August 2001)

made aware that they have certain responsibilities for implementation
of the project. The consultant is confident that the authorities are aware of their responsibilities in
such a high profile project. The development of the EMPs required for construction
and operation would involve close collaboration with the authorities as to the
responsibility of the different agencies, client and NGOs.
8.6 The present lack of capacity within the Eastern Cape Department of SAMREC Agreed. The national and provincial authorities must prioritise funding to ensure
Economic Affairs, Environment &Tourism, Marine and Coastal that they can operate effectively and meet their mandates.
Management and the Nature Conservation Division of the Nelson
Mandela Metropolitan Municipality is of extreme concern. The
present ability of these departments to ensure that the Coega Project
complies with all applicable legislation is questionable, and means
must be sought to provide these bodies with additional staff, budgets
and transport to undertake the responsibilities that will result from
authorisation of the Coega Project.
8.7 All items that require permitting in terms of legislation concerning Habitat Council The CDC is currently undertaking certain baseline measurements and monitoring
water quality, emissions to air, marine protection and other relevant for Air Quality, Surface and Ground Water and Marine as per the US EPA
legislation or regulations must be stringently conformed with. standards. The construction and operational EMPs will have monitoring as an
Provision must be made that harmful substances which are not at the activity that the proponent will need to undertake and which can be independently
present time being tested (such as dioxins in air emission and ground audited by the authorities. All relevant legislation will be complied with. If higher
ash, and TBT that affects marine life) should be tested for. standards are considered to be essential, the appropriate Government body can take
a view. The Port Authority is obliged to comply with legislation as a minimum.
8.8 In the light of the requirements of the SA Constitution with respect to Habitat Council The authorities will need to ensure that both the provincial and national agencies
co-operative Governance, in the likelihood that the local and can meet their mandates.
provincial authorities of the Eastern Cape now or in the future find
themselves under too great financial stress to fulfil the obligations
which this project will place upon them, DEAT (on behalf of the
National Government) will underwrite these obligations, and if
necessary step in and provide the funding in order that the necessary
environmental mitigating measures may be conscientiously and fully
complied with.
8.9 An independent Environmental Monitoring Committee reporting to Habitat Council This is the mandate of the Ngqura Environmental Committee.
the provincial Minister for the Environment must be set up by the
Minister to meet regularly and monitor compliance with the
Environmental Management Plan during all phases of the
development.
8.10 It must be stipulated in the Management Plan that sub-contractors for Habitat Council This is part of the tender document that gets issued to contractors.
each and every aspect of this development be contractually bound to
comply with the environmental requirements in the Environmental


Management Plan.
8.11 The aesthetic aspects of the whole (short term and long term) Habitat Council This is addressed in the Town Planning Urban Design and Architectural,
development (such as structure design be as non-intrusive as Infrastructural and Landscaping Guidelines. In addition, the local government
possible) will be given due prominence, possibly by creating a Coega body, the NMMM, requires the submission of building designs and plans for
Aesthetics Committee on which independent architects and city approval.
planners with a good record of respecting the environment, as well as
representatives of the NGO fraternity will serve, to scrutinise and
comment on development drawings before plans are passed.
8.12 Adequate baseline studies on groundwater quality, existing levels of Habitat Council Baseline monitoring that CDC has commissioned covers all the aspects that are
pollution in the river and the estuary, and in the seawater or the bay, raised
as well as on ambient air quality, and the current state of marine
organisms, must be commenced with prior to any construction being
started.
8.13 There are a number of areas where mitigation measures are given or SANP The proponent will be required to conform to the ROD and accompanying
proposed which would reduce the negative impacts associated with conditions of approval. These conditions will probably require that an EMS and
the proposed port development. However, the success or actual various EMPs will need to be completed and approved prior to the different stages
realistic implementation of these measures is unknown, which gives a of the project, viz. construction and operation. The ROD should be specific with
misleading assessment of the impact. E.g. the impact on existing respect to penalties for non-compliance.
businesses such as the salt works as well as the abalone farm hinge The report specifically provides pre-mitigation impact assessments. This is in order
on the successful negotiations between the CDC and the respective for the I&APs and authorities to get a sense of what the impact will be without
parties, relocation of communities. Many of the environmental mitigation. The report clearly states in a number of places that the reader should
impacts assume that the necessary EMS procedures are in place but a consider the pre-mitigation implications e.g. Section 7.4 in the draft and Final EIR
review of the environmental targets (Appendix B) set for the port states that “The size, duration and nature of the construction has the potential, if
reveal them to be lacking. This issue will have to be addressed in poorly managed, to impact significantly on the environment. The majority of pre-
order to provide the public with assurances that these measures will mitigation construction impacts (Table 7.2a) are severe or very severe, which
be undertaken and implemented, and if limits are exceeded that there indicates that if the process is poorly managed and the recommendations made in
are mechanisms in place to deal with offenders. this EIA and the subsequent Environmental Management Plan are not heeded, the
impacts may well be significant.”
In addition the impact statements concerning the successful negotiations and

relocation of the Abalone farm clearly state in the draft and Final EIR that “if the
relocation is successful the impact should be of NO SIGNIFICANCE, but if poorly
managed, the overall impact could be VERY HIGH (-)”.
The comment provided by SANP does, however, highlight the fact that as with any
development, there are a number of unknowns and risks.
8.14 Do individual projects within the port / IDZ require separate EIAs P Martin This EIR is applying for the construction and operation of the port and associated
(August 2001)

and infrastructure before port construction begins? Authorities and port activities. In addition it is applying for the construction of the back-of-port
public are unsure of a procedure that should be followed. infrastructure (below N2) required for various future tenants. The tenants that
move to the IDZ will still be required to undertake an EIA, as required by
legislation. This question was dealt with in section 1.4.1. of the draft and final
EIRs.
9. Algoa Bay Management Plan (ABMP)
9.1 The ABMP forms an important component of the mitigatory WESSA The ABMP is a long term management plan, which must involve numerous
measures. There are recommendations in the plan that must form players in addition to the CDC and PAD. It is of great importance that the plan be
part of the conditions of approval and must be implemented prior to fully developed and implemented. It is suggested that the Marine and Coastal
construction and some prior to operation. Provincial and National Management wing of DEAT should be the agency responsible for ensuring the
DEAT need to ensure the ABMP is taken forward. Other major role updating and implementation of this plan.
players are Marine and Coastal Management and the Nelson Mandela
Metro. There is a process proposed to take the ABMP forward and While this plan is important and should be considered in the development of the
this has not happened. CDC has some level of responsibility to construction EMP for the Port, its completion is a separate issue to the construction
ensure the process is taken forward. of Ngqura Port as it is a holistic and not a specific project management plan. The
construction of the port should comply with and be guided by a specific
construction environmental management plan, which takes cognisance of the
recommendations contained in this EIR.
9.2 The subsequent environmental impact report dated July 2001 identifies Swartkops Trust The ecology of Algoa Bay is used in a holistic sense and incorporates all its
various events, which could cause damage to the ecology of the Algoa habitats e.g. beaches, estuaries and rocky shores.
Bay. Some of these are rated Very High in view of the potential for
immense and possibly irreversible harm. This, in turn, as stated above,
will have a direct impact on the Swartkops and Sundays River which
will, in turn, have a deleterious effect on Algoa Bay and so the cycle
will spiral downwards.
9.3 There is at present no over-arching Management Authority, which plans Swartkops Trust This statement serves to enforce the need for an inclusive Bay Management Plan
and manages the protection of the Bay with the power to take whatever with buy-in from all user groups, NGOs and authorities. Marine and Coastal
steps it deems necessary for this purpose. There are at best a number of Management should actively pursue the implementation of the Algoa Bay
agencies operating in different spheres, normally without proper co- Management Plan.
ordination and certainly without proper funding and resources.
9.4 An over-arching Management Authority (possibly similar to the US Swartkops Trust The development of the Algoa Bay Management Plan and its continued refinement
Coast Guard) be established by law for planning and managing the should ensure effective management.
protection of Algoa Bay and the estuaries which flow into it.
9.5 Its authority would include all forms of water-based pollution but must Swartkops Trust Agreed.
be extended to include land-based pollution sources (particularly water
and air) which affect the Bay in and around the Bay
9.6 This Managing Authority must be properly and adequately funded and Swartkops Trust All authorities should be adequately funded to ensure the sustainable management
given the resources it needs, not only to carry out its day-to-day of the environment. The Algoa Bay Management Plan should establish what the


functions but also to cope with disaster management immediately and requirements are and, within the present legislative framework, what authorities
effectively. are responsible for various aspects of management in the Bay.
9.7 An amount of least R25million should be made available immediately Swartkops Trust The funding of the management of the Bay should form part of the Algoa Bay
to show the relevant authorities are serious and be placed into a separate Management Plan. The exact requirements and sources of funds would need to be
Trust account in which all NGO's related to Algoa Bay are represented. established in an inclusive manner by the stakeholders.
This payment is to be regarded as an interim measure to fund an
investigation as to what is required in order to establish such an over-
arching Management Authority. Further funding must be made
available once these requirements are known and what needs the
management authority have.
9.8 There must also be a meaningful undertaking / commitment from Swartkops Trust The form of funding that the government provides is a matter that only they can
Government that the reasonable future funding requirements of the answer. In terms of environmental levies, this form of raising funds can be
Management Authority will be met. This funding would come directly considered by the ABMP but many companies regard company tax as including
from Arms offset / Government or by way of a levy on the parties who effective environmental controls as one of the services they are paying for.
benefit from the Port and the Industrial Development Zone. Certainly
those who set up businesses there should be required to contribute an
environmental levy as determined by the managing authority.
9.9 The Algoa Bay Management Plan (ABMP) contains many of the SAMREC/ Habitat The ABMP should be completed ASAP and should be driven by all stakeholders.
mitigatory measures for the Coega Project, many of which need to be Council Marine and Coastal Management should be tasked with driving the completion and
implemented prior to initiation or construction of the port. It is implementation of the plan. In terms of timing, the ABMP can inform both the
therefore crucial that the ABMP is workshopped with all the relevant construction and operational EMPs for the port but must be regarded as a separate
role players and amended, and an Algoa Bay Management Authority exercise (see 9.1).
(ABMA) is set up to drive the implementation of the Plan before
construction of the port commences.
10. Regional Transportation System
10.1 The impact on the regional road and rail network needs to be looked WESSA The development of the port and container terminal will extend over twenty years
at in terms of increased road and rail traffic associated with the and an increase in the demand for rail and road capacities, which are presently
development. National and provincial government needs to be made underutilised, will manifest itself gradually. It is the responsibility of Spoornet,
aware of this and it should be budgeted for. SA Roads Agency and the Provincial Roads Department to keep abreast of the
public demand for rail and road capacity and respond accordingly.
11. Bontveld
11.1 1:250000 mapping is needed for planning of an entire vegetation type WESSA The Bontveld specialist study aimed to put the distribution of Bontveld in the
to assess its conservation status. But for the planning of a specific Eastern Cape in perspective. For this purpose the level of mapping was at 1:
project 1:10000 scale should be used. A more detailed map showing 250000 level. The specialists' studies conducted by Cambell (1988) (See Specia list
the entire occurrence of Bontveld in the port area needs to be Study Series - Part 2) mapped the area at a greater resolution.
developed. The scale used for mapping Bontveld is too large. The
open space plan for Coega should be updated and completed. The EIR recommends that the different components of the EMS system should be
(August 2001)

Bontveld within the back of port area should be integrated into this completed prior to the phase that they are pertinent to. It is stated that the Open
area. Space management Plan will be commissioned once the formal go ahead for the
rezoning of the Core Development Area has been given (see Section 10 Appendix
B - Draft and Final EIR). It is recommended that the Bontveld be integrated into
this plan according to the recommendations outlined in the EIR (see section 2.2.1
Vegetation) which a states " All undisturbed Bontveld patches should be fenced
and actively protected from illegal dumping and infestation with alien vegetation.
The development of the tank farm and industrial precinct in the eastern section of
the back -of-port area must ensure that viable corridors are maintained between
Bontveld habitats”
12. Salt Marshes
12.1 The draft report states that salt marsh vegetation has been destroyed National Salt Limited The creation of a salt works on an estuary will have resulted in impacts on the
as result of the salt related production in the area. What baseline for functioning of both the estuary and littoral habitats.
measurement has been used to indicate that the Saltworks have
negatively impacted on zonation, fauna and flora in the area?
13. Open Space Management System
13.1 Sensitive areas identified for inclusion in the open space system are WESSA An OSMS will be prepared for the IDZ and this will be integrated with the Metro
based on erosion; there are more biophysical criteria that should be OSMS. OSMS is not only based on erosion as stated. It is based on other
applied to assess the open space system. There is no OSMS plan to biophysical criteria e.g. topography, esthetics, proximity to sensitive features,
comment on. When the OSMS has been finalised rezoning needs to Coega fault exclusion zone, etc.
take place differentially. WESSA is busy with a conservation plan
for the Metro and would like to meet with CDC to see how these two
plans link.
14. Monitoring of the Islands
14.1 The draft EIA made provision for the regular monitoring of the SAMREC The operational Environmental Management Plan will include a component, which
islands in Algoa Bay to determine the effects of the proposed port addresses ongoing monitoring. The EIR clearly recommends the establishment of
and IDZ on the island inhabitants. The draft subsequent EIR does not a marine rehabilitation centre. Monitoring marine bird populations for oiling
appear to cater for such monitoring. It is essential that a properly victims should form part of the activities undertaken by the facility. The
funded programme of regular visits to the islands be implemented to infrastructure required by the facility, e.g. boats, should be determined when an
ensure that any adverse effects on the island inhabitants can be inclusive process is undertaken to determine the exact nature of the rehabilitation
monitored and oiling victims can be identified and removed for centre.
treatment at the rehabilitation centre. This programme is essential as
a mitigating factor for the proposed port and IDZ. It is recommended
that a properly maintained vessel is made available at the port to
facilitate the monitoring process.
15. Economic Impacts
15.1 The EIR notes that due to lack of information about the future MMSC Cost-Benefit Studies necessarily take account of the costs and benefits throughout


expansion and development of the harbour, no assessment can be the economic lifetime of a project or an evaluation period, to the extent that the
made on the impact of such future expansion. Yet the economic social time preference takes no account of the subsequent costs and benefits. In
justification in the Merit report is premised on future expansion to 8 doing so a conservative escalation in the number of berths was considered in the
berths. This discrepancy between the assessment of the assessment.
environmental consequences of the development and the economic
benefits of the port biases the assessment in favour of the project. An in depth and exhaustive study was made on the impacts on the biophysical
environment of the initial ports. The impact of the entire future development was
qualitatively reviewed in section 10.2.4 to provide the reader with an insight into
possible future scenarios. In addition the ecological footprint assessed includes the
reclaimed area inside the port alongside the secondary breakwater. This would
allow for a further 2-3 container berths within the existing footprint which was
rigorously assessed. In terms of operational impacts specialist studies such as air
emissions and the risk assessment evaluated future scenarios as well as the initial
design. For the following reasons the consultants do not feel that the report was
biased in terms of equating the socio-economic and biophysical benefits and costs.
15.2 The viability of the IDZ has yet to be either assessed or MMSC The viability of the IDZ fall outside the scope of this EIR. It should however be
demonstrated, and no economic viability or cost-benefit analysis of noted that decisions on the port should only be taken if the authorities are
the IDZ has been undertaken since the withdrawal of Billiton as the adequately informed regarding the sustainability of the Coega Project as a whole.
anchor tenant.
15.3 The approval of the EIR by the authorities unless and until the IDZ MMSC Statement noted.
has been shown to be viable, would be action in direct violation of
the recommendations contained dint he EIR and would fatally
undermine SA's entire EIA process and procedure.
15.4 The Merit report has not been subjected to peer review or MMSC A peer review is not appropriate for an independent report. Furthermore, the
independent review of any form and reaches conclusions that are contention that the conclusions are fundamentally at odds with the almost
fundamentally at odds with the almost unanimous opposition of the unanimous opposition of the project in SA’s shipping community is far-fetched
project in SA's shipping community. and unsupportable without any proof. In fact, all the major ship owners agree with
the conclusions, but obviously have their own preferences for the location of the
new terminal, which includes Coega.
15.5 The preliminary findings of an independent review of the Merit MMSC Without providing any substantiation the comment that the Report on the Cost-
report by the MMSC are that the report is fundamentally flawed in its Benefit Study is “fundamentally flawed in its conclusions” and that “a technical
conclusions. A technical error has been identified in the merit error has been identified…. which would render the project economically
analysis, which would render the project economically unjustifiable. unjustifiable” cannot be answered. However, a fax was received from a researcher
at MMSC showing calculations which attempt to prove the flaw or technical error,
but in which costs have been confused with revenue and the logistics of container
operations seem to have been misunderstood. When the confusion was sorted out,
the calculations of MMSC substantiated the conclusions reached in the report.
(August 2001)

Presumably MMSC will withdraw, or may already have withdrawn its comment.
15.6 The Merit report has failed to look at the adequacy of the connecting MMSC The rail and heavy vehicle road traffic, which the container terminal will generate,
infrastructure between Coega and the main economic areas of SA. has been calculated and mentioned in the report – the increase is well within the
infrastructure capacities available. (See also the response to 10.1). It may be
added that the road infrastructure serving Richards Bay is inadequate and that if the
costs of its upgrading were to be included in the Cost-Benefit Study, the result
would add substantially to the net benefits of the development at Coega.
15.7 The concerns raised with regards to the Merit report suggest that any MMSC See response to 15.5. MMSC should withdraw this comment.
decision made would be based on a profoundly flawed economic
analysis.
15.8 There is concern about certain statements made with respect to the SANP These concerns have been addressed in comments 4.1 and 15.2.
sustainability and viability of the port development as well as other
socio-economic factors, as there seem to be contradictory statements,
which are made. The concerns expressed by the SANP revolve
around:
The fact that the viability of the IDZ has not been established, there
has been a lack of assessment regarding alternatives and there has
been a lack of a holistic approach. (See detailed submission for areas
of concern).
15.9 Impacts on the local economy must be reduced to a minimum e.g. try WESSA The draft and final EIR clearly indicate that relocation is the preferable option for
and avoid closure of the salt works and marine growers but relocate both the salt works and the abalone farm. The closure of the salt works is the most
them. significant negative socio-economic impact in the EIR.
15.10 The economics of the port are totally unconvincing. The salt works P Martin This appraisal is very simplistic and does not take into consideration the range of
provide about 140 jobs, abalone farm about 50 jobs. The port will direct and indirect economic implications of the Port. In addition this approach of
require about 350 people mostly skilled. Therefore about 150 jobs valuing a project is not sound in terms of infrastructural developments such as
will be created at the cost of R2 billion = R13 million to be paid by ports and roads. The studies have indicated that a port is required in the country
the taxpayer to create each job! over the next 20 years and the successful development of the IDZ can only add to
the economic justification of the port.
15.11 The report does not look at the feasibility of the Port. The PPC The Cost Benefit Study by MERIT is the only appraisal presently available. The
Income/Revenue from containers is assumed and the analysis only MERIT report considers a range of options but concentrates on Richards Bay and
looks at the difference between the costs of the two options (Richards Ngqura.
Bay and Ngqura). Has a proper feasibility study been done? Where
can this be examined?
15.12 In terms of container capacity, it is my understanding that Durban PPC All the alternative options were considered in detail in consultation with marine
Island can be developed further and the East London IDZ will create engineers, including Portnet’s chief engineer.
container capacity and a deeper port. Port Elizabeth is currently
under-utilized and Cape Town can be extended at a cost. Were the
above options included in the study or were they excluded from the


Scope? Alternatively were these costs examined in detail?
15.13 The accuracy of the Ngqura Capex estimate is within 15 - 20% and PPC It is uncertain how the accuracy of the cost estimates has been calculated by PPC –
the Richards Bay order of magnitude estimate is accurate to within it cannot be derived from the allowance for contingencies – nor is it clear how the
20-30%. The present Value Cost difference between the two options difference of R12m – R18m is calculated.
ranges from R 12m -R18m. Is there any justification in the claim that
the one option is "clearly" superior to the other? The accuracy of estimates is related to the level of detail to which investigation and
design work has reached.
16. Waste Management
16.1 A strong objection is noted against placing a nuclear waste site Khayamnandi No nuclear waste site is envisaged or will be permitted within the IDZ.
nearby. Alliance Meeting
16.2 The, current aloes dumping site crisis has not been resolved. M Vezile The CDC and the Metro are presently undertaking a project to identify a new
Communities, especially from the previously disadvantaged groups Regional General Hazardous Waste Processing Facility for the region premised on
are paying a high human price and their health is at risk. It seems an integrated waste management approach and innovative technology. The Aloes
that disposal sites and burying waste is not a holistic solution to site is the responsibility of the Metro, DWAF, DEAET and the private operator.
modern industries to dispose of their waste. A catalytic plasma waste This includes investigations into a plasma waste converter as a potential option.
converter should be constructed. This will ensure that a certain The Metro is further in the process of developing an Integrated Waste Management
portion of industrial waste produced is being recycled for reuse, thus Plan as required by National legislation for all Local Authorities. This will
saving resources for future generations. include, amongst other, strategies for recycling, reduction and treatment of waste
over disposal to landfill.
17. Alien Vegetation
17.1 The removal of alien vegetation during site clearance is fully Khayamnandi Agreed.
supported and the use of alien vegetation for landscaping purposes Alliance Meeting
during operations should be prohibited.
18. Ngqura Environmental Committee
18.1 When the Ngqura Environmental Committee was formed, WESSA WESSA Noted. Will again be drawn to the attention of the Ngqura Environmental
was informed that they would receive regular updates on the Committee (NEC). It is the responsibility of the NEC to follow up this issue.
development of the Coega Project from this body, but these have not
been forthcoming. It would be greatly appreciated if a direct line of
communication between WESSA and this body could be established.
19. Marine Rehabilitation Center
19.1 An updated, comprehensive oil spill contingency plan for Algoa Bay WESSA Agreed. This was one of the recommendations in the draft EIR (see Appendix C).
and a ballast water plan must be drawn up for both ports prior to the
Ngqura port becoming operational.
19.2 A rehabilitation centre is proposed to be set up prior to operation of WESSA The impact on birds during the construction phase is rated as LOW for most
the port. This should be prior to construction of the port as there will marine species but HIGH for certain species of conservation concern. The impacts
be impacts on marine birds during construction. during construction will primarily revolve around the loss of beach habitat and
(August 2001)

disturbance. Impacts from blasting are expected to be slight as long as the blasting
guidelines are adhered to. The environmental impacts surrounding birds can be
adequately handled during the construction phase if specific guidelines are
established. The construction EMP must include but not be limited to the
monitoring of bird populations for injured or oiled birds, rehabilitation at a suitable
centre for any damaged birds, catastrophic event planning and the prior approval
for the release of funds by PAD should a major event occur. The cost and
implementation of such a plan must be borne by the proponent.
An inclusive process (not an unsolicited bid) on the requirements of the

rehabilitation centre should be initiated once the ROD is issued. The CDC and
PAD as major stakeholders, in conjunction with other stakeholders, should provide
the infrastructure and funding for an appropriately sized and equipped centre.
19.3 Concerned about oil spills so close to the last remaining major P Martin The following recommendation is made in the final EIR - Chapter 7 Issue 8 Impact
penguin colony in a globally important bird area. Penguin colonies 5.
never recover from a major oil spill and an oil spill may lead to their A seabird and marine mammal rehabilitation and cleansing centre is required for
extinction. A first world country would never develop a harbour here both catastrophic events and the day to day operation of the port. The CDC and
for this reason. A rehabilitation centre must be built with materials, PAD, as major stakeholders, in conjunction with other concerned organisations,
trained staff and facilities ready for a full-scale disaster. This is the should provide the majority of the infrastructure and funding for an appropriately
ports responsibility not volunteers and NGO’s. Also breeding sized and equipped centre. The CDC in conjunction with PAD must initiate an
success must be boosted and funding provided. investigation into the exact requirements of such a facility and ensure that it is
functional prior to the operational phase of the port.
19.4 Samrec has already submitted a proposal to CDC and PAD regarding SAMREC A proposal by SAMREC has been received. The proactive stance by SAMREC is
the establishment of such a centre. acknowledged and lauded but the nature of the facility should be established
through an inclusive process with all stakeholders. The process of establishing the
requirements of the facility should occur soon after the ROD is issued. As the
facility and the process followed in deciding on its nature will be part of an
operational EMP of the port, it will have to be signed off by the authorities.
19.5 The centre is required on a permanent basis not for catastrophic oil SAMREC The exact requirements of the rehabilitation centre must be established through an
spills but day-to-day care for seabirds and mammals in the area. An inclusive process. Certain functions of the centre should be available on a day to
emergency plan to cater for the large number of seabirds that will be day basis to deal with general port operations. The construction EMP, operational
affected by a catastrophic oil spill must be drawn up with the EMP (which would include a functioning facility) must make provision for a
assistance of the parties involved with the rehabilitation of seabirds catastrophic event.
as a result of the sinking of the MV Treasure near Cape Town. This There is a national oil spill contingency plan in place that needs to be reviewed
plan must be drawn up as a matter of urgency so that sites for the given that it is quite an old document. Role players may have changed hence the
necessary rehabilitation facilities can be identified and secured. need to update it. The pollution control division of Marine and Coastal
Management based in Cape Town is the champion of this project. PAD will
update their plans and ensure that it comp lements the broader one.


19.6 The mitigating factor should not be included under “catastrophic oil SAMREC Agreed. The mitigatory action of Issue 8 Impact 5 (Chapter 7) has been amended
spills” but should be a permanent facility to cater for the day to day to read.· “A seabird and marine mammal rehabilitation and cleansing centre is
oiling and other mishaps suffered by seabirds and marine mammals required for both catastrophic events and the day to day operation of the port.”
and that an emergency management plan be drawn up as a matter of
urgency to cater for dealing with catastrophic oil spills
19.7 In the light of the vulnerable status of this species and impact that the SAMREC The impact on birds during the construction phase is rated as LOW for most
construction phase of the port will have on these animals it is vital marine species but HIGH for certain species of conservation concern. The impacts
that a rehabilitation centre is established and becomes operational during construction will primarily revolve around the loss of beach habitat and
prior to the initiation of the construction of the port. disturbance. Impacts from blasting are expected to be slight as long as the blasting
guidelines are adhered to. The environmental impacts surrounding birds can be
adequately handled during the construction phase if specific guidelines are
established. The construction EMP must include but not be limited to the
monitoring of bird populations for injured or oiled birds, rehabilitation at a suitable
centre for any damaged birds, catastrophic event planning and the prior approval
for the release of funds by PAD should a major event occur. The cost and
implementation of such a plan must be borne by the proponent.
An inclusive process (not an unsolicited bid) on the requirements of the

rehabilitation centre should be initiated once the ROD is issued. The CDC and
PAD as major stakeholders, in conjunction with other stakeholders, should provide
the infrastructure and funding for an appropriately sized and equipped centre.
19.8 As indicated in the detailed submission by SAMREC damage to the SAMREC RESPONSE TO COMMENTS FROM SAMREC DOCUMENT TITLED:
marine environment from oiling is caused not only by ship collisions MARINE RISK ASSESSMENT BY WSP WALMSLEY AND METOC PLC
or vessel grounding but also from general shipping traffic and this
factor does not appear to have been considered in the Subsequent The specialist responses to the detailed SAMREC comments raised are as follows:
Draft EIR. Samrec therefore questions the statement that the overall
risk of oil pollution can be regarded as LOW and submits that the risk Aspect 1: Reduction in risk by a factor of 10 for refined oil products.(Paragraphs 1
should be rated as MODERATE to HIGH. Samrec supports the to 19)
recommendation that detailed oil spill response planning is needed
for Algoa Bay that looks not only at the operations of the Coega The oil spill figures taken from worldwide data is for both crude and refined
harbour but also Port Elizabeth as well. products, of which the vast bulk come from crude and not refined products. From
the risk perspective of the submitted report, refined products therefore contribute a
smaller component to world-wide figures and these therefore need to be reflected
in the risk factor.
Additionally, during a spill, the higher evaporation rates of the refined products
(August 2001)

result in a reduced volume entering the environment than of unrefined products.
Since less material will be entering the environment, the risk levels which are
categorised on tonne equivalents (Te) will also be reduced reflecting the decreased
volume of pollutant entering the environment.
The factor of 10 reduction arises from the fact that 90 % of oil transported is as
crude and only 10 % is as refined, thus representing a factor of 10 difference.
Aspect 2: Risk of oil spills from normal operations.(Paragraph 20)
Table 3.5 of the risk report presents the risk of oil spills for from normal operations
during periods that ships are in Algoa Bay.
Further more, in Appendix C of the report it concludes:
Most incidents are the result of a combination of actions and circumstances, all of
which contribute to varying degrees to the final outcome, see Table 3.7 in section
3.4 (Risk Report – Volume 2 Specialist studies series. From the data given in
Table 3.7, it is apparent that;
• Most spills from vessels are caused by routine operations such as loading,
discharging and bunkering, which normally occur in ports and at oil
terminals.
• The majority of these operational spills are small, with some 92%
involving quantities of less than 7 tonnes.
• Accidents involving collisions and grounding generally give rise to much
larger spills, with a fifth involving quantities in excess of 700 tonnes.
Aspect 3: Overall risk of pollution should be regarded as moderate to high and not
low.(Paragraph 21)
Essentially we are in agreement with this view, but are of the opinion that with
mitigation the risk can be effectively managed. The risk of probability of
occurrence of a significant oil spill was determined as being low. The impact of
such a risk event is moderate to high, but if managed properly, we believe reduces
the overall risk to tolerably low. For this reason we make the following statement
in the risk report::
These risks are tolerably low, but depend on the deployment and effective use of


oil spill containment and skimming equipment. If this equipment is not available
the risk will be much higher.
In order to clarify the matter, and to incorporate new information provided by

Samrec, section 3.3. of the Risk report has been revised (see addendum below) :
3.3 Consequences of Occurrence

Expected cargo types are provided in Appendix A (CDC, 2000).
Bulk ferrous materials, such as the mild steel sheet, wire, rods and scrap pose a
potentially limited danger, though water quality issues would need to be
considered.
Fine powdered bulk materials have potential impacts as a result of dispersion and
blanketing on the sea surface when settled.
Bulk liquid spills, other than hydrocarbons, may have locally significant effects,
such as release of a large volume of H2SO4 on marine or benthic life immediately
effected. However, dilution within the bay will help to dissipate the pollutant,
reducing the significance over time.
Given that the oil cargoes handled in Port Elizabeth or Coega ports are refined
products, liquid spills such as the refined products have a potentially lower impact
than heavier fuel products released from a vessel itself. They will have potentially
little or no effect on the environment within the bay due to higher evaporation rates
and disperse into the water column quite quickly, though may pose a hazard due to
ingestion by marine life. The Australian Maritime Safety Authority (AMSA) has
highlighted the differences between heavy fuels and refined products and the
difficulty in quantifying the consequence. In general, however, they have found
that refined petroleum products tend to be more toxic to organisms but less
persistent in the environment. Crude oils and heavy fuel oils like bunker fuels on
the other hand tend to be less toxic but are more persistent and more likely to have
physical impacts on wildlife e.g. coating feather, fur and skin.
Additionally the chemistry of the crude oils and refined petroleum products varies
significantly. For each occasion, spilt oil or fuel will behave differently and it is
difficult to predict accurately the impacts on wildlife. It has also been found that
ambient wind and water conditions can modify the impact of oil on wildlife. For
examp le, on a warmer sea and in high winds, evaporation may remove the lighter
aromatic compounds. This further compounds the quantification of consequence.
Potential impacts also depend on the timing of the contact. Certain individuals
oiled early in a spill may be exposed to the more toxic components of the oil by
(August 2001)

direct contact and ingestion and suffer greater toxicity than those affected by a
more weathered oil. The thermoregulatory problems for wildlife would not
change. Some of the identified impacts include:
• Mother / pup bonding is affected by odour thus oil could affect the
identification of young and thus nursing activity is affected.
• Oil affects sensitive tissues if ingested.
In Algoa Bay, it is unlikely that any heavy fuel oils would be released outs ide the
port area, wherein it can be contained and cleaned up.
The heavy fuel oil used by the MV Treasure is not common in newer vessels,
which tend to use lighter fuels, VGO (Vacuum Gas Oil) or diesel. Thus if the
incident had happened with a more modern vessel, with lighter refined products,
the impacts would have been greatly reduced.
The winds and wave regime within Algoa Bay would make containment and clean
up much easier than in the open sea, where the MV Treasure incident occurred.
Aspect 4: Oil spill response planning (Paragraph 22)
No comment required as Samrec is in agreement with our recommendation.
In addition to this response from the WSP and Metoc it should be noted that the
EIR rates catastrophic oil spill as a VERY HIGH impact (Chapter 7, Issue 8,
Impact 5). The EIR also states that the impact of such an event prior to any
mitigatory actions as being very severe while after mitigation the impact is rated
as being severe on the ecology of the bay. The introductory section indicates that a
spill the size of the Treasure incident would impact significantly on the various
ecosystems within the bay.
20. Public Participation
20.1 The issues raised as part of the Public Participation must be MMSC The issues raised as part of the comments on the EIR have been addressed in this
addressed fully in the final EIR. comments trail and, where appropriate, the draft EIR has been updated or
amended.
20.2 The issues and response trail is not an adequate tool to address issues MMSC Where required the draft EIR has been amended or updated. An additional
raised by I&APS. Issues should be fully and meaningfully specialist study concerning resettlement was commissioned and included as an
addressed. appendix to the final EIR.
The purpose of the issues and response trail is to indicate to I&APs how the issue
they have raised has been addressed, for example by amending the draft EIR or
how the issue will be addressed in future, for example in the EMP to be approved
by the authorities. It further highlights areas of concern and is used as a foundation
for the Public Participation Report to be submitted to the Authorities for their


consideration in the decision making process.
20.3 An extremely short time period has been allowed for public MMSC The Authorities approved the time period for public comment on the Subsequent
comment. The MMSC has been unable to commission and submit Draft Port EIR, although a period of 21 days was approved I&APs were provided
comments from independent experts which will only reduce the level 28 days for comment. In response to a request from the Mandela Metropolitan
of information available and impact on the quality of decision Sustainability Coalition they were granted an additional 7 days to submit their
making around the project. comments. It should be further noted that all I&APs were informed during the
month of May 2001 that the Subsequent Draft EIR report would be available for
public comment towards the end of June 2001. This notification included a list of
the specialist studies that would be undertaken as part of the Subsequent Port EIR.
20.4 There is a lack of information going to the public on a regular basis. WESSA A Stakeholder’s Forum is a tool that has been mooted by the CDC for mainly
A forum should be established that shares information with the public conflict resolution. CDC will continue to facilitate the establishment of a
on a regular basis. Such a structure would be supported as it is to the stakeholder forum. There are limitations that need to be overcome prior to the
advantage of I&AP’s to be informed about what is going on. establishment of the forum viz: Mandates from various sectors, acceptance of
This process should be facilitated by someone independent. Sub- ground rules, information sharing with various stakeholders as well as the
committees need to be established e.g. environment, labour, socio- necessary RODs’ for the Project.
economic. The establishment of a forum to facilitate ongoing
information sharing needs to become a condition of approval. The establishment of a 'platform' for amongst others continued dialogue and
information sharing on the project on an ongoing basis has been recommended in
previous public participation reports and is again recommended in this Public
Participation Report, It is strongly urged that for a project the size and complexity
of the Coega Industrial Development Zone and Port, which continues to evolve
over time, that a mechanism is put in place to facilitate ongoing dialogue, capacity
building and information sharing with all interested parties. This process would
be separate to Public Participation as required by the EIA regulations (Sandy &
Mazizi Consulting, August 2001)
20.5 Samrec submits that an environmental monitoring committee (outside SAMREC It is a recommendation of the Final Public Participation Report that ongoing
the Ngqura Environmental Committee) must be set up to allow all communication with I&APs be part of the construction and operational phases of
environmental bodies (including NGO’s) an opportunity to be the Port and IDZ. (See above 20.4) The development of a mechanism for ongoing
updated on the project, and to make meaningful input into public involvement is strongly recommended. This request has been made by
environmental compliance of the port and IDZ. numerous I&APs from various sectors and with different interests. The request
revolves mainly around two issues:
• The need for ongoing information sharing on the project
• The need for some kind of a 'forum' to be established for open dialogue
and information distribution (Sandy & Mazizi Consulting cc. August
2001)
20.6 Will there be similar meetings once the project has started to keep Kwalanga Alliance A proper information release strategy will be implemented and a site information
people informed of the process and the project? center will be set up.
(August 2001)

20.7 All ROD’s that are issued must be distributed to I&AP’s and they WESSA The ROD will be made available by the public participation consultants. I&APs
should afforded the opportunity to comment. will have 30 days to appeal the ROD.
20.8 Who are we meeting with and how do we identify them? What is the Kwalanga Alliance The Final Public Participation Report outlines the process implemented for public
legislative requirement for consultations? participation for the Subsequent Environmental Impact Report for Coega. This
includes the identification of I&APs. The process for Public Participation has
followed an Authority approved process in accordance with the regulations
governing Environmental Impact Assessments in terms of the implementation of
Sections 21, 22 and 26 of the Environmental Conservation Act.
20.9 Will there be a continuous mechanism for communicating progress to Kwazakhele See recommendation 20.4 and 20.5 above. In addition a proper information release
the public? Alliance/ Addo strategy will be implemented and a site information center will be set up.
Alliance
21. Breakwater Construction
21.1 Where will the rocks for the construction of the breakwater come Kwalanga Alliance The rocks for construction will come from Coega Kop, and the rock for the
fro m and will they be compatible with what is around there? breakwater is the same type of rock as Jaheel and the other islands in the St Croix
Island Group. No adverse effect on the ecology of the area is expected to arise
from the rock material used.
22. Noise
22.1 Concerned about the sound decibels of ships at the harbour, Khayamnandi While a specific noise study has not been commissioned, it is unlikely that the
disturbing elephants at the nearby Greater Addo National Park Alliance Meeting ships will be noisy enough to impact on the elephants at Addo. This is certainly the
case in the regions where the National Road will be near the proposed Greater
Addo reserve.
23. Project Description
23.1 Were the additions or changes made to the initial project description Khayamnandi The changes in the port design from that proposed in the revised EIR were
necessary? If so, why? Alliance Meeting necessary as a container terminal was required. These changes in design resulted in
the authorities requiring a new EIA on the proposed development.
23.2 Is there a need in the SA shipping industry for a container terminal? Khayamnandi The MERIT specialist study (see Specialist Studies Volume 2) clearly indicated
Is there space in the harbour for ships requiring mechanical repair or Alliance Meeting that the projected demand in container traffic required an additional facility to be
attention? created in South Africa. The proposed port does not include extensive ship repair
facilities. The port would provide a haven for any ship in distress assuming that it
is not regarded as an environmental risk.
23.3 Will there be any nuclear powered ships docked in the harbour? If Khayamnandi Commercial ships are at present generally not nuclear powered. The port may from
so, how many? Alliance Meeting time to time receive courtesy calls from nuclear powered Naval ships.
24. Water
24.1 Will there be any impacts on underground water and if so, to what Khayamnandi The impacts on groundwater resources are reviewed in Chapter 5 (Issue 7 – Impact
extent? How will this be mitigated? Otherwise how will Alliance Meeting/ 1) as well as in the Specialist Dredging, Excavation and Disposal report (Specialist
underground water be protected? Vezile Studies Volume 2 - page 18). The impact is regarded as being of LOW


environmental significance. Mitigation involves control of drainage patterns and
where possible maintain normal drainage regimes.
DWAF have set stringent guidelines so that existing underground sources are
protected e.g. limit on depth of quarrying at Coega Kop. CDC has commissioned
SRK to undertake this baseline ground water monitoring. Further, all the tenants
within the IDZ will be required to undertake ground water monitoring in and
around their activity.
24.2 Is there a plan to use recycled water where possible at the harbour? Kwazakhele Alliance No. The opportunities for use of recycled water in the port are limited and unlikely
to warrant a dual water supply system. However, recycled water will be used for
industrial purposes.
24.3 What will be the cumulative impact of the port’s water consumption SANCO PE Water is a legislated resource in South Africa and administered by the National
on the availability of water for the general public? It is understood Department. The water needs of the port although not substantial are in addition to
that the public pays 0,24 cents per litre and that industry pays 0,12 existing needs and additional supply capacity, if this is not already available it will
cents. Does this mean that the public will subsidise the Coega Port? have to be provided by the Authority responsible for water supply. It is not
expected that the supply of water to the port will impact negatively on existing
water users in the Metropole. It is standard practice to that bulk water users
receive a discount.
25. Municipal Services
25.1 What impact will the high consumption of water and electricity have Kwazakhele Alliance There will be a limited impact on the general public. The power supply will be
on the general public? How will the above impact on current service taken directly from the main Grassridge Switching Station. For large consumers of
charges? Are we going to pay more once the project starts? water, recycled water will be supplied.
26. Socio-Economic
26.1 What will be the direct economic benefits of the port? What Khayamnandi The direct economic impacts of the port are assessed in Issue 2 (Chapter 9). The
mechanisms are in place to ensure that the poor also benefit from the Alliance Meeting direct economic spin-offs (i.e. employment and multiplier effects) of a container
economic spin-offs and not just the rich? terminal are invariably small in relation to the investment. The economic spin-offs
from the port itself will depend upon its development; if many ships call – say as a
result of the development of the IDZ - the spin-offs through the multiplier effect
could be substantial.
The CDC and PAD have equitable procurement and employment policies. The
CDC has specific policies to enhance local procurement and redress the inequities
of the past. (See further details in 26.2 below)
26.2 Will there be a single database or labour pool used for the different Khayamnandi It is the CDC’s intention to maximize the use of local labour. The CDC will
contractors, or will contractors source labour on their own using Alliance Meeting/ follow an approach to develop the skills that will be needed for the project and has
different sources? Local labour must be used. Northern Areas set a target of using 70% of local labour on the project. It must be understood that
Alliance with the diverse skills that will be utilized during the construction phases not all
the skills will be available from the local skills base nor would it be possible to
(August 2001)

develop all the skills for the project due to the long term of training needed for
specialized skills. In the cases where the skills are not available from the local area
strategies will be formulated to engage these skills from other areas. The CDC will
use a central database for sourcing of labour for training and is in an advanced
stage of developing this process.
26.3 How will we know when employment commences? Will people Kwalanga Alliance/ The CDC will advertise widely when recruitment starts and will also communicate
from Uitenhage and Addo also have access to job opportunities Addo Alliance/ through various governmental and community bodies.
offered by the port? Recruitment offices must be accessible e.g. a Kwadwesi Alliance/
mobile office Veeplaas Alliance/ The CDC are currently exploring the strategy of giving wide access to the
Northern Areas recruitment process by using any method available for recruiting people from
Alliance/ Wells different geographic locations. This strategy will include the use of satellite
Estate recruitment offices or making application forms available at central points.
26.4 What criteria will be used for selecting trainees and employing Kwalanga Alliance/ During the tender phase all contractors will have to submit a skills demand form.
people? How will we know about training opportunities? People Kwazakhele alliance/ This will stipulate the number of skills, timeframe when these skills will be needed
cannot afford training, how is training going to be co-ordinated and Addo Alliance/ as well as the skills level that will be needed. The CDC will utilize a Labour
where is the money going to come from? How will the community SANCO PE/ Management System that will assist in the planning for training and establishing
benefit during the tender process? Kwadwesi Alliance/ when training should commence.
Addo/ Zwide
Alliance/ SANCO/ This system would analyse the demand for skills with the availability of skills. If
Missionvale Alliance/ there is a shortage of skills the CDC will apply to the national skills fund for
SATAWU/ Veeplaas training. The Department of Labour is managing the funds and will approve skills
Alliance/ Bethelsdorp training on a demand basis. The selection of training will be based on an
Alliance/ Northern assessment basis and also on a random selection process in the cases where there is
Areas Alliance/ Wells high availability of skills needed. People will register as job seekers on a database
Estate/ Vezile and will be selected from this database.
The community will benefit two fold from the tender processes. The CDC will
utilize strategies maximized to access the project for manual labour. Through
demanding the demand side needs from the contractors during the tender process
the need for specific skills can be established and preparation work can be started
long before what is normally the case. This can assist the project team with
facilitating funds for training where needed and also to prepare communities to
register for the specified skills needed.
26.5 The opportunities for emerging contractors need to be checked. How Kwadwesi Alliance/ The CDC will follow a procurement process that is in line with government
will the community benefit during the tendering process? SATAWU policies as set up by Department of Public works and the Department of Finance.
This will ensure that emerging contractors will have greater access to the project
and that price will not be the only denominator for awarding tenders.


Further, the CDC will enter into partnerships with different stakeholders like local
business service centers, advisory bodies, government agencies, finance and
lending agencies to facilitate a cohesive plan to prepare prospective emerging
businesses. This process has already started. Work packages will also be
structured to ensure greater access to the project. The CDC aims to set targets for
emerging businesses and this method of targeted procurement will be able to be
audited by independent bodies.
The type of jobs that will be created is dependent on the phases of the project. In
the first phase of development all levels of construction related jobs would be
created e.g. civil & building jobs, mechanical, electrical, instrumentation jobs.
Specialised skills will be needed in Engineering and the building industry. There
will also be jobs in service industries like financial, hospitality, security and
transport.
In the operational phase, manufacturing jobs in the metallurgical, automotive, and

electronic and textiles industries will be created.
The jobs that can be created during the operational phase are dependent on the type
of investors that settle in the zone. During this phase there will also be jobs created
in administrative, financial, transport, information technology, hospitality, property
and services sectors.
The Port Authority has developed and is maintaining a database with details of
suppliers and contractors. This database will be provided to tenderers for the port
related construction contracts in order that they may engage these suppliers and
contractors. It is the responsibility of emerging contractors to register their details
with the Port Authority.
26.6 How many sustainable jobs will be created? There seems to be SANCO PE/ Addo/ Until the investors have finalised their investment the figures of sustainable jobs
inconsistency in the messages sent out by CDC in this regard. SANCO/ SATAWU/ for the IDZ are an exercise of speculation. Approximately 350 permanent jobs will
Veeplaas Alliance result within the Port Authority area and container terminal as a result of the first
phase of port development.
26.7 Is this not going to encourage tax holidays on companies based at SANCO National Government has not adopted a policy of tax holidays.
Coega?
26.8 How will people be protected from exploitation by companies? SANCO The project will not deviate from the current legislation. The project will comply
to the current Labour Relations Act, Basic Conditions of Employment Act, Skills
Development Act, Skills Development Levies Act, Occupational Health and Safety
(August 2001)

Act and all the other relevant acts and regulations to ensure that any participants in
the project are protected.
26.9 What about existing companies will they relocate to Coega? SANCO Existing companies will be encouraged to remain as presently located but will also
be encouraged to plan for future expansion and downstream activities at Coega.
26.10 What type of jobs will be created? SATAWU This is difficult to comment upon, without knowledge of the exact companies that
will locate within the IDZ. Within the Port Authority the majority of the new jobs
will be associated with marine services.
26.11 How will the container terminal affect the present harbour? SATAWU The exact effect of the container terminal on the PE harbour has not been
established, as the working relationship between the two harbors in the Bay has not
been finalised. The impact has been rated as being HIGH (-) on a precautionary
basis. The impact is clearly outlined in Chapter 9 Issue 3 Impact 3 in both the draft
and final EIRs.
27. Wells Estate Relocation
27.1 What are the details of the relocation process? People are not happy. SANCO/ Motherwell A number of questions and comments were raised on the resettlement of people to
What does the relocation / resettlement agreement contain? Were Community Wells Estate. In order to adequately address this issue an additional specialist
human rights violated during this process? Is the relocation process Development Forum/ study was commissioned to investigate what transpired in the move and what the
legitimate. SATAWU/ current impacts on the people are (See appendix E). The reader is encouraged to
Bethelsdorp Alliance/ read this study as well Chapter 9 Issue 5 (Resettlement) which has been updated to
Fishing Forum/ incorporate the findings of the Resettlement Specialist study.
Northern Areas
Alliance The details of the relocation process are outlined in Appendix E. The CDC was not
the developer for Well’s Estate Phase 1. The developer was the NM3. CDC
facilitated as per the request of the developer. There are numerous agreements
between different parties such as the CDC, PEM municipality and the resettled
community.
27.2 Why was the Wells Estate site selected for relocation? Concern SANCO PE Well’s Estate was selected by the Port Elizabeth TLC as an area for low cost
about the site in relation to the truckers inn, which is notorious for its housing. In terms of safety the recent specialist study indicated that many people
commercial sex workers. Is there a master plan for the area with felt that they now live in a safer environment.
regards to growth and development? The Coega Community has a
school, is there provision for that and any other facilities? At present the Nelson Mandela Metropole has undertaken to provide a school,
In terms of the resettlement plan, families were given R3000 as part clinic and communal garden while the CDC will provide a soccer field.
compensation. The houses at Wells Estate are small, have very little
room for extensions whereas eKuphumleni would have had 250m2. The municipality is developing an integrated development plan. Water is available
There is no electricity in the Wells Estate houses, no running tap on site but it is up to the individual households to apply to be connected. Some
water, a terrible smell from the nearby Markman area and not houses are experiencing plumbing problems. Appendix E provides examines the
everyone from Coega has been accommodated at Wells Estate. current state of the houses as well as the aspirations and expectations of the people.
27.3 People at Wells Estate over the age of 18 with their own families Northern Areas This is a matter for Local Government, which administers the process.


should be given their own houses and not have to stay with their Alliance
parents.
27.4 Why has CDC relocated communities before it obtained a temporary SANCO PE CDC facilitated the relocation of the Community as per the agreement between the
operators license? local government and the community.
27.5 Is there a written relocation agreement between the CDC and the SANCO PE/ The process and history of the relocation is outlined in appendix E. There are a
Coega Community, or is the agreement between the CDC and the Missionvale Alliance number of agreements between different parties such as the CDC, resettled
Algoa Regional Services? If not, why? There have been confusing community and the Nelson Mandela Metropole. There is however no overarching
statements in the media – what is the process for relocation? resettlement and compensation plan.
27.6 The Coega Community has a school, is there provision for that and SANCO PE See comment 27.2
any other facilities?
In terms of the resettlement plan, families were given R3000 as part
compensation. The houses at Wells Estate are small, have very little
room for extensions whereas eKuphumleni would have had 250m2.
There is no electricity in the Wells Estate houses, no running tap
water, a terrible smell from the nearby Markman area and not
everyone from Coega has been accommodated at Wells Estate.
27.7 Have human rights been violated in the relocation process? SANCO PE This is a matter, which the Human Rights commission is presently investigating.
27.8 Does the agreement between the CDC and ourselves (Wells Estate) Wells Estate Yes
regarding employment still stand?
27.9 The houses need to be inspected because on rainy days some flood or Wells Estate This will be attended to as part of the normal defects liability responsibility of the
leak. contractors.
28. Access to Beaches
28.1 St Georges Beach and Jooste Park Beach are filled to capacity during SANCO PE/ M It is planned to use the Joorst Park resort as a construction village and this will not
the festive season and are the closest and cleanest to the township. Tofile be open to the public. The public will not have access to the port construction site.
The New Brighton Beach is not clean and Bluewater Bay Beach is The contractor is required to secure the construction site and this will probably
not that accessible. There is a concern about the possible closure of occur along a line south of the sand bypass site.
access to Jooste Park Beach, which is likely to be compounded by the
expansion of the Addo Elephant Park, wh ich might include some
coastal areas as reserves. The closure of Jooste Park will be
inconsistent with the provisions of the Coastal Management Policy
regarding access to the coast. It is recommended that Jooste Park
Beach be open to the public during the festive season until a suitable
alternative is found.
29. Effect of Blasting on Aloes
29.1 The assessment of the Zwartkops Trust and certain independent expert Swartkops Trust The quarrying of rock at Coega Kop falls outside of the scope of this EIA. The
advisors is that the blasting which will take place at Coega Kop could scope of work and parameters of this EIA are outlined in the authority approved
(August 2001)

destabilise the rock and other geological strata around Aloes 1, which Plan of Study (Appendix A in the Draft and Final EIR). The quarrying activities
could result in the escape of large quantities of toxic leachate into the have been subject to a separate Environmental Management Programme Report
Swartkops Estuary. This will have a devastating affect on the estuary (EMPR) which is a requirement of the Department of Minerals and Energy (DME).
and surrounds. Depending on the nature, quantity and quantity of the This EIA has not investigated the issue of quarrying in any manner and thus cannot
leachate, which escapes into the estuary, the result could be catastrophic comment.
and possibly irreversible.
29.2 That prior to any blasting, funds be made available for the appointment Swartkops Trust The quarrying of rock at Coega Kop falls outside of the scope of this EIA. The
of a highly competent geological survey team from sources totally scope of work and parameters of this EIA are outlined in the authority approved
unconnected with any activity related to the industrial development Plan of Study (Appendix A in the Draft and Final EIR). The quarrying activities
zone and the harbour to carry out a survey on the impact of blasting on have been subject to a separate EMPR, which is a requirement of the Department
Aloes 1, the likelihood of the escape of leachate into the environment of Minerals and Energy (DME). This EIA has not investigated the issue of
and recommendations as to measures which should be taken to prevent quarrying in any manner and thus cannot comment.
this occurring.
29.3 In the event that it is recommended that certain steps be taken, sufficient Swartkops Trust The quarrying of rock at Coega Kop falls outside of the scope of this EIA. The
funding must be made available for this purpose, which may include scope of work and parameters of this EIA are outlined in the authority approved
funding for possible future spills and clean-up operations. If funding for Plan of Study (Appendix A in the Draft and Final EIR). The quarrying activities
such future requirements is recommended, these funds should be made have been subject to a separate EMPR, which is a requirement of the Department
immediately available and placed in a separate account which may not of Minerals and Energy (DME). This EIA has not investigated the issue of
then be allocated for any other purpose without the written approval of quarrying in any manner and thus cannot comment.
the Zwartkops Trust and any simi lar
30. General Comments
30.1 The environmental imp act assessment process has been a charade. Swartkops Trust In the undertaking of the subsequent PORT EIR due process has been followed
Statements were made publicly, prior to the conclusion of the throughout. The Coega IDZ and Port form part of the National Government’s
environmental processes required by law, that the Port was to be macro-economic strategy and it is not appropriate to comment further.
constructed and that the industrial development zone would continue.
These actions make it impossible for any alternatives to be considered The marketing of the project should not be confused with complying with
and the only thing then left is to try and ameliorate the environmental legislated approval processes. An application to undertake this activity has been
degradation, which may be caused by the projects. submitted and due process is being followed. The outcome is still to be determined
and will be challenged if perceived to be above the law.
30.2 In accordance with NEMA an independent review of the report MMSC The MERIT report, as with the other specialist reports, was undertaken by
should be conducted and especially on the Merit study. professional academics who are independent of the entire project. The EIR was
undertaken by a reputable impact assessment agency, which is independent of the
proponent. The studies were reviewed and scrutinized by I&APs as part of the
public participation process. The Public participation process was undertaken by an
independent company specialising in public part icipation.
30.3 Request that the independent report to be submitted by the MMSC on MMSC An authority approved public participation plan was followed. It is expected that
the Merit Study be legally and procedurally incorporated as part of the authorities will follow the process stipulated. An additional seven days was
the comments submitted by the MMSC. provided to the MMSC for comment to allow them to submit specialist comment


as requested. Their comments on the MERIT study are included in the Final
Public Participation Report.
30.4 Meaning of the term “environmentally sensitive areas” in the report. SANP Environmentally sensitive areas are those areas which are sensitive to perturbations
Does this mean that these areas are no go areas for development or or are of conservation importance. Figure 5.2a indicates the proposed
will there still be development taking place in these areas and if so development, no go and go areas and their definitions. As can be seen,
what types of development and what mitigation measures will be in development will occur in certain areas which are regarded as sensitive (No go
place? areas). The definition of the no go areas does however allow for development of
What actions will be taken against tenants who breach environmental activities such as the harbour. Specific mitigatory actions concerning a wide range
standards and regulations? of habitats and biota are outlined in Appendix C. Section 2.2. of appendix is
entitled “Recommendations for the protection of specific flora and fauna as well as
specific habitats.
Action to be taken by defaulting tenants is subscribed by law and will be applied.

Activities at the IDZ and Port will be part of an independent auditing process
which will l be made available to the authorities and non compliance should be
responded to.
30.5 Will the discharge of sediment from the sand bypass system be sub- SANP The sand bypass system is a mitigatory action. The sediment will be discharged in
tidal (mention is made that it would be dumped on the beach) and the shallow intertidal zone as this will result in it being effectively reworked into
what monitoring systems are in place to ensure that the systems is the long shore littoral drift. The sand bypass facility will be operational once the
operating properly? It is also stated that this sand bypass system breakwater is finished. In order to ameliorate any short term impacts, clean
would be commissioned before the breakwater construction is excavated sands will be deposited on the northern beaches (see Dredging,
completed (pg. 42) but then later that it will only be commissioned Excavation and Disposal report – Specialist Studies Volume 2).
after completion of the breakwater (pg. 125). This needs to be
clarified, but should presumably be operational prior to completion of Monitoring will take place and will be specified in the operational EMP.
the breakwater. Monitoring will involve monitoring beach profiles and aerial photography which
will be compared to baseline data.
30.6 Further blasting operations mitigation (in addition to the 2-km SANP Blasting guidelines, which will need to be approved by the authorities, have been
exclusion zone for marine mammals prior to a blast operation) should proposed. These guidelines are designed to prevent any physical damage being
include no blasting periods, specifically when there are whales in the inflicted on marine mammals and birds. While it would be ideal to stop all blasting
vicinity and particularly when calving. while whales are in the Bay, this would economically cripple the project as
construction and dredging would be stopped. In addition it would lengthen the
construction period which would have associated impacts. It should be noted that
extensive blasting is not expected.
30.7 The nature of some of the impacts on species of special concern is SANP The impact in question is the disturbance of species of special concern. This
listed as being of localised impact or concern. However, it appears impact primarily relates to the impact that the proposed port will have on Jaheel
that contradictory statements are also being made here, specifically in Island, which is located 500m from the breakwater. The impact associated with
connection with the African penguin. ‘Bearing in mind the recently the port is localised and will primarily impact upon Jaheel Island. The
(August 2001)

reported decline in the Algoa Bay penguin population, the reduced ramifications are significant on a regional scale and as such the rating is HIGH (-).
productivity has regional as well as international implications’ (pg. The rating was not Very High (-) as the impact will be predominantly on Jaheel
135). Impacts on such species of special concern should be rated as Island and not some of the bigger islands such as Bird.
VERY HIGH.
30.8 Need to review the EIA for the proposed IDZ and the activities SANP At the inception of the Coega project an SEA (Strategic Environmental
associated with this area. The area has not yet been declared an IDZ Assessment) was undertaken on the whole project. In addition a rezoning EIA was
and the CDC do not yet hold a provisional operators permit but there completed for the IDZ, an EMPR for the quarrying of rock at Coega Kop and three
are currently activities being undertaken for the development of the EIA studies on the port (culminating in this report) were undertaken. As
port facilities. Furthermore there has been no holistic assessment of mentioned in previous comments the large number of reports and iterations in
the impacts associated with the area demarcated for the IDZ (12 000 combination with the period of the project has resulted in a complex situation. An
ha at last indication). It is critical that these activities are assessed in attempt at providing a holistic overview was undertaken by the proponent in the
the light of the overall development of both the port and IDZ. production of the Integrated Environmental Summary Report. Unfortunately this
report preceded the latest Port EIR.
The authorities in their assessment must however note and be aware of the
interactive nature of the various studies on the Coega Project as a whole.
30.9 There is no indication of how the assessment of potential fatal flaws SANP As with the entire impact assessment process, professional judgement is used to
was handled. At what level must an impact be listed (there are ascribe impact levels. Most impacts are qualitatively assessed but certain impacts
already some which are of VERY HIGH significance) for it to be can be quantified and where necessary a quantitative approach is taken e.g. risk
recognized as a fatal flaw. Furthermore, who determined whether assessment. There are no hard and fast rules regarding a fatal flaw but they are
these impacts constituted fatal flaws or not? normally associated with impacts of VERY HIGH negative significance. Most
fatal flaws in projects are identified at a strategic or scoping stage, but this does not
preclude a fatal flaw being identified in the EIR.
The VERY HIGH impacts associated with the project in terms of the natural
environment were catastrophic oil spills and the introduction of invasive
organisms. These were not classified as fatal flaws as they are not project specific
and are unlikely to occur. The only other VERY HIGH impact was associated with
the one scenario concerning the salt works, which is a macro-economic impact
associated with closure of the facility. This impact was rated as VERY HIGH on a
precautionary basis as no specialist study had been conducted. In addition the loss
of jobs and revenue goes against the very purpose of the Coega Development. The
port will only employ 350 workers, and therefore the loss of 140 jobs is very
significant. It must however be recognized that the port is the infrastructure for a
larger development (IDZ) which, if successful, will provide significant input into
the region’s economy and fulfill a need in the country’s long term port needs. The
closure of the salt works is a very significant impact and, as stated in the final EIR,
concerted efforts should be made to relocate the operation.

30.10 Is a "deep" water port as opposed to a "normal depth" port, still a PPC Yes, to the extent that provision should be made to accommodate ships in future
necessity? carrying 4000 to 5000 containers with a draft of 14m and requiring 16.0 m of water
– the existing port at Port Elizabeth has a maximum depth of only 12.2 m and
cannot accommodate even the ships in current employ when fully loaded.
Container ship sizes are steadily increasing especially those serving container hub
ports. Bulk cargo ships, which are required to serve the IDZ needs, also require a
deep water port. The first phase of the Port of Ngqura is therefore to be dredged to
accommodate a design ship with draft of 14,0 m.
30.11 The CDC is apparently trying to exclude the eastern Coega Kop from P Martin The Port Authority has applied for permission to mine the Western Coega Kop and
IDZ so that they are not responsible for its protection. Unknown will comply with the approved EMPR.
until recently is that La Farge has mining rights and an approved
EMPR for the eastern Kop. This issue must be resolved quickly. No
safeguard for Eastern kop could equal no mining of Western kop and
therefore no harbour. These are all interlinked.
30.12 The industrial development will almost certainly lead to the P Martin “Butterfly valley” will not be developed and there will be a buffer zone.
extinction of the butterfly species in the area.
30.13 What plans are in place to recycle waste? Bethelsdorp Alliance An integrated waste management strategy will be developed.
30.14 There must be strict monitoring by the CDC and government of the Northern Areas The CDC will engage the services of a specialist in the verification of the
procurement process to avoid window dressing of companies using Alliance employment equity process and will also set up a process that can be audited
different names whilst there is only one company. independently. Adjudication processes are designed to ensure that this problem is
addressed and can be managed effectively. PAD’s procurement process requires
tenderers to provide details of company ownership and the supplied information is
carefully scrutinised and verified.
30.15 Site clearing should be labour intensive and the wood given to people Centenary Hall The CDC is looking at labour intensive methods of construction and will utilise
who need it. more labour intensive methods where possible. The CDC is very aware of its
social responsibility and will look at ways of maximizing the benefits to the
communit ies. Wherever possible wood would be made available to the
communities.
30.16 We appreciate the project, but it must begin now so people can work Bethelsdorp Alliance/ Construction of the port may not commence without environmental permission
and crime reduced. The process must be speeded up and job creation Northern Areas from the Authorities for the implementation of the proposed project. Within these
must begin. Alliance/ Wells constraints the project will be started as soon as possible.
Estate
30.17 Laws need to be implemented to ensure that CDC acquires land at a SATAWU Land procurement will follow and comply with the existing legal frameworks.
lower price from landowners to ensure development takes place.
30.18 What is the relation between CDC and the arms deal and what will be SATAWU The relationship between the arms deal and Coega falls outside of the scope of this
(August 2001)

the effect on construction? Are the people opposing Coega confusing EIR. The proponent maintains that there is no relationship between Coega and the
us by relating it to the arms deal? arms deal
30.19 What control measures will be in place to prevent foreign ships SATAWU Existing legislation will be strictly enforced. National and international legislation
dumping waste in SA waters? is already in place. Enforcement is by the relevant Authorities including the Port
Authority within the port limits.
30.20 Where does the money for the project come from? Missionvale Alliance National and Provincial Government and, ultimately, from the private sector.
30.21 If there is an appeal how long will it take, because people need jobs? Missionvale Alliance The appeal period is 30 days after the record of decision.
30.22 Will the IDZ operate as a section 21 and how will it affect our SATAWU The CDC is a (Pty) Ltd Company and not a Section 21 Company. The IDZ
members? operator will be a private company.
30.23 What is the current and future role of the government? SATAWU To facilitate and promote environmental and socio-economically sustainable
development. The Port of Ngqura will be part of the national network of ports
provided and managed by the Port Authority. The Governments role is also to
implement the National SDI policy.
30.24 Appreciate the project, enough talk about marine mammals, people Zwide Alliance The socio economic characteristics and needs of the Eastern Cape have been
need jobs. clearly outlined in the EIR. The EIR covers biophysical, economic and social
assessments in order to get an overview of the merits of the project.
30.25 How is the fishing industry going to be affected? What are the Zwide Alliance/ The impact on the fishing industry is covered in Chapter 9 (Issue 4 – Impact on
impacts on the quality and availability of fish? SATAWU/ existing businesses) of both the Draft and Final EIRs. The overall after mitigation
Bethelsdorp Alliance significance was rated as LOW. Specific desktop assessments were undertaken by
Sauer and Booth and their study can be found in Volume 1 of the Specialist
Studies.
30.26 Will the harbour or IDZ be constructed first and when? Zwide Alliance They will be constructed in parallel. The various contracts for the construction of
the marine infrastructure for the port will be awarded approximately 6 months after
tenders for the marine infrastructure contracts are advertised. Although the
contractors will begin mobilising thereafter it is anticipated that full-scale
construction activities will commence within 3 months of this award. The port will
be completed in just more than 3 years after award of the contract.
30.27 Are there any tenants for Coega yet and where will they come from? Addo/ Northern P&O Nedlloyd is currently negotiating a concession with the Port Authority to
Areas Alliance develop and run a common container terminal and will also develop a Logistics
Park in the IDZ. Other investors are being targeted. It is envisaged that investment
will come from abroad, as well as locally.
30.28 Is there a site in the plan for the airport cluster and is it viable vs. the Addo Alliance There is a site for a future airport, should the existing airport need to be re-located,
current airport, which is presently being upgraded? due to higher traffic volumes. Viability has not been tested yet.
30.29 Will there be a railway line at Coega? SATAWU Planning provides for a rail link from the container terminal to the main Port
Elizabeth/Johannesburg rail line at Coega. The main railway line to the rest of the
country runs through the IDZ.


30.30 What is the difference between a deep-water harbour and the existing Zwide Alliance/ The depth available in the existing port is 12.2m. At least 16m is required for the
harbour and how will the existing harbour be affected? SATAWU container ships likely to be employed to South Africa in the future, while 20m or
more is required for large bulk carriers. The existing port is not a deep-water port.
The ports at Richards Bay and Saldanha Bay are deep-water ports and the intention
is to provide deep-water at Coega at the outset, as it is readily possible to do so.
The exact nature of the impact on the PE harbour is unclear and has been rated as
being HIGH on a precautionary basis. Once the operational plans for the two ports
have been finalized, the impact on the PE port will be clearer. The impact on the
PE port is discussed in Chapter 9 - Issue 3 - Impact 3.
30.31 Were other sites considered for the proposed harbour and if so, SANCO PE Alternative sites for the harbour in the Bay were identified and reviewed in the
where? Why was this site chosen? Initial EIA (CEN 1997). A summary of this process is available in section 2.8.2 of
both the draft and Final EIRs.
In terms of the Cost Benefit Study, Saldanha Bay, Cape Town, Port Elizabeth, East
London, Durban and Richards Bay were considered. Coega seems to be the best
site on economic grounds.
30.32 Are there still residents at King Neptune and what kind of relocation SANCO PE No.
or compensation plan has been reached with them?
30.33 Recommendations made on the report with regards to the destruction SANCO PE/ There is a formal agreement between the CDC and the Coega Community that
of graves are fully supported if they are followed as proposed. How Bethelsdorp Alliance their graves will be fenced and preserved.
will families be consulted on the relocation of graves?
30.34 How much money has been spent by CDC on the development in SANCO PE Individuals employed by the CDC are employed on contract and sign conflict of
general? Are there any individuals within CDC who benefit or have interest documents to avoid undue enrichment from the Coega Project. The total
benefited from contracts awarded? development costs to day, (last audited report as of 30th June 2000 ) are R15 426
000.00
30.35 What exactly does a change in social systems and behavior mean and SANCO PE The extent of change will vary from person to person and household to household.
what will be the extent of this change? The move to Wells estate will have disrupted the community in terms of their day
to day life and this may involve changes in social networks, income sources,
disruption of support networks etc. In light of a number of comments regarding
the resettlement process an additional specialist study was commissioned which
can be found in Appendix E.
30.36 Who is CDC accountable to? SANCO PE National and Provincial Government.
30.37 Is the project happening because there are so many things being said Kwadwesi Alliance The Coega Project is subject to all Government regulations governing the approval
about it in the media, especially re ownership and the shareholders of of projects and as such needs to comply with these processes and procedures.
the CDC?
30.38 What kind of assistance is CDC going to offer the Metro to control Kwadwesi Alliance The CDC can facilitate but responsibility within the existing legislative framework
(August 2001)

the influx of people and avoid land invasion? rests with the Metro.
30.39 There needs to be strict monitoring of contractors not to under pay Kwadwesi Alliance It is the CDC’s intention to maximize the use of local labour. The CDC will
their workers. follow an approach to develop the skills that will be needed for the project and has
set a target of using 70% of local labour on the project. It must be understood that
with the diverse skills that will be utilized during the construction phases not all
the skills will be available from the local skills base nor would it be possible to
develop all the skills for the project due to the long term of training needed for
specialized skills. In the cases where the skills are not available from the local area
strategies will be formulated to engage these skills from other areas. The CDC will
use a central database for sourcing of labour for training and is in an advanced
stage of developing this process.
30.40 Why did the contractors busy installing services in Coega only Kwadwesi Alliance CDC facilitated a municipal contract, point 30.32 lays out the procurement process
employ Motherwell residents?
30.41 How will we be protected from pollution in the future? How will air Kwadwesi Alliance/ Baseline monitoring of air and water quality has already commenced and such
pollution be monitored and will the CDC assist hospitals and clinics Missionvale Alliance/ monitoring will continue. The TAP will ensure a safe environment.
if there is an emergency, will they help the public protect themselves Bethelsdorp Alliance
from air pollution?
30.42 Women should be empowered and given opportunities. Kwadwesi Alliance/ Noted and agreed
Wells Estate
30.43 This might be a good idea to create jobs for our well developed motor Khayamnandi Noted and agreed
industry skills base Alliance Meeting
30.44 A strong objection is leveled at the use of hydrogen powered Khayamnandi Heavy machinery will be required to build the port but where ever possible the
machinery during construction. Alliance Meeting operation will be labour intensive.
30.45 When will actual construction start? Motherwell Construction as outlined in the project description, Chapter 3, will proceed once
Community the project is approved by the authorities and the construction EMPs are approved.
Development Forum/ The main contracts are planned to start in the first half of 2002.
Wells Estate
30.46 Is there a natural environment fatal flaw identified by the report? SANCO PE There are a number of impacts of High and Very High significance but none are
regarded as a fatal flaw to the project assuming the correct mitigatory actions are
implemented and successful.
30.47 Will there be major damages caused by the port construction? SANCO PE See 30.46 above.

4. CONCLUSION AND RECOMMENDATIONS
4.1 INTRODUCTION
This Chapter outlines conclusions based on the public participation process that has been
implemented and makes recommendations with regards to ongoing public involvement.
4.2 CONCLUSION
The level of discussion and debate on the environmental (socio-economic and biophysical)
impacts associated with the construction of a Port in the vicinity of the Coega River mouth
has been in-depth, extensive and detailed.
There has been a definite increase in the level of understanding of the project and the EIA
process in general. This is evident in the comprehensive and extensive Issues Trail that has
emerged through the Public Participation Process. The benefit of the increased level of
understanding is that decision making authorities are provided with a broad and
comprehensive list of issues and concerns that reflects the interests of a broad cross spectrum
of I&APs. This should contribute to a sound decision making process. It may be the situation
that previous Issues Trails have been dominated by the concerns of a few organisations and
may not have reflected the broader interests within the Metropolitan area as comprehensively
as this Issues Trail.
The fact that public participation has been conducted over an extended period of time to
provide for re-iterations of the EIA has allowed for broad consultation, discussion and debate.
While it is apparent that certain organisations oppose the Coega Project in totality the
majority of the issues raised by I&APs require clarity on specific areas of concern raised and
make recommendations for mitigatory action should the project proceed.
A logical conclusion that could be draw from this is that these organizations are in support of
the project provided the mitigatory measures proposed, issues and concerns raised are
implemented as part of the project.
4.3 RECOMMENDATIONS
The following are recommendations for ongoing public involvement.
The development of a mechanism for ongoing public involvement is strongly recommended.

This request has been made by numerous I&APs from various sectors and with different
interests. The request revolves mainly around two issues:
• The need for ongoing information sharing on the project

• The need for some kind of a 'forum' to be established for open dialogue and information
distribution

It is strongly urged that for a project the size and complexity of the Coega Industrial
Development Zone and Port, which continues to evolve over time, that a mechanism is put in
place to facilitate ongoing dialogue, capacity building and information sharing with all
interested parties. This process would be separate to Public Participation as required by the
EIA regulations.
It is proposed that two mechanisms be put in place to facilitate ongoing communication and
dialogue.
4.3.1 Newsletter
In order to facilitate information sharing at a more general level it is proposed that a

newsletter is produced on a regular basis and distributed to interested parties. The contents of
the newsletter and the frequency of distribution should ideally be based on the needs of
I&APs and the project proponent. That is, research should be conducted to establish the
needs and areas of interest of I&APs. The existing database of I&APs would be used as a
point of reference.
4.3.2 Discussion Group/Forum
A number of I&APs have made a request for some kind of a discussion group or forum to be
established. It is envisaged that the primary purpose of this forum would be to facilitate
ongoing information sharing and dialogue on the project. The forum could act as a proactive
mechanism for the identification and resolution of potential issues and areas of concern. It
could facilitate information sharing around the environmental status of the project, new
tenants, EIA processes to be implemented, training and employment opportunities.
The establishment, role and purpose of the forum would require consultation with key I&APs
within the Metropolitan area and those that have been part of the public participation process.
It is important to note that the purpose of the forum would not be to resolve specific private
issues, such as land acquisition. Nor would it take over the monitoring and environmental
management responsibility of the Authorities. This would not however exclude NGO's
monitoring the development in their private capacity.
There are a number of positive benefits to be derived from creating an environment to

facilitate ongoing information sharing and capacity building on the Project, namely;
• Increased awareness on the intricacies of the project

• An understanding of due process that needs to be followed for various aspects of the
project
• The proactive identification and where possible resolution of potential problem areas,
conflicts of interest and issues and concerns
• A platform to correct and clarify misconceptions and perceptions that often occur with a
project of this size
• The development of a common approach and method to address areas of concern
• To provide a platform for cross pollination of ideas, views and opinions in a structured
environment between the developer, interested parties and between different interest
groups
The two mechanisms proposed for ongoing public involvement are not mutually exclusive.

APPENDIX A
EXPLANATION OF APPENDIX A
The content of this Appendix relates to information that was distributed, presented or made
available during the Public Participation Process. It contains the following:
• Report Distribution List - The Executive Summary of the Subsequent Draft

Environmental Impact Report was distributed to the following I&APs.
• Briefing Paper containing a map of the proposed Port layout
• Input presented at Public Meetings and at most networking meetings
• Copy of the Advertisement placed to advertise Public Meetings and notifying I&APs to
register their interest in the project.
Report Distribution List - The Executive Summary of the Subsequent Draft Environmental Impact Report was distributed to the following
I&APs.
Surname Initials Capacity Organisation Address1 Address2 Town Postcode

Baiwa G ABET Tutor 40A 2nd Avenue Zwide Port Elizabeth 6201
Crews D Hougham Park PO Box 612073 Bluewater Bay 6212
de Beer T SA Rail Commuter Private Bag X2 Sunninghill 2157
Corporation
De Klerk A Transport Division PEM & EP Shore PO Box 88 Port Elizabeth 6000
Anglers Association
Des-Fountain RC PE Business Unit Lafarge SA (PTY) Ltd P O Box 7170 Newton Park Port Elizabeth 6055
Manager
Exley J St Croix Development Sonop Farm, Coega PO Box 4016 Port Elizabeth 6014
Co. Mouth
Husselman JH Sundays River Citrus Private Bag 24 Addo 6105
Co-operative
Kantor P Labour, Kantor Legal Services 19 Milldene Avenue Rondebosch 7700
Environmental & cc
Constitutional Law
Lake L LW Lake & Sons PO Box 75 Coega 6100
Tankatara
Luiters J Riverside Construction PO Box 1959 Uitenhage 6230
Martin P Manager PEM Nature PO Box 12435 Centrahil 6006
Conservation
Mote P&T Owner Coastal Livstock & PO Box 120 Colchester 6175
Farming cc.
Myers NM Attorney Norman Myers Attorney Barkley Bridge PO Box 339 Addo 6105
& Notary Farm
Schumann E Wildlife Society of SA 26 Marine Gardens Glengarry Crescent Humewood 6001
Sims-Castley R Dept of Zoology UPE UPE PO Box 4600 Port Elizabeth 6000
Briefing Paper containing a map of the proposed Port layout
SUBSEQUENT DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PORT

OF NGQURA
July 2001: Briefing Paper
WHAT DOES THIS DOCUMENT TELL YOU?

This document aims to provide you, as an interested and/or affected party (I&AP), with background information
on the proposed project, the Subsequent Draft Environmental Impact Report (EIR) that has been undertaken as
well as details for public participation. The sharing of information on the project forms the basis of the public
participation process and offers you the opportunity to become actively involved and encourages you to raise key
issues, concerns and suggestions.
ABOUT THE PROCESS
The Coega Development Corporation (Pty) Ltd (CDC) has been mandated by the South African Government to
investigate the possible implementation of the Coega Industrial Development Zone (IDZ). It is proposed that a
new deepwater port will be built and operated by the Port Authority Division (PAD) of Transnet to act as the
primary transport facility for the IDZ.
The proposed port is located at the mouth of the Coega River in Algoa Bay and falls within the Fish River
Spatial Development Initiative (SDI). Ten Regional SDI's and four Industrial Development Zones have been
identified as part of the Government of South Africa's SDI programme.
An assessment of the potential environmental (socio-economic and biophysical) impacts associated with the
construction and operation of the port and back-of-port has been undertaken and follows an authority approved
plan of study. These studies have been undertaken in compliance with the regulations governing Environmental
Impact Assessments (EIA's). The public participation process has been initiated in line with the regulations
governing EIA's.
THE PROPOSED NGQURA PORT
P&O Nedloyd/TCI Consortium have been identified as CDC's preferred private partner and have expressed their
interest in establishing a container terminal at the proposed port. The port has been designed to handle
containers and various bulk and break bulk cargos and to take account of projected business opportunities as well
as changes in world shipping and logistics operations.
The harbour will have two breakwaters, with the main breakwater extending more than two kilometers into the
sea, while the lee breakwater will be just over 1km long. Five berths will be constructed initially, with two
berths each being allocated to the container terminal and dry bulk materials facility and one to a bulk liquid
materials facility.
The main construction activities associated with the building of the marine infrastructure are:
v The dredging of an approach channel and turning basin;
v Construction of quay walls and breakwaters
v Land excavation to create the area for the container terminal and transport corridor and the resulting
transport of material to the east headland deposition site; and
v The building of a sand by pass facility.
The main land based construction activities involve the development of infrastructure and service facilities for
the future port users and IDZ tenants. This will involve preparing sites, transport routes, water and electricity
services, waste sites and telecommunications.
While no tenants have as yet been signed up the landside development area is envisioned to encompass a
customs secure logistics park, and E Commerce park, areas designated port and allied industries, Mixed use
corridor and electronic and technical cluster.
The port is expected to be developed in phases over a number of years as a function of prevailing demand to a
possible total of 35 berths. All future developments will be subject to a separate EIA exercise.
ENVIRONMENTAL STUDIES
The Coega Development Corporation has appointed Coastal and Environmental Services (CES) to undertake the
Draft Subsequent Environmental Impact Report for the Port of Ngqura. Sandy & Mazizi Consulting have been
appointed to facilitate the process of public participation.
This Draft Subsequent Environmental Impact Report for the Port of Ngqura takes into account the change in the
Port configuration associated with the establishment of a container terminal as required by the preferred private
partner, P&O Nedloyd.
The area covered by this assessment is the area enclosed by the port limits as described in Government Gazette
No. 19401 of 28 October 1998. This area includes the main marine infrastructure, back of port activities and
other land uses seaward of the National Road.
The EIR does not cover, or attempt to assess, the environmental or socio-economic implications of the Coega
Industrial Development Zone in its entirety and is specifically focussed on the port and back-of-port activities. It
further does not comment on the overall feasibility or rationale of the IDZ, although it does comment on the
economic feasibility of the port facility.
The environmental studies for the Subsequent Port EIR have followed a two phased approach:
Phase 1: Draft and Final Scoping Report for the Proposed Port of Ngqura: Subsequent Impact Assessment
(August 2000 to Decemb er 2000)
This phase entailed the identification of impacts associated with the construction and operation of the Port. The
Draft Scoping Report together with the comments received interested and affected parties was submitted to the
authorities for their consideration and approval of the Plan of Study for the Subsequent Port Environmental
Impact Report.
Phase 2: Subsequent Environmental Impact Report for the Port of Ngqura

(March 2001 - August 2001)
The Draft EIR assesses the socio-economic, and bio-physical implications of the construction and operation of
the port. Specialist studies that have been conducted as part of the EIR include an Economic Cost Benefit Study,
Air Quality Impact Study, Risk Assessment, a review of the possible impact on Bontveld, Visual Impact
Analysis and Dredging, Excavation and Disposal Impact Study. This is the stage in the process, which is now
open for comment by interested and affected parties.
This document forms part of the public partic ipation process for interested and affected parties to comment on
the Draft Subsequent Port EIR for the Port of Ngqura.
If you consider yourself an interested and/or affected party you can make use of the opportunities created by the
public participation process to raise issues and concerns, which affect and/or interest you and about which you
would like more information.
The following process will be implemented in stages to ensure effective participation of all interested and
affected parties:
Stage One: Release of the Draft EIR for comment

Stage Two: Identification of and consultation with interested and affected parties
Stage Three: Public Meetings and Open Days to provide the opportunity for interaction between the consultants
and I&APs.
Stage Four: Closure for comment and issues trail submitted to the consultants for consideration in the Final
EIR.
Stage Five: Submission of the Final EIR, including public participation report to the authorities for their
consideration.
To obtain further information or raise issues of concern all I&APS are invited to attend any one of the Open
Days or Public Meetings, view the Draft EIR in libraries or contact the public participation consultants, Sandy &
Mazizi Consulting, directly.
OPEN DAY
v 1 August, 10am - 6pm, Port Elizabeth City Hall
PUBLIC MEETINGS
v 31 July 2001, 5:30pm, Raymond Mhlaba Sports Centre, Motherwell
v 2 August, 5:30 pm, Centenary Hall, New Brighton
REPORTS IN LIBRARIES
Copies of the report are available for viewing at the following venues:
• The following libraries in the Nelson Mandela Metropolitan Municipality Libraries - Govan Mbeki,
Newton Park, Walmer, Motherwell, New Brighton, Uitenhage Main Library and Despatch
• University of Port Elizabeth
• University of Cape Town
• Port Elizabeth Technicon
• Rhodes University
Executive Summaries of the report can be obtained directly from the Public Participation Consultants.
FOR FURTHER INFORMATION CONTACT:
Sandy & Mazizi Consulting cc.

120 Diaz Road, Adcockvale, Port Elizabeth, 6001
PO Box 23088, Port Elizabeth 6000
Phone: 041-3748426 Fax: 041-3732002 Email: sjwren@iafrica.com
Closure for all comments is 14 August 2001.

Turning
basin
Breakwaters
Indian
Ocean
Environmentally sensitive areas Phase 1 port

Industrial/office precinct Core development area boundary
Business and administrative precinct Coastline
Logistics park/E-commerce
Input presented at Public Meetings and most networking meetings.
Slide 1
Subsequent Draft Port Environmental

Impact Report for the Port of Ngqura
Public Participation Process

Sandy & Mazizi Consulting
July - August 2001
Slide 2
Overview of Input
b Background Project Information
b Background Port Information
b Background EIA Process Information
b Additional Specialist Studies
b Environmental Impact Assessment Process
b Environmental Impacts
b Public Participation Process
b Comments & Input
Slide 3 Background Project

Information
b 1994 Elections - Spatial Development Initiative
Programme (SDI) of National Government
• unlock inherent economic potential in specific
spatial locations
• using public resources to leverage private sector
investment
b Coega Development Corporation mandated by
the SA government to investigate the possible
implementation of the Coega Industrial
Development Zone
Slide 4 Background Project Information
cont...
b Key to attracting industry to the IDZ is providing

an effective transport operation for imports to &
exports from
b A new deepwater port will be built to operate as
the primary transport facility for the IDZ
b Enabler to attract business to the IDZ and viewed
as a catalyst for development
b Success of IDZ and Port are linked
Slide 5
Background on the EIA Process
b Initial Environmental Assessment : 1996-1997
• Lack of detail: worst case scenario & precautionary
principle adopted
• Different options assessed e.g. expand PE Harbour
b Revised Environmental Assessment : 1998 -2000
• Detailed design phase
• More accurate assessment of impacts
• Transhipment point for bulk cargoes for industries
Slide 6
Background on the EIA Process cont ...
b Subsequent Environmental Assessment :

Present Study
• P&O Nedloyd/Technology & Communications
International preferred private partner
• Development of a container terminal and
transshipment hub
• Increase in size of port (3 - 5 berth)
• Changes to back-of-port structures and activities
• Authority Decision: Conduct a Subsequent
Environmental Assessment
Slide 7
Background on the Process
b This process deals specifically with the

Subsequent Draft Environmental Impact Report
(EIR) for the Port of Ngqura
b Assesses the socio-economic and biophysical
impacts of the port & back of port activities
b Authority approved Plan of Study
b Does not assess the IDZ
Slide 8
Additional Specialist Studies
b Bontveld Study
b Risk Assessment
b Visual Assessment
b Economic Evaluation of the Proposed Port
of Ngqura & Development of a Container
Terminal
b Dredging, Excavation and Disposal Study
b Air Quality Impact Assessment
Slide 9 Environmental Impact

Assessment Process
b Three Phases
• Scoping Phase
• Environmental
Impact Assessment
Phase
• Record of Decision
Slide 10
Scoping Phase
b Objectives
• I&APs identify issues
• Identify alternatives
• Generate all key
environmental impacts
• Identify any fatal flaws
b Consult Authorities
b Consult I&APs
b Scoping Report
Slide 11 Environmental Impact

Assessment Phase
b Gather and evaluate
environmental information
b Evaluate impacts &
consider alternatives
b To ensure the best
development alternative
b Results in an
Environmental Impact
Report
Slide 12
Record of Decision
b Authority examines the
EIR
b Issues a Record of
Decision (ROD), or
b requires further details
to clarify issues
b ROD carries conditions
of approval
b Inform all I&APs
b 30 Appeal period
Slide 13
Port Information
b Coega one of the best locations for a Port

on SA coast
• Depth & environment of Algoa Bay
b Handle containers and various bulk and
breakbulk cargo
b Projected business opportunities, future
world shipping trends & logistics operations
b Potential relocation of existing ore and fuel
facilities to Coega
Slide 14
Port Information cont …
b Two breakwaters
• Main breakwater : + 2km into the sea
• Lee breakwater : + 1 km long
b Two main sections
• Seaward
• Landward
Slide 15
Landward Development
b A customs secure logistics park

b E-commerce park
b Port related activities & allied industries
b Mixed use corridor
b Electronic and technical cluster
Slide 16
Seaward Development
b Breakwaters & quay walls

b Sand bypass system
b Turning basin
b Approach channel
b Developed in phases up to 34 berths
Slide 17 Map indicating port and back of port

activities pg. ii
Slide 18 Map indicating conceptual layout of

the port pg. 51
Slide 19
Rating of Impacts
b Temporal Scale : duration of impact

• short, medium, long term or permanent
b Spatial Scale : locality of impact
• household, local, district, region, national or
international
b Severity/Beneficial Scale
• Very severe, severe, moderate severe, slight, no
effect & no effect : very beneficial beneficial,
moderately beneficial, slightly beneficial, don’t
know, can’t know
Slide 20
Rating of impacts cont...
b Significance Scale : Importance & values

• Very high, high, moderate, low, no significance,
don’t know
b Risk or Likelihood Scale :
• Very unlikely, unlikely, may occur, will definitely
occur
b Degree of Certainty or Confidence:
• Definite, probable, possible or unsure
Slide 21
Environment Assessed
b Terrestrial
• Biotic - living e.g. fuana & flora
• Abiotic - non-living e.g. geology, climate, noise
b Marine
b Socio-Economic
b Construction and Operational phase of Port
b Assess impact without and with mitigation
measures
Slide 22 Terrestrial Impacts &
Mitigation
b Project Actions Construction Phase

• Transport corridors, road & rail access
• Servitudes to port & associated industries,
power lines, electricity, water
• Serviced sites for clusters
• Container terminal and staging yards
• Bulk liquid tank farm
• Port administration buildings/offices
Slide 23 Impacts without and with mitigation

Table on page 97
Slide 24
Terrestrial Impacts Cont...
b Impacts associated with the Operational

Phase:
• Electricity consumption
• Water Consumption
• Disposal of solid & liquid waste
• Noise levels
• Air quality
• Lighting
• Risk of explosions
Slide 25
Table of operational impacts, pg 104
Slide 26
Summary Terrestrial Impacts
b Construction and Operational

Phase
• 18% Very High
• 32% Moderate
• 50% Low
Slide 27
Marine Impacts and Mitigation
b Actions & Activities Construction Phase:

• Construction of breakwaters and quay walls
• Dredging of turning basin & approach channel
• Blasting in turning basin & approach channel
• Deposition of dredged material in nearshore
environment
• Building & operation of sand bypass system
Slide 28 Table of construction phase
impacts pg. 130
Slide 29
Marine Impacts & Mitigation
b Activities & Actions Operational Phase

• Refueling and general servicing of vessels
• Unloading & loading of various cargoes
• Light repair and maintenance
Slide 30 Marine operational phase table pg.

139
Slide 31
Summary Marine Impacts
b Operational Phase & Construction

Phase
• 8% Very High
• 17% High
• 25% Moderate
• 46% Low
• 4% No significance
Slide 32 Socio-Economic Impacts &

Mitigation
b Divided into economic and social based

issues
b Only relate to the port and container
terminal and not the whole IDZ
Slide 33 Socio-Economic Issues

Covered
b Expansion of the skills base

b Direct & indirect economic implications
b Ability of Port to act as a catalyst for growth
b Impact on existing businesses
b Resettlement
b Disruption of Graves
b Changes to social systems & structures
b Closure of recreational facilities
Slide 34 Socio-Economic Issues
Covered cont...
cont...
b Visual impacts of the Port area

b Influx of people to the area
b Air emission impacts of construction traffic
b Noise, air and light pollution
b Sites of historical or cultural interest
b Impact on proposed Greater Addo National
Park
Slide 35
Socio-Economic Impacts Summary
b Positive impacts
• 25% Moderate
• 75% Low
b Negative Impacts
• 4% Very High
• 19% High
• 33% Moderate
• 33% Low
• 11% no Significance
Slide 36
Public Participation Process
b
b PPP Table
Slide 37
Conclusion
b Sustainability
b Equity
b Efficiency
Copy of the Advertisement placed to advertise Public Meetings and the Open Day as
well as to notify I&APs to register their interest in the project.
APPENDIX B
EXPLANATION OF APPENDIX B
This Appendix contains the issues and concerns raised through the Public Participation
Process, expect detailed written submissions. The issues and concerns noted here are from
the following sources;
• Notes taken at networking meetings

• Issues and conc erns raised at public meetings
• Issues noted in comment forms
Notes taken at networking meetings
Chris v d Walt
Abra de Klerk
EP Shore Anglers
06/08/01
The recommendations made in the draft scooping report re shore angling must be included as part of the final
EIR and stated. This issue affects approximately 2000 affiliated anglers that represent only a percentage of the
angling population.
Guy Castley
SANP
08/08/01
Issues raised previously still stand. Port and IDZ are linked and this has still not been assessed in terms of its
impact on the park.
There is still no cumulative impact taking into account the IDZ and port.
Air emissions may be low for the port but taken into account with the IDZ it may be high.
The marine protection zone proposed for the expansion of the park is 85000 ha and extends right up to the Coega
River Mouth. It is a continuous area and not just a reserve around the islands.
Maintenance dredging – if you don’t know what the contaminants are going to be.
Will forward other comments.
Marine operations of the port may be high and not low.
Edward Schumann
Warrick Stewart (WESSA)
Val Hunt
There are a number of mitigating measures proposed in the report which affect the metropole, province and
national government. The report does not indicate who will manage this and whether government will be
provided with additional capacity to manage and monitor the mitigating measures.
They are presently understaffed
There are no significant problems with the mitigating measures proposed but more concern about how they will
be managed.
The ABMP forms an important component of the mitigating measures. There are recommendations in the plan
that must form part of the conditions of approval and must be implemented prior to construction and some prior
to operation.
Provincial and national DEAT need to ensure the ABMP is taken forward. Other major role players are MCM
and Metro. The next stage in the process is a workshop to expand on the plan and this needs to occur.
There is a process proposed to take the ABMP and this has not happened. CDC has some level of responsibility
to ensure the process is taken forward.
The government can support the project but they also need to be made aware that they have certain
responsibilities for implementation of the project.
All ROD’s that are issued must be distributed to IEAP’s and they should afford the opportunity to comment.
In terms of public involvement there is a lack of info going to the public on a regular basis. A forum should be
established that shares info with the public on a regular basis. Such a structure would be supported as it is to the
advantage of IEAP’s to be informed about what is going on.
Someone needs to be appointed to manage and deal with ongoing public info sharing. This process should be
facilitated by someone independent e.g. Wastech Monitoring
Considering the stakeholders :

Sub-committees need to be established e.g. environment, labour, socio-economic
The establishment of a forum to facilitate ongoing info sharing needs to become a condition of approval.
Regional impact on road and rail needs to be looked at ito increased road and rail traffic associated with the
development.
National and provincial government needs to be made aware of this and it should be budgeted for.
Bontveld :
1:250000 mapping is needed for planning of an entire vegetation type to assess its conservation status. But for
the planning of a specific project 1:10000 scale should be used. A more detailed map showing the entire
occurrence of Bontveld in the port area needs to be developed. The scale used for mapping Bontveld is too large.
Proposing of Bontveld in developed sections of Bontveld elsewhere are set aside, but this is not indicated.
Sensitive areas identified for inclusion in the open space system is based on erosion. There are more biophysical
criteria that should be applied to assess the open space system.
There is no OSMS plan to comment on.
Busy with a conservation plan for the Metro and would like to meet with CDC to see how these two plans link.
When OSMS has been finalised it needs to be rezoned differentially.
SA N Parks need to meet to mitigate visual impacts on the park. Proposed bridge across Coega River could be
visually intrusive.
Impacts on local Eco must be reduced to a minimum e.g. try and avoid closure of the salt works and marine
growers but relocate them.
Rehabilitation centre is proposed to be set up prior to operation of the port. This should be prior to construction
of the port – there will be impacts on marine birds during construction.
Meeting: Coega Subsequent Draft Environmental Impact Report

Date: 6 August 2001
Organisation: Marine Growers & 8CR Property Trust
Present: S Wren, Connie Muller and Johan Smith
Input from Marine Growers:

• The maps in the Subsequent Draft Port EIR are confusing and misleading for decision makers as it does not
indicate the proximity of the abalone farm to the port.
• Marine Growers and 8CR property Trust are the closest businesses to the harbour and it appears as if there
is a deliberate attempt to leave this information out of the report.
• In Part 2 (page 18) of the Specialist Studies reference is made to sand that would rise 1meter on the
northern beaches. This point has been excluded from the Subsequent Draft EIR and will have a significant
impact on Marine Growers. The rising of sand will cover the pumps required for pumping sea water which
is vital to the survival of the abalone on the abalone farm. Any changes to the beach profile, erosion or
attrition is going to impact on the abalone farm.
• CDC need to be aware that relocation is now not an option. Relocation would take two years before any
commencement of the harbour and IDZ could begin. The initial area identified for relocation is now
included within the Madiba Bay development.
• The Final Port EIR should include the Addendum's submitted by Marine Growers and the A5 maps in
colour.
Input from 8CR Property Trust:

• Chapter 7 issue 7 - 8CR Property Trust has not been considered under impacts on adjacent industries.
• Chapter 9 issue 4 - 8CR Property Trust has not been considered under impacts on existing businesses.
• 8CR must be considered and included in this report in both Chapters 7 and 9.
• The Final Port EIR must include all comments submitted by 8CR and the maps must be in full colour
Meeting: Coega Subsequent Draft Environmental Impact Report

Date: 6 August 2001
Organisation: National Salt Limited (Cerebos)
Present: S Wren, Len Chandler and Patrick Hill
Buyout and Closure Option

• NSL have to date been under the impression that their business will be relocated. To date the potential
impact of the harbour on NSL and the resolution thereof has concentrated on the relocation of the business
to a suitable area. Recommendations in previous Assessments reflect this and planning within NSL over
the past five years has focussed on relocation and not buyout or closre.
• The release of the Draft Subsequent Environmental Impact Assessment for the Port of Ngqura notes buyout
and closure as a mitigatory measure. According to NSL this option has not previously been discussed or
considered by NSL and is not a mitigatory option.
• The impact of the buyout or closure option would have far-reaching local and national socio-economic
impacts, which are not adequately reflected in the Draft SEA report.
• The existing business of NSL within the Coega Estuary provides infrastructural and other support to the
Tankatarra, Swartkops and Berg River Saltworks. The closure or buyout of the Saltworks at Coega would
impact directly on other Saltworks, which are dependent on the Saltworks at Coega. The closure would
further indirectly impact on other industries such warehouses and depots in Durban, Johannesburg and Cape
Town.
• The closure of the Saltworks at Coega and the potential impacts thereof can not be viewed in isolation. As
NSL provide the only form of iodised salt in SA the removal of this product from the market and the
resultant impact on the health of the population would also need to be considered.
• The Draft Subsequent Port EIR draws conclusions about buyout and closure which have not been discussed
with NSL.
• NSL note that there is still enough time to relocate the Saltworks to and avoid the negative socio-economic
impacts that would be associated with closure. Relocation may be the more expensive short-term option but
it is the more cost-effective long-term socio-economic alternative.
• In order for buyout or closure to be assessed as an option or even be considered as part of the decision
making process as a mitigatory measure a detailed assessment of the impacts of this option must be to
considered.
Salt Marshes
The draft report states that salt marsh vegetation has been destroyed as result of the salt related production in the
area. What baseline for measurement has been used to indicate that the Saltworks have negatively impacted on
zonation, fauna and flora in the area.
Khayamnandi Alliance Meeting

19/07/01
Project description
Were the additions or changes made to the initial project description necessary? If so, why?
Is there a need in the SA shipping industry for a container terminal?
Is there space in the harbour for ships requiring mechanical repair or attention?
This might be a good idea to create jobs for our well developed motor industry skills base
Will there be any nuclear powered ships docked in the harbour? If so, how many?
Will there be a nuclear waste site nearby? If so, a strong objection is hereby registered against such a proposal.
Flora and Fauna

Removal of alien vegetation during site clearance is fully supported.
Use of alien vegetation for decorative purposes should be prohibited during operations.
Will there be any impacts on underground water and if so, to what extent?
How will this be mitigated?
Otherwise how will underground water be protected?
Will there be hydrogen powered machinery used during construction?
If so a strong objection is hereby levelled at the use of such machinery.
Noise Impacts
Concerned about the sound decibels of ships at the harbour, disturbing elephants at the nearby Greater Addo
National Park.
Socio Economic Impacts

What will be the direct economic benefits of the port?
What mechanisms are in place to ensure that the poor also benefit from the economic spin-offs and not just the
rich?
Will there be a single database or labour pool used for the different contractors, or will contractors source labour
on their own using different sources?
Kwalanga Alliance Meeting

19/07/01

How will we know when employment commences?
Will people from Uitenhage also have access to job opportunities offered by the port?
What criteria will be used for selecting trainees?
Will there be similar meetings once the project has started?
Process
Who are we meeting with and how do we identify them?
What is the legislative requirement for consultations?
Motherwell Community Development Forum

19/07/01
Port Description
Where will the rocks for the construction of the breakwater come from?
Will they be compatible with what is around there?
Employment criteria
What does the relocation / resettlement agreement contain?
Were human rights violated during this process?
When will actual construction start?
Motherwell Councillors Forum

20/07/01
The meeting was rescheduled but the councillors expressed interest in the above issues and issues relating to
training.
Kwazakhele Alliance
20/07/01
Terrestrial impacts during operation
Is there a plan to use recycled water where possible at the harbour?
What impact will the high consumption of water and electricity have on the general public?
How will the above impact current service charges?
Are we going to pay more once the project starts?

Will there be a continuous mechanism for communicating progress to the public?
How will we know about training opportunities?
What criteria will be used in selection of candidates?
Addo Ward Councillors : Carolus

23/07/01
Training opportunities and criteria for Addo people, will we be kept informed?
Will we be informed of progress?
Will Addo be afforded equitable opportunities in terms of jobs and business opportunities?
SANCO PE
Natural Environment
Is there a natural environment fatal flaw identified by the report?
Will there be major damages caused by the port construction?
Change in Social Systems and Behaviour

What exactly does this mean?
What will be the extent of this change?
Water Consumption
What will be the cumulative impact of the port’s water consumption on the availability of water for the general
public?
It is understood that the public pays 024 cents per litre and that industry pays 0,12 cents. Does this mean that the
public will subsidise the Coega Port?
Training
Who will be trained?
What will be the criteria for selection?
King Neptune
Are the residents still there?
What kind of relocation compensation plan has been reached with these communities?
Destruction of graves
Recommendations made on the report are fully supported if they are followed to a T.
Access to the Beaches

St Georges Beach and Jooste Park Beach are filled to capacity during the festive season. These beaches are the
closest and cleanest to the township. The New Brighton Beach is not clean and Bluewater Bay Beach is not that
accessible to the previously disadvantaged communities. There is a concern about the possible closure of access
to Jooste Park Beach. This problem is likely to be compounded by the expansion of the Addo Elephant Park,
which might include some coastal areas as reserves.
The closure of Jooste Park will be inconsistent with the provisions of the Coastal Management Policy regarding
access to the coas t.
It is recommended that Jooste Park Beach be open t0o the public during the festive season until a suitable
alternative is found.
Harbour Location
Were there any other sites considered for the proposed harbour and if so, where?
Why was this site chosen?
Relocation / resettlement
Why was the Wells Estate site selected for relocation?
Concern about the site in relation to the truckers inn, which is notorious for its commercial sex workers
Is there a master plan for the area with respect of growth and development?
The Coega Community has a school, is there provision for that and any other facilities?
Is there a written relocation agreement between the CDC and Coega Community, or is the agreement between
the CDC and the Algoa Regional Services? If not, why?
In terms of the resettlement plan, families were given R3000 as part compensation
What is meant by a political agreement?
What are the implications for the Cerebos workers?
The houses at Wells Estate are small, have very little room for extension whereas eKuphumleni would have had
250m2
There is no electricity in the Wells Estate houses
There is no running tap water, which is a health hazard
There is a terrible smell from the nearby Markman area
Not everyone from Coega has been accommodated at Wells Estate
Why has CDC relocated communities before it obtained a temporary operator license?
Who is CDC accountable to?
How much money has been spent by CDC on the development in general?
Are there any individuals within CDC who benefit or have benefited from contracts awarded?
General
How many sustainable jobs will be created?
There seems to be inconsistency in the messages sent out by CDC in this regard
Opportunities seem to be on a piecemeal basis i.e. during EIA process
Have human rights been violated in the relocation process?
Kwadwesi – Hendry Fazzie Community Hall

25/07/01
Is the project happening because there are so many things being said about it in the media, especially re
ownership and the shareholders of the CDC?
How is recruitment going to be handled in terms of criteria and skills required?
What training skills will be required and when will it start?
What kind of assistance is CDC going to offer the Metro to control the influx and avoid land invasion?
Need to check opportunities for emerging business
Strict monitoring of small contractors not to underpay their workers
Why did the contractors busy installing services in Coega only employ Motherwell residents?
How will we be protected from pollution in the future?
Women should be empowered and given opportunities
People cannot afford training, how is training going to be co-ordinated and where is the money going to come
from?
Addo
18/07/01
Appreciate the project
What is the future of the Addo dumping site?
Is there a site in the plan for the airport cluster and is it viable vs. the current airport which is presently being
upgraded?
How many people will be recruited once the project starts?
Are there any tenants for Coega yet?
What skills will be required and how will the issue of training be approached?
Zwide Consultation
18/07/01
What type of jobs / skills will be required for the container terminal?
What is the difference between a deep-water harbour and the existing harbour? How will the existing harbour be
affected?
Appreciate the project, enough talk about marine mammals, people need jobs
How is the fishing industry going to be affected?
What are the impacts on the quality and availability of fish?
Will the harbour or IDZ be constructed first and when?
SANCO
24/07/01
Are the jobs going to be sustainable?
Is this not going to encourage tax holidays on companies based in Coega?
What are the details of the relocation process? People are not happy
What will be the criteria for employment?
How will people be protected from exploitation by companies?
What about existing companies, will they relocate to Coega?
Missionvale
29/07/01
Where does the money for the project come from?
If there is an appeal how long will it take, because people need jobs?
There have been confusing statements in the media – what is the process for relocation?
How will air pollution be monitored and will the CDC assist hospitals and clinics if there is an emergency, will
they help the public protect themselves from air pollution?
Will all areas be given an opportunity for employment?
SATAWU
31/07/01
What type of jobs will be created?

How many jobs?
Will there be a railway line at Coega?
How will the container terminal affect the present harbour?
Will the IDZ operate as a section 21 and how will it affect our members?
What is the current and future role of the government?
How will the community benefit during the tendering process?
What is the future role of the fishing industry?
Laws need to be implemented to ensure that CDC acquire land at a lower price from land owners to ensure
development takes place
Is the relocation process legitimate as people are unhappy and there is apparently no water and sanitation?
What is the relation between CDC and the arms deal and what will be the effect on construction. Are the people
opposing Coega confusing us by relating it to the arms deal?
What control measures will be in place to prevent foreign ships dumping waste in SA waters?
George Botha Sports Centre

07/08/01
Impacts of dredging on fish needs to be clarified
How will families be consulted with the relocation of graves?
How will the training process and employment be publicised?
What plans are in place to recycle waste?
Control measures to minimise air pollution will be necessary
What is the process for relocating people?
We appreciate and welcome the project
Alfin House
Fishing Forum
08/08/01
What is the process for relocating people?
We appreciate and welcome the project but will discuss it before 14/08/01 and submit further comments
Northern Areas Alliance
08/08/01
Community is confused about the relocation process?
What is the training plan?
People at Wells Estate over the age of 18 with their own families, should be given their own houses and not have
to stay with their parents
How will the training process and employment be publicised?
Will people have access to the training centres if they are staying far away?
Where will tenants come from?
Will training be made available to matric students?
Big business who are awarded tenders must use local labour, trucks etc
There must be strict monitoring by the CDC and government of procurement to avoid window dressing of
companies using different names whilst there is only one company
The process must be speeded up now and job creation begin
Recruitment offices must be accessible e.g. a mobile office
Issues and concerns raised at public meetings
Wells Estate
13/08/01
We appreciate and welcome the project and job opportunities
How will the container terminal work in relation to job opportunities?
What is the future for the salt works and other farms in Coega?
Does the agreement between the CDC and ourselves regarding employment still stand?
What is the training plan and what skills are needed?
What of empowerment of women?
When does the project start?
The houses need to be inspected because on rainy days some flood or leak
Centenery Hall
02/08/01
When does the project start?
What is the process followed for emerging business and opportunities?
Why was PE identified for the deep-water harbour and how will it benefit us?
Why not expand the present harbour instead of building a new one?
We appreciate and welcome the project and job opportunities
What is the problem with relocation of families to Wells Estate?
Will there be training for the container terminal?
What of empowerment of women?
The process mu st be speeded up now and job creation begin
Site clearing should be labour intensive and the wood given to people who need it
People can be employed to fill water tanks with sea water to keep the ground wet and reduce dust
Training must commence as soon as possible
Training should start before the permit is granted
The development must be a balance between job creation and the environment
How will waste be handled, what is the plan for a waste site?
What are the plans for the future water demand?
What are the opportunities for emerging business?
What will be the criteria for recruitment?
Raymond Mhlaba Sports Centre, Motherwell

31/07/01
It was unjust to remove the Jooste Park caretaker, as he is entitled to land rights
Why are the Wells Estate houses so small?
Why is there so much negativity about Coega in the media?
We appreciate the project and the related opportunities
This project is to promote corruption in terms of kickbacks by the CDC
Will there be essential services, schools etc at Wells Estate?
How much has CDC had to top up the government subsidy for the residents?
How will the training process be publicised?
We support the plan insofar as it will alleviate poverty by creating jobs
The CDC should help people who have bonds, meet them halfway like with the Wells Estate residents
The media should stop their negative and misleading opinions
Why was the media report Special Assignment opposed to the development?
We are not interested in what the report has to say about frogs and birds; we want to know when the project
starts
Is the authorisation of the project dependant on the above studies of wildlife?
Why are the contractors installing services so arrogant?
How many jobs will be created?
Veeplaas
31/07/01
What skills will be required?
When will training start and how will we know?
We appreciate the project, but it must begin now so people can work and crime reduced.
Issues noted in comment forms
G J Sampson
Consultations in the Northern Areas
Removal of land occupants at Wells Estate
Skills Development Programme
More tourism in the Eastern Cape
Affirmative must include all races
N Janki
No new comments
Appreciate being informed
In support of the developments
T M Mbiyabo
Endorse the development
Present port is shallow
Feel that there is insufficient planning of the government relating to the fishing industry
Environmental issues are handled at the top
W Keyizana
Supports the development
Believe it will alleviate the unemployment
Hope the development will improve the exchange rate
Our country has important minerals like gold and diamonds but we need development like this
Appreciate the opportunity to give feedback
T Mxokozeli
Suspicious of this ‘Public Participation’ because it seems the poorest of the poor are the ones who are not
developed
Propose that the focus be on these people
Skills must be developed in these communities so that the people can get employment
B Gedze
It is inevitable that wild areas will be developed for business so the project must go ahead
Quick thinking is needed to keep up with our fast growing population
Thankful to the government
N Nika
When will something be done about the cleaning of the water in Motherwell
Concerned about the animals at Ngqura
V W Bontsi
Project must go ahead and create employment and thereby stop crime
Should be a parastatal institution
Should not be controlled by private companies
What will be the impact of the port on the rail lines
What will be the impact of the port on the roads
What will be the impact of the port on the inland areas
The removal of flora and fauna will not be a danger to the government
Unemployment could lead to a revolt to overthrow the government
A Visani
Supports the development and job creation
Must not take long for project to begin
There are valid reasons why people are against the project but there are ways that these problems can be
addressed
All stakeholders must be involved in order for the development to take place
M Hendricks
Hopes the project will start soon so that the unemployed can get jobs
D C Claasen
Hopes the project will start soon so that the unemployed can get jobs
A C Stokwe
Painter by trade who would like to get more work from the project
Z Mxoli
Thanks for the Draft Environmental Impact Report
The work done has been excellent
Continue to keep the people informed
M Clingham
Representative of the PEM water reclamation division
Will be treating the effluents generated and feel it is important to remain informed on the progress of the
developments
M A Phillip
Found the presentation very informative
Joorst Park will be upgraded and contractors will be accommodated
Foresees interdependence between the harbour and industry and job creation
S Sobantu
Appreciates the EIR and work done by Sandy and Mazizi
Supports the project and hopes it will bring employment
W J de Jong
It is said the project may be a danger to the environment, but unemployed people are also a problem for the
environment so lets rather go ahead with the project
We can create employment and eliminate poverty
PE will also be more tourist friendly be the removal of the manganese ore dumps thereby generating more
wealth and further eliminating poverty
M Tshawuza
In full support of the project and congratulate Sandy and Mazizi on the work well done
Look forward to alleviation of poverty
X Ndungane
Believe that jobs need to be created to alleviate crime
Welcomes the opportunity to be more informed about the project
Concerned that people need more skills
C L Makisi
Welcomes the opportunity to be more informed about the project
In Motherwell the employment will be welcomed and will stop crime
When employing people you must not only look for experience, because some of the people are school leavers
with no experience
Also people who are over 40 can still be strong enough to work and do not yet qualify for a pension
Supports the project
L Tuswa
Hopes the development will put us closer in line with developed countries like the UK
The layout of this new port will be the envy for all to see, it is much better than the present harbour
T C Watani
Would like to work at the new port
Believes it will create many opportunities
Hopes to receive training through the development
Want to be kept informed
Concerned about the issue of transmitted diseases
M Jawula
Supports the Project
Hopes to get work as a sub-contractor and hopes to see unemployment lowered
C Goliath
Suggests an in depth look at the resettlement of the Coega Community as soon as possible
R M Mlomo
What is being done to ease the relocation process
Does the process taking so long not put off the potential investors
P Martin
Concerned about oil spills so close to the last remaining major penguin colony in a globally important bird area
Penguin colonies never recover from a major oil spill and may lead to extinction
A first world country would never develop a harbour here for this reason
Mitigation is required if the development goes ahead
A rehabilitation centre must be built with materials, trained staff and facilities ready for a full-scale disaster
This is the ports responsibility not volunteers and NGO’s
Also breeding success must be boosted and funding provided
Also the industrial development will almost certainly lead to the extinction of the butterfly species in the area
The CDC is apparently trying to exclude the eastern Coega kop from IDZ so that they are not responsible for its
protection. Unknown until recently is that La Farge has mining rights and an approved EMPR for the eastern
kop. This issue must be resolved quickly. No safeguard for E kop = no mining of W kop = no harbour. All
interlinked.
Do individual projects within port / IDZ require separate EIA’s and infrastructure required before port
construction begins? Authorities and public are unsure of a procedure, which accounts for a lot of the recent
criticism.
The economics of the port are totally unconvincing. The salt works provide about 140 jobs, abalone farm about
50 jobs. The port will require about 350 people mostly skilled. Therefore about 150 jobs will be created at the
cost of R2 billion = R13 million to be paid by the taxpayer to create each job!
V Pandle
Please continue to update us
P Van Dam, PPC

1. Why were PPC not considered to be an Interested and Affected Party (IAP) in the study. We are the biggest
neighboring landowner and intend investing over one billion Rand in the area. PPC have done numerous
EIA's and have an approved EMPR. Our plans include the following:
• A Mining Venture
• A Cement Manufacturing Plant
• A Rare Game Breeding programme
• Land based Tourism Venture
• Marine based Tourism Venture
2. I understand that the port development is now based on containers and not bulk or break bulk. Is a "deep"
water port as opposed to a "normal depth" port, still a necessity?
3. The report does not look at the feasibility of the Port. Income/Revenue from containers is assumed and the
analysis only looks at the difference between the costs of the two options (Richards Bay and Ngqura). Has
a proper feasibility study been done? Where can this be examined?
4. I believe that the accuracy of the Ngqura Capex estimate is within 15-20% and the Richards Bay order of
magnitude estimate is accurate to within 20-30%. The Present Value Cost difference between the two
options ranges from R 12m-R 18m - Is there any justification in the claim that the one option is "clearly"
superior to the other?
5. In terms of container capacity, it is my understanding, that Durban Island can be developed further, that the
East London IDZ will create container capacity and a deeper port, that Port Elizabeth is currently under-
utilized and that Cape Town can be extended at a cost.
Were the above options included in the study or were they excluded from the scope? Alternatively were these
costs examined in detail? (My understanding is that they weren't and that the consultant had less than 6 weeks to
do what is actually a major study).
M Z Tofile
Object to the closure of St Georges Strand and Joorst Park at the expense of the local people
Protest against the government’s departure from the principle of our coast for life: from policy to action.
Propose that the Department of Environmental Affairs and Tourism must come to PE and provide clarity
regarding interpretation and implementation of policy vs. inaccessibility of the coastal area to the local populace
and tourists. Propose that the port development be considered for redirection to the coastal physical space of
Colchester
M G Manganya
Feel that the project will be very important in terms of the unemployment
Want to see the development begin now
Training for the previously disadvantaged will be important
Also to bring South Africa into competition with other countries of the world
M Vezile
The Ngqura project should make a conscious investment in people and communities
surrounding the Nelson Mandela Metropole.
The communities should be taken on board on all relevant matters as much as possible.
Water resource management
Water for industrial Processing
Utilization of recycled water and contraction of suitable facility to ensure water consumption supply is in place
Equality in awarding tenders
Ngqura project should ensure that a certain portion is awarded to tenders from the previously disadvantaged
communities. The process should also be transparent and free of nepotism. Emphasis should be made to
implant entrepreneurship and assistance is rendered to those less experienced tenders.
Waste dumping lands / sites and waste, management plans

The, current aloe dumping site crisis have not been entirely resolved. Communities especially from the
previously disadvantaged groups are paying a high human price. Health of community is at risk.
It seems to me that dumping sites and waste burying is not a complete solution to modern most producing
industries. I would like to propose that a modern waste catalytic plasma converter plant is constructed. This
will ensure that a certain portion of industrial waste produced is being recycled for reuse, thus saving resources
for future generations.
M Stout
Happy about the issues covered in the report
Looking forward to direct and indirect economic spin offs to emerge from the project
Looking forward to harnessing some of the opportunities and benefits to be derived from the project
I.e. jobs, training and business opportunities
K T K Dlala
Approach through the consultation has been excellent
Social responsibility and accountability to government policy on development has been crucial before
proceeding with the development
Need information in terms of selling the initiatives of the IDZ nationally and internationally (Globalization
factors that would affect sustainability of the project)
Tourism
What are the spin-offs based on the PDI irrespective of the direct tenant of the area, but the entire community
What about securing jobs and skills development
L H Maqakaza
Sanco PE
Who is going to manage the port and IDZ?
How much of CDC’s budget goes to employees?
Paraffin Mtutuzeli
EAT Cape
Unemployment contributes to crime escalation.
Poverty ravages both black and white South Africans.
What measures will PAD put in place to circumvent drug trafficking through the port?
What kind of job opportunities will the port have?
Peter Mvandaba
ANC
I support the Coega development.
I am concerned about possible introduction of alien organisms.
Stringent measures need to be put in place to deal with these.
Nontutuzelo Ndenza
ANCWL
Will there be job opportunities for people without matric?
Will short courses be taken into account in the selection process?
Xola Madela
ANCYL
What sort of training opportunities will the port provide?
Monwabisi Lupondwana
I suggest that those on the database be kept informed via mail of development during and after construction.
Nyebo Qoni
ANC
I would like employment forms to be sent via mail to registered I&AP’s.
What can we as ordinary citizens do to fight poverty and unemployment?
Lulama Gxulwana
Secufu Project
Interested in application forms for training and wants to be kept updated.
Vusumzi Sahlito
Abumda
Supports the job creation and training opportunities.
Would like equal opportunities to be given to women and youth.
Thembisa Ketse
More people should be trained in science and technology.
Thobeka Manini and Nonezile Nojoko

ANCWL
There must be equitable share of jobs and opportunities across previously disadvantaged families.
Nomzamo Mazondwa
ANCWL
Concerned about jobs being taken by people from other provinces.
Suggests that the voter’s roll be used to establish if someone is from the Eastern Cape or not.
Siviwe Madela
ANCYL
When will construction commence?
Zoleka Mtwalo
ANC
What preventative measures will be put in place to prevent the introduction of alien organisms?
Yoliswa Phephetha
ANCWL
Training opportunities to be offered will be profound.
Luyanda Nqai
SACP
Other private consortiums should be challenged to become involved in the Coega Project, and thereby boost the
economy and create employment.
Nelson Dayile
ANC
Supports the project and the initiative taken to boost the economy and create employment.
Yoliswa Mjuza
ANC
Concerned about the impacts on the environment, but also believes that the harbour will improve living
conditions for many people.
Elias Noruka
ANC
Very interested in the project.
Jacky Tana
ANC
The project will re-dress the socio -economic standards of the E Cape. Poverty alleviation and job creation.
Khanyiswa Mangesi
ANC
Concerned about the impact on the environment.
Advantages are the job creation, increase in tourism, and also the opportunity for learners to benefit from
learning how the harbour operates.
Mazwi Lama
ANC
Looks forward to the boost in the economy.
Pleased that those relocated have been well provided.
Thinks that the government should approve the project. The project will encourage overseas investors that could
invest in the rural communities.
Kulukazi Ncipa
ANCWL
Pleased with the information supplied so far and looks forward to the job opportunities.
Johnson Fani
ANC BEC
People must be trained so that they can get employment more easily.
The people of the area should be the first priority.
Khaya Vusani
ANC
When will the project begin and what will be the wages paid?
December Genu
ANC
The process must get sped up, people must be trained and jobs created.
Boneka Mahlahla
ANCWL
Suggests that the voter’s roll be used to establish if someone is from the Eastern Cape or not.
Affirmative action according to gender must be applied.
Mninawa Ncobo
ANC
What about job creation for people in outlying areas of the metropole? Will accommodation and transport be
provided?
Lindiwe Jafta
ANCYL
What skills are needed?
How will we apply, will we be contacted?
Nkululeko Banzi
ANC
Why are we still debating this, we need to create jobs?
Thandiwe Klaas
ANCWL
Employment structure should focus around the metropole.
CDC must arrange for upgrading of skills.
People must not be discriminated against for employment if they are 35 – 45 years old.
Thokozile Sahlulo
Women in Construction
Please consider women when employing during the construction phase.
Also empower the SMME’s.
Also in the employment of those responsible of transport – women must be first priority.
William Ngwane
ANC
Supports the project insofar as it will create job opportunities.
Andile Nkatsha
ANCYL
How will training be conducted?
Christopher Cuba
ANC
Project will decrease crime levels and increase jobs and training.
Nomonde Gulwa
Student
Supports the project and is impressed with the Public Participation process.
Saddam Mgwantashe
ANC
Project must go ahead.
Simphiwe Huhu
PANAC
The dumping site near Addo must not affect peoples lives.
Edward Mjadu
ANC
Project will create job opportunities and put SA on the map.
Nomthandazo Qashani
ANC
Supports the job creation and upliftment of people.
Zolile Bisa
ANC
Project must have a positive impact on addressing poverty.
Standards of living can be improved.
Thamsanqa Bana
ANC
Supports the creation of jobs.
Nonzaliseko Madlavu
PRDP
The port and international airport will bring more tourism and generate more income.
Mzukisi Dayile
PRDP
Will better the lives of people.
May uplift the province as we are the poorest province.
Will empower the people with more skills.
Andile Lamani
ANC
Will assist in job creation and alleviate poverty.
Boost E Cape socio-economically.
How will they avoid dumping of waste and stop the spread of disease.
Miranda Sam
SANCO
Speed up the process, we need jobs to rid poverty.
Dugard Gojela
SANCO
What criteria will apply when recruiting people?
How much compensation will be given to each person?
People need proper consultation in order to be properly prepared.
The homes of those relocated need to be re-looked at in terms of hygiene, sanitation and electricity.
Sampson Gotyi
SANCO
The project is very viable. Need to look closely at issues like the relocated families and the environment.
Sicelo Sitonga
SANCO
Who is P & O Nedloyd?
What benefits will derive from these containers?
When will the project commence?
Monde Lubambo
ANC
Re issue no.11 table 3, preventative measures will decrease the likelihood of injury.
We must be careful that the disadvantaged communities are not deceived with regards to employment.
Nokuzola Swepu
SACP
Must put Nelson Mandela Metropole on the map.
Vuyani Gaxela
SANCO
We want jobs, and when will it start we need to start training?
Lunelwa Kula
ANC
Wants to see poverty alleviated and crime brought to an end.
T B Mafana
ANC
Supports the project.
With regards to the relocation, the process ran smoothly, the houses are an improvement, would not live
anywhere else.
Need an upgraded clinic, community hall.
Training provided as part of the agreement will impact our lives and the community of Wells Estate.
APPENDIX C
EXPLANATION OF APPENDIX C
The following Appendix contains the comments sumbitted in response to the 50/50
programme and the letter to be distributed in response.
• Comments in response to the 50/50 Programme

• Letter of explanation in response to 50/50 comments
Comments in response to the 50/50 Programme
Date: Wed, 25 Jul 2001 12:30:09 +0200

From: Jacques Serfontein
I have been following the latest reports on the Coega Harbour Project and also saw the reports on SABC2's 50/50 on Sunday
night and last night on SABC 3's Special Assignment. If possible can you give me more information on this project, as I
would like to know about cost of this project as well as the development of this project?
Date: Sun, 29 Jul 2001 21:16:14 +0200

From: Andre Coetzee
I am concern about the way the Coega Project is being implemented. No environmental impact, economic feasiblity studies
are done. The way in which the project is being steamrollered through, implies that a holistic approach is not being applied.
This can lead some short gains and a lot of longer term pains.
Date: Thu, 26 Jul 2001 15:03:46 +0200

From: DG Hall
Having heard the discussion re making a new port for Coega project over the
TV (and radio) I feel that to improve the existent ports would be a far better proposition. I am against anything that will
disturb birds anywhere and any "development" near to the birds nesting on islands near to Port Elizabeth is bound to cause a
major problem so should not be allowed. I hope I am not too late in adding my name to the protest.
Date: Tue, 24 Jul 2001 21:03:22 +0200

From: Gisela Gilich
I would like to add my voice to the many others that are objecting to the
Coega harbour project. I think it will impact negatively on the environment, besides I do not think that another harbour is
necessary at this time. If ever a ship should run aground or leak oil it would have catastrophic results.
Date: Mon, 13 Aug 2001 12:43:22 +0200

From: Glenda Webster
I would like to express my deep concern about the destruction of yet

Another piece of habitat on account of the harbour project at Port Elizabeth.
Please let me know if there is anything I can do. And thank you for providing us with a channel to register our protests.
PS I have an excellent leader page opinion from 'The Star' by Max du Preez on what could have been done with the money
being spent on Coega and the money spent on armaments. Perhaps I could photocopy it and send it to every cabinet
minister?
Date: Mon, 13 Aug 2001 10:30:24 +0300

From: Mark Owen
To Whom it May Concern

As a citizen of South Africa I wish to lodge my objection to the Coega
Project for the development of a deep water harbour on the following grounds:
The project is not economically viable (have we learned nothing from Mossgas and Saldhana Steel?).
The ecosystem in the area will be severely damaged by the project.
As a taxpayer I do not wish our taxes to be spent wastefully.
We should rather upgrade existing harbours and facilities, as the market demand requires. This is a course of action any
unbiased decision makers would take.
Date: Sun, 19 Aug 2001 20:51:24 +0200

From: Jeanette and Sandy Garner
We wish to record a resounding NO vote to the (already illegally commenced) Coega harbour development, inter-alia for the
following reasons: -
It will undoubtedly have a huge negative effect on the bird, animal and plant life - particularly bird island, and the
surrounding sea-life with the inevitable pollution from industry and shipping. This damage does not take into account the
inevitable damage that is being done and will continue to be done with the development of the infrastructures and industries
of the Coega development. One would ask how much opportunity would be created should
Coega go ahead - we feel it would be very limited, at best, whereas should this area be included in the Addo National Park,
the job opportunities will be long-term and not dependent on damaging our precious environment. We sincerely hope and
pray that this Coega development will be terminated and will never be allowed to continue any further. What has Minister
Moosa got to say about this destruction? Kind regards, in the hope that our NO vote will be recorded
Date: Tue, 14 Aug 2001 07:08:27 +0200
From: "A.S. V.D.WALT
Although we are deeply under the impression of the need for socio -economic development particularly in this region we have
to express our grave concern with the way in which this development is taking its course.
Apart from questions regarding the manner in which the project was started on the ground without heed to the environmental
impact assessment report, or the completion thereof, there are serious questions around the members or participants of the
CDC and its bona fides.
Furthermore the environmental impact assessment done by CES, was limited to the harbour and the activities around same
only. It did not pay attention to the 14000 odd ha of development and activities back of port which are part of the package.
Such industrial activities and the influx of people will without a doubt add to the burden placed on the environment? We
would like clarity as to the status of any environmental impact study done in this regard, before the project is taken any
further. Should none have been done, we insist that they be done and their findings made public before the development
proceeds.
What is a most serious concern, is the apparent lack of foresight to keep the Coega river, mouth and other areas concerned in
its current state in order to incorporate it in the greater Addo Park - in a restored state, as had been done with other reclaimed
previously utilised areas in South Africa.
Furthermore, what independent socio -economic assessments and impact studies have been done which can render substantial
material regarding the full-scale development of the park to compare with what is found in similar studies concerning the
harbour d evelopment on which an informed conclusion can be based?
If no such comparison had been made, it is my contention that the development cannot proceed any further at all unless it had
been done. The development shall also only continue should such a comparison prove that writing off the Coega area in the
name of economic development of the proposed kind is warranted in the face of the potential long-term benefits of tourism in
the whole of the Eastern Cape or extending the Addo Park to include inter alia the Coega mouth and the other areas
concerned.
Co-development of the park and the harbour does not seem viable, as the tourist who brings with him much-needed money
(Pounds and Dollars in many instances) does not pay to have a second-hand nature experience with an industrial development
of the proposed scale of the Coega development incorporated in a nature area or immediately bordering it. He will spend his
Rands Dollars and Pounds somewhere else where his experience of nature is real and no excuses have to be made for the odd
mega-development which he stumbles onto when taking his trip through wildest Africa.
Do we really need a harbour of this scale in South Africa? Why can Durban
Cape Town and the rest not manage as they have done before or be upgraded for the future needs? Can the Port Elizabeth
harbour not be re -developed? What will happen to same, once the Coega harbour exists? What are the alternatives for this
development further up the coast or near East London?
I besiege the authorities concerned to please make the necessary probes and comparisons and should the outcome be against
your current planning, be brave enough and turn this ship around before we lose what we can never replace.
P Opperman
Against the Project
Why invest so much money and in the process destroy the only natural habitat left for certain birds, animals and plants? The
area does not mean anything to the developers because the natural assets do not bring in any profits
It is easy to talk about pros such as job creation, but what about negative aspects such as pollution and the rise in crime in the
nearby areas
People should be made more aware of these factors too
The project is unnecessary and just another way of showing the decline of moral values in our society
It all revolves around money. If money needs to be spent let it be spent of conservation issues!
J J Malan
I object in the strongest terms to this project for the following reasons:
Work has already started prior to a) hearing all objections and b) prior to an independent and competent Environmental
Assessment having been done and publicized. They are literally and physically trying to bulldoze it through.
According to my research Port Elizabeth can handle present shipping needs. Should these change, then this h arbour should
be upgraded to accommodate the new needs as the infrastructure of the city is up and running and is on the doorstep of the
harbour.
Exactly the same applies to East London, which has suffered a more serious downturn than Port Elizabeth and also needs
economic upliftment
The ruination and devastation of an ecologically sensitive area ~ namely land, coastline and sea to satisfy the whims of
politicians is diabolical. This project has nothing to do with improving economics of the area.
There is no proof of any one enormous project in this country that has benefited the local community. They all require
expertise that we do not have. This fact only becomes apparent after the project is under way.
By contrast the value to be added by preserving this as an Eco -tourist area, guaranteeing the involvement of the local
community, is vast and ongoing.
The cost to taxpayers will naturally be exorbitant. This money could be spent in thousands of different ways ~ the first of
which should be teaching people skills and entrepeneurship so that they can contribute to the economy and provide for
themselves.
L Eriksson (50/50)
E Heunis
The following are my reasons for objecting to the above-mentioned development:
The project is likely to cost over 2 Billion Rand and closer to 4 or 5 Billion Rand. This amount is being paid by the South
African taxpayer as the Coega Development Corporation is being funded by the Government. This is a vast sum of money
for a project, whose viability is at best dubious.
There are no committed tenants as yet; this means no definite jobs once construction is completed and no revenue for the
area.
There is no need for such a deep water harbour in this area at this stage. Less money could better be spent upgrading existing
harbours.
Many people have to be relocated for a questionably sustainable project. Underthese circumstances such social upheaval is
unwarranted.
Certain existing businesses which already provide definite jobs will have to close down or relocate, e.g. the salt factories.
Not all employees are able to relocate and retain their jobs,
Other existing businesses are jeopardized, e.g. the farming of abalone which environmental assessments say will be affected
by the pollution from a harbour and industrial development zone.
It is impossible to conduct accurate environmental impact studies without knowing what industrial activities will take place.
None of these can be specified, as there are no tenants
The industrial development of the area will change the nature of the important wildlife areas that could be developed as
projects to more certainly benefit local communities, e.g. the African Penguin breeding sites.
The Coega development is linked to the arms deal. The arms deal is currently under investigation and none of the spin -offs
offered are guaranteed.
Furthermore many people obtained lucrative contracts related to the Coega development which could be seen as involving a
conflict of interests. This needs to be fully investigated.
The veracity or otherwise of the objections raised need to be investigated. In the interim we call for the development to be
halted until such time that a full investigation is completed and taxpayers' questions are adequately addressed.
Letter of explanation in response to 50/50 comments
DRAFT TO BE DISTRIBUTED
Dear
RE: Subsequent Draft Environmental Impact Report for the Port of Ngqura
We acknowledge receipt of your correspondence in response to the 50/50 Programme on

SABC with regards to the above project.
The assessment of the potential environmental (socio-economic and biophysical) impacts

associated with the construction and operation of the port and back-of-port has been
undertaken over a period of years, since 1996 and has entailed a number of iterations based on
changes in the Port design. The environmental impact assessment process has and continues
to follow an authority approved plan of study, as per the regulations governing Environmental
Impact Assessments (EIA's). Public participation and consultation with interested and
affected parties (I&APs) forms an integral part of the this process.
In terms of the regulations Coastal & Environmental Services have been appointed to co-
ordinate the environmental assessment process for the Subsequent Draft Environmental
Impact Report for the Port of Ngqura. Sandy & Mazizi Consulting have been appointed to
facilitate the public participation process for the environmental studies.
Through the correspondence received in response to the 50-50 programme the following has
been brought to our attention:
• It may not have been noted that environmental studies have/or are being undertaken for
the establishment of a Port in the vicinity of the Coega River Mouth
• The impression may have been created that the above company, Sandy & Mazizi
Consulting, is an anti-Coega Lobby.
In order to clarify the above we have enclosed the following documents for your information:
• Public Participation Briefing Paper

• Executive Summary of the Subsequent Draft EIR for Ngqura
• Tables of the proposed impacts and mitigatory measures
The Subsequent Draft EIR and related specialist studies can also be accessed on the following
website www.cesnet.co.za
We have however included your comments in the Final EIR report to be submitted to the
authorities for their consideraiton.
We trust that this clarifies our role in the process. Should you have any additional queries
kindly contact us at the above numbers.
Yours sincerely
SANDY WREN MAZIZI MSUTU

APPENDIX D
EXPLANATION OF APPENDIX D
Appendix D contains the detailed written comments submitted by I&APs. If further includes
the second submission by the Mandela Metropolitan Sustainability Coalition and the response
by Merit (see end of submissions)
• Detailed written comments submitted by I&APs

• Second written submission, dated 21 August 2001, by the Mandela Metropolitan
Sustainability Coalition(MMSC)
• Response by Merit to the second MMSC submission, dated 21 August 2001
Detailed written comments submitted by I&APs
COMMENT FORM
SUBSEQUENT DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PORT OF NGQURA
Comment from South African Marine Rehabilitation and Education Centre

Trust (Samrec)
Contact person Clive Sharwood
Chairman
P O Box 20101
Humewood
6013
Telephone 041 398 4000
Fax 041 398 4100
Email csharwood@deloitte.co.za
1. COMMENTS
Monitoring body
The subsequent EIR notes that the there will be impact of HIGH significance of the harbour
on the disturbance of birds. The impacts associated with pollution during the operational
phase are rated as being severe or very severe prior to mitigation. It is noted that the impacts
can be managed and the significance reduced to MODERATE with proper management of the
port and IDZ.
Samrec submits that it is essential that a proper monitoring body be put in place to monitor
the management of the port and IDZ and to ensure the mitigating factors are implemented.
The body should have powers to impose sanctions if the measures are not properly
implemented. This monitoring body should contain representatives from interested NGO’s as
well as government bodies.
Samrec submits that environmental monitoring committee (outside the Ngqura Environmental
Committee) must be set up to allow all environmental bodies (including NGO’s) an
opportunity to be updated on the project, and to make meaningful input into environmental
compliance of the port and IDZ.
Compliance with legislation

The present lack of capacity within the Eastern Cape Department of Economic Affairs,
Environment &Tourism, Marine and Coastal Management and the Nature Conservation
Division of the Nelson Mandela Metropolitan Municipality is of extreme concern. The
present ability of these departments to ensure that the Coega Project complies with all
applicable legislation is questionable, and means must be sought to provide these bodies with
additional staff, budgets and transport to undertake the responsibilities that that will result
from authorisation of the Coega Project.
Seabird and marine mammal rehabilitation and cleansing centre
Samrec supports the statement contained in Chapter 7.3 Impact 5 which states:
“A seabird and marine mammal rehabilitation and cleansing centre is required. The CDC and
PAD, as major stakeholders, in conjunction with other concerned organisations, should
provide the majority of the infrastructure and funding for an appropriately sized and
equipped centre. The CDC in conjunction with PAD must initiate an investigation into the
exact requirements of such a facility and ensure that it is functional prior to the operational
phase of the port.”
This recommendation is repeated in the general recommendations in paragraph 2.2.5.
Samrec has already submitted a proposal to CDC and PAD regarding the establishment of
such a centre.
The comment is included under a heading “catastrophic oil spills”. It is submitted that the
contemplated centre is required on a permanent basis not for catastrophic oil spills but day-to-
day care for the seabirds and mammals in the area. It is submitted that an emergency plan to
cater for the large number of seabirds that will be affected by a catastrophic oil spill must be
drawn up with the assistance of the parties invo lved with the rehabilitation of seabirds as a
result of the sinking of the MV Treasure near Cape Town. It is submitted that this plan must
be drawn up as a matter of urgency so that sites for the necessary rehabilitation facilities can
be identified and secured.
Samrec submits that a permanent centre is required to care for seabirds and marine animals.
A long-term study in Algoa Bay has attributed 44% of all causes of death of African penguins
to oiling (referred to by Dr Norbert Klages in Bee-eater 50(4), October 1999). Statistics of
adult African penguins introduced to the hospital facilities at Bayworld as a result of stranding
indicate that 60% are as a result of oiling. (Dr Norbert Klages Bayworld) These statistics
illustrate the need for a permane nt rehabilitation and cleaning centre to cater for the daily
oiling of birds that occur in Algoa Bay.
A recent newspaper report indicated that a number of African penguins were taken to
SANCCOB as result of oiling from a ship “cleaning out its bilges”. This factor is also a daily
risk not related to catastrophic oil spills.
Samrec submits therefore that the mitigating factor should not be included under “catastrophic
oil spills” but should be a permanent facility to cater for the day to day oiling and other
mishaps suffered by seabirds and marine mammals and that an emergency management plan
be drawn up as a matter of urgency to cater for dealing with catastrophic oil spills.
Timing of establishment of rehabilitation centre
The Port EIR identified the negative impact on marine birds of special concern (e.g. African
penguins) during the construction phase of the port as being HIGH (Port EIR p 123). The
port EIR also identified the negative impact on marine birds of special concern (e.g. African
penguins) during the operational phase of the port as being HIGH (Port EIR p 135). Yet the
recommendation for the construction of and operation of the marine bird rehabilitation centre
is made only prior to the operation of the port.
Samrec submits that in the light of the vulnerable status of this species and impact that the
construction phase of the port will have on these animals it is vital that a rehabilitation centre
is established and becomes operational prior to the initiation of the construction of the port.
Regular monitoring of islands in Algoa Bay
The draft EIA made provision for the regular monitoring of the islands in Algoa Bay to
determine the effects the proposed port and IDZ on the island inhabitants. The draft
subsequent EIR does not appear to cater for such monitoring.
Samrec submits that it essential that a properly funded programme of regular visits to the
islands is implemented to ensure that any adverse effects on the island inhabitants can be
monitored and oiling victims can be identified and removed for treatment at the rehabilitation
centre. It is submitted that this programme is essential as a mitigating factor for the proposed
port and IDZ. It is recommended that a properly maintained vessel is made available at the
port to facilitate the monitoring process.
Algoa Bay Management Plan
The Algoa Bay Management Plan (ABMP) contains many of the mitigatory measures for the
Coega Project, many of which need to be implemented prior to initiation of construction of
the port. It is therefore crucial that the ABMP is workshopped with all the relevant role
players and amended, and an Algoa Bay Management Authority (ABMA) is set up to drive
the implementation of the Plan before construction of the port commences.
Marine Risk Assessment
In the Marine Risk Assessment for Coega Harbour prepared by WSP Walmsley a statement is
made in paragraph 3.2 that:
“These figures are for all oil spills, both crude and refined products. Bearing in mind that the
oil cargoes handled in PE or Coega ports are refined products only, these world-wide
average risk rates have been reduced by a factor of 10, to 2 and 0.73 incidents a year
respectively. …”
No authority is given for the reduction in the risk rates. No evidence is given that the effect
of refined products on seabirds is any less harmful than crude. In fact, effects on bird
populations such as those resulting from the sinking of the MV Treasure were caused not by
crude oil but by heavy bunker fuel oil. This sinking was a mere six years after the Apollo Sea
sank also spilling 2000 tons of fuel oil. Both ships were ore carriers not oil carriers. The
assessment assumes that oil spills above 700 tons will be from Petroleum tankers.
(Paragraph 3.2).
Further in paragraph 3.3 it is stated:
“Given that oil cargoes handled in Port Elizabeth or Coega ports are refined products, liquid
spills such as refined products have a potentially lower impact than heavier fuel products
released from a vessel itself. They will have little or no effect on the environment within the
bay due to the higher evaporation rates and disperse into the water column quite quickly,
though may pose a hazard due to ingestion by marine life.
It is unlikely that any heavy fuel oils would be released outside the port area, wherein it can
be contained and cleaned up.
The heavy fuel oil used by the MV Treasure is not common in newer vessels which tend to
use lighter fuels, VGO (Vacuum Gas Oil) or diesel. Thus if the incident happened with a
more modern vessel, with lighter refined products, the impacts would have been greatly
reduced.”
The Australian Maritime Safety Authority summarises various reports on the effects of oil on
a variety of wildlife on its website www.amsa.gov.au in a page entitled “The Effects of
Maritime Oil Spills on Wildlife” (“the AMSA report”). No differentiation is made between
crude or refined fuel oils in the effect on seabirds, apart from the ‘increased toxicity of
refined fuels’. Certain differences are, however, discussed which are summarised below.
The following statement is made regarding the differences between heavy fuels and refined
fuel products:
“In general, refined petroleum products tend to be more toxic to organisms but less
persistent in the environment. Crude oils and heavy fuel oils like bunker fuels tend to be less
toxic but are more persistent and more likely to have physical impacts on wildlife e.g. coating
feather, fur and skin.
This compositional variation of oil also governs its behaviour, weathering after being spilt
into the marine environment. …
The chemistry of crude oils and refined petroleum products varies significantly. Each spilt oil
or fuel will behave differently and it is difficult to predict accurately the impacts on wildlife.
For example, some oils will become more “sticky” as they weather and have greater
tendency to adhere to surfaces such as animal skins, fur, hair or feathers. Some liquid oils
will form solid waxes very quickly after only a few hours of weathering at sea, others will
leave little residue and other oils may contain high levels of persistent hydrocarbons.
Ambient wind and water conditions can modify the impact of oil on wildlife. For example, on
a warmer sea and in high winds, evaporation may remove the lighter aromatic compounds.
As a result they do not dissolve into the water column and affect marine life and are
incorporated into the food chain.”
As far as the effect on marine mammals are concerned the AMSA report states:
“Individuals oiled early in a spill may be exposed to the more toxic components of the oil by
direct contact and ingestion and suffer greater toxicity than those affected by a more
weathered oil. The thermoregulatory problems for wildlife would not change.”
The AMSA report gives, inter alia, the following effects on pinnipeds (seals)
“Recent evidence suggests that pinniped pups are very vulnerable during oil spills because
the mother/pup bond is affected by the odour. Pinnipeds use smells to identify their young.
If the mother cannot identify its pup by smell in the large colony it may not feed it or it
might even reject attempts by the pup to suckle. This leads to starvation and abandonment.
The ingestion of oiled food or the inhalation of oil droplets is also a possibility. Oil, especia lly
light oils will attack exposed sensitive tissues. These include mucous membranes that
surround the eyes and line the oral cavity, respiratory surfaces, anal and urogenital orifices.
This can cause abrasions, conjunctivitis and ulcers. Consumption of oil-contaminated prey
will lead to the accumulation of hydrocarbons in tissues and organs.”
This study clearly illustrates that spills of lighter fuels could have equally devastating effects
on marine populations as heavier fuels, therefore we question the assumption used in the
Marine Risk Assessment that refined products will have a lower impact than heavy fuels.
The assumption that the average risk rates should be reduced by a factor of 10 is also
questioned.
As indicated above damage to the marine environment from oiling is caused not only by ship
collisions or vessel grounding but also from general shipping traffic and this factor does not
appear to have been considered.
Samrec therefore questions the statement that the overall risk of oil pollution can be
regarded as LOW and submits that the risk should be rated as MODERATE to HIGH.
Samrec supports the recommendation that detailed oil spill response planning is needed for
Algoa Bay that looks not only at the operations of the Coega harbour but als o Port Elizabeth
as well.
HABITAT COUNCIL
1 Bertha Court
Exner Avenue
Vredehoek 8001
Cape Town
Tel: 021 465 3972
Fax: 021 461 0709
e-mail: mlroux@new.co.za
14 August 2001
SJWren
Consultant for the Coega project
e-mail: sjwren@iafrica.com
Sirs
Coega Port & IDZ Project
The Habitat Council, a nation-wide environmental umbrella body since 1974, hereby wishes to
submit certain comment on the proposed Coega project for port development and the creation of an
industrial zone, particularly in the light of the experience of the President of the Habitat Council
through chairing the Saldanha Steel Environmental Monitoring Committee since the approval of the
Saldanha Steel project at Saldanha, Western Cape, and more recently, with the creation of the West
Coast Environmental Monitoring Committee, his chairing of that as well.
As in the case of the Saldanha development, we realise that this large industrial development can hold
great benefit to your province in work creation and economic development. We therefore are in
support of the project going ahead.
We do, however, most earnestly request that binding safeguards be ensured regarding effective
monitoring at every phase of development.
We have not had the opportunity of studying the Management Plan proposed by the Coega
Development Corporation (CDC) for the development, so perhaps what we are putting forward will be
a duplication of what is already included. We. however, request that the following principles and
requirement be built into the project:
1. that the Algoa Bay Management Plan be formally endorsed by the Department of
Environmental Affairs and Tourism (DEAT), and that they ensure:
1.1 that all items that require permitting in terms of legislation concerning water quality,
emissions to air, marine protection and other relevant legislation or regulations be stringently
conformed with,
1.2 that provision be made that harmful substances which are not at the present time being tested
for ( such as dioxins in air emission and ground ash, and TBT that affects marine life) should
be tested for;
2. that, in the light of the requirements of the South African Constitution with respect to Co-
operative Governance, in the likelihood that the local and provincial authorities of the Eastern
Cape now or in the future find themselves under too great financial stress to fulfil the
obligations which this project will place upon them, DEAT (on behalf of the National
Government) will underwrite these obligations, and if necessary step in and provide the
funding in order that the necessary environmental mitigating measures may be
conscientiously and fully complied with;
3. that an independent Environmental Monitoring Committee reporting to the provincial

Minister for the Environment be set up by the Minister to meet regularly and monitor
compliance with the Environmental Management Plan during all phases of the development;
4. that adequate baseline studies on groundwater quality, existing levels of pollution in the river
and the estuary, and in the seawater or the bay, as well as on ambient air quality, and the
current state of marine organisms, be commenced with prior to any construction being
started;
5. that it be stipulated in the Management Plan that sub-contractors for each and every aspect of
this development be contractually bound to comply with the environmental requirements in
the Environmental Management Plan;
6. that aesthetic aspects of the whole (short-term and long-term) development (such as structure
design to be as non-intrusive as possible) will be given due prominence, possibly by creating a
Coega Aesthetics Committee on which independent architects and city planners with a good
record of respecting the environment, as well as representatives of the NGO fraternity will
serve, to scrutinise and comment on development drawings before plans are passed.
We heartily welcome and support the envisaged declaration of the eastern section of Coega
Kop as a provincial nature reserve; the inclusion into an open space system of all sensitive
areas in the port and IDZ area; the development of a no-take (fishing) zone between PE
harbour, Bell Buoy and Cape Recife; marine and terrestrial pollution monitoring; and the
broad range of other recommendations that have been made by the Port Elizabeth branch of
the Wildlife and Environmental Society of SA (WESSA), the national branch of which is a
member organisation of the Habitat Council’s.
We also applaud the recommendation of the Algoa Bay Management Plan for the construction
and operation of a world-class rehabilitation and education centre for marine birds in Port
Elizabeth.
Considering how important the natural environment is to the promoting of tourism in our
country we are sure that you and the Algoa Bay Municipality will be as anxious as we are that
the important development will be a benchmark of responsible planning and environmentally
sound development. It is our sincere hope that this will be achieved.
Yours sincerely
Marie-Lou Roux
Executive Officer: Habitat Council
Eastern Province Region
2B Lawrence Street, Central Hill
Port Elizabeth
Tel: (041) 585 9606 / 585 1157
Fax: (0410 586 3228
E- mail: wildirma@iafrica.com (Admin. & Education)
: wessaep@iafrica.com (Conservation)
________________________________________________________________
_____
14 August 2001
Sandy and Mazizi Consulting

120 Diaz Road
Adcockvale
Port Elizabeth
6000
c.c. Mr. Vincent Matabane (Nat. Department of Environmental Affairs and Tourism)
Dear Ms. Wren
WILDLIFE AND ENVIRONMENT SOCIETY OF SOUTH AFRICA (WESSA), EASTERN PROVINCE

REGION, ISSUES OF CONCERN: NGQURA PORT EIR
The Wildlife and Environment Society of South Africa, Eastern Province Region, has no
fundamental objections to the Subsequent EIR for the port of Ngqura, provided that all
mitigatory measures recommended by the Port EIR and Algoa Bay Management Plan are
implemented. However, we do have a number of concerns in relation to the planning and
implementation of the port EIR mitigatory measures which we believe require consideration.
These issues of concern are as follows:
1) The Algoa Bay Management Plan (ABMP) contains many of the mitigatory measures for
the Coega Project, many of which need to be implemented prior to initiation of
construction of the port. It therefore is crucial that the ABMP is workshop with all
relevant role-players and amended, and an Algoa Bay Management Authority (ABMA)
must then set up to drive the implementation of the ABMP before construction of the
port begins .
2) The present lack of capacity within the Department of Economic Affairs, Environment &
Tourism (e.g. see point 1, pg. 127), Marine and Coastal Mana gement and the Nature
Conservation Division of the Nelson Mandela Metropolitan Municipality is of extreme
concern. The present ability of these departments to ensure that the Coega Project
complies with all applicable legislation is questionable, and means must be sought to
provide these bodies with additional staff, budgets and transport to undertake the new
government responsibilities that will result from authorisation of the Coega Project.
3) An environmental monitoring committee (outside of the Ngqura Environmental

Committee) must be set up, and must meet on a quarterly basis, to allow all environmental
bodies (including NGOs) an opportunity to be updated on the Project, and to make
meaningful input into environmental compliance of the port and IDZ.
4) The port EIR identified the negative impact on marine birds of special concern (e.g.
African penguins) during the construction phase of the port as being HIGH (Port EIR, pg
123). Subsequently, a recommendation was made for the construction and operation of a
marine bird rehabilitation centre prior to operation of the port. However, the port EIR
identified the negative impact on marine birds of special concern (e.g. African penguins)
during the operational phase of the port as also being HIGH (Port EIR, pg 135). In light of
the ‘vulnerable’ Red Data Book status assigned to this species and impact that the
construction phase of the port would have on these animals it is vital that a rehabilitation
centre is establishment and becomes operational prior to the initiation of construction of
the port.
5) The present negative impact which shipping has on African penguins in Algoa Bay is
also of concern. The African penguin population in Algoa Bay has decreased from 80 000
individuals in 1993 to approximately 60 000 in 1999 due to shipping disturbance and
oiling (Klages, 1999). The recommendations in the Algoa Bay Management Plan for a
contingency marine animal rehabilitation centre are inadequate to address the marine
animal rehabilitation needs within and around Algoa Bay. Research by Dr. Norbert
Klages, a marine bird expert based at Bayworld, has found that a minimum of 1 000
African penguins per year need to be rehabilitated and returned to the wild to stabilise the
decline of the African penguin population in Algoa Ba y. Therefore, there is presently a
need for a full-time rehabilitation centre for marine bird species of special concern
whether or not authorisation is granted for the port to proceed, and Portnet must be made
aware of their present responsibility to protect this species.
6) The Open Space System, and an associated management plan, for the Ngqura port and
IDZ must be finalised and implemented prior to initiation of any construction for the
Project. The Coega O.S.S. must also be workshopped with the Technical Team that is
presently drawing up a strategic conservation plan (NM MOSS) for the Nelson Mandela
Metropole in order that the Coega O.S.S. is integrated into the NM MOSS.
The O.S.S. has been based primarily upon the physical sensitivity (e.g. erosion potential)
of areas within the port and IDZ. This is an outdated form of conservation planning of an
O.S.S., and the Coega O.S.S. must be re-planned taking conservation targets and threats,
and species of special concern, into account. The areas that are set aside for the Coega
O.S.S. must also be differentially zoned (Private Open Space) to afford them an increased
degree of protection. Furthermore, the eastern section of Coega Kop must be purchased by
the Coega Development Corporation (CDC) and included in the Coega O.S.S. as agreed
upon by the Department of Minerals and Energy and the CDC via the EMPR for the
mining of the western section of Coega Kop.
No fires must be allowed on site due to the lack of the natural occurrence of fire within the
area under question.
7) The bontveld was mapped at a 1: 250 000 scale, which provides the basis for the
determination of the conservation status of this vegetation type in the Eastern Cape (A
regional assessment). However, this scale is insufficient for project specific planning. It
therefore is imperative that a vegetation map at a 1: 10 000 or 1: 50 000 scale is produced
for the port and core IDZ in order that adequate planning of the O.S.S. can take place for
the project. This must then be workshopped with the relevant stakeholders (e.g. NM
MOSS Project Technical Team).
The EIR also recommends that a compensatory portion of bontveld be set aside for
conservation in light of the loss of bontveld in the area planned for bulk storage (back of
port area). This compensatory portion of bontveld must be identified and included into the
O.S.S. prior to the initiation of construction of the
Project.
8) Some of the proposed infrastructure for the port and IDZ (e.g. Coega River bridge) is in
conflict with the recommended measures to mitigate the negative visual impacts of the
port. These plans must be reviewed in light of the Port EIR recommendations, and South
African National Parks must be adequately consulted in order that the negative visual
impact of the Ngqura port on the Greater Addo National Park is reduced to the greatest
degree possible.
9) An updated, comprehensive oil spill contingency plan for Algoa Bay and a ballast water
plan must be drawn up for both ports prior to the Ngqura port becoming operational.
10) When the Ngqura Environmental Committee was formed, WESSA was informed that we
would receive regular updates on the development of the Coega Project from this body,
but these have not been forthcoming. It would be greatly appreciated if a direct line of
communication between our organisation and this body could be established.
11) WESSA would like to request the Records of Decision for all environmental
authorisations for the Ngqura Port and Industrial Development Zone Project.
Due consideration of our organisation’s concerns would be greatly appreciated.
Yours sincerely
Warrick Stewart
Environmental Officer
SOUTH AFRICAN NATIONAL PARKS
CONSERVATION DEVELOPMENT, SCIENTIFIC SERVICES
National Parks: PO Box 20419, Humewood, 6013
Addo Elephant
Sandy Wren
Agulhas Sandy & Mazizi Consulting
PO Box 23088
Augrabies Falls Port Elizabeth
6000
Bontebok 15 August 2001
Cape Peninsula
Dear Sandy
Re: Comments on the Subsequent Draft EIR for the Proposed Ngqura Port.
Golden-Gate
Highlands
Below are a number of comments the South African National parks would like to submit in response to
the recently released Subsequent Draft EIR for the proposed Port of Ngqura. These comments are in
Karoo
addition to those which have previously been submitted to your offices for previous reports relating to this
lagadi T/Frontier development but should also be viewed in the light of comments submitted to the DTI with respect to the
rezoning application for the IDZ. As with the previous comments there are a number of overriding issues
Kruger
which are of primary concern but these comments are listed in no particular order.
Marakele
Mountain Zebra
Issues
1). Although the report states that it does not address the Coega IDZ in its entirety and that this falls
Richtersveld
beyond the scope of the port EIR, in essence the IDZ activities are inextricably linked to the activities of
Tankwa Karoo the port and vice versa. For example the quarrying of Coega Kop, the construction of the haul road and
the water provision pipelines are all activities which are linked to the construction of the port but are taking
sitsikama
place in the IDZ and their impacts have not been considered here. Consequently SANParks still finds it
Vaalbos unacceptable that there has been no attempt by the CDC or the respective consultants to review the
development of the port and indeed the IDZ in a holistic fashion. These developments and the impacts
hembe/Dongola
associated with them need to be assessed in a coordinated manner and not in parallel isolation. Once again
West Coast the concern is that the impacts associated with a small component of the development may appear to be of
little significance but when viewed in combination with the impacts of associated developments may
Wilderness
indeed by of greater significance.
Furthermore there are activities which have been identified for inclusion in the proposed port and back of
port area which have still not been assessed in terms of their potential impact on the entire development. I
refer here to the relocation of the tank farm and ore berths from the existing Port Elizabeth harbour to the
Coega port area. It is stated in the subsequent EIR that such a relocation operation will be subject to an
individual EIA. However, this is an activity that has already been planned by the CDC and the PAD and
as such the potential impacts of such an activity need to be included now for public scrutiny to assess any
potential impacts. Once again projects are being undertaken in a piecemeal fashion.
2). Linked to point 1 above is the need to review the EIA for the proposed IDZ and the activities
associated with this area. The area has not yet been declared an IDZ and the CDC do not yet hold a
provisional operators permit but there are currently activities being undertaken for the development of the
port facilities. Furthermore there has been no holistic assessment of the impacts associated with the area
demarcated for the IDZ (12 000 ha at last indication). It is critical that these activities are assessed in the
light of the overall development of both the port and IDZ.
3). Once again it is difficulty to assess the impacts of the proposed development when one has no
indication of the types of activities that will ultimately be undertaken. Merely listing a range of broad
scale activities (e.g. mixed use) provides little information on the scale and degree of potential impacts in
the area, specifically the back of port area which will be impinging on the sensitive foredune and
hummock habitats. The vague nature of the assessment of potential impacts has been a problem
throughout the suite of EIA/R’s that have been forthcoming for the proposed development.
4). There a number of areas where mitigation measures are given or proposed which would reduce the
negative impacts associated with the proposed port development. However, the success or actual realistic
implementation of these measures is unknown which gives a misleading assessment of the impact. For
example the impact on existing business such as the salt works as well as the abalone farm hinge on the
successful negotiations between the CDC and the respective parties, relocation of communities, many of
the environmental impacts assume that the necessary EMS procedures are in place but a review of the
environmental targets (Appendix B) set for the port reveal them to be lacking. This issue will have to be
addressed in order to provide the public with assurances that these measures will be undertaken and
implemented and if limits are exceeded that there are mechanisms in place to deal with offenders.
5). In both the assessment of the terrestrial and marine environmental impacts the consultants conclude
that although all the impacts listed would produce negative impacts of varying severity and significance
none of these constitute a ‘fatal flaw’ to the project. However, this appears to be rather subjective and
there is no indication of how the assessment of such potential fatal flaws was handled. At what level must
an impact be listed (there are already some which are of VERY HIGH significance) for it to be recognized
as a fatal flaw. Furthermore, who determined whether these impacts constituted fatal flaws or not?
6). Appendix B outlines some of the measures that have been put in place for the EMS but falls short in
addressing all of the issues identified. This has to be rectified as one of the conditions before construction
can proceed is that there is an adequate EMS in place. As an example in the section detailing the
environmental targets section (i) gives no mention of the African penguin and the impacts associated with
this population. Furthermore, the report states that the list of targets set has not yet been approved by the
CDC which is cause for concern as this provides the public with no guarantee that such measures and
targets will actually be used in the operational phase of the port and IDZ. Although the CDC have
indicated that there will be measures in place to monitor activities will there be any independent
monitoring that is undertaken to see that the activities adhere or comply with national and international
standards?
7). There is concern about certain statements made with respect to the sustainability and viability of the
port development as well as other socio-economic factors, as there seem to be contradictory statements
which are made these include;
- ‘It is , however, not recommended that the port should not be built if the IDZ is not viable, as
expansion of the container handling capacity in South Africa could be undertaken through the
expansion of the Port of Richards Bay.’– there has yet been no study of the viability of the IDZ
and how this links with the current port development (see point 1)
- ‘…the project has the potential to provide limited direct jobs and economic input into the
regional economy.’ And ‘the facility will not generate large numbers of jobs during
construction or operation.’ It appears that a large proportion of the work will be contracted
outside of South Africa. Were any other economic alternatives identified for the land in
question. Other development scenarios for Port Elizabeth have been proposed along eco-
tourism principles (Madiba Bay etc.) and could possibly be expanded to include the current
IDZ.
- ‘…one needs to examine the viability and rationale behind the entire Coega Project, which is
outside the scope of this EIA.’ Will such a study be undertaken and why hasn’t such a study
already been undertaken? Again, there needs to be an assessment of alternative land uses for
the proposed IDZ which would have greater returns on the investment of the South African
taxpayer.]
- ‘It must, however, be emphasized that no existing need (i.e. excluding any future possible need
generated by the IDZ) was identified for the proposed bulk and breakbulk berths and that these
berths are presently not economically viable without rerouting traffic from other ports.’ – This
brings into question again the need for a deepwater port and the impact of the port activities on
the existing PE harbour (which are still unclear). Here again there is no indication as to the
possible use of the bulk and breakbulk berths as there has been no comprehensive and holistic
assessment of the IDZ and Ngqura Port.
8). The impact that the proposed port would have on the greater Addo Elephant National Park is listed as
being high or moderate with the most severe impacts being related to the visual intrusion. SANParks does
not necessarily agree with this conclusion as the impacts are not solely related to aesthetics. The expansion
of the Addo Elephant National Park is centered on the conservation of the regions unique biodiversity which
includes some 6 biomes. Although the enhancement of eco-tourism is one of the primary focal areas
ultimately conservation is of critical importance. As such because the expanded park will also be
negotiating a marine protected area (which includes both offshore island groups) which overlaps with the
port control area SANParks is particularly concerned about the potential impacts to the fauna and flora of the
marine and island habitats, particularly species of special concern (African penguin, Roseate tern, Damara
tern, Duthie’s golden mole, southern right whale etc.). Although some of these are listed in the subsequent
EIR it should be noted that these should also be seen as impacts associated with the greater Addo Elephant
National Park and should therefore be listed as HIGH (currently listed as LOW, pg 174)
Furthermore the level of the visual impacts is reduced as the consultants point out that the park is already in
close proximity to a number of industrial and township areas. However, the scale of these impacts cannot
necessarily be equated to those that exist at present. The present impacts are of a known scale (small scale
industry?) whereas the potential impacts from developments that would take place from activities within the
IDZ (HEAVY industry) as well as port area are undefined and as yet undetermined. There is therefore
potential for these impacts to be of much greater significance. Furthermore, with the envisaged expansion
the access to the park is likely to change which will re-route potential tourists around unsightly
developments and/or industrial areas. Mitigation of the loss of sense of place as a result of the visual impact
of the proposed port is based on SANParks undertaking developments in areas which would be out of sight
of the proposed developments. However, given the extent of the park expansion it is unlikely that there will
be many areas where the port would not be visible to some extent. It may be necessary for SANParks to
forgo preferred sites for rest camps and/or private concession areas purely based on the visual impact from
the port and IDZ developments. The impacts of such requirements on revenue generated by the park is
undetermined.
There are also some discrepancies associated with the demarcation of the proposed boundaries of the
expanded Addo Elephant National Park. Although the original proposal was drafted by Kerley & Boshoff
this has undergone substantial revision and review of the boundaries. The terrestrial zone is in the region of
330 000 ha whereas the marine protected area is in the region of 83 000 ha and includes the coastal area
between the Sundays and Coega Rivers.
Other issues
- Meaning of the term “environmentally sensitive areas” in the report. Does this mean that these areas
are no go areas for development or will there still be development taking place in these areas and if so
what types of development and what mitigation measures will be in place?
- What actions will be taken against tenants who breach environmental standards and regulations?
- Will the discharge of sediment from the sand bypass system be sub-tidal (mention is made that it
would be dumped on the beach) and what monitoring systems are in place to ensure that the systems
is operating properly? It is also stated that this sand bypass system would be commissioned before the
breakwater construction is completed (pg 42) but then later that it will only be commissioned after
completed of the breakwater (pg 125). This needs to be clarified, but should presumably be
operational prior to completion of the breakwater.
- The nature of some of the impacts on species is special concern is listed as being of localised impact
or concern. However, it appears that contradictory statements are also being made here, specifically
in connection with the African penguin. ‘Bearing in mind the recently reported decline in the Algoa
Bay penguin population, the reduced productivity has regional as well as international implications’
(pg 135). Impacts on such species of special concern should be rated as VERY HIGH.
- Further blasting operations mitigation (in addition to the 2 km exclusion zone for marine mammals
prior to a blast operation) should include no blasting periods, specifically when there are whales in the
vicinity and particularly when calving.
I trust that these comments will be included in the final comments report. If there are any points of
clarification that are required please do not hesitate to contact me.
Yours sincerely
Dr Guy Castley
Animal Ecologist
14 AUGUST 2001Error! Bookmark not defined.
SUBMISSION BY ZWARTKOPS TRUST ON THE DRAFT SUBSEQUENT ENVIRONMENTAL

IMPACT REPORT RELATING TO THE NGQURA PORT
1. BACKGROUND
1.1 The Zwartkops Trust is a non-governmental organisation founded in

1967 whose sole purpose is the protection and preservation of the
Swartkops River Valley and surrounds.
1.2 Of the 7 pristine rivers which originally flowed into Algoa Bay, only
the Sundays and Swartkops Rivers remain in anything remotely
resembling their original form. Of these, the Swartkops River is
under serious threat from various sources as a result of wetland
encroachment, surrounding urbanisation and unsuitable industrial
development along the whole length of the valley and surrounds.
1.3 International research has shown that these irreplaceable estuarine

wetlands are a vital link in the breeding and reproduction of fish,
crustaceans and other creatures of the sea and also bird life. The
health of the whole of Algoa Bay will be adversely affected by any
deterioration of the Swartkops River. Likewise, the health of Algoa
Bay will affect the River. In other words, there is an ongoing cycle
of cause and affect.
1.4 There has up to now been injudicious and ad hoc planning which has
resulted in the incorrect siting of industrial and other developments.
Most of the development has been justified on considerations of job
creation and economic benefit and have been implemented on the
basis that on its own a particular development will have a relatively
small impact on the environment.
1.5 The time for decision-makers to accept this argument is past.

Developments can no longer be seen in isolation and regarded as a
small increment. These increments if allowed to continue will
eventually destroy the habitat entirely. The Coega IDZ and Port is in
any event massive by any measure. The cost of re-establishing this
wetland will be prohibitive.
1.6 Furthermore, although threats to the environment are identified in

environmental impact reports, in practice nothing or very little is done
about this. Moreover, the resources, both financial and material,
which are made available to agencies enjoined with the responsibility
of protecting the environment, are hopelessly insufficient and most
of the environmental protection measures fail dismally in the
application.
1.7 There is now a Constitutional imperative for the State and its various
organs to protect and preserve the environment for present and
future generations. No longer therefore can the State pay "lip
service" to these Constitutional requirements.
2. GENERAL COMMENT REGARDING THE ENVIRONMENTAL IMPACT ASSESSMENT
PROCESS
2.1 The perception of the Trust and many similar environmental

organisations is that the environmental impact assessment process
has been a charade.
2.2 This perception is reinforced by the fact that at the highest

Government level and through the Coega Development Corporation,
statements were made publicly, prior to the conclusion of the
environmental protection processes required by law, that the Port
was to be constructed and that the industrial development zone
would continue. These actions make it impossible for any
alternatives to be considered and the only thing then left is to try and
ameliorate the environmental degradation which may be caused by
the projects.
2.3 This is an un-wholesome approach which flies in the face of any

democratic process, let alone the Constitutional protection about
which we boast worldwide. The State should, by example, be the
leader in adherence to Constitutional imperatives and enabling
legislation.
3. CONCERNS AND RECOMMENDATIONS
Given the above, the Trust has decided to focus on what it considers the two most
important areas, namely, the effect of blasting on the Aloes 1 containment dam
and the need for an over-arching Management Authority for the protection of Algoa
Bay.
3.1 EFFECT OF BLASTING ON ALOES 1
3.1.1 The Aloes 1 hazardous waste site is unlined and over the past
years, toxic leachate has been seeping out through
various cracks and fissures. Certain remedial
measures have been taken but the position is volatile
and unstable. Moreover, the extent of the leachate
which is escaping and the possible routes by which it
is escaping are largely unknown.
3.1.2 The assessment of the Zwartkops Trust and certain

independent expert advisors is that the blasting which
will take place at Coega Kop could destabilise the rock
and other geological strata around Aloes 1 which
could result in the escape of large quantities of toxic
leachate into the Swartkops Estuary.
3.1.3 This will have a devastating affect on the estuary and

surrounds. Depending on the nature, quantity and
quantity of the leachate which escapes into the
estuary, the result could be catastrophic and possibly
irreversible.
RECOMMENDATION
n That prior to any blasting, funds be made available for the
appointment of a highly competent geological survey team
from sources totally unconnected with any activity related to
the industrial development zone and the harbour to carry out
a survey on the impact of blasting on Aloes 1, the likelihood
of the escape of leachate into the environment and
recommendations as to measures which should be taken to
prevent this occurring.
n In the event that it is recommended that certain steps be
taken, sufficient funding must be made available for this
purpose, which may include funding for possible future spills
and clean-up operations. If funding for such future
requirements is recommended, these funds should be made
immediately available and placed in a separate account which
may not then be allocated for any other purpose without the
written approval of the Zwartkops Trust and any similar non-
governmental organisation operating in this area.
3.2 OVER-ARCHING MANAGEMENT AUTHORITY FOR ALGOA BAY
3.2.1 The subsequent environmental impact report dated July 2001

identifies various events which could cause damage to
the ecology of the Algoa Bay. Some of these are rated
Very High in view of the potential for immense and
possibly irreversible harm. This, in turn, as stated
above, will have a direct impact on the Swartkops and
Sundays River which will, in turn, have a deleterious
effect on Algoa Bay and so the cycle will spiral
downwards.
3.2.2 There is at present no over-arching Management Authority

which plans and manages the protection of the Bay
with the power to take whatever steps it deems
necessary for this purpose. There are at best a
number of agencies operating in different spheres,
normally without proper co-ordination and certainly
without proper funding and resources.
RECOMMENDATION
n That an over-arching Management Authority (possibly similar

to the US Coast Guard) be established by law for planning
and managing the protection of Algoa Bay and the estuaries
which flow into it.
n Its authority would include all forms of water-based pollution
but must be extended to include land-based pollution sources
(particularly water and air) which affect the Bay in and around
the Bay.
n This Managing Authority must be properly and adequately
funded and given the resources it needs, not only to carry out
its day-to-day functions but also to cope with disaster
management immediately and effectively.
n To show that the authorities are serious about these
protection measures, an amount of least R25million should be
made available immediately and placed into a separate Trust
account in which all NGO's related to Algoa Bay are
represented. This payment is to be regarded as an interim
measure to fund an investigation as to what is required in
order to establish such an over-arching Management
Authority. Further funding must be made available once
these requirements are known and what needs the
Management Authority have.
Portion of the R100bn in offset spending related to the arms

deal should be used if necessary. Our overseas partners will
no doubt welcome the opportunity to fund environmental
protection measures.
There must also be a meaningful undertaking / commitment

from Government that the reasonable future funding
requirements of the Management Authority will be met. This
funding would come directly from Arms offset / Government
or by way of a levy on the parties who benefit from the Port
and the Industrial Development Zone. Certainly those who
set up businesses there should be required to contribute an
environmental levy as determined by the managing authority.
CONCLUSION
Although the Zwartkops Trust believes that the establishment of an Industrial Development
Zone and second Harbour alongside one of the most pristine bays in South Africa with two
unique estuaries is ill-conceived and totally incompatible with the development of a tourist
industry in Port Elizabeth and in the greater Addo National Park and surrounds. However,
if this project is pursued, then this must occur under the most stringent environmental
protection measures. This is the only trade-off which will be acceptable to the Zwartkops
Trust.
DATED AT PORT ELIZABETH ON THIS 14TH DAY OF AUGUST 2001

ROB McWILLIAMS
CHAIRMAN
for and on behalf of the Executive Committee
Mandela Metropole Sustainability Coalition
c/o Southern Africa
Environment Project,
14 Berkeley Square
173 Main Road
Rondebosch, South Africa 7700
Tel and Fax: (27) 21 689 2020
E-mail: saepnft@iafrica.com
Visit The Coega Monitor:

www.coega.org
The Mandela Metropole Sustainability Coalition is comprised of Birdlife South Africa, the Endangered Wildlife
Trust, The International Fund for Animal Welfare, and the Southern Africa Environment Project
14th August 2001
FAO: Ms. Sandy Wren,

Sandy and Mazizi Consulting CC,
Fax: 041 373 2002
Submission of comments on the Subsequent Draft Environmental Impact Report for the
Proposed Port of Ngqura
Dear Ms. Wren,
We are writing to submit our comments on the Subsequent Draft Environmental Impact Report (EIR)
for the Proposed Port of Ngqura.
1. The Viability of the Harbour Development
1.1 As the EIR indicates, the fundamental requirement of the EIR is to advise on whether the
proposed harbour project is a justifiable development when set against the considerable social,
economic and environmental costs and risks of the proposals set out in the EIR. In analysing this,
the EIR concludes: “It is, however, not recommended that the port be built if the IDZ is not viable,
as expansion of the container handling capacity in South Africa could be undertaken through the
expansion of the Port of Richards’s Bay.”
The viability of the IDZ has yet to be either assessed or demonstrated, and no economic viability
or cost-benefit analysis of the IDZ has been undertaken since the withdrawal of Billiton as the
anchor tenant for the project.
In so far as these issues are considered in the new EIR, the specialist study undertaken by MERIT
on the economics of the harbour is scathing in its assessment of the prospects for the IDZ:
“Neither the Port nor the IDZ are well-located in relation to large markets or sources of raw
materials and it can readily be shown that the transport costs, including transshipment costs, for
the producers of bulky goods will impose a substantial penalty in delivered prices. Furthermore,
the prospect of attracting so-called footloose industries from abroad to the IDZ is hampered by the
labour and tax regimes, which are far less friendly than those of competing industrial development
or export processing zones elsewhere in the Indian Ocean Rim.”
The MERIT report also concluded: “the construction of the Port of Ngqura and the development
of the container terminal can be economically justified provided (i) the port infrastructure is
limited only to the basic requirements needed to serve the [container] terminal”. However, the
Port infrastructure is not being so limited. Hence, the MERIT report actually concludes that the
harbour proposals as they currently stand cannot be economically justified, and concludes that no
evidence could be found of the existence of cargo in large enough volumes to justify the
construction of the bulk facilities envisaged for the harbour.
The approval of the EIR by the authorities unless and until the IDZ has been shown to be viable,
which it has not up to this point in time, would be action in direct violation of the
recommendations contained in the EIR, and would fatally undermine South Africa’s entire
environmental impact assessment process and procedures.
1.2 The finding of the EIR that the port can be justified economically to serve South Africa’s future
container handling requirements is based on the conclusions of the specialist study undertaken by
MERIT. This report was conducted in a seven week period – thoroughly insufficient for an
adequate study of an issue of this complexity, has not been subjected to peer review or
independent review of any form, and reaches conclusions that are fundamentally at odds with the
almost unanimous opposition to the project in South Africa’s shipping community.
An analysis of the MERIT report is currently being undertaken by economists working in

association with the Mandela Metropole Sustainability Coalition (MMSC). Due to the extremely
short time frame for public comment allowed for the EIR and the complexity of the issues
involved in the MERIT report, it has proved impossible for this report to be finally completed in
time for incorporation in these comments.
The preliminary findings of the report, however, indicate that the MERIT report is fundamentally
flawed in its conclusions. A crucial technical error appears to have been made by MERIT in their
analysis, in the absence of which the proposals would have been found to be fundamentally
economically unjustifiable. The MERIT report has indicated a number of serious limitations
imposed by the short-time frame available for their study, and a number of serious issues and
challenges for the project appear to have been overlooked by the authors of the MERIT study, in
particular the adequacy of the connecting infrastructure between Coega and the main economic
areas of South Africa, including Gauteng.
These concerns fundamentally challenge the conclusions of the EIR, and suggest that the
irreversible economic and environmental damage that would result from the construction and
operation of the port would be based on a profoundly flawed economic analysis. It is imperative
that these issues are given the serious consideration that they deserve, and we hereby specifically
request that the report to be submitted by the MMSC economists on the MERIT report be legally
and procedurally incorporated as part of these comments. We specifically request that you
confirm this in writing to us.
1.3 The EIR notes that the harbour development is only weakly sustainable. The impact of the
development on existing and potential industries, while extensively analysed in the EIR, does not
appear to have been incorporated in this conclusion. In addition to the probable impacts on the
saltworks and abalone farm, the EIR rates the port as having a High or Moderate impact on the
proposed Greater Addo National Park (GANP). The EIR concludes, however, that while the port
will detract from the GANP, the two are not mutually exclusive. Whilst this is strictly speaking
true, it fails to come to grips with the issues that have been raised concerning the impact of the
port on the GANP. In detracting from the appeal of the GANP, in particular, as the EIR notes, the
marine section, the port will reduce the economic success of the GANP, as well as threatening a
number of its conservation goals. The reduction in the economic success of the park is a
significant economic cost of the port, and one that must be factored into the evaluation of the
desirability of the proposed port. The failure to consider the marginal economic impacts of the
port on GANP and set these against the marginal benefits of the port results in the key issue
relating to the compatibility of the port and the GANP proposals being missed by the report.
2. Project mitigations.
The EIR follows the previous impact assessments of the Coega project in requiring a whole series of
mitigatory measures to alleviate the many threats posed by the harbour to the human and natural
environment. The EIR notes that these mitigatory measures are required in order to prevent any of the
impacts being regarded as a fatal flaw. These include crucial mitigatory measures for the management
of ballast water from shipping and the inspection and management of shipping to prevent oil spills.
The EIR notes: “The size, duration and nature of the construction has the potential, if poorly managed,
to impact significantly on the environment … the construction and operation of an environmentally
unmanaged or unmonitored port will most likely have very severe impacts on the environment.”
We believe that it is optimistic in the extreme to expect that the full range of mitigatory measures can
be satisfactorily implemented and maintained throughout the construction and operation of the port.
Our faith in the will to enforce these mitigatory measures has been substantially eroded by the
consistent disregard shown for key environmental requirements throughout the planning of the project,
including the requirements concerning the location of the harbour, the extent of development allowed
South of the N2, and the disregard for the SEA air pollution guidelines.
The consequence of this optimism is, we maintain, that the environmental impacts of the project have
been under-estimated in the EIR. If the project does proceed, guarantees need to be put in place prior
to approval that the full range of mitigatory measures will be enforced. These measures, and clarity on
who will pay for them, must be included in the impact assessment process and incorporated as
requirements as part of any authorisation for the project and the issuing of any record of decision.
3. Future Development of the harbour
The EIR notes that due to lack of information about the future expansion and development of the
harbour, no assessment can be made of the impacts of any such future expansion. This argument is
advanced despite the fact that the economic justification for the port set out in the MERIT report is
premised on the expansion of the port to 8 container berths in the near future, which contrasts sharply
with the 2 container berths envisaged for the harbour as assessed in the EIR. This discrepancy between
the assessment of the positive economic impacts of the harbour and the environmental consequences
of such development has the effect of biasing the assessment in favour of the project.
The EIR states that any further development of the harbour must be subjected to future assessment
prior to its approval. This requirement is naïve, as it significantly underestimates the pressure for the
full exploitation of the harbour once the considerable in itial sunk costs have been invested. It is
important that parameters on the future development of the harbour be set out prior to the decision to
proceed with the project, as such limitations may significantly impact on the decision to proceed with
even the initial phase of the project. Among the limitations that should be imposed at the outset on the
project is the prohibition on the establishment of a ship-breaking yard at the port, as such a facility
would have unacceptable environmental impacts.
4. Independent review
The National Environmental Management Act requires the independent review of environmental
impact assessments. No such independent review has been conducted of the impact assessments for
the Coega project since the review conducted in the first half of 1997 by Arthur D. Little.
Such an independent review is of particular importance in the context of a development on the scale of
the proposed port, a need exacerbated by the considerable debate that has surrounded the impact
assessments for the project to date. In particular, we wish to highlight the need for an independent
review of MERIT’s economic study in the light of the highly contested conclusions of that study.
5. Final EIR.
The EIR on which these comments are based is at this stage a draft report. It is essential that the issues
raised by the public participation process are addressed fully in the final EIR. A number of the issues
that we raise here are highly significant, and have a crucial bearing on the viability of the project. We
would be surprised if other interested and affected parties do not raise issues of similar importance.
In previous impact assessments associated with the Coega project, comments have been dealt with
through the use of an ‘Issues and Responses Trail’. Such an approach has proved a thoroughly
inadequate tool in addressing the concerns that have been raised, and has typically involved the simple
restatement of the facts and analyses that were being contested in the first place. This can result in the
impression that public comments are not given the weight that they merit in the impact assessment
process, an impression borne out in Common Ground’s review of the public participation process for
the project.
It is imperative that the final subsequent EIR fully and meaningfully addresses and considers the
issues that arise out of the public participation process.
6. Public Comment Period.
We note that we have received no response to our request for the extension of the public
comment period. It is important to restate again our concern at the extremely short time period
allowed for public comment. One of the consequences of this short time period is that the
MMSC has been unable to commission and submit comments from independent experts, a
short-coming which can ultimately only reduce the level of information available over the
project, the quality of the decision- making surrounding the project, and the success of the
project should it proceed.
We can see no justification for the latest rush that has been applied to the consideration of the
considerable bulk of new material that is presented in the EIR. The lack of time available to
the specialist consultants to prepare their reports is in large part responsible for the flaws in
the MERIT report. The compressed time-frame for the assessment process must ultimately be
self-defeating, and extends back to the earliest days of the planning of the Coega project. Had
adequate time been given for the compilation of specialist reports and the consideration of
public comment in the first stages of the planning of the project in 1997, the subsequent
controversies might well have been avoided.
The repeated setting of short timeframes for public comment on the project has set a
damaging precedent for the future of participatory democracy in South Africa, and we
maintain that it is the responsibility of the consultants employed for the project to make clear
to decision- makers that such constraints are unacceptable.
The Ngqura harbour development poses unacceptable risks to the social, economic and
natural environment of the Eastern Cape. The social and environmental damage that would
result from the proposed project should not be countenanced unless the concomitant socio-
economic benefits are considerable and have been clearly demonstrated. It is manifest that
those benefits remain to be demonstrated at this point in time, and, indeed, the project may
actually result in greater economic harm than good. Under such circumstances, no
authorisation to proceed with the project should be given.
Sincerely,
_____________________________ _____________________________
Norton Tennille W.B. Papu
Executive Director Managing Director
Southern Africa Environment Project Southern Africa Environment Project
On behalf of: Birdlife South Africa

The Endangered Wildlife Trust
The International Fund for Animal Welfare
Southern Africa Environment Project
Second written submission, dated 21 August 2001, by
the Mandela Metropolitan Sustainability
Coalition(MMSC)
Mandela Metropole Sustainability Coalition
c/o Southern Africa
Environment Project,
14 Berkeley Square
173 Main Road
Rondebosch, South Africa 7700
Tel and Fax: (27) 21 689 2020
E-mail: saepnft@iafric a.com
Visit The Coega Monitor:

www.coega.org
The Mandela Metropole Sustainability Coalition is comprised of Birdlife South Africa, the Endangered Wildlife
Trust, The International Fund for Animal Welfare, and the Southern Africa Environment Project
21 August 2001
Sandy & Mazizi Consulting
Fax: 041-373-2002
Re: Coega: Draft Subsequent EIR for Ngqura Port
Dear Sirs:
Attached please find a supplement to our comments on the draft EIR for the Harbour
entitled “The container economics of Ngqura: a note on MERIT’s May 2001 ‘Economic
Evaluation of the Proposed Port of Ngqura and Development of a Container Terminal’” (Tom
Le Quesne (August 2001).
It analyses the study conducted on the economics of the proposed harbour and notes in particular that
that study concludes that the port as proposed, with bulk loading berths and terminal, is not
economically viable.
Sincerely yours,
Norton Tennille
Executive Director
Southern Africa Environment Project
The container economics of Ngqura: a note on MERIT’s May 2001 ‘Economic Evaluation of
the Proposed Port of Ngqura and Development of a Container Terminal’
2. Tom Le Quesne *, August 2001
Executive Summary
The economic justification of the proposed Port of Ngqura on the basis of the report
conducted by MERIT does not appear to be justified by a close examination of the report and
an analysis of its limitations. Considerable further work is required to arrive at any conclusion
regarding the economic viability of the Port of Ngqura with confidence given the enduring
disadvantages of the proposed location.
• The report found that the proposals for the Port of Ngqura as they currently stand could
not be economically justified.
• A number of costs associated with the Port of Ngqura were not included in the analysis,
including costs of rail subsidies and the closure of existing businesses at Coega; the
inclusion of these costs may have resulted in differing conclusions from the analysis.
• The report highlighted a number of limitations in its analysis, and made a series of
important recommendations to redress these; the implications of these limitations may
have an important impact on the conclusions of the study.
• A number of important challenges for the proposed Port of Ngqura did not receive the
attention that they warranted in the report, while others appear to have been
disregarded entirely; these issues include the adequacy of the connecting road and rail
infrastructure between the port and South Africa’s main industrial areas and markets,
and the lack of an economic hinterland in the Eastern Cape to be serviced by the port.
• The uncertainties involved in the economic benefits that would derive from the port
contrast with the more certain disadvantages of the port. The uncertainties involved in
these benefits should be kept strongly in mind in any decisions on the viability of the
port.
*
Tom Le Quesne, BA, MSc (Oxon), Centre for the Study of African Economies, University of Oxford.
I. Introduction
A substantial cost-benefit analysis of the use of the proposed Port of Ngqura, or Coega, as a
container terminal by Bernal Floor and Henriette van Niekerk, of Maritime Education and
Research Information Technology (MERIT), was released to the public in July 2001 as part of
the subsequent environmental impact assessment process conducted for the Port of
Ngqura 1.
The conclusio ns of the report have been widely quoted as providing the required economic
justification for the construction of the port. These conclusions have been based on the finding
in the report that the construction of a harbour and container terminal at Ngqura/Coega is
economically justifiable to meet South Africa’s container handling needs over the next twenty
years.
This reaction to the report is unfortunate and unjustified for two reasons. Firstly, it does not
appear to be based on a careful reading of what the report actually says, the limitations that
the report itself highlights, and the relationship of the analysis carried out in the report to the
actual proposed development. Such a careful reading suggests that the report is far from
providing such a clear justification for the development. The authors of the report can hardly
be blamed for an insensitive or selective reading of their analysis and conclusions, and would
themselves agree that a decision of this scale and complexity should not be made on the basis
of a study limited to seven weeks 2 .
Secondly, the report contains a number of limitations and omissions. No review of the report
has been undertaken, a requirement that is widely recognised as necessary for analyses of this
nature. Any paper submitted for publication in any reputable journal must pass through a
stringent process of independent peer review, and such requirements are recognised in the
National Environmental Management Act which states that an independent review must be
conducted at all stages of the impact assessment process 3 . Such reviews are welcomed by
authors as an essential part of the process of providing rigour to the conclusions, and checking
to ensure the veracity of any statistical analysis and the assumptions upon which it is based.
This note aims to attempt to make a start on remedying the current situation by spelling out
the conclusions of the report, and the limitations of it as stated by the authors. The paper also
raises a number of issues which have not received the attention in the report which they
appear to deserve, and which have an important bearing on the economic justification of the
proposed development.
The considerations in this note may help to explain the discrepancy between the conclusions
being claimed on the basis of the MERIT report and the almost unanimous opinion in South
Africa’s shipping community that the construction of the Port of Ngqura does not constitute
1
MERIT, ‘Report on the Economic Evaluation of the Proposed Port of Ngqura and Development of a Container
Terminal’, May 2001.
2
Personal communication, H. van Niekerk.
3
National Environmental Management Act (No. 107 of 1998), Section 24.7 (d).
the best solution to South Africa’s container handling requirements. An indication of the
strength of this opinion is provided in a recent edition of Freight and Trading Weekly, South
Africa’s freight industry journal, which conducted a survey of leading shipping executives.
With the exception of P&O/Nedlloyd, the preferred private partner fo r the project, opinion
was unanimously against the Ngqura proposal4 . Similar concerns have been expressed over
the plan by shipping economists and academics 5 . Conversations conducted with many parties
in the shipping industry in the preparation of this note confirmed this widespread scepticism
over the proposed Ngqura port.
4
Freight and Trading Weekly, 22nd June 2001.
5
e.g. University of Natal economist Professor Trevor Jones, on SAfm’s ‘Friday File’, 10th August 2001.
II. What the Report Actually Says
While the analysis set out in the MERIT report concludes that the construction of the Port of
Ngqura as a container terminal can be economically justified, it makes a number of important
qualifications to this statement. Some of these qualifications concern the limitations of the
study, and these are examined in Section III of this note. However, other qualifications
concern the limited support that the report provides for the existing port proposals, as well as
the limited benefits that the report envisages flowing from the port for the region.
1. Port Specifications, and bulk and breakbulk handling facilities. The MERIT report
focuses on the economic viability of the construction of the harbour and container handling
facilities alone at Ngqura. However, the current plans for the construction of the port indicate
that not only container handling facilities, but significant bulk and breakbulk facilities will be
constructed at the harbour 6 . This discrepancy between the project evaluated by the MERIT
report and the project that is actually to be constructed has a number of important
implications.
Firstly, the MERIT report found: “ the construction of the Port of Ngqura and the
development of the container terminal can be economically justified provided (i) the port
infrastructure is limited only to the basic requirements needed to serve the [container]
terminal” 7 . However, the Port infrastructure is not being so limited. The implications of this
are spelt out in the report: “In the absence of any confirmed bulk or breakbulk cargo for the
port, the inclusion of the costs of providing such berths or facilities without any definite
benefits would result in a negative return and favour the development of Richard’s Bay.”8
Hence, the MERIT report actually concludes that the harbour proposals as they currently
stand cannot be economically justified.
What are the prospects for the level of confirmed bulk or breakbulk traffic that would be
required to render the proposed port viable? The possibilities are examined at some length in
the MERIT report, which concludes that no bulk or breakbulk traffic can be identified which
would justify the construction of the bulk and breakbulk handling facilities: “No new bulk or
breakbulk cargo for the proposed Port of Ngqura can be identified with sufficient certainty to
evaluate the costs and benefits of the traffic in this study … Similarly, no breakbulk traffic
can be identified which will make any significant contribution to the justification for the
Port.” 9 The report concludes: “no evidence could be found that cargo in such large volumes is
likely to exist.” 10
The other possible source of traffic for the bulk and breakbulk handling facilities at the port is
from industries located in the proposed IDZ, a possibility discussed below.
6
Coastal Environmental Services, Subsequent Draft Environmental Impact Report for the Proposed Port of
Ngqura, July 2001.
7
MERIT, p.92.
8
MERIT, p.iii.
9
MERIT, p. 57-8.
10
MERIT, p. 93.
A last issue arises from the construction of the bulk and breakbulk facilities at the port. The
cost of the expansion of the container handling facilities at the port over the twenty year time
horizon considered in the report may be considerably raised by the use of three of the initial
berths to be constructed at the harbour for bulk traffic, as indicated in the port layout plan.
While few details are provided in either the subsequent environmental impact report or the
MERIT report of the technical specifications of the future expansion of the port, the devotion
of three berths within the first phase of the harbour to bulk traffic may entail considerable
extra expense in the extension of breakwaters and quaywalls, and land reclamation in order to
provide the eight cargo handling berths specified by the MERIT report. Insufficient
information is currently available to evaluate this impact.
2. The harbo ur and the IDZ. In evaluating MERIT’s report, the subsequent draft
environmental impact report concludes: “It is, however, not recommended that the port be
built if the IDZ is not viable, as expansion of the container handling capacity in South Africa
could be undertaken through the expansion of the Port of Richard’s Bay.” 11 While the EIR
does not, unfortunately, provide detailed reasons for this conclusion, it is presumably linked
to the need for the IDZ to generate significant traffic to justify the current proposals for the
harbour, which incorporate significant bulk handling facilities. It may also be linked to the
significant negative externalities, both socio-economic and environmental, that would result
from the construction of the Port of Ngqura.
The economic viability of the proposed harbour is closely tied, therefore, to the viability of
the IDZ. Up to this point in time, the viability of the IDZ remains to have been satisfactorily
demonstrated. The only cost-benefit and economic viability analyses of the IDZ that have
been conducted were undertaken in 1997 on the premise that the IDZ would be focused
around Billiton’s proposed zinc refinery. The studies were also extremely thin in their
analysis. No economic study of the viability of the IDZ has been conducted since the
withdrawal of Billiton (or, if one has, it has not been made available to the public).
The MERIT report itself is highly sceptical over the potential of the IDZ to attract the tenants
for which it is designed: “Neither the Port nor the IDZ are well- located in relation to large
markets or sources of raw materials and it can readily be shown that the transport costs,
including transshipment costs, for the producers of bulky goods will impose a substantial
penalty in delivered prices. Furthermore, the prospect of attracting so-called footloose
industries from abroad to the IDZ is hampered by the labour and tax regimes, which are far
less friendly than those of competing industrial development or export processing zones
elsewhere in the Indian Ocean Rim.” 12 The recent decision by Ramatex to invest in Namibia
rather than the Eastern Cape would appear to be an example of exactly this kind of challenge
for the proposed Coega IDZ.
3. The benefits to the Eastern Cape. Since the inception of the Coega/Ngqura project, one
of the justifications that has been advanced in its favour is the desire to redress the low level
of development in the Eastern Cape. This is noted in the draft EIR for the harbour: “a final
11
Coastal and Environmental Services, op. cit., p. xiv.
12
MERIT, p.90.
decision to support and fund the Coega Project will most likely not only be based on a purely
economic best return basis, but also include aspects such as the strategic development of a
previously and presently economically marginalised area of South Africa.” 13
In this respect, the MERIT report highlights the limited benefits that would result to the
Eastern Cape as a result of the Port. In its initial operation phase, the container handling
facilities would employ some 350 people, of whom, however, only 20 would be drawn from
the ranks of the unemployed. 14 The report envisages the figure employed rising to 1600 by
2020, on the assumption that the envisaged annual throughput of 1,8 million TEUs
materialises. This would lead to the creation of less than 100 jobs for the unemployed, a
disappointing figure for a project that has been specifically touted as an attempt to address
unemployment in the region.
The report specifies, however, that the bulk of the employment generation potential from the
project will be in support industries for the harbour and in the IDZ. It cautions, however, that
the former will not be generated for some time, and the extent will be limited. With respect to
the job creation prospects of the IDZ, we have already noted the extreme caution of the
MERIT study towards the success of the IDZ proposal. It is also worth noting that the heavy
industrial facilities targeted for the IDZ are by their nature low employers. By way of
example, the proposed Billiton refinery would have employed only 600 people, of whom,
again, only a small fraction would have been drawn from the existing unemployed in the
region.
The income effects of the port will be similarly limited, with the report finding that the
operational phase of the development will make only “a small contribution” to the GGP of the
area, while the impact of the construction “is again insignificant in comparison with the gross
regional product of the Port Elizabeth-Uitenhage area”. 15
The primary justification, therefore, for the construction of the Port of Ngqura would appear
to be to satisfy South Africa’s national infrastructure requirements, in particular the needs of
the industries of Gauteng. In this respect, it is of some concern that some of the costs of the
harbour may be met by the Eastern Cape. Not only do these include environmental costs and
the indirect impacts on existing industries in the area, but also financial input from the Eastern
Cape Provincial government. While the bulk of the finance for the construction of the port
will be provided by Portnet, some of the land purchase and preparation costs for the port
appear to be being provided by the Coega Development Corporation16 . A significant element
of the funding for the CDC is being provided by the Eastern Cape Provincial government 17 .
The extent to which significant funding from the Eastern Cape government, either directly or
through the CDC, is being used for elements of the preparation, enabling and construction of
the harbour remains unclear. However, the use of EC provincial finance towards a project
13
Coastal and Environmental Services, op. cit., p. xv.
14
MERIT, p.86.
15
MERIT, p.87,91.
16
By way of example, the July 2001 EIR for the harbour appears to have been commissioned by the CDC, as
have a number of the further studies on the harbour and its impacts.
17
Raymond Hartle, Daily Dispatch, 27th July 2001.
whose bene fits would be principally realised for industries in Gauteng would appear to
reverse the intentions of the project to redress geographical imbalances in the South African
economy.
III. Limitations Recognised by the Report
The economic factors involved in decisions over the expansion of South Africa’s container
handling facilities are highly complex. The MERIT report, initially envisaged as being
conducted over a six week period, was eventually completed in seven weeks. Such a time-
frame is excessively short for a study that must deal with the many complex factors involved
in such a decision, and the authors of the report note this by highlighting a series of
limitations to their study and factors that could not be included in the analysis.
The impact of these factors on the final conclusions of the study are likely to be significant,
and warrant further study and inclusion in an expanded analysis. In this respect, it is important
to note that the conclusions of the analysis showed that the proposed harbour was only weakly
economically sustainable, and that the inclusion of the costs of R275 million for the bulk
handling facilities in the analysis led to the analysis favouring development at Richard’s Bay.
Many of the limitations noted by the study are likely to be on this scale, or greater, and could
therefore have led to a very different result of the study.
While the type of cost-benefit analysis conducted by the authors can provide a useful
formulation of the issues, the limitations of the report mean that the specific numeric
conclusions of the report must be treated with the greatest scepticism, and regarded at as best
a highly preliminary indication. While the report does recognise these limitations, it is
perhaps unfortunate that the limitations of the study and the hazards of basing a decision of
this complexity and importance on such a necessarily limited study were not spelt out more
clearly by the authors.
1. The need for a logistical model. The conclusion of the report notes that the timeframe
imposed on the report did not allow for the construction of a logistical model that would allow
for the detailed incorporation of the many complexities surrounding the decision. The report
recommends that such a model be constructed.
The absence of such a model is highly significant in the current context. The majority of the
benefits projected from the construction of the Port of Ngqura as against alternative options
would derive from the detailed logistics of container movements. As the report notes, “these
costs or savings will depend upon the logistics of the container flows arranged by the
shipowners.”
By way of example, the report is premised on the assumption that the majority of ships calling
at Ngqura will be able to turn around at Ngqura, rather than continuing to further South
African or other ports. This key assumption needs to be tested through the logistical model.
The importance of the construction of such a model is exacerbated by the limited local
requirements of the Ngqura area, meaning that many of the containers will need to be
transferred on through either a transshipment service or the continuation of ships. In the
absence of the full logistical model, these details and any associated costs cannot be easily
specified.
2. Limited information on alternatives and costs. The second important limitation
highlighted in the conclusion of the study concerned limited information on the costs involved
in the options, in particular the lack of details of the costs at Richard’s Bay and the further
expansion of Durban.
In addition to these highlighted limitations, there area a number of other occasions in the
report where the lack of information constrained the analysis. These include other possibilities
alluded to for the construction of a further terminal within the existing port of Durban, the
construction of a new port at Durban, the expansion of Cape Town, and the possible role of
Maputo. 18 Again, the authors of the report cannot be blamed for the lack of this information
due to the highly limited nature of their brief, but the exclusion of these important possible
options on the basis of lack of information again cautions against basing firm conclusions on
the report.
3. Rail subsidies. In order to encourage the utilisation of the Port of Ngqura with its
locational disadvantages in relation to the Gauteng market, subsidies on the rail networks are
likely to be necessary, in particular if any guarantees are made to possible private partners in
the construction and operation of the container terminal at Ngqura. The report notes this, but
states: “No account has been taken of subsidies incorporated in rail rates in order to induce
traffic to move to or from particular ports. Such rates distort the utilisation of resources and, if
introduced in order to promote the use of the proposed Port of Ngqura or container terminal,
would constitute a disbenefit of the project.” 19 Thus, any rail subsidy between Ngqura and the
interior is a significant cost of the project that has not been included in the analysis.
4. Existing businesses. The report states that the cost of the removal or purchase of Marine
Growers’ abalone farm and the Cerebos saltworks has not been included. These costs have not
been included in part because of a lack of information concerning the fate of these two
enterprises, but also because the authors assume that such concomitant costs have been
included in the cost estimates.
There are good reasons to believe that both businesses will be fatally impacted by the
development, with the long-term plan of the port showing it extending into the saltworks,
while the owners of the Marine Growers farm have repeatedly stated the incompatibility of
their operation with the proposed port development. An examination of the cost estimates for
the harbour do not, however, reveal the inclusion of any sum on the scale of the type of costs
that would be required to relocate or purchase these two enterprises, suggesting that these may
be additional costs.
18
MERIT, p.26, 30, 34.
19
MERIT, p. 71.
IV. Limitations in the Analysis
In addition to the limitations highlighted by the report itself, there are a number of other
issues raised by the proposals which do not appear to have received the attention that they
deserve. A fuller consideration of a number of these issues might again have led to different
conclusions, and their exclusion appears to have biased the report in favour of the proposed
Ngqura port.
1. Inland infrastructure. There appears to have been no consideration given in the report to
the adequacy of the connecting infrastructure between Ngqura and Gauteng, the destination
for the majority of the traffic envisaged for the port in the development.
The report envisages that 75% of the traffic travelling inland from the port will be carried by
rail. While spare capacity does currently exist in the rail link between Port Elizabeth and
Gauteng, the rail link from Port Elizabeth inland is only a single track line with passing loops,
which may lead to considerable, even exorbitant, costs in rail infrastructure investment as port
traffic expands. The installation of further passing loops is likely to be necessary, and the use
of a single line with passing loops will increase the time for containers to reach Gauteng, a
time delay that will presumably increase with traffic. Neither of these costs has been included
in the analysis.
The pressure on the railway line will be further exacerbated by any bulk traffic sourced from
within South Africa for the port, as intended by the construction of the bulk terminal at the
port, and the need for railway capacity for any traffic of products from the IDZ to the interior
and elsewhere in South Africa. Ultimately, it is far from clear that all of the container traffic,
let alone the container and bulk traffic, could be satisfactorily met without enormous cost to
upgrade the rail link. It is also worth noting that the purchase of far greater quantities of
rolling stock will be required for the rail link from Ngqura to Gauteng than from Richard’s
Bay due to the greater distance between Ngqura and Gauteng than Richard’s Bay and
Gauteng, a further cost of Ngqura that has not been included in the analysis.
The report also fails to examine the adequacy of the road links between Ngqura and Gauteng.
While the immediate environs of the proposed port are well served by the N2, quality road
infrastructure does not currently exist for the duration of the route to Gauteng, and the
necessary upgrading of any sections will impose further costs.
While a detailed consideration of these issues would have been beyond the scope of the
report, it is surprising that while the problems of inland infrastructure quality were considered
for both Richard’s Bay and Saldhana, no mention is made of these potentially serious
problems for Ngqura. Detailed studies are required of these connections to establish whether
they are adequate to meet the projected traffic from Ngqura, and what the costs would be of
the upgrading required.
2. Lack of an economic hinterland. The container requirements of the Eastern Cape, the
immediate hinterland of the proposed port, are small when compared to the hinterlands of
alternatives in the Western Cape or KZN. The container needs of the Eastern Cape can be met
through the existing harbour at Port Elizabeth.
The lack of an economic hinterland poses challenges for the proposed Port of Ngqura.
Container ships calling at a port will often carry containers for both the local hinterland of the
port and for the inland Gauteng market. The construction of a major container facility with
little significant economic hinterland removes this possibility. The report notes that “it is
unlikely that the need to service two ports with virtually the same hinterland would be well
received by shipping lines”, 20 but fails to make the observation that the need to service a port
with virtually no hinterland would be equally unwelcome for precisely the same reasons –
namely a consequent increase in the number of ports that would need to be serviced.
The study addresses this issue by assuming that traffic from the West for the Durban
hinterland will continue to use the existing port of Durban, while traffic for Gauteng will be
offloaded at Ngqura. Such an arrangement would either require ships to continue from
Ngqura to Durban, so obviating the liner operating savings which constitute the key
justification for Ngqura, or separate liner services from the West for Durban, an unfeasible
arrangement. 21
The alternative possibility is for traffic bound for Durban to be offloaded at Ngqura and
transported onwards by a feeder service. While such costs are touched on in the report, the
lack of clarity over the model used for the cost-benefit analysis makes it unclear as to whether
these costs have been fully included, including the time cost for containers travelling to
Durban that would result from the use of a feeder service. More clarity is required on this.
3. Delivery time saving for containers . A key argument in the report in favour of the
development of Ngqura over Richard’s Bay was the quicker delivery time of containers to and
from the West to Gauteng through Ngqura as opposed to the use of Durban for traffic to and
from the West. In the report, the time saving is estimated as the gain of eighteen hours in
shorter shipping times, set against the loss of seven hours increased overland transport time. 22
The estimate in the report of the loss of only seven hours in overland transit time from Ngqura
to Gauteng as opposed to Durban to Gauteng would appear to be highly optimistic. The time
loss for road hauled containers from Ngqura to Gauteng is in reality more likely to be 12
hours. Equally, the increased traffic on the single track rail line will result in considerable
time delays from the required use of passing loops, again incurring a greater time cost penalty
than appears to have been allowed for in the report. 23 While more details are required to
specify these costs, it appears as if they may have been significantly underestimated in the
report.
20
MERIT, p.41.
21
Bruce Lennon, Stimela Consulting, Personal communication, 13th August.
22
MERIT, p. 73.
23
Personal communication, Lawrie Bateman, Director, MSC Logistics, 13th August 2001.
4. Liner Operating Costs. The key saving from the construction of the Port of Ngqura as against the
construction of a container terminal at Richard’s Bay is due to the savings in liner operating costs that
can be achieved by turning ships from the West around at Ngqura 18 hours earlier than if such liners
had to travel on to Durban.
The report is unclear as to the method by which the figures were derived on which this key saving was
calculated. It appears that they are based on an average revenue figure for liners in the course of a
voyage from the West to South Africa. What is less clear is whether this is the correct figure that
should have been used, or whether the report should instead have used the marginal resource saving
from the decreased voyage length, which is a considerably lower figure.
In this respect, it is important to note that the report assumes that all liner operating savings will be
passed on to South African importers and exporters. Considerably more work is required on liner
operating costs and pricing structures before assumptions can be made about the extent of cost
reduction that will be experienced by South African importers and exporters as a result of this saving.
It must also be born in mind that the switch to more efficient and larger new generation liners also has
the potential to considerably reduce this figure, and hence the benefits derived from locating a
container handling facility at Ngqura.
5. Costs of land purchase. It is not clear that the full costs of land purchase at Ngqura have
been factored into the analysis. Of particular note in this respect are recent reports that a
figure of R100 million may be required for the purchase of Coega Kop, the source of rock
material for the proposed harbour. 24 The inclusion of such additional costs, when added to the
relocation costs for existing businesses, may substantially impact on the viability of the port.
6. Institutional arrangements and environmental problems. In discounting the expansion

of either Cape Town or Saldhana as options for South Africa’s container handling needs, the
report highlights the need to convince shippers to transfer cargo from the existing Port of
Durban in the light of the greater overland costs, as well as discussing the institutional and
possible constitutional problems of any integrated inter- modal service provided by shipping
companies. It is not clear why these similar problems for the proposed Port of Ngqura are not
discussed.
Remarkably, while the environmental problems attendant on expansion at Cape Town,

Saldhana, Richard’s Bay and Durban are discussed in the report, no mention is made of the
environmental issues, problems and costs attendant on the expansion of Ngqura, despite the
considerable concerns that have been raised over these issues by an extraordinarily diverse
range of local, national and international environmental organisations.
7. Rand depreciation and cost escalation. The capital costs of the construction of the Port of
Ngqura are far greater than alternative expansion options, exposing the proposed port to
greater risks from cost escalation. The engineering uncertainties involved in the construction
of a new harbour heighten the risk of cost escalation when compared to the construction of
24
Eastern Province Herald, July 27th 2001.
terminals at existing harbours. The increase in the projected cost of the proposed Port of
Ngqura from less than R1 billion in 1997, to estimates of over R2 billion for the first phase
alone in 2001, illustrates the very real dangers of such significant escalation. 25
Of particular importance, a number of elements of the construction of a new harbour, as

opposed to the construction of a container facility at an existing port, require the use of
foreign contractors. Greater required expenditure on foreign contractors, increasing the
exposure of the costs to rand depreciation, heightens the risk of further cost escalation for the
project. A comparative estimate of the sensitivity to rand depreciation would be dependent on
a breakdown of the costs of the various harbour expansion alternatives, but it might prove to
be a significant factor in the ultimate economic viability of the project.
8. Inherent risk of Ngqura. A number of the points considered above point to the inherent
risk associated with the economic benefits that would derive from the construction of the Port
of Ngqura. The construction of the new port would require greater capital costs than the
construction of a container terminal at existing harbours, and, as the report notes, the distance
of Ngqura from Gauteng will remain an enduring disadvantage to the port.
Set against these disadvantages, the advantages of Ngqura derive from the logistics of
container movement: the time savings that may be achievable by the use of Ngqura, and the
savings in liner operating costs. The report is obliged to make a series of assumptions about
these savings, and the manner in which any such savings will be passed on to and benefit the
South African economy. These savings are sensitive to changes in liner scheduling, transport
technology and pricing structures. When set against the more clear disadvantages of the
Ngqura option, it is important that the inherent uncertainty of these savings and the nature of
the assumptions on which they are based is clearly recognised. It remains far from clear that
these savings will manifest themselves, and continue to manifest themselves, in line with the
assumptions made by the report. This uncertainty must be born in mind in assessing the
conclusions of the report and the advisability of proceeding with the project.
25
McIntosh, Latilla, Carrier and Lang, Coega IDZ Cost Evaluation Report, 1997.
Response by Merit to the second MMSC submission,
dated 21 August 2001
RESPONSE TO THE NOTE ENTITLED “THE CONTAINER ECONOMICS OF
NGQURA: A NOTE ON MERIT’S MAY 2001 ECONOMIC EVALUATION OF THE
PROPOSED PORT OF NGQURA AND DEVELOPMENT OF A CONTAINER
TERMINAL” BY TOM LE QUESNE, CENTRE FOR THE STUDY OF AFRICAN
ECONOMIES, UNIVERSITY OF OXFORD, AUGUST 2001
The paragraphs in the note have been numbered consecutively under each section for the
purpose of this response.
3. Section I
Para 3: Cost-Benefit Studies usually include caveats which decision- makers should take into
account when re-acting to the conclusions. There are no grounds for avering that these
caveats have not been considered by readers of the Report or that the authors do not stand by
their conclusions, whatever the time taken for the study.
Para 4: The Report is not an academic treatise requiring peer review. It is merely one of
many documents which will assist in the decision- making process, which invariably involves
repeated reviews of those documents.
Para 5: The notion that there is a current situation which requires remedying is
presumptuous.
Para 6: South Africa’s shipping community agrees with the projections in the Report, but has
undertaken no research to establish that the provision of a new container terminal at Coega is
not the “best” solution for the impending lack of container handling capacity. Furthermore,
all the major shipping lines operating to South Africa wish to operate container terminals and
their opposition to the preference received by P&O Nedlloyd is to be expected.
4. Section II
Para 2: The port will be constructed in phases – we are not aware that the first phase has
been decided upon. As stated in the Report, facilities in the port additional to the phases taken
into account in the Cost-Benefit Study should be justified according to their marginal cost, on
which Portnet must decide.
Para 3-5: The port proposals “as they currently stand” provide for all the infrastructure which
might be required and construction phases currently envisaged – what is actually built and
when will depend upon the demand as it develops. The Report did not deal with all the
possible development – only with what is now evidently required.
Para 6: The concern about the construction of bulk and breakbulk facilities when no such
traffic seems to be forthcoming is not warranted. If and when a demand is manifested and
Portnet considers the cost justified, the bulk and breakbulk facilities will no doubt be provided
in accordance with the plans now being considered in the EIA.
Para 7: The presumption is wrong – the justification for the port does not depend on any
traffic generated by the IDZ.
Para 8: The economic viability of the port is not dependent on the viability of the IDZ, as the
Report clearly establishes.
Para 14: Although many of the containers through the port will move to and from Gauteng,
the benefits of that distribution accrue nationally – the Eastern Cape also benefits. The
financing of the port construction was not dealt with in the Cost-Benefit Study and in any
event, it seems to be premature to adjudge the supposed funding arrangements.
Section III
Para 1-3: There is no limit to everyone’s subjective opinion on what is “likely to be” and
obviously everyone’s opinion cannot be taken into account. However, the Cost-Benefit Study
would not have been undertaken (or would not have been completed) if the authors of the
Report, in their experience, did not believe that satisfactory results could be obtained within
the limitations of the study period. In the nature of Cost-Benefit Studies, further research
(which could often continue indefinitely) is terminated when the marginal gain in knowledge
is evidently not worth the cost.
Para 5-6: The comment seems to be based on a misapprehension of the present logistics of
container shipping. After offloading cargo for Cape Town, Gauteng and Port Elizabeth from
the West, it would be unprofitable to operate full-cellular ships with the remaining cargo
further up the coast.
Para 7-8: All these options are considered in the Report, based on background knowledge
and research, including investigations by Portnet over several years. It should be borne in
mind that the consultants were appointed on the grounds of their knowledge of transport and
shipping and previous research concerning ports. In any event, the EIA concerns Coega - the
possible functions of other ports are not relevant to the EIA.
Para 9: This comment is based on a presumption, evidently without foundation, that the rail
services will be subsidised. Furthermore, the basis for cost-benefit analysis and the economic
principles to be applied are apparently not understood. Subsidies constitute transfer payments
and do not reflect the opportunity costs of resources and are not taken into account in cost-
benefit studies. (The rates equalisation between Port Elizabeth and Durban does not involve
subsidization, but can be accommodated within the range of rate differentiation. It is not
feasible to explain the economic principles involved within the scope of this response).
Para 10-11: The financial and resource implications of the consequences of port for the salt
works and abalone farm are separate issues. At this stage, there is no factual information
available on the resource implications which could be taken into account.
5. Section IV
Para 1: This is a subjective and unwarranted criticism of the work put into the Report and is
apparently intended to reflect adversely on the objectivity and ethics of the authors. The
comment must be withdrawn.
Para 2-4: The existing transport infrastructure is adequa te at the outset and in any event it
will need to be upgraded within the period to 2019/20 to cope with the demand for traffic
other than that generated by the development at Coega. That is the task of Spoornet, the SA
Road Agency and the Provincial Government. No specific State intervention is required, nor
will the effect on resource utilisation of the eventual upgrading be attributable directly to the
provision of the port. However, new roads would be required specifically to carry the
container traffic generated if terminals were built at Richards Bay and Saldanha, as well as
rail infrastructure if a terminal were to be located at Saldanha Bay. Such resource
consequences would be important.
Irrespective of where the expansion of container handling capacity takes place, additional
rolling stock and road vehicles will be required as the traffic develops. There are no
potentially serious inland infrastructural problems or “enormous” costs which the
establishment of the port and container terminal at Coega will cause. As explained in the
Report, no bulk traffic could be identified at this stage and thus could not be taken into
account.
Para 8-10: These comments seem to stem from a misunderstanding of shipping and container
logistics – see the response to III 5-6. All the costs of feeder services have been taken into
account.
Para 11-12: The calculations undertaken for the purpose of the Report were based on
averages of actual rail and road transit times.
Para 14: The savings to liner operators will be reflected in operating as well as capital costs.
Para 15: As a result of intense competition in the liner industry, there is no reason to believe
that any monopolisation exists in the market, which is almost homogeneous. The use of
larger liners was taken into reckoning – the savings will then be larger.
Para 16: The quoted price of R100m seems to be speculation. In any event, the land will
retain its opportunity cost throughout the evaluation period and its use will result in no
resource loss.
Para 17: Business economics will favour the use of the Port of Ngqura, but not the Ports of
Cape Town or Saldanha Bay for container traffic to Gauteng.
Para 18: Surely the EIA concerns the environmental problems attributable to the Port?
Para 19-20: Constant costs are always used in cost-benefit studies as cost escalation
attributable to inflation or rand depreciation is assumed to affect all costs equally. It is
impossible to predict differential inflation and rand depreciation for cost components over the
evaluation period.
Para 21: The opportunity costs of construction and the containers are only elements in the
overall evaluation of the costs and benefits of the port.
Para 22: The Report describes the assumptions made and the caveats specifically to enable
decision- makers to be aware of the uncertainties. That is the function of a cost-benefit
analysis, which aids decision- making and is never intended to supplant the political discretion
which the decision- maker must exercise.
APPENDIX E
EXPLANATION OF APPENDIX E
Updated database of I&APs
Surname Title Name Capacity Organisation Sector Address1 Address2 Town

Abdol Mr Hedaayah SADTU Labour 75 Aubrey Street Gelvan Park
Adams Mr/Ms ANC - Kwazakhele CS 8655 Site and Service Kwazakhele
Addomsi Mr SANCO CS NB18 Qaqawuli
Adem Mr/Ms Zuko SACP PE CS 10080 Site and Service Kwazakhele Port Elizabeth
Adshade Mr Swartkops Trust Env 15 Ponta Del Mare De Mist Circle Bluewater Bay
Albertyn Mr LC Consulting Buss P O Box 34808 Newton Park
Allan Mr David Bird Life SA Env C/o Durban Natural Private Bag 4085 Durban
Science Museum
Allison Ms Bivian Metroplan Buss PO Box 12313 Centrahil
Annel Mr Uitenhage LG Gov PO box 31 Uitenhage
Anthony Ms Sophia HEHAWU Labour 26 Frolick Cresent Ext 22 Bethelsdorp
Apolisi Mr Zamkele ANC Addo CS P O Box 10 Addo
April Mr/Ms Welle ANC - Uitenhage CS 33 Maqoabi Cres Uitenhage
April Mr Thembile ANC CS 24136 Soweto on Sea PE
August Mr Siphokazi ANC - Kwazakhele CS 10621 Vakaza St Kwazakhele
Baatjies Mr Styles SANCO - Langa Civil CS 9 - 24th Avenue Langa Uitenhage
Society
Baba Mr/Ms Thobile CPF - Khayamnandi CS 72 Bantu Holomisa St Kayamnandi Despatch
Baily Mr Darrell Environmental Health Western District Council Gov PO Box 318 Port Elizabeth
Officer
Baiwa Mr Gerald ABET Tutor CS 40A 2nd Avenue Zwide Port Elizabeth
Bakker Mr Bosho Steel (Ballast Buss PO Box 151 Despatch
Nedham)
Balchin Mr John Depot Manager Atlas Plant Hire Buss PO Box 2017 North End Port Elizabeth
Balfour Mr Manager Zwide Community CS c/o OR Tambo Cnr of Tambo & Zwide
Active Trust Community Centre Ludwaba Street
Balley Mr Maweza Chief Environmental Western District Gov PO Box 318 Port Elizabeth
Health Officer Municipality
Bambiso Mr/Ms ANC Organiser CS A472 Ra maphosa Motherwell
Bana Mr/Ms ANC Xaba - Langa Civil CS 2 Naxazula Street Mandela V Uitenhage
Society
Bana Mr Elvis ANC - Langa Civil CS P O Box 301 Uitenhage
Society
Bana Mr/Ms Sanco - PE CS 8952 Site and Service Port Elizabeth
Banana Mr/Ms Misumzi ANC - Uitenhage CS 26 Menta St Uitenhage
Bangani Mr/Ms ANC Coega CS P O Box 10 Coega
Banzi Mr Lindile ANC - Khayamnandi CS 126 Chief A Luthuli St Khayamnandi Despatch
Banzi Mr ANC 101 Philani Ntsiko Rd Kwanobuhle
Barnes Ms Samantha PE Regional Chamber of Buss PO Box 2221 North End Port Elizabeth
Commerce
Barnes Mr VRN Steel Buss P O Box 2046 North End
Barwood Mr Lafarge SA Buss Moregrove Quarry Gravoel Street Cotswold, PE
Basson Mr Uitenhage TLC Gov PO Box 45 Uitenhage
Bavuma Mr Mzamo ANC - New Brighton CS Blk 9D4 White Location New Brighton
Bavuma Mr ANC - New Brighton CS Block 9D4 White New Brighton
Location
Beer Mr/Ms Department of Welfare Gov Private Bag X3906 Port Elizabeth
Befile Ms Margaret SANCO PE CS P O Box 50895 Joe Slovo Port Elizabeth
Beja Mr Siphino MCDF 135 Ndumba St NU7 Motherwell
Bele Mr/Ms Sanco - PE CS 10586 Maguga Street Port Elizabeth
Belu Mr Sekiwe ANC - Kwazakhele CS 2946 Myati St Kwazakhele
Benekane Mr/Ms SANCO PE CS P O Box 50801 Joe Slovo Port Elizabeth
Bester Mr/Ms Steeledale Buss P O Box 14124 Sidwell
Biljon Mr Keith Classic Exposure Buss PO Box 2195 Port Elizabeth
Bisa Mr/Ms Phindile SANCO - Langa Civil CS 17 Daku st Kwa Langa Location Uitenhage
Society
Bisa Mr/Ms Zolile Envirobooster P O Box 620 Addo
Bisu Mr/Ms ANC Despatch CS 93 Khozi Street Despatch
Biyana Mr PEM Gov 16th Floor Brister House Govan Mbeki Rd Port Elizabeth
Biyana Cllr PE City Council Polit PO Box 116 Port Elizabeth
Blaauw Mr Mandla ANCYL - Despatch CS 95 Bantu Holomisa Kayamnandi Despatch
Street
Blaauw Mr/Ms ANC Despatch CS 93 Khozi Street Despatch
Blaauw Mr/Ms ANC - Despatch CS 6929 Bantu Holomisa St Kayamnandi Despatch
Blaauw Mr/Ms Nombuyiselo ANC - Uitenhage CS 27 Lawrence Vingi St Kwanobuhle Uitenhage
Blaauw Mr Godfrey ANC - Uitenhage CS P O Box 4330 Kwanobuhle Uitenhage
Blaauw Ms Cynthia ANC 141 Lodewyk St Chatty
Blacklaws Mr Alex Bluewater Bay CS 79 Maureen Circle Bluewater Bay Port Elizabeth
Ratepayers
Bobo Mr/Ms Mbuyiseli Sanco PE CS 59 Thoba Street New Brighton Port Elizabeth
Bok Mr Anton Anton Bok & Associates Prof 5 Young Lane Mill Park Port Elizabeth
cc.
Boltina Mr John ANC - Despatch CS 19 1st Ave Kayamnandi Despatch
Bolting Mr Michael ANC - Khayamnandi CS 790 Sibra Mkonto St Khayamnandi Despatch
Bomvana Mr Uitenhage TLC Gov PO Box 34 Uitenhage
Bona Mr Jackson Ward Councillor P O Box 225 Addo
Bonga Mr/Ms Zola ANC - New Brighton CS 4 Teya St New Brighton
Bongani Mr Wesley SANCO- Khayamnandi CS 206 Solomon Mahlangu Khayamnandi Despatch
St
Bontsi Mr/Ms SATAWU Labour 23 Lower Mount Road Mount Croix Port Elizabeth
Booi Mr/Ms ANC - Khayamnandi CS 213 Chief A Luthuli St Khayamnandi Despatch
Booi Mr PSI 402 NU 8 Endlovini Motherwell
Bosch Ms Hester SACTWU Labour 36 Foxglove Street EXT 13 Gelvandale
Boshoff Dr Andre Terrestrial Ecology Prof UPE PO Box 1600 Port Elizabeth
Research Unit UPE
Boswell Mr Jeremy Director Bohlweki Environmental Env PO Box 11784 Vorna Valley Midrand
Boweka Mr Mahlahla Ward 42 8 Ncede St Kwanobuhle
Boyce Mr/Ms Pumla ANC - Langa Civil CS 61A Tambo Crescent Langa Uitenhage
Society
Bozo Mr/Ms SANCO PE CS 283 NBRR New Brighton
Bozo Mr SANCO 1943 S/S Port Elizabeth
Breakfast Mr Yoliswa ANC CS 51326 Spingo St Veeplaas
Breakfast Mr Douglas FAWU Labour PO Box 1531 Port Elizabeth
Bredell Mr Claude Cadbuild System Buss 53 Sherlock Street Central Port Elizabeth
Brett Mr Patrick BirdLife Eastern Cape Env PO Box 27454 Newton Park
Brown Mr David Project Manager Haul Portnet Buss PO Box 162 Port Elizabeth 6000
Road
Bucwa Mr Les Black Management Buss PO Box 34776 Newton Park
Forum
Budaza Mr/Ms Thozama SANCO Consultation CS 27 Vuka St Kwazakele Port Elizabeth
Bulbring Mr Wally PE Ratepayers Rat 40 Dan Pienaar Street Glendeningvale Port Elizabeth
Association (PERRA)
Bungane Mr SACP PE CS A18 Joe Slovo P O Box 51267 Port Elizabeth
Bunu Mr/Ms Lindile ANC - Khayamnandi CS 19 Pikoko St Khayamnandi Despatch
Burden EAS Buss P O Box 13867 Humewood
Buthelezi Mr ANC - Kwazakhele CS 1942 Zokwano St Kwazakhele
Button Mr/Ms CSIR Prof Private Bag x11227 Nelspruit
Cacela Mr Richmond ANC - Kwazakhele CS 6304 Tshanke St Kwazakhele
Cacela Mr Patrick SANCO CS 9754 Site and Service Kwazakhele
Calata Mr/Ms Mkuseli KS Centre Khayamanadi CS 8398 Chief A Luthuli St Khayamnandi Despatch
Calata Mr Patrick SACP Consultation CS 20 Mnbomphinz St Uitenhage
Calata Mr Bruce Sanco Despatch CS 108 Bantu Holomisa Khayamnandi
Calvert Mr/Ms SACP PE CS 202 Emerald Court Schauderville Port Elizabeth
Captain Mr ECBA 18 Hlosi St NU1 Motherwell
Carous Mr Ward Councillor P O Box 305 Addo
Carr Mr John Director Dept. Mineral & Energy Gov Private Bag X6076 Port Elizabeth
Affairs
Castley Dr Guy Animal Ecologist, SA National Parks Gov PO box 20419 Humewood Port Elizabeth
Scientific Services
Cawe Mr Douglas NUMSA Labour 18 Petele Street Zwide Port Elizabeth
Cekisani Mr Moki Ubuntu Env PO Box 5612 Walmer
Chabula Dr Director, Health Western District Council Gov PO Box 318 Port Elizabeth
Services
Chait Mr Sidney Portnet Buss PO Box 162 Port Elizabeth
Chalmers Ms Judy Wildlife Society Of SA Env 22 Cuyler Cres Central Port Elizabeth
Chandler Mr Len Manager National Ingrediant Buss PO Box 446 Port Elizabeth
Suppliers
Ciwadela Mr/Ms Mewabantu SAMWU - CS 6600 Chief A Luthuli St Khayamnandi Despatch
Khayamnandi
Claasen Ms Dorothy Helenvale Resource CS Baatjie Street Helenvale Port Elizabeth
Centre
Claassen Mr Deon PE F&S Env P O Box 579 Port Elizabeth
Classen Mr/Ms Fuleka ANC - Kwazakhele CS 11994 Matomela St Kwazakhele
Clay Mr/Ms SACP PE ca 6 Zono Street Zwide
Clingham Mr/Ms PEM Gov Fish Water Flats P O Box 7 Port Elizabeth
Cockroft Mr Vic Centre for Dolphin Env Bayworld PO Box 13147 Humewood
Studies
Cohen Dr Mike CEN IEM Unit Env 36 River Road Walmer Port Elizabeth
Conrad Mr ANC 21313 oesak St Kwadwesi
Conway Mr/Ms SACP PE CS 7 Bass close Booysens Park Port Elizabeth
Cook Mr Bruce Manager Outspan Buss PO Box 7733 Hennopsmeer
Cooper Mr Director Conservation Wildlife & Environment Env 100 Brand Street Durban
Society
Couldridge Mr Sam Dept. of Water Affairs Gov Private Bag X6041 Port Elizabeth
Coulridge Ms Joan Swartkops Trust Env PO Box 75 Swartkops Port Elizabeth
Cqona Mr Sindile SACP PE CS 16 Nginza Street New Brighton Port Elizabeth
Crews Mr & David LO Hougham Park PO Box 612073 Bluewater Bay
Mrs
Cronje Mr/ms Uitenhage TLC Gov PO Box 613 Uitenhage
Crooijmans Ms Hedwig Urban Services Group CS PO Box 21575 Port Elizabeth
Cuba Mr Christopher ANC 117 Nxarana St Kwanobuhle
Da Costa Mr Alfred CEO PE Regional Chamber of Buss PO Box 2221 North End Port Elizabeth
Commerce
Da Costa Mr VRN Steel Buss P O Box 2046 North End
Dama Mr John SANCO Consultation CS s36 303 Soweto on Sea Port Elizabeth
Dambuza Mr SANCO 3189 Ext 23 KwaNoxolo
Daniels Mr Harry SANCO Consultation CS 34 3rd Ave Windvogel PE
Dano Mr Mabhuti ANC PE Region Polit 3rd Floor, Standard 344 Govan Mbeki Ave North End
House
Dastile Mr Uitenhage TLC Gov PO Box 45 Uitenhage
Davids Mrs Arcadia School Indiv PO Box 17027 Arcadia Port Elizabeth
Davids Ms Mandisa ANC - Langa Civil CS 3 Ngeni Street Langa Uitenhage
Society
Davids Mr/Ms ANC - Khayamnandi CS 6889 Bantu Holomisa St Kayamnandi Despatch
Davies Ms Denise Regional Manager Wildlife & Environment Env 2B Lawrence Street Central Port Elizabeth
Society of SA, PE
Davies Mr AECI Buss 10 Tin Pot Creek 8th Ave Walmer
Daweti Mr Victor ANC - Khayamnandi CS 7686 John Dube St Khayamnandi Despatch
Dayile Mr/Ms ANC Zwide CS 10 Mtembu Street Zwide
Dayile Mr/Ms Mzukusi PRDP P O Box 262 Addo
Dayimani Mr Mfusi ANC - Khayamnandi CS 180 Solomon Mahlangu Khayamnandi Despatch
St
de Beer Mr Tuli SA Rail Commuter Gov Private Bag X2 Sunninghill
Corporation
De Bruin Mr Cecil SANCO CS 7 Hoek St Daleview Despatch
De Keyser Mr Hougham Park Oysters Buss 17 Claude Crescent Bluewater Bay Port Elizabeth
De Klerk Mr Abra Transport Division PEM & EP Shore Gov PO Box 88 Port Elizabeth
Anglers Association
De Kock Mr Glenton Tourism Port Elizabeth Tou PO Box 357 Port Elizabeth
De La Harpe Mr John FNB Buss 292 Cape Road Newton Park Port Elizabeth
De Vos Mr Zama ANCYL CS 9642 Buyambo ST Kwazakhel
Dechant Mr Tony Wildlife & Environment Env 2B Lawrence Street Central Port Elizabeth
Society SA
Des-Fountain Mr Rod PE Business Unit Lafarge SA (PTY) Ltd Buss P O Box 7170 Newton Park Port Elizabeth
Manager
Desi Mr Fikile PETLC Polit 60 Mpunzi Street Motherwell Port Elizabeth
Didiza Mr/Ms Zola ANC - New Brighton CS 86 Jabasu St New Brighton
Didiza Mr ANC CS a128 Weslyan ST Walmer
Dingele Mr Mlindi Ithuba Lethu 42 Boto St NU 1 Motherwell
Ditala Mr Mpumelelo POPCRU Labour Private Bag X6055 Port Elizabeth
Dlabathi Mr/Ms Mntukanti SACP PE CS 8 Goniwe Street Masangwana Village New Brighton
Dladla Ms Nozimasile ANCWL 16 Pepheta St Zwide
Dlala Mr/Ms Kunase SACP Consultation CS 148 Dubula St New Brighton Port Elizabteh
Dlamini Mr/Ms Nokuzola Sanco PE CS 9057 Site and Service Port Elizabeth
Dloto Mr/Ms Mcebisi ANC - New Brighton CS 86 Moduka St New Brighton
Dobela Mr Sandile ANC - Kwazakhele CS 9329 Matomela St Site and Service Kwazakhele
Dold Mr Tony Selmar Schonland Prof Albany Museum Grahamstown
Herbarium
Dondashe Mr/Ms Zolani ANC Motherwell CS 76 Busila Street NU4A Motherwell
Dondashe Mr/Ms Buyiswa ANCWL - Despatch cs 6889 Bantu Holomisa St Kayamnandi Despatch
Doubell Mr Marius Indiv P O Box 334 Swartkops Port Elizabeth
Du Plessis Mr Brad Cape Fastner Supplies Buss P O Box 2114 North End
du Plessis Mr Action Bolt Buss 8A Sutton Road Sidwell Port Elizabeth
Du Plessis Mr ANC Moodleys Ground Kleinskool
Du Preez Mr Indiv PO Box 10368 George
du Preez Mr IP du Preez Eng Cont/ Buss P O Box 123 Swartkops
Ibhayi Eng Cont
du Toit Mr Shaun Steeldale Buss P O Box 14124 Sidwell
Du Toit Mr Cape Gate Buss P O Box 31136 Braamfontein
Dubb Mr Eric John Price Estates Buss 5 The Grange Church Road Walmer
Duda Mr Monde ANCYL 6 Sidulu St Kwadwesi
Dukwe Mr Mazotsho SACP Consultation CS 15 Matroos St Kwamagxaki Port Elizabeth
Dulwana Mr/Ms Ewemasenze - TLC CS A40 Witbooi Walmer Location Port Elizabeth
office
Dunjana Mr/Ms Sanco - PE CS 61 Aggrey Rd New Brighton Port Elizabeth
Dunjwa Ms Virginia Portnet Buss P O Box 181 Richards Bay
Dunjwa Mr/Ms Lindelwa SACP PE CS 47 Besman Cres Kwamagxaki
Duvalele Mr ANC CS 39 Mcelu St NU8 Motherwell
Dyakala Mr/Ms Nomakhaya Enviro Boosters - Addo CS P O Box116 Addo
Meeting
Dyanti Ms Agnes SANCO CS 75 Kali St New Brighton
Dyantyi Mr Simphiwe ANC - Kwazakhele CS 196 Vuku Rd Site and Service Kwazakhele
Dzeya Mr/MS SANCO CS 20 Hlavula ST New Brighton
Els Mr Leon Deputy Director Dept. Economic Affairs, Gov Private Bag X5001 Greenacres
Environment & Tourism
Elson Mr Andile SACP PE CS 764 Site and Service Nobatana St Port Elizabeth
Eric Mr Dingaan ANC - Khayamnandi CS 6915 3rd Ave Khayamnandi Despatch
Exley Mr John St Croix Development LO Sonop Farm, Coega PO Box 4016 Port Elizabeth
Co. Mouth
Faas Mr Nombulelo ANC - Kwazakhele CS 10469 Tsotsobe St Kwazakhele
Faku Mayor Nceba Mayor PE City Council Polit PO Box 116 Port Elizabeth
Faku Ms Joyce ANC - New Brighton CS 5 Limba St New Brighton
Fedana Mr Melumzi SAMWU Labour 9 Mgealagala Street Kwadwesi Port Elizabeth
Felix Mr Clive Urban Services Group CS PO Box 21575 Port Elizabeth
Feni Mr/Ms ANC Coega CS PO Box 22 Coega
Feni Mr/Ms Fezeka ANC - Zwide CS 23156 Soweto On Sea Port Elizabeth
Feni Mr ANC CS P O Box 2308 Coega
Feni Mr Makhi ANCYL 172 Koyana St Zwide
Feren Mr Uitenhage TLC Gov PO Box 31 Uitenhage
Ferreira Mr Enduleni Estates Buss PO Box 36 Patensie
Ferreira Mr Alwyn A F Farms LO P O Box 3763 North End
Ferreira Mr LO P O Box 612061 Bluewater Bay
Ferreira Mr Lambson's Hire Buss P O box 2451 North End
Fesi Mr/Ms Sanco - PE CS No 1Bekwa Street New Brighton Port Elizabeth
Fezi Ms Nomhle ANC 9 Mhlalokotshane St Kwadwesi
Fihlani Mr/Ms Sebenzile ANCYL - Despatch CS 7005 Bantu Holomisa St Kayamnandi Despatch
Fillis Mr/Ms SACP PE CS 44 Da Silva St Chetty Port Elizabeth
Fillis Mr Mantoor NUMSA Labour 44 Da Silva Street Chatty Port Elizabeth
Finn Ms Joan Swartkops Trust Env 47 Riverside Drive Amsterdamhoek Port Elizabeth
Finnemore Ms UPE Prof P O Box 1600 Port Elizabeth
Fischer Mr Gavin Bopite Engineering Buss PO Box 22727 Port Elizabeth
Geologists cc.
Fitchet Mr SA IMATU Labour PO Box 31 Uitenhage
Fourie Mr Wynand Director National Dept. of Gov 315 Pretorious Street Fedsure Forum Pretoria
Environmental Affairs Building
France Mr/Ms Tamsanga SACP PE CS 3750 Mcebisi Xundunu Kwadwesi Zwide
Extension
Frans Mr/Ms Galekile Ethiopia Orthodox CS 7015 Chief A Luthuli St Kayamnandi Despatch
Church - Khayamnandi
Friel Mr Sheldon Buss 37 Somerson Village Summerstrand Port Elizabeth
Fumba Mr/Ms Odwa SACP Consultation CS 52 Avenue C New Brighton Uitenhage
Fundam Mr HPBEC SANCO 46 Ngqokweni NU9 Motherwell
Funde Mr Mzwandile ANC Zwide CS 8025 Makhubalo Street Kwazakhele
Funde Mr/Ms Nonkululeko SACP Consultation CS Flat 23 Tshangane New Brighton
Funde Mr/Ms Nomvuzo ANC Block 42 C26 Red Location New Brighton
Gaans Mr George ANC - Khayamnandi CS 8287 Nkonjane St Kayamnandi Despatch
Gamade Mr Elliot ANC - Uitenhage CS 8 Fu mbhata St Uitenhage
Gamble Mr Barry SANCO CS PO Box 5452 Walmer
Gamtolo Mr/Ms ANC - Langa Civil Society 164 Joe Slovo Uitenhage
Ganga Ms Patricia ANC Motherwell CS 3 Nkumbi NU11 Motherwell
Gangla Mr/Ms ANC - New Brighton 91 Masangwanaville New Brighton
Garner Mr Kevin Lafarge SA Buss P O Box 7170 Newton Park
Gaska Mr ANCYL 10 Nama St Kwadwesi
Gaughlan Mr John RMB Buss P O Box 837 Port Elizabeth
Gayi Mr/Ms Thozama ANC - Kwazakhele CS 11281 Khuzwayo St Kwazakhele
Gazi Mr Moses ANC 20 Nova Balfour Missionvale
Heights
Gcezengana Mr Vuyani ANC 10998 Site and Service Kwazakhele
Gedze Mr/Ms Nomalungisa ANC - Kwazakhele CS 6758 Ngwendu St Kwazakhele
General Mr Secretary PE Civil Society Forum CS PO Box 116 Port Elizabeth
Genu Mr September ANC - Uitenhage CS 34 Mbotya St Uitenhage
George Mr Jan East Cape Tourism Tou PO Box 1611 Port Elizabeth
Board
Gerhard Mr Marx Albany Museum Prof Albany Museum Grahamstown
Geswindt Mr SANCO - Langa Civil CS 54 Stephen Street Blikkiesdorp
Society
Geza Mr/Ms Thandolinilethu ANC Despatch CS 72 Khozi Street Despatch
Geza Mr Phillip SANCO - Khayamnandi CS 6897 Bantu Holomisa St Khayamnandi Despatch
Gibbs Mr Winton General Manager Sundays River Citrust Agri Private Bag 24 Addo
Co-operative
Gilbert Mr Peter Bureau of Industrial Prof Private Bag X6011 Port Elizabeth
Liaison
Girdlestone Ms Esme Swartkops Trust CS PO Box 32 Redhouse
Godongwana Mec Enoch Minister Economic Eastern Cape Province Gov Private Bag X0054 Bisho
Affairs, Environment &
Tourism
Goedhart Mr Marc Council for Geoscience Prof PO Box 1774 Port Elizabeth
Goehart Mr Council for Geoscience Prof PO Box 1774 Port Elizabeth
Gojela Mr ECBA 28 Mlonji St Motherwell NU8
Goliath Mr Charles SANCO P O Box 69 Despatch
Gomomo Mr/Ms Monwabisi ANC - Kwazakhele CS 9681 Site and Service Port Elizabeth
Gomomo Ms Vera 14 Modiko St Langa
Gonana Mr/Ms Ncamisa ANC - Zwide CS 18 Mboya Street Zwide Port Elizabeth
Goss Ms Nita SACTWU Labour 147 Renecke Street Ext 12 Gelvandale
Gotyana Mr/Ms ANC Zwide CS 9 Ngwatyu Street Zwide
Gotyana Mr/Ms Nomonde SANCO CS 20 Cengimbo Lane New Brighton
Gotyi Mr Roy The Secretary SANCO PE Region CS PO Box 14558 Sidwell Port Elizabeth
Govender Mr Portnet Buss PO Box 162 Port Elizabeth
Govoni Mr Town Engineer Uitenhage TLC Gov PO Box 45 Uitenhage
Gqabi Mr/Ms ANC - Langa Civil CS 269 Joe Slovo Uitenhage
Society
Gqamana Mr/Mr Sanco PE CS 82 Ngwevala Street Port Elizabeth
Gqamand Mr Sam SANCO Consultation CS 82 Gwevana St Motherwell Port Elizabeth
Gqibana Mr Michael w b forum 47 Booi St Zwide
Gqirana Mr/Ms Xolani AZAPO - Despatch CS 29 Chief A Luthuli St Khayamnandi Despatch
Gqobisa Mr/Ms Ntombomzi ANC - Zwide CS 36 Zondeki Street Zwide II Port Elizabeth
Green Mr Civic & Ratepayers PE Civil Society Forum CS 21 Coral Road Booysen Park Port Elizabeth
Sector
Griesel Mr/Ms Uitenhage TLC Gov PO box 31 Uitenhage
Grootboom Mr/Ms SACP CS 31 Dyeshama Street Zwide
Grootboom Mr/Ms Monde SANCO PE CS 3648 Site & Service PE
Grundlingh Mr Swartkops River Rides Buss P O Box 265 Swartkops
Gulwa Mr ANC 124 Ngqokweni St NU9 Motherwell
Gwadela Mr/Ms Phumelelo ANC - Khayamnandi CS 219 Joe Modise St Kayamnandi Despatch
Gwaqu Mr Mabhuti Tomie Building Constr 42 Dowse Cres Kwanobuhle
Gweka Mr Howard ANC - Kwazakhele CS KRRS20 Kulati St Kwazakhele
Gwija Mr/Ms ANC - Khayamnandi CS 6983 Bantu Holomisa St Khayamnandi Despatch
Gxalela Mr/Ms Vuyani ANC - Zwide CS 5 Mlokovu St Zwide Port Elizabeth
Gxasheka Mr Co ordinator 3 Kaumba St NU 2 Motherwell
Gxilishe Mr Gongani CEO Western District Council Gov PO Box 318 Port Elizabeth
Gxulwana Mr Lulama SECUFU 78 Kama St Kwanobuhle
Hahn Mr SA Rail Commuter Gov Private Bag X2 Sunninghill
Services
Handile Mr Nicholas ANC 25788 NU29 Motherwell
Hans Mr Ben ANC - New Brighton CS Block NI4 New Brighton
Harrington Mr Geoff Indiv 55 Alcock Road Port Elizabeth
Headbush Mr/Ms ECACOC Buss 3rd Floor Ortacs 16 Darling St Port Elizabeth
Building
Heather-Clark Mr Stuart CSIR Environmentek Env PO Box 320 Stellenbosch
Heimann Mr Jackie Factory Perseverence Buss P O Box 4060 Korsten
Hendricks Mr Lungisa ANC 7 Mahaluba St Kwanobuhle
Hendriks Ms Maggie Helenvale ANC CS 95a Vioson Rd Gelvandale Port Elizabeth
Hermans Mr/Ms SACP PE CS 483 Elias Ground Kleinskool Port Elizabeth
Hewitt Mr Indiv Private Bag 26 Addo
Hill Mr Acting Assistant Fire & Emergency Gov PO Box 579 Port Elizabeth
Director Services
Hilton-Taylor Mr Craig National Botanical Prof Private Bag X7 Kirstenbosch Claremont
Institute
Hliso Ms Gladys SANCO CS 24 Mhlaba St New Brighton
Hoffman Ms Sue Swartkops Trust/Aloes Env 40 Yale Road Bluewater Bay Port Elizabeth
Environmental Cmt
Hoffman Mr Bernie Sundays River/Colchester Indiv PO box 2350 Port Elizabeth
Hoggons Ms Judy Northern Areas CS PO Box 17228 Port Elizabeth
Development Trust
Holewyn Mr Indiv 151 Valley Road Theesecombe Port Elizabeth
Hopo Mr Simo Disaster Management Western District Council Gov PO Box 318 Port Elizabeth
Horsburgh Mr Indiv 13 Harbour Heights Castle Hill Port Elizabeth
Hosking Mr Stephen Department of Prof PO Box 1600 Port Elizabeth
Economics UPE
Hote Cllr Stanley Uitenhage Cllr ANC Uitenhage Branch Polit PO Box 45 Uitenhage
Howell Mr Mike FNB Buss 293 Cape Rd Port Elizabeth
Hoyi Mr Melisizwe ANC 7 Xhama St Motherwell
Hoza Mr/Ms Nosikumbuzo ANC - New Brighton CS 113 Silvertown Ntintili New Brighton
St
Huhu Mr Simphiwe PAC PO Box 188 Addo
Human Mr ANC 4 Hertsog St Despatch
Hungana Mr ANC 21593 Boesak St Zinyoka Govan Mbeki
Hunt Ms Valerie Wildlife & Environment Env 2B Lawrence Street Central Port Elizabeth
Society
Husselman Mr Sundays River Citrus Agri Private Bag 24 Addo
Co-operative
Illenberger Mr Werner Co-Chair Eastern Cape Clean Air Env 55 Emerald Street Mount Pleasant Port Elizabeth
Initiative
Ingram Mr/Ms Dept of Housing and Gov Private Bag X6005 Port Elizabeth
Local Gov.
Issacs Mr Mervin Helenvale ANC CS 50a Pienaar St Gelvandale Port Elizabeth
Jaca Mr Nompuluko NUMSA Labour Aloes Industrial Park Main Road Markman
Township
Jack Mr Mlungisi V3 Consulting Engineers Buss PO Box 7587 Newton Park Port Elizabeth
Jack Mr/Ms Lulamile ANC - Khayamnandi CS 32 Khozi St Khayamnandi Despatch
Jack Ms Noncinci ANC - New Brighton CS Block 8E2 White New Brighton
Location
Jack Mr Sport Forum CS P O Box 1 Fountain Ave
Jackson Mr Brian East Cape Tourism Tou PO box 1611 Port Elizabeth
Board
Jackson Mr Sandile Ward 38 19 Madaki St Uitenhage
Jacobs Mr Indiv 59 Quude Street NU1 Motherwell Port Elizabeth
Jacobs Mr/Ms ANC - Langa Civil CS 35 Madaki Street Langa Uitenhage
Society
Jacobs Mr/Ms Vuyokazi ANCYL - Despatch CS 77 Fort Calata St Kayamnandi Despatch
Jacobsen Mr Richard Sani Tech Buss P O Box 883 Amanzimtoti
Jafta Mr/Ms Lindiwe ANCYL - Uitenhage CS 83 9th Ave Kwanobuhle Uitenhage
Jama Mr Bukelwa Ward 38 33 Dlala St Uitenhage
Jamda Mr Chris SACP PE CS 3191 Moyakhe Street Kwazakhele Port Elizabeth
Jamjam Mr Lulama SANCO Consultation CS 120 Mlimane St NU6 Motherwell Port Elizabeth
Jam-Jam Mr Department of Welfare Gov Private Bag X 3906 Port Elizabeth
Jantjies Cllr Henry Councillor Addo/Sundays River Polit 34 Kirkwood Road Enon
Jantjies Mr/ms SANO Uitenhage CS 10 Fingwana Street Kwanobuhle Uitenhage
Jantjies Mr Thomas SANCO 22135 Ural Street Missionvale
January Mr/Ms Monwabisi ANC - Despatch CS 36 Kozi St Kayamnandi Despatch
Jawila Mr/Ms ANC - Kwazakhele CS 1793 Zokwana St Kwazakhele
Jeffrey Mr Chris Wildlife & Environment Env 2B Lawrence Street Central Port Elizabeth
Society
Jelwane Mr/Ms Nelson ANC - Despatch CS 6985 Chief A Luthuli Kayamnandi Despatch
Jerry Mr/Ms SACP PE CS P O Box 53208 Walmer Port Elizabeth
Jim Mr SMWU Labour PO Box 31 Uitenhage
Jinikwe Mr/Ms SACP Consultation CS 12 Orleyn St Kwamagxaki Port Elizabeth
Jobela Mr Lulama ANC 152 Mgwanqa St Motherwell
Johnson Mr Luvuyo Indiv 202 Gqamlana Street New Brighton Port Elizabeth
Johnson Mr Anthony SANCO Consultation 10 Second Ave Windvogel Port Elizabeth
Johnson Mr ANC 21320 Boesak St Kwadwesi
Jokani Mr Washington ANC - Kwazakhele CS 1947 Zokwana Area Kwazakhele
Jokazi Mr Okuselwandle Fishing CS P O Box 141 New Brighton
Jolingana Mr Ithuba 37 Mbaza St NU10 Motherwell
Jonga Mr/Ms Thembekile Sanco PE CS 3626 Tonjoni Street Kwazakhele Port Elizabeth
Joni Mrs AWL - Addo CS P O Box 802 Addo
Joni Mr/Ms ANC - Langa Civil CS 285 Joe Slovo Street Langa Uitenhage
Society
Jordaan Cllr Julie Councillor Addo Polit PO Box 53 Coega
Jordaan Mr Special Advisor to the DTI Gov Private Bag X84 Pretoria 0001
Minister
Jorgenson Ms Noleen PPC Buss PO Box 2016 North End Port Elizabeth
Joxo Mr/Ms Nomasango ANC - Kwazakhele CS 273 Mavuso Rd Site and Service Kwazakhele
Jozela Mr/Ms Busisiwe ANC - Kwazakhele CS 5769 Site and Service Kwazakhele
Juku Mr/Ms Thando PECSF CS S37 165 Soweto On Sea Port Elizabeth
July Mr/Ms Sphiwo ANC - Despatch CS 6673 Rogers Mwanda St Kayamnandi Despatch
July Mr Andile NUMSA Labour 27 Teya Street New Brighton Port Elizabeth
Jusiwa Mr/Ms Lindiwe SANCO Consultation CS 40 Connacher St New Brighton Port Elizabeth
Jwambi Ms Thembelina ANC 55 Mcikilishe ST Kwadwesi
Kakana Mr/Ms Sanco - PE CS 122 Bira Street NU4A Motherwell
Kalvin Mr/Ms Nkotili SACP PE CS 368 Vuku Rd Port Elizabeth
KamKam Mr/Mr Sanco - PE CS 36 Mtati Street NU7 Port Elizabeth
Kamteni Mr/Ms Malakhiwe Sanco Uitenhage CS 20 Mnamata St Kwanobuhle
Kantor Mr Peter Labour, Environmental Kantor Legal Services cc Env 19 Milldene Avenue Rondebosch
& Constitutional Law
Kanzi Mr/Ms Noyenayena ANC - Kwazakhele CS 10925 Site and Service Kwazakhele
Kate Mr Temba ANC - Kwazakhele CS 10479 Maguga St Kwazakhele
Kayser Ms Priscilla Helenvale ANC CS 242 Kobus Rd Gelvandale Port Elizabeth
Kepe Ms Joyce ANC - New Brighton CS 210 Adcock Homes New Brighton
Kerley Dr Graham Director Terrestrial Ecology Prof UPE PO Box 1600 Por;t Elizabeth
Research Unit
Ketse Mr Thembisa ANCYL 1 Jibiliza Kwanobuhle
Keulder Mr Rhodes University Prof 2 Hobson Street Grahamstown
Khame Mr/Ms Noluthando ANC - New Brighton CS Block 9 EZ White New Brighton
Location
Khohlakala Mr/Ms Mongezi ANC - Despatch CS 12 Hobe St Kayamnandi Despatch
Kilian Mr Area Co-ordinator Blue Circle/La Farge PO Box 7170 Newton Park
Kinana Mr Mzwandile SACP 1 Mboya St Zwide
Klaas Mr/Ms Mandisa SANCO PE CS 3650 Kwazakhele
Klaas Mr SANCO CS 27 Chief A Luthuli Despatch
Klaas Mr/Ms ANC CS 19 Mvusi St Zwide Port Elizabeth
Klaas Ms Linda SANCO CS 27 Chief Albert Luthuli Khayamnandi Port Elizabeth
Klaas Mrs ANCWL 10 Kasibe ST Kwanobuhle
Klaas Mr Mxolisi SANCO 4 Nghona St Zwide
Klages Mr Norbert Marine Mammal Env Bayworld PO Box 13147 Humewood
Institute
Klassen Ms Monica ANC - Kwazakhele CS 11994 Matomela St Site and Service Kwazakhele
Knight Dr Manager Scietific Services Gov Conservation PO Box 20419 Humewood
(Northern Parks) Development UPE
Koba Mr ANC CS 34 Mcelu ST NU8 Motherwell
Kobese Mr Patrick SANCO CS 2 Ntsikelelo Ketani Chris Hani Kwanobuhle
Kolesi Mr/Ms ANC Coega CS P O Box 22 Coega
Koli Mr Bishop SANCO 1 Mara Cres Kwanobuhle
Kolisi Mr Lungile SACP Consultation CS Flat11 Tshangane St New Brighton
Koliti Mr/Ms ANC CS 18 Nondlwana NU8 Motherwell
Koliti Mr/Ms Lebisile ANC - Zwide CS 48 Mwani Street Zwide Port Elizabeth
Koliti Mr ANC CS 18 Nondlwana ST NU8 Motherwell
Kom Mr/Ms Thembisa ANC - Zwide CS 63 Maku Street Zwide Port Elizabeth
Kom Mr/Ms Sanco PE CS 131 Ngwanana St Motherwell Port Elizabeth
Kompeni Mr SANCO 30605 Tjoksville Motherwell
Kona Ms Mandisa ANC Despatch CS 794 Sibra Mkhonto Street Despatch
Kondile Mr/Ms Civil Society Forum CS 3989 Sali St Kwazakhele
Kondile Mr Temba SANCO PE CS 10637 Vakaza Street Site & Service Kwazakhele
Kondile Mr Mmeli Ward 38 7 Mahani Cres Uitenhage
Kondlo Mr Shakes c/o Office of the Gov Private Bag X0047 Bisho
Premier, Eastern Cape
Province
Koom Mr/Ms Nomasomi ANC - New Brighton CS Block 36 B2 New Brighton
Kopo Mr Uitenhage TLC Gov PO Bo x 45 Uitenhage
Kosana Mr Vukile NEHAWU Labour 40 Gqwaru Street NU5 Motherwell
Kosi Mr/Ms Sanco PE CS 10353 Totsobe Street Site and Service Port Elizabeth
Kota Mr/Ms Lindile Sanco PE CS 11848 Site and Service Port Elizabeth
Kozi Ms Esther Sanco PE CS 18 Mpofi Street Motherwell Port Elizabeth
Krabie Mr Mlamu SANCO 10644 S/S Kwazakhele
Krweda Mr/Ms ANC - New Brighton CS 50 Mandela St Masangwana Village New Brighton
Kuba Mr/Ms Melikhaya ANC - Despatch CS 173 Soloman Mahlangu Khayamnandi Despatch
St
Kula Mr/Ms ANC - Khayamnandi CS 136 3rd Ave Kayamnandi Despatch
Kula Mr/Ms Lindelwa ANC P O Box 62 Addo
Kula Ms ANCWL 22 De Bruin St Kwanobuhle
Kulani Mr/Ms Ntsikelelo ANC - Khayamnandi CS 6857 Fort Calata St Kayamnandi Despatch
Kulati Mr ANC 177 Gaba ST NU2 Motherwell
Kutta Mr/Ms SACP Consultation CS 35 Frans St Kwamagxaki Port Elizabeth
Kutu Mr Thamasanqa SATAWU 9 Mpakathi Zwide
Kwanini Mr/Ms ANC Office CS 25 Ranisi Street Motherwell
Labithi Mr ECBA 28 Ngada St Motherwell
Lake Mr LW Lake & Sons LO PO Box 75 Coega
Tankatara
Lake Mr Gordon LW Lake & Sons LO P O Box 75 Coega
Tankatara
Lake Mr Peter LW Lake & Sons LO P O Box 75 Coega
Tankatara
Lake Mr LW Lake & Sons LO P O Box 75 Coega
Tankatara
Lama Mr Mazwi ANC PO Box 749 Addo
Lamani Mr Andile ANC PO Box 230 Addo
Lande Mr/Ms Mlungesi Sanco PE CS 23 Rwantsa Street Motherwell Port Elizabeth
Lange Mr & Tom & Kathy Indiv 7 Gipson Road Mount Croix Port Elizabeth
Mrs
Langman Mr WDC Gov P O Box 318 Port Elizabeth
Lawu Mr Thobile ANC Alliance Despatch Polit 166 Xolile Botoman Street Despatch
Le Quesne Mr Tom SA Environment Project Env PO Box 44340 Claremont
Le Quesne Mr Will SDMPT Indiv
Le Roux Mr Dun Roven Citrus Buss PO Box 41 Klein Rivier Hankey
Lengoasa Mr Jerry Chairperson Ngqura Environmental Gov 315 Pretorious Street Fedsure Forum Pretoria
Committee Building
Lepela Mr/Ms SANCO Consultation CS 311 Site and Service Port Elizabeth
Letom Mr/Ms Kholisi ANC - New Brighton CS Block 7H3 White New Brighton
Location
Leve Mr Mncedisi ANC 11781 S/S Kwazakhele
Lewis Mr Joorst Park Health Buss Joorst Park Health Joorst Park Port Elizabeth
Resort Resort
Libala Mr/Ms Department of Welfare Gov Private Bag X3906 Port Elizabeth
Light Mr Wayne Engineering Manager Billiton Aluminium Projects P O Box 1649 Bedfordview
Lindop Mr Swartkops Trust CS PO Box 89 Redhouse
Linhart Mr Indiv PO Box 34 Bathurst
Lloyd Mr Chief Air Pollution DEAT Gov Private Bag X447 Pretoria
Control Officer
Lloyd Mr Elroy NUMSA Labour 158 Durban Road Korsten Port Elizabeth
Lobese Mr/Ms ANC - Kwazakhele CS 10498 Maguga St Site and Service
Logie Mr Clarence Wildlife & Environment Env 45 Thomas Road Walmer Port Elizabeth
Society
Lolonga Mr/Ms Sizakele ANCYL - Khayamnandi CS 756 Zwayo Peta St Khayamnandi Despatch
Lombo Mr Bongani ANC - Kwazakhele CS 8805 Site and Service Kwazakhele
Long Proff Department of Civil Prof Port Elizabeth PO Box X6011 Port Elizabeth
Engineering, PE Technican
Technicon
Longo Mr Alfred ANC - New Brighton CS 122 Silver Town New Brighton
Loonat Ms Mia Civil Society Forum CS 24 Plaatjies St Parkside Port Elizabeth
Lose Cllr Jeremy Councillor Addo/Sundays River Polit PO Box 245 Addo
Lovemore Cllr Annette Councillor Ward 9 Nelson Mandela Polit 25 Van Wyk Street Westering Port Elizabeth
Metropole
Lubambo Mr Monde ANC 38 Kattoo St Zwide
Lubengo Mr/Ms Xoliswa ANCWL - Khayamnandi CS 169 Khozi St Kayamnandi Despatch
Luiters Mr Johan Riverside Construction Buss PO Box 1959 Uitenhage
Lukwe Mr George SACP Consultation CS 16 Leru ST NU5 S/Valley
Lukwe Mr George SADTU Labour 16 Ceru Street Motherwell
Lumka Mr/Ms Mongezi ANC - New Brighton CS Blk 36 U2 Red Location New Brighton
Lupondwana Mr Monwabisi ANC 17 Sangxa St Kwanobuhle
Mabala Mr/Ms ANC Coega CS P O Box 24 Coega
Mabele Mrs ANCWL Addo CS P O Box 505 Addo
Mabombo Mr Sydney Ward 38 40 Makapa St Kwanobuhle
Mabulu Mr/Ms ANC - Khayamnandi CS 320 Tobile Busakwe St Kayamnandi Despatch
Mabulu Mr/Ms ANC - Khayamnandi CS 7174 Bantu Holomisa St Khayamnandi Despatch
Macaleni Mr/Ms Nokupumla ANC - New Brighton CS N113 Qaqawuli New Brighton
Madakana Mr/Ms Tonityi ANCYL - Khayamnandi CS 8135 Khozi St Kayamnandi Despatch
Madakana Mr ANC 3158 Ext 23 Kwanoxolo
Madasi Mr Vuyo 22 Debooi St Langa
Made Mr/Ms ANC - Langa Civil CS 25 Macuba Street Langa Uitenhage
Society
Made Mr/Ms Mboneleli ANC - Zwide CS 24149 Soweto on Sea Port Elizabeth
Madela Ms Xola ANCYL 14 Mqhaba St Kwanobuhle
Madela Mr Sivive ANCYL 1 Lupuwana St Kwanobuhle
Madida Mr/Ms SANCO CS 67 Madala St New Brighton
Madika Mr/Ms Nontobeko ANC - Zwide 11 Naka Street Zwide Port Elizabeth
Madikane Mr/Ms Nomtobeko Sanco PE CS 154 Mjuza Street Zwide Port Elizabeth
Madikane Mr/Ms Noxolo ANC - Kwazakhele CS 4670 MK 11153 Mcaphukiso St Kwazakhele
Madikane Mr/Ms Noxolo ANCYL 11909 Ndongeni St Kwazakhele
Madlanu Mr Tembisa ANC - Uitenhage CS 2 Mlambo St Tyosville Uitenhage
Madlingosi Mr/Ms Sanco - PE CS 68 Nlondlwana Street NU8 Motherwell
Madolo Mr T S Builders 56 Mbaza St Motherwell
Madonci Mr/Ms Mncedi ANC - Khayamnandi csn 6899 Bantu Holomisa Khayamnandi Despatch
Mafana Cllr Themba Chairperson PE TRC & Coega Polit PO Box 318 Port Elizabeth
Mafani Mr SAMWU Labour 302 Rosedale Street Rose Street Central
Mafika Mr Sisa UNEWUSA 74 Ncera ST NU7 Motherwell
Mafu Mr/Ms CS 3850 Kwazakhele
Magcotsho Mr ANC - Kwazakhele CS 23 Tanyengo St Site and Service Kwazakhele
Magqala Mr/Ms Nondumiso ANC - Kwazakhele CS 4686 MK 11153 Mcaphukiso St Kwazakhele
Mahala Mr/Ms SACP PE CS 3004 Site and Service Kwazakhele Port Elizabeth
Mahala Mr Andile SAMWU Labour PO Box 22673 Port Elizabeth
Mahlaba Mr Mzukisi ANC CS 29 Mboya ST Uitenhage
Mahlahla Mr Boneka ANCWL 8 Ncede ST Kwanobuhle
Mahlakahlaka Mr/Ms ANCYL Zwide CS 23 Magi Street Zwide
Mahlulo Mr Kraby EC African Chamber of Buss 16 Darling Street Newton Park Port Elizabeth
Commerce
Mahlulo Mr Mhleli SANCI Uit CS 48 Ponana Tini Rd Kwanobuhle
Mahote Mr ANC 22 Mhlolokotshane St Kwadwesi
Majali Mr/Ms Buyile ANC Addo CS P O Box 575 Addo
Majenge Mr SATAWU 31 Gxara St NU 5 Motherwell
Maji Mr/Ms Zwelitsha SANCO Consultation CS P O Box 14558 Sidwell Port Elizabeth
Majika Mr Thembe ANC 100 Mgwalana St Motherwell
Majikela Mr/Ms SANCO CS 59 Tabata ST New Brighton
Majola Mr Sizwe SACP B211 Ext 23 Kwanoxolo
Makama Mr Mlangisi ANC - Kwazakhele CS 1962 Zokwana St Kwazakhele
Makana Mr Kenneth ANC - Khayamnandi CS 8117 Khosi St Khayamnandi Despatch
Makasi Mr Cheeky SACP PE CS 40 Mtengenya St Kwanobuhle Uitenhage
Makasi Mr/Ms Nkosinam Nomatamsanqa P/School CS P O Box 50 Khayamnandi Despatch
Makeleni Mr ANC 21593 Boesak ST Zinyoka Govan Mbeki
Makgatho Mr Charles1 ANC - New Brighton CS 88 Dubula St New Brighton
Makgato Mr ANC REC and MPL Polit Po Box 9163 Estadeal
Makinana Mr/Ms Nombulelo SANCO Consultation CS 28 Mtati St NU7 Motherwell
Makinana Mr/Ms Lindiso SANCO PE CS 6925 Kwazakhele
Makinana Mr Silumko 3 Mboya St Langa
Makotyana Mr/Ms Sanco PE CS 140 Hintsa Street Motherwell Port Elizabeth
Malalo Mr Khawulezile SAMWU Labour 8 Mni Street Zwide
Malawi Mr SANCO Consultation CS 93 Dubula St New Brighton Port Elizabeth
Maledu Mr James Chairperson Coega Development Polit PO Box 92 Coega
Forum & ANC Coega
Branch
Maledu Mr James Chairperson ANC Branch Coega Polit PO Box 92 Port Elizabeth
Maleki Mr Mkauleli SACP Labour 15 Mbolekwa St Zwide Port Elizabeth
Consultation/CEPPWA
WU
Mali Mr/Ms Xolelwa ANC - Kwazakhele CS 3270 Site and Service Kwazakhele
Mali Mr Aubrey SANCO CS 108 24th Ave Langa Location Uitenhage
Mamase Mec. Max Minister, Agriculture & Eastern Cape Province Gov PO Box X0040 Bisho
Land Affairs
Mamcotwa Mr PEM Gov Fishwater Flats P O Box 7 Port Elizabeth
Manakaza Mr SANCO 3216 Ext 23 Kwanoxolo
Mandela Mrs SANCO CS 28 Mhlaba ST New Brighton
Mangcangaza Mr ECBA 41 Kaodo St NU5 Motherwell
Mangena Mr Fire & Emergency Gov PO Box 579 Port Elizabeth
Services
Mangesi Mr/Ms Khanyiswa ANC P O Box 59 Addo
Manini Ms Thobeko ANC 37 Sanunana St Kwanobuhle
Mankahla Mr Mkhongozeli ANC - New Brighton CS Block 11 B2 New Brighton
Manxanga Ms Veronica ANC - Zwide CS 41 Mbanga Street Zwide Port Elizabeth
Manxiwa Mr/Ms Sanco - PE CS 42 Quza Street Zwide Port Elizabeth
Manyakawyaka Mr ANC 2498 Ext 23 Kwanoxolo
Manzana Mr Mac ANC Zwide CS 8 Dladla Street Zwide
Manzi Mr/Ms Sanco - PE CS 10204 Madikane Street Site & Service Port Elizabeth
Mapu Mr/Ms SACP PE CS P O Box 61147 Bluewater Bay Port Elizabeth
Mapuma Mr/Ms Nompumelelo Sanco PE CS 11886 Site and Service Port Elizabeth
Maqakaza Mr/Ms Luvuyo SANCO Consultation CS 1705 Kwazakhele Port Elizabeth
Maqolo Mr Griffiths ANC CS F245 Mtyhobo ST Walmer
Maqungo Mr/Ms Mphumzi NUMSA Labour 18 Cengimbo Lane New Brighton Port Elizabeth
Maqxwalisa Mr Duma CSIR Prof P O Box 1124 Summerstrand Port Elizabeth
Maranjosa Mr/Ms Sibokasi ANC Despatch CS 819 Chief A Luthuli Khayamnandi Despatch
Maranjosa Mr/Ms Nomonde ANC Despatch CS 828 Chief A Luthuli Khayamnandi Despatch
Maree Mr George SEEFF Properties Buss 183 Cape Rd Mill Park
Martin Dr Paul Manager PEM Nature Gov PO Box 12435 Centrahil
Conservation
Martin Mr Alfred SANCO CS 1685 Befile St Kwazakhele
Martin Mr Shaun Indiv 526 St Martini Gardens Queen Victoria Street Cape Town
Martindale Mr Robert Environmental Rights Env PO Box 5467 Walmer
Association
Martines Mr/Ms Lunga Sanco PE CS 2277 P O Box 11112 Algoa Park Port Elizabeth
Masala Mr/Ms Nomakathini ANC - Kwazakhele CS 11020 Site and Service Kwazakhele
Mashicila Ms Nellie ANCWL 5 Mzunkulu St Kwadwesi
Masitshana Mr/Ms ANC - Kwazakhele CS 9681 Buyambo St Kwazakhele
Masualle Mec. Phumulo Minister Public Works Eastern Cape Province Gov Private Bag X0022 Bisho
& Transport
Matabese Mr Elijah ANC - Uitenhage CS 4 Ngcunqcu Cres Kwanobuhle Uitenhage
Matabese Mr Likaya Ward 54 7 Nkamela St Motherwell
Matabiele Mr/ms Uitenhage TLC Gov PO Box 45 Uitenhage
Matanse Mr/Ms Philiswa ANC - New Brighton CS 275 Qaqawuli St New Brighton
Matchett Mr Chris Portnet Buss 101 De Korte Street Braamfontein
Matebese Mr Vuyisile ANC - Despatch CS 62 Fort Calata St Kayamnandi Despatch
Matebese Mr Willy Khayamnandi S Centre CS 60 1st Ave Kayamnandi Despatch
Matebese Mr SANCO 16 Chief Albert Luthuili Despatch
St
Matenjiwa Mr/Ms Sanco - PE CS 61593 Greenfields Struandale Port Elizabeth
Mateto Mr/Ms Vuyani ANC - Despatch CS 173 Soloman Mahlangu Khayamnandi Despatch
St
Mathenjiwa Mr ANC CS f192 Ngayisa ST Walmer
Mathulu Mr/Ms Nompumelelo ANC - Khayamnandi CS 320 Tobile Busakhe St Kayamnandi Despatch
Matiso Mr/Ms Nomhle ANCWL - Khayamnandi CS 106 Khozi St Kayamnandi Despatch
Matiso Mr/Ms SANCO - Khayamnandi CS 106 Khozi St Khayamnandi Despatch
Matiwane Ms Florence ANC - New Brighton CS F75 Chris Hani New Brighton
Matiwane Mr Monwabisi Ward 21 Comm 11765 Kwazakhele
Matomela Mr/Ms ANC - Kwazakhele CS 1771 Zokwane St Kwazakhele
Matros Mr/Ms SANCO - Langa Civil CS 20 Magawu Street Uitenhage
Society
Matsaba Mr/Ms SANCO CS 2306 Site & Service Nkata St
Matshisi Mr/Ms Sicelo ANC - Khayamnandi CS 150 Xolile Botoman St Kayamnandi Despatch
Matshisi Mr/Ms ANC - Uitenhage CS 64 3rd Ave Kwanobuhle Uitenhage
Matsini Mr SANCO CS NB98 Qaqawuli
Matthews Mr Mineraland Energy Gov Private Bag x6076 Port Elizabeth
Matthews Soya Mr Monwabisi SACP Consultation CS 144 Ntshekisa Rd New Brighton Port Elizabeth
Matyana Mr Indiv 8 Mtati Street Nu7 Motherwell Port Elizabeth
Maveca Mr Luvuyo Nicro CS 1st Floor Giddy's Centre North End
Maweni Mr Nicholas BMF - Coega Buss P O Box 27504 Greenacres
Maweni Mr Temba ANC - New Brighton CS I 91 Chris Hani New Brighton
Maxengama Mr PSI 176 NU8 Edlovini Motherwell
Maxengama Mr PSI 176 NU8 Endlovini Motherwell
Maxhela Ms Winnie ANC - New Brighton CS Block 39I2 Red Location Port Elizabeth
Mayekiso Mr SANCO 152 Zweliyazuza St Motherwell
Mazitshana Mr Xolani ANCYL CS 9681 Buyambo ST Kwazakhele
Mazondiva Mr/Ms Sikhumbuzo ANC - New Brighton CS 100 Moduka St New Brighton
Mazondwa Ms Nomzamo ANCWL 43 Ngwekazi ST Kwanobuhle
Mbanga Mr ANC CS d36 Topia St Walmer
Mbekisa Ms Women in Construction CS 47 Kinikini St Uitenhage
- Uitenhage
Mbele Mr/Ms Baba ANC - Zwide CS 31 Dyeshana Street Zwide Port Elizabeth
Mbelekane Mr Mvuzo ANCYL 9848 S/S Kwazakhele
Mbengashe Ms Maria Deputy Permanent Provincial Dept. of Gov P O Box 8031 Bisho
Sectretary Environment Affairs
Mbengashe Mr/Ms Sanco - PE CS 18 Indwe Street NU3 Motherwell
Mbengashe Mr/Ms Nokuzola ANC - New Brighton CS Block 5B4 New Brighton
Mbensepo Mr ANC 139 Mhlolokotshane St Kwadwesi
Mbewu Mr Councillor Forum 107 Hobe St Motherwell
Mbiyabo Mr Thembile PE Fishing Forum 510 Govan Mbeki Port Elizabeth
Mboyi Mr/Ms Noluthando ANC - Kwazakhele CS 10584 Vakaza St Kwazakhele
Mboyi Ms Nomonde ANC Media PO Box 323 Addo
Mbujoza Mr Swartkops CS 7668 Site and Service Kwazakhele
Mbunyiiza Mr Sandile ANC - Kwazakhele CS 2930 Myali St Kwazakhele
Mbuqe Mr CSF CS 16th Floor Brister House Govan Mbeki Rd Port Elizabeth
Mbuqu Mr Madoda ANC CS 14 Van Der Heever Str Overbaakens
Mbuqu Mr ANC 10 Ngoma St NU
Mbuqu Mr ANC 10 Ngoma St NU9 Motherwell
Mbusi Mr/Ms Lindiwe ANC - Uitenhage CS 36 freemantle St Uitenhage
Mbuthumi Mr SANCO 3081 Ext 23 Kwanoxolo
Mbuzi Mr ANC 38 Gquara ST NU5 Motherwell
Mc Gregor Mr Murray Manager: SA National Parks Gov PO Box 787 Pretoria
Environmental Services
Mc Gregor Mr Indiv 1 Settlers Steps Amsterdamhoek Port Elizabeth
Mc Hugh Ms Liz PEM Housing PE Municipality Gov PO Box 116 Port Elizabeth
Mc Williams Mr Rob Zwarkops Trust Env PO Box 27192 Greenacres
McEwan Mr Derek Indiv 143 Mowbray Road Greenside
Mckonie Ms Louisa ANC - Kwazakhele CS 11282 Khuzwayo St Kwazakhele
McLean Mr Duncan Moeller Electric Buss P O Box 14136 Sidwell
Mdayi Mr/Ms Zalisile ANC - Khayamnandi CS 17 Siphiwo Vengane St Khayamnandi Despatch
Mdlela Mr/Ms Venus FAWU Labour 6954 Site & Service Port Elizabeth
Mdliva Mr/Ms Xolani ANC - Kwazakhele CS 11985 Matomela St Site and Service Kwazakhele
Mdoda Ms Gwen Women in Construction CS 61 Pontanatin Rd Uitenhage
- Uitenhage
Mdoda Mr Orsmond ANC - New Brighton CS 7 Zokuba St New Brighton
Mdoda Mr SANCO CS NB33 Qaqawuli
Mdunyelisa Mr Phumzile ANC Polit 18116 Mkwayi St Govan Mbeki Port Elizabeth
Township
Medlawu Mr/Ms PRDP PO Box 262 Addo
Mei Mr James SANCO CS Block C Flat 11 Share Complex Kwanobuhle
Meintjes Mr Renier Town Engineer Uitehage Town Council Env P O Box 45 Uitenhage
Memani Mr Mzwandile ANC Motherwell CS 11 Mpofu Street NU Motherwell
Memani Mr/Ms Nomuyise ANCWL - Despatch CS 6905 Bantu Holomisa St Kayamnandi Despatch
Memani Ms Lillian SANCO PE CS 2057 Chris Hani Kwazakhele
Memani Mr Sipho FAWU Labour 166 Govan Mbeki Ave Port Elizabeth
Mengu Mr/Ms Thando ANC - Khayamnandi CS 159 Xolile Botoman St Khayamnandi Despatch
Menong Mr/Ms Dikeledi ANC - New Brighton CS 36 Ncwana St New Brighton
Mens Mr/Ms Themisile ANC - Khayamnandi CS 100 Khozi St Khayamnandi Despatch
Menze Mr Charlie Khayamnandi S Centre CS 175 4th Ave Khayamnandi Despatch
Menze Mr Lex SAMWU Labour 76 Masolla Street Zwide Port Elizabeth
Mercer Mr Jonathan Chief Town Planner PE TLC Gov PO Box 116 Port Elizabeth
Metiwane Mr/Ms CHW - TLC Office CS D7 Majola Street Walmer Location Port Elizabeth
Metula Mr/Ms Sanco - PE CS 10919 Site and Service Port Elizabeth
Mfecane Mr/Ms ANC Zwide CS 532 - 54 Soweto on Sea
Mfengu Mr/Ms Periyane ANC - Despatch CS 1 Somi St Kayamnandi Despatch
Mfo Mr/Ms Yoleka ANC - Uitenhage CS 35 Molly Blackburn St Uitenhage
Mfuduka Ms Mimmie ANC Motherwell CS 219 Ngoma Street NU9 Motherwell
Mfunda Mr/Ms SACP Consultation CS 18 Dyabele St Kwamagxaki Port Elizabeth
Mfunda Mr/Ms Skhumbuzo ANC - New Brighton CS 11 Kali St New Brighton
Mfunda Mr/Ms ANC - New Brighton CS 11 Kali St New Brighton
Mgimza Mr Thozamile ANC - Kwazakhele CS 284 Hostel Kwazakhele
Mgoantashe Mr Saddam ANC P O Box 528 Addo
Mgoqi Mr ANC 40 Bikana St NU4a Motherwell
Mguca Mr Bongani ANC - New Brighton CS 169 Dubula St New Brighton
Mgwanza Mr Eric PETLC Polit 200 Tonjeni Street Zwide
Mhlabeni Mr Mfundo ILDP - SBU UPE Prof 6 Cuyler Street Central Port Elizabeth
Mhlahlo Mr ANC 7 Tuswa St Zwide
Mhlaluka Mr/Ms Portnet Buss P O Box 102 Port Elizabeth
Milanzi Mr Temba ANCYL - Uitenhage CS 39 6th Ave Khayelitsha Uitenhage
Milanzi Mr/Ms Aleka ANCYL - Uitenhage CS 39 6th Ave Kwanobuhle Uitenhage
Milne Mr MMK Architects Prof P O Box 12019 Moffat Place
Minnaar Mr PPC Buss P O Box 2016 North End
Misi Mr/Ms Vusi Zwica Trust - Zwide CS Cnr Mboya ludwaba Zwide
Street
Mitchell Mr Colin PPC Buss P O Box 2016 North End Port Elizabeth
Mjadu Mr Sipho ANC CS 929 Main Rd Addo
Mjakuca Mr/Ms Nceba SANCO PE CS 59 NBRR New Brighton
Mjuza Ms Yoliswa ANC 60 Silvertown Limba's Ground Zwide
Mkalali Ms Barbara ANC - New Brighton CS Block 36 E1 New Brighton
Mkavy Mr 19 Magawu St Langa
Mkhetshana Mr Owen ANC - Uitenhage CS 47 Ngcungcu Cres Kwanobuhle Uitenhage
Mkhosana Mr Mncedisi ECBA 5 A Wesleyan St Walmer Port Elizabeth
Mkonto Mr/Ms Thembisa ANC - New Brighton CS Block 39 I2 New Brighton
Mkosi Mr/Ms Thembile SACP Zwide CS 1 Shode Street Zwide
Mkoto Mr/Ms ANC - Kwazakhele CS 3155 Site and Service Kwazakhele
Mkumatela Ms Ruth CEN Env P O Box 14636 Sidwell
Mkunqwana Mr/Ms Simphiwe SACP PE CS 10 Kruisman Rd Zwide Port Elizabeth
Mkunyane Mr Zandisile ANC 9494 Myali St Kwazakhele
Mkweta Mr Mncedisi ANC Polit Block 59 F8 Red Location New Brighton
Mkwetshana Mr ECBA 39 Dyakalsha St NU 12 Motherwell
Mlakalaka Mr Bantu ANC - New Brighton CS 169 Dubula St New Brighton
Mlalandle Mr Walter ANC - Uitenhage CS 41 Nkohli St Kwanobuhle Uitenhage
Mlanjana Mr/Ms Xolelwa ANC - Zwide CS 133 Koyana Street Zwide Port Elizabeth
Mlolomba Mrs ANC - Langa Civil CS 303 Joe Slovo Uitenhage
Society
Mlomo Mr/Ms Linda Sanco PE CS 2433 Site and Service Port Elizabeth
Mlomo Mr Reginald Vista University Indiv 2418 Stofile Street Kwazakhele Port Elizabeth
Mlonzi Mr/Ms SACP PE CS 60A Papenkuil St Westering Port Elizabeth
Mlunguzi Mr Hamilton FAWU Labour 166 Govan Mbeki Ave Port Elizabeth
Mngcobo Ms Evelyn ANC - New Brighton CS 14 Singapi St New Brighton
Mntushe Mr Vuyo ANC 9320 Nomjila St Kwazakhele
Mnweba Mr/Ms Mpendulo SANCO - Uitenhage CS 36 Zinuela St Kwanobuhle Uitenhage
Mnyamezeli Mr ANC - Khayamnandi CS 190 Chief A Luthuli Khayamnandi Despatch
Mokonenyane Mr/Ms SACP PE CS 20 Kuruman Street Summerstrand Port Elizabeth
Molato Ms Eunice NUMSA Labour 21 Billet Street Gelvandale
Molutsi Mr/Ms SANCO Consultation CS 7978 Site and Service Port Elizabeth
Mona Mr Arnold Landowner LO PO Box 12609 Amalinda
Mongwele Mr/Ms Mthetheleli ANC - Kwazakhele CS 9735 Buyambo St Kwazakhele
Moni Mr Kolekile Moni Builders 7 Ngxotwane St NU9 Motherwell
Mooi Mr/Ms ANCYL - Uitenhage CS 30 Myatoza Cres Uitenhage
Moorehouse Ms Sherry Moorehouse Consulting Prof 29 Wiehahn Avenue Benkamma
Moosa Ministe Vali c/o Vincent Matalani National Department of Gov Private Bag X 447 Pretoria
r Environmental Affairs
Mostert Mr Berto Department of Welfare Gov PO Box 586 Uitenhage
Mote Mssrs Peter & Tony Owner Coastal Livstock & LO PO Box 120 Colchester
Farming cc.
Moyeni Mr December SACP Consultation CS 511226 Mbengashe St Zwide
Mpambani Mr Myebo FAWU Labour 282 Ferguson Rd New Brighton Port Elizabeth
Mpeqeko Mr Siphiwe SANCO Consultation CS 105 Zokufa St New Brighton Port Elizabeth
Mphali Mr/Ms Vayisile ANC - Despatch CS 219 Chief A Luthuli St Kayamnandi Despatch
Mpinga Mr Mandla Ward 38 23 Makuleni St Kwanobuhle
Mpofu Mr/Ms SACP PE CS 31 Myulutsi NU4 Motherwell
Mqloma Mr Siphelo ANC - Despatch CS 673 Fort Calata St Kayamnandi Despatch
Mrara Mr/Ms SACP PE CS 2 Mdhlyelo Street Kwadwesi Zwide
Mrausi Mr/Ms Sanco - PE CS 2764 Site and Service Port Elizabeth
Msayi Mr Temba ANC Motherwell CS 52 Mpofu Street Motherwell Port Elizabeth
Msila Ms Sylvia ANC - New Brighton CS g98 Chris Hani New Brighton
Msingizane Mr Theo CAWU Labour 5316 Site & Service Kwazakhele Port Elizabeth
Msitshana Mr/Ms Nkosana ANC Despatch CS No 146 X Botoman Khayamnandi Despatch
Street
Msiwa Mr City Engineer PE TLC Gov PO Box 116 Port Elizabeth
Msutu Mrs SANCO PE CS NB 114 Qaqawuli New Brighton
Msutwana Mr/Ms Nompumelelo J & S labour Brokers CS 14 Ndimeni St Uitenhage
(Uitenhage)
Mtabazi Mr/Ms Yoliswa ANC - Kwazakhele CS 2722 Masakane Kwazakhele
Msutuma
Mtakatana Mr/Ms Thembani ANC - Khayamnandi CS 305 Thobile Busakwe St Khayamnandi Despatch
Mtana Mr Lizo Uitenhage TLC Gov PO Box 45 Uitenhage
Mtanga Mr Monde Chairperson PE Civil Society Forum CS PO Box 116 Port Elizabeth
Mtanga Mr/Ms Andile SACP Consultation CS 143 Kwaza St New Brighton Port Elizabeth
Mtanga Mr MCDF 38 Chief Poto St Motherwell
Mtanga Mr Councillor Forum 38 Chief Poto St Motherwell
Mtati Mr Themba ANC - Zwide CS 36 Mphakathi Street Zwide Port Elizabeth
Mtinjama Mr/MS Mthetho ANC 102 Spondo ST Zwide
Mtongana Mr/Ms Viola SACP PE CS P O Box 205 Port Alfred
Mtshatsheni Mr/Ms SANCO Consultation CS 26 Teko St NU48 Motherwell
Mtshiselwa Mr Oscar NUMSA Labour 10258 Madikane Street Kwazakhele Port Elizabeth
Mtwalo Ms Zoleka ANCWL 9 Ndimeni St Kwanobuhle
Mtyeku Mr Kevin NUMSA Labour 29 Affrey Road New Brighton
Mtywaru Ms Linda ANC 174 Mlimane NU6 Motherwell
Muller Mr Connie Owner Marine Growers Buss PO Box 21555 Port Elizabeth
Murrell Mr Environmental Control Western District Council Gov PO Box 318 Port Elizabeth
Musa Mr/Ms Mzingisi ANC - New Brighton CS Block6 J4 New Brighton Port Elizabeth
Mwaculi Mr/Ms Nzimeni ANC - Khayamnandi CS 296 Thobile Busakwe St Khayamnandi Despatch
Mxokozeli Mr SATAWU P O Box 361 Port Elizabeth
Mxoli Mr/Ms Zoleka ANC CS 2 Gqunqe St NU5 Motherwell
Mxube Mr Lungile NEHAWU Labour Private Bag X6011 Port Elizabeth
Myers Mr Norman Attorney Norman Myers Attorney LO Barkley Bridge Farm PO Box 339 Addo
& Notary
Mynhardt Mr Nick VRN Steel Buss P O Box 2046 North End
Mzamo Mr Thembisile DWAF Gov Private Bag X6041 Port Elizabeth
Mzazela Mr Stanley ANC - Khayamnandi CS 6678 Rogers Mwanda St Kayamnandi Despatch
Mzizi Mr Siphiwe Youth Project - TLC CS A50 Witbooi Street Walmer
Office
Mzizi Mr ANC 25784 NU 29 Motherwell
Mzwanam Mr Mbulelo ECBA 6390 Tshawuka ST S/S Motherwell
Mzwandile Mr/Ms Mjadu SANCO - Khayamnandi CS 6939 4th Ave Khayamnandi Despatch
Mzwandile Mr/Ms SACP Consultation CS 4 Whitehall Court Western Rd Central
Nango Ms Mary ANC - Zwide CS 40 Menze Street Zwide Port Elizabeth
Naran Cllr Balu PE City Council Polit PO Box 116 Port Elizabeth
Ncamiso Mr/Ms Lindelwa Uniting Reformed CS 829 Fort calata St Khayamnandi Despatch
Church - Khayamnandi
Ncamiso Mr Macdonald ANC - Khayamnandi CS 7119 Chief A Luthuli St Khayamnandi Despatch
Ncaphayi Ms Linda SACP Consultation CS 29 Norongo St New Brighton Port Elizabeth
Ncarashe Ms Esther ANC - New Brighton CS NBRR 227 Qaqawuli New Brighton
Ncedo Mr/Ms Made ANC - Zwide CS 39 Bucwa Street Zwide Port Elizabeth
Ncetezo Mr/Ms Nqabile ANC - Uitenhage CS 53 Nongauza Cres Uitenhage
Ncipa Mrs ANC 32 Ngkungcu St Kwanobuhle
Nciza Ms Amanda ANC - Kwazakhele CS 10621 Vakaza St Kwazakhele
Ncobo Mr Samson ANC - Uitenhage CS 21 Lindipasi Cres Kwanobuhle Uitenhage
Ncxiiho Mr Sabelo SACP 24 Nqomo -Nqomo St Kwadwesi
Ndabambi Mr/Ms Sanco - PE CS 10 Bawa Street Motherwell Port Elizabeth
Ndayo Mr ANCYL 19 Imtowa St NU5 Motherwell
Ndema Mr Sandile Govan Mbeki Forum CS 18180 Fazzie Street Govan Mbeki Port Elizabeth
Township
Ndesi Mr/Ms Zomele ANC Zwide CS 17 Maya Street Zwide
Ndevu Mr/Ms Thandiwe ANC - Khayamnandi CS 101 Bantu Holomisa St Kayamnandi Despatch
Ndevu Mr Vusumi ANCYL 513-223 Koza St Zwide
Ndimba Mr/Ms Langa Civil Society CS 21 Oliver Street Langa Uitenhage
Ndimba Mr Zongezile ECBA 21 Nqabara ST NU9 Motherwell
Ndinisa Mr/Ms Nompumelelo ANC - Uitenhage CS 92 Goliath St UITENHAGE
Ndinisa Mrs SANCO PE CS NBR87 Qaqawuli New Brighton
Ndinqeye Mr/Ms Pumla ANC - Uitenhage CS 134 1st Ave Kwanobuhle Uitenhage
Ndiphiwe Mr/Ms Giyose ANC 39 Dzeya St Zwide
Ndlaleni Mr Sam SANCO CS 65 Kali St New Brighton
Ndlebe Mr/Ms Nokuzola SANCO CS 107 Mandela Village PE
Ndlebe Mr Sabelo NEHAWU SA Institute Medical Labour Buckingham Road Port Elizabeth
Research
Ndlovu Ms Patricia ANC - New Brighton CS 170 Gqamlana St New Brighton Port Elizabeth
Ndlumbini Mr Phiwe ANC 8491 S/S Kwazakhele
Ndlwana Mr Lafarge SA Buss Moregrove Quarry Grasvoel Street Cotswold PE
Ndongeni Mr/Ms Nkosomzi SACP Consultation CS 20 Mtengenya St Kwanobuhle Uitenhage
Ndongeni Mr/Ms Mbuzeli ANC - New Brighton CS 171 Dubula St New Brighton
Ndube Mr CIIR 47 Indwe St Motherwell
Ndwayana Mr ANC 4 Mbonyane St Kwadwesi
Ndweyane Mr/Ms Soweto Clinic CS S36 184 Soweto on Sea Port Elizabeth
Ndyaneli Mr/Ms ANC - Langa Civil CS 34 Oliver Street Langa Uitenhage
Society
Ndzenza Ms ANCWL 23 Poto St Kwanobuhle
Ndzombane Mr Ndaba Metroplan Buss PO Box 12313 Cenrahil
Nel Mr Uitenhage TTD Gov PO Box 31 Uitenhage
Nelami Mr SANO Uitenhage CS 13 Daku Street Langa Uitenhage
Nelani Mr/Ms ANC - Langa Civil CS 13 Daku Street Langa Uitenhage
Society
Nell Ms Department of Welfare Gov Private Bag X3906 Port Elizabeth
Newington Ms Heather Indiv 32 Hill Street Grahamstown
Newman Mr Brent SAB Institute for Prof UPE PO Box 1600 Port Elizabeth
Environmental &
Coastal Mang.
Ngalonkulu Mr/Ms Sanco - PE CS 11 Koza Street Zwide Port Elizabeth
Ngani Mr/Ms Sanco - PE CS 17 Koza Street Zwide Port Elizabeth
Ngaphe Ms Anna SANCO Consultation CS 21 Zamukulugisa St Port Elizabeth
Ngcaba Mr ANC PCO 132 Ndumba NU7 Motherwell
Ngcangca Mr ANCYL 31 Makwenkwe St Kwadwesi
Ngcete Mr Mthetheleli Chairperson, Executive PE City Council Polit PO Box 166 Port Elizabeth
Committee
Ngcezula Mr/Ms Sanco PE CS 18 Ramra Street Nu4 Motherwell
Ngcongcobela Mr SACP 2533 Ext 23 Kwanoxolo
Ngibe Mr Vuyani ANC - Uitenhage 20 Manta St Uitenhage
Nginza Mr/Ms Thozamile ANC - Kwazakhele CS 284 Hostel Kwazakhele
Ngoma Mrs SANCO CS 1191 S&S Kwazakhele
Ngona Mr Samual SANCO Consultation CS 8952 Mavavana St Port Elizabeth
Ngoqo Mr/Ms Andile SANCO - Langa Civil CS 28 Magawu Street Langa Uitenhage
Society
Ngqamfana Mr/Ms Lulama ANC - Uitenhage CS 46 Mbengashe St Uitenhage
Ngqeshe Mr Dorcas ANC - Kwazakhele CS 1805 Zokwana St Kwazakhele
Ngqiqhi Ms Yoliswa ANCWL 15 Bikwe ST Kwanobuhle
Ngqond Mr/Ms Simpie SANCO - Langa Civil CS 4 Nobakada Street Langa Uitenhage
Society
Ngqondi Mr/Ms Vuyelwa Sanco PE CS 38 Indwe Street NU3 Motherwell
Ngumbela Mr SANCO CS 10536 Jali RD Kwazakhele
Ngwane Mr ANC 19 Gomomo St Kwanobuhle
Ngwangu Mr Lifukazi NEHAWU Labour 49 Mangcaka Street Kwa -Magxaki Port Elizabeth
Ngxito Mr/Ms Sabelo SACP Consultation CS 14 Ngomu -Ngomu St Kwadwesi Uitenhage
Ngxokwana Mr/Ms Mangaliso ANC - Kwazakhele CS 10594 Maguga St Kwazakhele
Ngxovu Mr Luvuyo Easy Sector CS BLN 37 I New Brighton PE
Nini Mr Mzandile SAMWU Labour 14 Cotshana Street NU5 Swartkops Motherwell
Valley
Niven Mr Clive Amanzi Packhouse Agri PO Box 57 Addo
Njokweni Mr/Ms UNEWUSA CS NU10 E441 Motherwell Port Elizabeth
Nkala Mr Wonga SACP PE CS 27 Mjikwa St Kwanobuhle Uitenhage
Nkatsha Mr Andile ANCYL 6 Mgwari St Kwanobuhle
Nkayi Mr Sivuyile WRF S 31115 Soweto on Sea
Nkebe Mr/Ms ANC - Kwazakhele CS 524 Site and Service Mpeti St Kwazakhele
Nkolongo Mr/Ms Mbulelo SACP PE CS 1767 Zokwana Street Kwazakele Port Elizabeth
Nkombisa Mr/Ms Skulu SANCO - Langa Civil CS 60 Hintsa Street Kwanobuhle
Society
Nkombisa Mr/Ms UNEWUSA CS 28 Ndakana St NU7 Motherwell
Nkone Ms Lerato Community Env PO Box 14636 Sidwell Port Elizabeth
Environment Network
Nkosi Mr/Ms ANC - Kwazakhele CS 893 Zokwana St Kwazakhele
Nkumanda Mr General CEN CS 69 Ntshinga Street New Brighton Port Elizabeth
Nkumenbe Mr/Ms Njengele CEN Env P O Box 14636 Sidwell
Nkwali Mr/Ms ANC - Khayamnandi CS 280 Dr J Moroko St Khayamnandi Despatch
Nkwinti Mec. Gugile Minister Housing & Eastern Cape Province Gov Private Bag X0054 Bisho
Local Government
Nobadula Ms Molly SANCO CS 71 Madala St New Brightn
Nock Mr Warman Africa Buss 91 Berg Road Fishhoek
Nodongwe Mr/Ms Phumzile SACP PE CS 7 Mama St Kwanobuhle Uitenhage
Nodongwe Ms Phumzile NUMSA Labour 7 Mama Street Kwanobuhle Uitenhage
Nodwele Mr Xola MYDF 123 Nkolo ST NU9 Motherwell
Nogqala Mr Peter Ithuba Lethu 268 Khalendala ST NU11 Motherwell
Nogumpula Mr/Ms ANC - Uitenhage CS 10 Mgafaza Cres Uitenhage
Nokolo Mr Nokolo Builders 18 Mkombe St Motherwell
Nokwe Mr/Ms Department of Welfare Gov Private Bag X3906 Port Elizabeth
Noloyiso Mr/Ms Nika ANC CS 25 Gqunqe St NU 5 Motherwell
Nomamfene Mr/Ms Quluba ANC Zwide CS 23 Tunyiswa Street Zwide
Nomawisile Mr/Ms Dlanga SANCO PE CS 3609 Kwazakhele
Nonceba Mr/Ms Sonjica ANC - New Brighton CS 166 Kwaza St New Brighton
Noncembu Mr/Ms Nopinky CS Forum CS 9 Teja ST New Brighton
Nondi Mr Vuyani 27 Debooi St Langa
Nondzube Mr/Ms Thembakazi ANC - Zwide CS 1 Maya Street Zwide Port Elizabeth
Nonimba Mr/Ms ANC - Kwazakhele CS 10568 Site and Service Kwazakhele
Noruka Mr Elias ANC 26 Mdani St Zwide
November Mr/Ms Yoliswa Development Forum CS P O box 8112 Kwanobuhle Uitenhage
Uitenhage
Noyila Mr/Ms Vumile ANC - Uitenhage CS 80 Bantom Gunguluza Uitenhage
Noyo Mr/Ms Department of Welfare Gov PO Box 586 Uitenhage
Nqai Mr/Ms Luyanda SACP - Uitenhage CS 12 Myataza Cres Holomisa Uitenhage
Nqandu Mr/Ms Ntuthuzelo ANC - New Brighton CS Block 8E2 New Brighton
Nqikashe Mr/Ms Nuyisile ANC - Despatch CS 6655 Chief A Luthuli St Kayamnandi Despatch
Nqinqi Mr Busisiwe 68 23rd Ave Langa
Nqwata Mr/Ms Mbuyiselo ANC - New Brighton CS 34 Ncwana St New Brighton
Ntamo Ms Maureen ANC Despatch CS 24 Chief A Luthuli Khayamnandi Despatch
Ntamo Mr/Ms Kholekile ANC - Khayamnandi CS 105 Khozi St Kayamnandi Despatch
Ntamo Mr/Ms Thembisa Creche - Khayamnandi CS 6813 Chief A Luthuli St Khayamnandi Despatch
Ntando Mr Lulamo ANC 100 Bambani St NU4A Motherwell
Ntantiso Mr/Ms Nosipho Despatch CS 842 Fort Calata St Khayamnandi Despatch
Ntantiso Mr/Ms Nkosana ANCYL - Despatch CS 842 Fort Calata St Khayamnandi Despatch
Ntantiso Mr/Ms Lindiswa ANC - Kwazakhele CS 10974 Site and Service Kwazakhele
Ntayana Mr Christopher Ewemasenze - TLC CS Area Q Walmer Location Port Elizabeth
office
Nteto Mr Boy SANCO New Brighton CS 80 Gaamlana St New Brighton
Ntiwanamibi Mr/Ms Sanco - PE CS 149 Vinjiwe Street Motherwell Port Elizabeth
Ntlaki Mr/Ms ANC Zwide CS 26 Dladla Street Zwide
Ntlonze Mr ANC CS 531-56 Soweto On Sea
Ntoba Mr/Ms Kindness SANCO PE CS NBRR319B New Brighton
Ntola Mr/Ms SACP PE CS 4 Ngele Street Kwamagxaki Port Elizabeth
Ntotha Mr Michael Ithuba Lethu 37 Mbaza St NU10B Motherwell
Ntshalaba Mr/Ms SACP PE CS 30 Gamanda Street Zwide Port Elizabeth
Ntuntwana Mr SACP 20436 Rohrich St Govan Mbeki
Ntutwana Mr/Ms ANC CS 50 Msintsana St NU7 S/V Motherwell
Nxoti Ms Xoliswa ANCWL 7 Nkombisa St Kwanobuhle
Nyaba Mr Gradima 5 Ncera ST NU7 Motherwell
Nyamakazi Mr ANC Addo CS P O Box 10 Addo
Nyamakazi Mr Mzimasi ANC BEC CS 47 Kwamanube NU6 Motherwell
Nyamakazi Mr ANC 7 Ncwazi St NU7 Motherwell
Nyawe Mr Lungiswa ANC 21494 Boesak St Zinyoka Govan Mbeki
Nyoka Mr/Ms Nosebenzile ANC Despatch CS 17 Hobe Street Khayamnandi Despatch
Nyoka Mr/Ms Mzikayise ANC Despatch CS 17 Hobe Street Khayamnandi Despatch
Nyoka Mr/Ms Khayamnandi CS 802 Hobe St Khayamnandi Despatch
Nyoka Mrs Department of Water Gov
Affairs & Forestry
Nyoni Mr Allan Civil Society Forum CS P O Box11166 Algoa Park Port Elizabeth
O'Conner Mr Indiv 74 Maureen Circle Bluewater Bay Port Elizabeth
Odeyan Mr Uitenhage TLC Gov PO Box 1001 Uitenhage
Odolo Mr/Ms ANC Office CS 61 Ngwenkala Street NU9 Motherwell
Odolo Mr Nokanyo ANC 9 Tanga ST NU4B Motherwell
Oliphant Mr ANC SACP 3 Mkovoti St Kwadwesi
Olivier Mr Marius Setplan Buss PO Box 2446 North End
O'Moore Mr Manager EP Agriculture Union Agri PO Box 3380 North End Port Elizabeth
Pamba Mr/Ms Tabisa Sanco Uitenhage CS 10th Avenue Kwanobuhle
Pana Mr Zama Ward 42 20 Vazi St Kwanobuhle
Pandle Mr/Ms ANC - New Brighton CS Block 40 K I New Brighton
Panga Ms Phumla ANC - Kwazakhele CS 476 Site and Service Kwazakhele
Papu Mr Boyce Deputy Director SA Environmental Env PO Box 21459 Port Elizabeth 6000
Project
Paraffin Mr Ward 38 82 Kwabha St Kwanobuhle
Paterson Mr International CS PO Box 22356 Port Elizabeth 6000
Development &
Empowerment Trust
Patrick Mr Brett EC Wild Bird Society Env PO Box 27454 Greenacres
Paul Ms Stephanie Department of Welfare Gov PO Box 372 Swartkops
Paul Mr ANC 13 Mhlalokotshane St Kwadwesi
Pearson Mr Roald Indiv 20 Myrtle Avenue Strelitzia Park Uitenhage
Pepese Mr/Ms ANC Coega CS P O Box 53 Coega
Pepeto Mr/Ms Lungelwa ANC - Langa Civil CS 25 Mboya Street Langa Uitenhage
Society
Peta Ms Joyce ANC Despatch CS 2 Boboyi Street Khayamnandi Despatch
Peta Mr/Ms Sandiswa ANC Despatch CS 26 Chief A Luthuli Khayamnandi Despatch
Peteni Mr/Ms ANC Motherwell CS D223 Tjoks Valley Motherwell
Peter Mr Sithembiso Co-ordinator Gqebera Development CS PO Box 5638 Walmer Port Elizabeth
Trust
Peter Mr SANCO 24 Mbane Cres Zwide
Petros Mr PE CS Forum CS P O Box 672 Port Elizabeth
Phillip Mr Amos SANCO 84 Mabophe St Zwide
Pieter Mr/Ms Nomalungelo ANC Despatch CS 12 Nkonjene Street Khayamnandi Despatch
Pieter Mr/Ms Aaron ANC - Khayamnandi CS 304 Thobile Busakwe St Kayamnandi Despatch
Pietersen Mr Cornelius Action Committee EP Agricultural Union Agri PO Box 232 Uitenhage
Member
Pieterson Mr Kelvin SANCO - Langa Civil CS 8-23rd Avenue McNaughton
Society
Pinini Mr/Ms Mqondisi SANCO - Langa Civil CS 22 Mboya Street Langa Uitenhage
Society
Plaatjie Mr/Ms Nontsikelelo ANC - Kwazakhele CS 7171 Mbilana Cres Kwazakhele
Plaatjies Mr 7 Madobela St Langa
Potter Mr Reginald Secureco Buss Embassy Building 17 Grahamstown Road Port Elizabeth
Pram Mr Martin UPDEF -Langa Civil CS 42 20th Ave Langa Uitenhage
Society
Pretorius Mr Attie CEO Despatch TLC Gov PO Box 42 Despatch
Price Mr John John Price Estates Buss P O Box 40169 Walmer
Prince Mr Ronnie SACP PE CS 55 bosch Rd Bloemendaal Port Elizabeth
Prinsloo Mr PPC Buss PO Box 2016 North End
Punani Mr/Ms SANCO - Khayamnandi CS 96 Bantu Holomisa St Khayamnandi Despatch
Puwana Mr/Ms Mzwandile KS Centre Khayamanadi CS 96 Bantu Holomisa St Khayamnandi Despatch
Qanda Mr/Ms Cleanet UNEWUSA CS 34 Bhobhoyi ST Motherwell NU8
Qebe Mr/Ms Phindile ANC - Uitenhage CS 5 Khanyisa St Uitenhage
Qekema Mr/Ms ANC - Kwazakhele CS 376 Siwisa St Kwazakhele
Qoni Mr ANC 43 Lawrence Vingqi Rd Kwanobuhle
Qoshani Ms Nomthandazo ANC P O Box 820 Addo
Quma Mr Zamuxolo SACP CS 1160 Mabindisa Street Port Alfred
Qupe Mr Bulelwa PE Fishing Forum 510 Govan Mbeki Port Elizabeth
Rabotapi Ms Joy AEL Buss 46 Emboren Street Birchleigh North
Radasi Mr/Ms ANC - New Brighton CS Block E1 White New Brighton
Location
Rademeyer Ms Pat UCT Library, Prof Private Bag Rondebosch
Government
Publications
Ranisi Mr Thozama ANC 801 Gruisground Missionvale
Rasmeni Mr/Ms Mbuyiselo SANCO Consultation CS 121 Hintsa St Port Elizabeth
Rawula Mr/Ms Bulelani ANC - Khayamnandi CS 214 Soloman Mahlangu Khayamnandi Despatch
Raya Mr/Ms Vukile ANC Zwide CS 10 Tshiki Street Zwide
Rezi Mr/Ms Mzwandile ANC - Zwide CS TN313A Veeplaas Port Elizabeth
Richards Mr Graham CEO PE TLC Gov PO Box 116 Port Elizabeth
Richards Mr Bob Nukakamma Canoe Trail Buss PO Box 36 Colchester
Riordon Mr Rori Director Human Rights Trust CS PO Box 13197 Humewood Port Elizabeth
Rockman Mr Christopher SACP PE CS 294 Barberry Dr Ext 34 Bethelsdorp
Rode Mr Phindile Rode Builders 20517 Xundu St Govan Mbeki Port Elizabeth
Township
Rogers Mr Guy EP Herald Media P O Box 1117 Port Elizabeth
Rossouw Ms/Mr Protea Place of Safety Gov PO Box 13383 Humewood
Roux Mr Swartkoppen (Farm LO PO Box 2434 North End
North of Coega)
Royi Mr Siphiwo ANC Motherwell CS 74 Busila Street NU4A Motherwell
Royle Ms Carol Gardneri Investments Indiv PO Box 144 Sunland
(PTY) Ltd
Rubusana Mr/Ms SACP PE CS P O Box 14 Mendi Rd New Brighton
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Street
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Mr
APPENDIX E:
FORENSIC AUDIT OF THE
RELOCATION PROCESS AND IMPACT
OF THE PROPOSED PORT OF NGQURA
FORENSIC AUDIT OF THE COEGA
RESETTLEMENT PROCESS AND ITS IMPACT
ON THE AFFECTED PARTIES
Prepared by:
H. Van Vlaenderen and N. Nongwe
Coastal & Environmental Services
P.O. Box 934
Grahamstown
6140
Prepared for:
Postnet Suite 35, Private Bag X 13130
Humewood
Port Elizabeth
6013
September 2001
EXECUTIVE SUMMARY
(I) BACKGROUND
The Coega Development Corporation (CDC) has been mandated by the South African
Government to investigate the viability of a Coega Industrial Development Zone (IDZ). Within this
development plan it is envisaged that a new deepwater port will be built and operated by the Port
Authority Division of Transnet to act as the primary transport facility for the IDZ. This proposed
port will be located at the mouth of the Coega River in Algoa Bay, which lies on the south-eastern
coast of South Africa.
An Environmental Impact Assessment (EIA) study for the port of Ngqura has been conducted by
Coastal and Environmental Services (CES). Although the EIA included a broad social impact
assessment, a detailed compensation and resettlement plan for the community that needs to be
resettled as part of the Ngqura deepwater port development did not form part of the approved plan
of study for the EIA.
The resettlement process is currently being undertaken and the CDC has received certain allegations
from civic and other interest groups with regard to the resettlement process and the impacts on the
resettled communities. In the light of this development a forensic audit of the process and impact of
the resettlement, outlining the nature and impact of the resettlement process to date was deemed
necessary. This report presents the results of this audit.
(II) AIMS AND OBJECTIVES
The forensic audit aims to provide the following information about the Coega resettlement.
• An assessment of the resettlement process and impacts according to World Bank guidelines.
• Conclusions and Recommendations.
(III) METHODS
Information for the audit was gathered through interviews with various stakeholders, consultation of
relevant documents, a survey of the resettled people and field observations.
(IV) OUTCOME OF THE FORENSIC AUDIT
The audit revealed that the Coega resettlement process as it unfolded has resulted in some positive
impacts for the resettled communities. Many of the resettled households now have access to housing
and facilities (such as water, sanitation, transport) which are of a better quality than in their original
communities. An Integrated Development Plan has been prepared by the NM3 for the resettlement
area, which is expected to address their needs for services, hopefully in the medium term future.
communities and has left those engaged in the process vulnerable to criticism.
Appendix E: Forensic audit of the Coega Resettlement Process i


• People with an economically weak status (a high percentage of unemployed people) have been
moved from a rural area, where they had developed a survival strategy, to an urban
such as water and electricity charges. This change in life style, coupled with a lack of financial
means to survive in an urban setting, may lead to marginalisation of the resettled people, resulting
in feelings of disempowerment and in decreased physical and mental well-being. It needs to be
acknowledged, however, that due to the contributions of CDC, people were relocated in Phase
I Wells Estate, instead of Phase II or III, which provided them with additional benefits, above
those of a normal RDP housing development.
do not meet the people’s expectations. The houses have many of the problems and
characteristics associated with low cost housing.
In order to mitigate these impacts the following recommendations are made:

ongoing development plan should be established, which ensures that people’s quality of life is
focus of such a plan. The implementation of the plan should be the responsibility of both the
CDC and NM3.
polarising groups within the affected community.
• A plan to monitor and evaluate people’s living conditions and to address unforeseen problems
should be set up.
ii Appendix E: Forensic audit of the Coega Resettlement Process

TABLE OF CONTENTS
1. INTRODUCTION ........................................................................................................... 1
2. OBJECTIVES OF THE FORENSIC AUDIT ................................................................ 1
3. RESEARCH APPROACH .............................................................................................. 2
3.1 Data collected ......................................................................................................... 2
3.2 Data collection process............................................................................................ 2
4. RESULTS OF THE FORENSIC AUDIT....................................................................... 3
4.1 The stakeholders ..................................................................................................... 3
4.1.1. Coega Development Corporation................................................................. 3
4.1.2. Western District Council.............................................................................. 3
4.1.3. Nelson Mandela Metropolitan Municipality.................................................. 3
4.1.4. The communities.......................................................................................... 3
4.1.5. Community representatives .......................................................................... 4
4.2 Background to the resettlement process. .................................................................. 4
4.2.1. The Coega Community................................................................................ 5
4.2.2. The Council Ground and King Neptune Communities................................... 6
4.3 The resettlement process. ........................................................................................ 6
4.4 Roles of the different stakeholders............................................................................ 7
4.4.1. The CIA/CDC fulfilled the following roles and tasks ..................................... 7
4.4.2. The WDC fulfilled the following roles and tasks............................................ 8
4.4.3. The PETLC/NM3 fulfilled the following roles and tasks................................ 9
4.4.4. The community representatives fulfilled the following roles and tasks.............. 9
4.4.5. The community members fulfilled the following roles and tasks ...................... 9
4.4.6. ANC regional and national structures and SANCO national,
governmental authorities............................................................................. 10
4.4.7. Other Stakeholders.................................................................................... 10
4.5 The resettled communities’ experience of the resettlement process.......................... 10
4.5.1. The decision to move................................................................................. 10
4.5.2. The resettlement process............................................................................ 11
4.6 The impact of the resettlement on the resettled communities.................................... 12
4.6.1. Housing..................................................................................................... 12
4.6.2. Employment and economic status............................................................... 13
4.6.3. Land for grazing and cultivation.................................................................. 13
4.6.4. Graves ...................................................................................................... 14
4.6.5. Health services .......................................................................................... 14
4.6.6. Educational facilities................................................................................... 14
4.6.7. Electricity.................................................................................................. 15
4.6.8. Water........................................................................................................ 15
4.6.9. Sanitation.................................................................................................. 15
4.6.10. Transport and access to facilities................................................................ 16
4.6.11. Safety........................................................................................................ 16
4.6.12. Natural resources ...................................................................................... 16
4.7 Communities’ experience of their resettlement ........................................................ 16
5. AN ASSESSMENT OF THE RESETTLEMENT PROCESS AND IMPACT IN
RESPECT OF WORLD BANK GUIDELINES .......................................................... 17
6. CONCLUSION AND RECOMMENDATIONS......................................................... 20
Appendix E: Forensic audit of the Coega Resettlement Process iii

7. APPENDICES…………………………………………………………………………223
Appendix A: Sources of Information
Appendix B: Relocation Conditions by Coega community to be met by District
Council and Ngqura Implementing Authority
Appendix C: Letter regarding physical relocation to Wells Estate
Appendix D: Hand-Over Certificate
Appendix E: Relocation package in respect of the Coega community
iv Appendix E: Forensic audit of the Coega Resettlement Process

1. INTRODUCTION
The Coega Development Corporation (CDC) has been mandated by the South African
Government to investigate the viability of a Coega Industrial Development Zone (IDZ). Within this
development plan it is envisaged that a new deepwater port will be built and operated by the Port
Authority Division of Transnet to act as the primary transport facility for the IDZ. This proposed
port will be located at the mouth of the Coega River in Algoa Bay, which lies on the south-eastern
coast of South Africa.
An Environmental Impact Assessment (EIA) study for the Port of Ngqura has been conducted by
Coastal and Environmental Services (CES). The area covered by the assessment is the area
enclosed by the port limits as described in Government Gazette No 19401 of 28 October 1998.
This area includes the main marine infrastructure, back-of-port activities and other land uses
seaward of the National Road (N2). Although the EIA included a broad social impact assessment, a
detailed compensation and resettlement plan for the community that needs to be resettled as part of
the Ngqura deep water port development, did not form part of the approved plan of study for the
EIA.
The resettlement process is currently being undertaken and the CDC has received certain allegations
from civic and other interest groups with regard to the resettlement process and the impacts on the
resettled communities. In the light of this development a forensic audit of the process and impact of
the resettlement, outlining the nature and impact of the resettlement process to date was deemed
necessary. This report presents the results of this audit.
It is important to note that the research period for the audit was 14 days and as such, is limited to a
depth of analysis possible during such time-span.
2. OBJECTIVES OF THE FORENSIC AUDIT

The forensic audit aims to provide the following information about the Coega resettlement.
• An assessment of the resettlement process and impacts according to World Bank guidelines.
• Conclusions and Recommendations.
It is important to note that the audit focuses on the socio-political aspects of the resettlement
process, rather than on the legal aspects, which are in the realm of legal experts. The resettlement
process embarked upon with respect to the Coega development is described in terms of ‘best
practice’ as outlined by the World Bank guidelines for resettlement and does not scrutinise the
lawfulness or legal status of the resettlement process.
It is also important to note that the main focus of the audit is the King Neptune community. This
audit forms part of the EIA of the Ngqura Port and the only community resident in the area of the
port is King Neptune. However, since the resettlement processes of the three communities in the
overall Coega IDZ are interlinked, they have been included in the report.
Appendix E: Forensic audit of the Coega Resettlement Process 1

3. RESEARCH APPROACH
3.1 DATA COLLECTED
Information for the audit was gathered through interviews with various stakeholders, consultation of
relevant documents and field observations. The following data collection took place.
• Interviews with:
o Themba Koza (CDC)
o Nancy Sihlwaya (PE Nelson Mandela Metropolitan Municipality)
o Bongani Gxilishe (Western District Council)
o Members of the Executive Committee of SANCO-PE
o Sarah Sephton (Legal Resources Services)
o Ben Hiles (Urban Services Group)
o Mathew Angus (Rhodes University student, conducting a study on resettlement in the
Coega area)
o Three inhabitants of the Coega community, who have not been resettled.
o Thembikoza Mafana (ANC local branch at Wells Estate)
o Rosina Matibele (Representative of the Relocation Project Steering Committee).
• A survey was conducted at Wells Estate including:
o 34 households who were resettled from King Neptune
o 15 households who were resettled from Council Grounds
o 15 households who were resettled from Coega.
Because the King Neptune community is the main focus of the report, as many households from
King Neptune as were feasible to reach in the allocated time were included. For the resettled
communities of Council Grounds and Coega, a smaller sample was taken. However to avoid bias, a
random sample was attempted. Every tenth household was selected for the survey, until a total of
fifteen households was reached. Where a tenth household was not available (due to absence or
refusal to talk to the researcher), the next house was selected. Six households refused to talk to the
researcher.
• Documents consulted include:

o Reports from CES
o Documents provided by the CDC
o Minutes of meetings between Western District Council, PE Transitional Local Council and
Coega Implementation Agency
o Reports produced by Matthew Angus
o Α socio-economic and health survey report produced by a team of researchers from UPE
• Observations by the researchers took place at Wells Estate, King Neptune, Council Ground
and the Coega area.
See Appendix A for a comprehensive list of sources and types of data collected.
3.2 DATA COLLECTION PROCESS

The research team (consisting of the two authors of the report and a field assistant) adopted a
standardised approach to the people interviewed. The team introduced itself to the interviewees as
consultants for CES and explained that the aim of the interview was to gather information for a
2 Appendix E: Forensic audit of the Coega Resettlement Process

forensic audit about the resettlement process of the communities from the Coega IDZ area to Wells
Estate. It was also indicated to the interviewees that they were free to decline the interview.
Amongst those approached, only the Human Rights Commission declined an interview and justified
this by explaining that they were currently investigating the resettlement process and that their
information was not available for scrutiny. Six community members, two from Council Ground and
four from the Coega community declined to take part in the survey. They said they felt anxious to
talk to a researcher about their feelings.
4. RESULTS OF THE FORENSIC AUDIT

4.1 THE STAKEHOLDERS
What follows is a description of the different stakeholder groups and their representatives, involved
in the negotiations around the Coega resettlement process.
4.1.1. COEGA DEVELOPMENT CORPORATION
The Coega Development Corporation (Pty) Ltd is a body acting under government mandate to
facilitate the delivery of the Coega Project. The CDC was established in September 1999 and took
over the functions of the Coega Implementing Authority (CIA), which was a Government structure
established in July 1998 to promote the Coega Project. CDC has been represented in the
resettlement process by Themba Koza (environmental specialist) and Pepi Silinga (CEO).
4.1.2. WESTERN DISTRICT COUNCIL
Western District Council (WDC) is a Port Elizabeth local government structure, which had
jurisdiction over the Coega community during the preparation phases of the resettlement process
until 1999. The WDC has been represented in the resettlement process by CEO Bongani Gxilishe,
the WDC chairperson and its administrative officer.
4.1.3. NELSON MANDELA METROPOLITAN MUNICIPALITY
The Nelson Mandela Metropolitan Municipality (NM3) is the local government authority
which has jurisdiction over the two resettled communities, King Neptune and Council Ground as
well as the Wells Estate resettlement area. The NM3 is the local government structure that took
over from the Port Elizabeth Transitional Local Council (PETLC) in December 2000. The NM3,
then the PETLC, has been represented in the resettlement process by the City Engineer, Liz Mc
Hugh; the Assistant City Engineer (Housing); and the Chairperson of the Housing Committee,
Nancy Sihlwayi.
4.1.4. THE COMMUNITIES
The King Neptune Community is located near the sea (Joorst Park), west of the water pipe and
falls into the NM3 jurisdiction. The community consists of about 45 households, none of which own
land in the area.

The Council Grounds community is an informal settlement, built on the site of an old road camp,
which lies to the west of the water pipe, close to the Truckers Inn, and falls under the jurisdiction of
the NM3. None of the community members own land in the area.
The Coega community is located east of the pipe-line, an area which used to fall under the
jurisdiction of the WDC, but is currently also included in the NM3. It consists of about 300 families
spread over several areas, including The Old Mission School, The Coega location, the Brickworks
hostel, the Cerebos hostel, and some small farmsteads. The Coega location consists of about 200
households. Many residents have lived there for over 30 years, but some have only arrived there
since the resettlement process has started. From discussion with community members and Angus
Matthew it appears that people did not have landownership status, but no conclusive information
was accessed. The Brickworks hostel has approximately 30 households, which have access to fairly
good facilities, including electricity in a common room, several taps and sanitation. The Cerebos
hostel has around 40 households. The land on which they live is owned by Cerebos and the people
will be resettled on Sundays River together with the salt works. The Old Mission School community
was established in 1950 by the Catholic Church. The mission is currently defunct and there are
about fourteen households who live on church land.
A socio-economic and health survey was conducted of all households in the Coega IDZ . (See
Rossouw, A., Potgieter, F.E and Venter, D.J.L, 1999. Social baseline report: Coega socio-
economic and health survey of households. University of Port Elizabeth.) For details of the study
the reader is referred to the report. Some of the main findings are however presented in this report.
4.1.5. COMMUNITY REPRESENTATIVES
Negotiations on behalf of all three communities was done through the following mechanisms:
• A Project Committee, consisting of community members. This committee was intended to
provide a link between the builders of the houses at Wells Estate and the beneficiaries. The
members of the committee are: Mrs R Matibeli (chair); Mr T Mafana (secretary); Mr R
Hendricks; Mr S Mzayiya; Mrs N Deyi; Mrs N Buqa; Mrs N Dyakamela; Mrs N Fiti; Mrs N
Juy; Mrs Z Bangani.
• Representation on:
o the PETRepC (Mr Mafana)
o the local council (Mr T Mafana)
o the Executive Committee of the WDC (Mr Mafana)
o the ANC local branch (Mr T Mafana)
4.2 BACKGROUND TO THE RESETTLEMENT PROCESS

The resettlement process was the result of a coming together of the needs and intentions of various
stakeholders.
The CDC needed to resettle communities, since no residential areas were allowed in the proposed
IDZ and the Coega Project was gaining momentum. The CDC approached the NM3 (then
PETLC) and the WDC to discuss the issue of resettlement.

The PE local government was involved in a low cost housing programme and was in the process of
developing areas in which people, such as those from Coega, could be resettled. It should be noted
that the Coega residents were not on their priority list.
The communities in the Coega IDZ area (particularly Coega community and Council Grounds),
were engaged in processes to enhance their living conditions, including upgrading their housing
facilities.
What follows is an account of the events leading to the resettlement in each of the three
communities.
4.2.1. THE COEGA COMMUNITY
The historical background to the resettlement of the Coega community can be traced back to 1994,
when the WDC, which at that time had jurisdiction over the Coega community, embarked on a
housing project for Coega. This was congruent with the Port Elizabeth local government programme
of establishing better houses and conditions for people living within the Coega area. This housing
project was to be developed in Pumlani, an area within the proposed IDZ area close to their original
site. The WDC identified 198 families as beneficiaries of this project. In 1996 the Provincial
Housing Board (PHB) approved the applications of the 198 people and surveying of the area in
Pumlani started. At that moment the Coega Development Project gained momentum and in July
1998 the Coega Implementing Authority (CIA), which is the predecessor of the CDC, approached
the WDC and explained the need for resettlement of all people from the proposed Coega IDZ area.
In terms of the Manufacturing Development Act No 187 of 1993 (as amended), it is envisaged that
no residential sites should be allowed in Industrial Development Zones.
The WDC and CIA jointly explored other possibilities for the housing project, and three alternative
sites were identified at, Colchester, Wells and Motherwell. These options were discussed with the
community at several meetings and they prioritised Colchester, which is located about 30 km from
Coega. People were taken to Colchester in buses to assess the site and WDC subsequently did a
household survey which revealed that 90% of the people were prepared to move to Colchester,
provided certain conditions were fulfilled. They drew up a list of demands, which they presented to
the WDC and CIA as conditions for their resettlement (see Appendix B). After further investigation,
the Colchester option was discarded for various reasons - the WDC/CIA felt that it could not fulfill
the demands of the community, the Colchester residents were not in favour of the resettlement and
there were problems regarding the purchase of land.
Meanwhile the process of identifying a suitable location had taken more than two years since the
approval of funds and the PHB advised the WDC that the funds approved for the Coega
Community Housing Project would be forfeited if the Project did not get underway. The two other
options were considered, namely Motherwell and Wells Estate and, the latter was chosen. Wells
Estate is located between Markman industrial township, Motherwell and the sea, and is
approximately 5 – 8 km from the various areas within Coega from which the families would be
relocated. Wells Estate was earmarked by the PETLC for development of a low cost housing
project for people under its jurisdiction. The Wells Estate development plan was demarcated into
three Phases. Phase I involved the development of 100 plots with ready-built houses, and was
allocated for people from ‘danger areas’, which were not appropriate for human habitation. Phase II
and III are earmarked for plots with minimum services. Communities which are accommodated in

Phases II and III are expected to build temporary structures pending approval of application for
funding to the PHB for construction of permanent structures. This policy is called the ‘Four Peg-
Policy’.
The WDC and CDC negotiated with the PETLC to have members of the Coega community (those
who qualified for a housing subsidy) accommodated in Wells Estate. Although they originally only
qualified for a Phase II or III, the municipality agreed in September 1999 to accommodate the
Coega community in Phase I, as they considered the Coega Development Project as a national
endeavour that needed to be supported. Approximately 200 houses were allocated to the Coega
community.
Since Wells Estate is under the jurisdiction of the PETLC, the municipality agreed in September
1999 to take over from the WDC as the developer of the housing project for the Coega community.
The PHB was notified of this arrangement and the WDC provided bridging finance for the
earthworks at Wells Estate. Once these decisions were made, the choice of Wells Estate as the best
resettlement option was communicated to the community.
4.2.2. THE COUNCIL GROUND AND KING NEPTUNE COMMUNITIES
The Council Ground community had been working together with the Urban Services Group since
1979 on an empowerment and sustainable development programme, which involved the
development of better houses and living conditions. As part of this endeavour, the Urban Services
Group was negotiating resettlement options with the PETLC on behalf of the community. The
research did not reveal any such existing programmes with the King Neptune community.
Once it was decided that the Coega community would be resettled on Wells Estate, CDC
approached the PE Municipality to also accommodate Council Grounds and King Neptune at Wells
Estate. As part of their low cost housing programme, the PETLC was able to accommodate those
communities in Phases II and III of Wells Estate. However, after negotiations with CDC, who
motivated for the need for uniformity for all those affected by the Coega IDZ Project, PETLC
undertook to accommodate the Council Ground and Neptune communities in the Wells Estate
Phase I and to assume the responsibility as the developer of the facilities for these communities.
Both communities were informed by their local political representatives about the need to relocate in
the short term as a result of the development of the Coega IDZ. They were also informed about
Wells Estate as the area of resettlement and their inclusion in Phase I. The PETLC identified the
community members who qualified for a housing subsidy and an additional 100 houses were
allocated for the resettlement of people from Council Ground and King Neptune.
4.3 THE RESETTLEMENT PROCESS

When the three communities had been informed about the move to Wells Estate (1999), a series of
community meetings took place to discuss the resettlement process. The researcher did not have
access to the minutes of those meetings, and as such cannot report on their exact content and
composition. However, from the interviews with the relocated communities, it can be derived that
various aspects of the resettlement were discussed by a variety of authorities. The majority of the
meetings were held with Mr Mafana (local ANC branch and councillor), but some meetings were
attended by Mr T Koza (CDC) and Mr Bongani Gxilishe (WDC). People discussed the types of
houses they would get and were informed about the extra compensation they would receive from

CDC (see Section 4.4. Roles of the CDC). They were also told that they would receive certain
services, including electricity and water in each house, flushing toilets, a permanent school, clinic and
land for a communal garden.
Building contractors were contracted by CDC, on behalf of the NM3, and houses were built. Some
of the community members were involved in the building of their houses under the supervision of the
contractors. The constitution of a Relocation Project Steering Committee was facilitated by NM3 to
liase between the beneficiaries and the builders.
Next, people were informed about the process of their physical resettlement. They were told that
they would receive a letter for relocation 7 days in advance of the physical relocation date. They
were sent a letter outlining the process of relocation. The letter stated the particular date they
needed to have their goods packed ready to be loaded on the truck to drive to Wells Estate (See
Appendix C for a copy of this letter). They were also asked to demolish their houses. The physical
relocation took place during June 2001.
Concurrent with the above process, people were asked to inspect their new houses for quality and
requested to sign a ‘hand-over certificate’ which gave them responsibility for the house and which
implied that they were satisfied with the condition of the house. Once this letter was signed it was
forwarded to the PHB for release of the funds to the developer (See Appendix D for a copy of a
hand-over certificate).
People’s goods were removed by truck to their new houses, followed by taxis, which transported
the community members. The people took possession of their houses. The conditions of their new
environment is elaborated in Section 4.6. ‘Impact of the resettlement’.
Currently approximately 300 households have been relocated from the Coega IDZ area. To the
researcher’s knowledge there are no people left in the King Neptune and Council Ground areas.
There are still some people left in the Coega community (no exact figures were available). Some of
those did not qualify for a housing subsidy, because their earnings are too high or because they have
been allocated a house in another area and/or did not want to move.
The nature of the resettlement of those living in the Cerebos hostel is regarded as depending on a
corporate agreement between CDC and the company employing the people.
4.4 ROLES OF THE DIFFERENT STAKEHOLDERS

In order to fully understand the nature of the resettlement process, the roles played and actions
taken by the various stakeholders, as well as the decisions made, is described below.
4.4.1. THE CIA/CDC FULFILLED THE FOLLOWING ROLES AND TASKS
• It motivated the need to relocate people from the IDZ.

• It searched for resettlement options for the Coega community together with the WDC.
• It identified, together with WDC, the Colchester area for resettlement of the Coega community.

• It rejected, together with the WDC, the Colchester area as a viable option due to various
reasons: problems with purchasing the land, too high demands of the community and a local host
community which was hostile to the move.
• Together with WDC, it negotiated with the PETLC to obtain accommodation for the Coega
community in Wells Estate Phase I.
• It negotiated with the PETLC to obtain accommodation for the King Neptune and the Council
Ground communities in Wells Estate Phase I.
• It assisted the NM3 as the developer of the housing project as follows:
o It contracted and provided bridging funds for an SMME company called MCDT to
manage the project of the construction of the houses, using a construction management
delivery approach.
o It appointed forty PDI small builders who were drawn from the database of NM3. These
builders hired some workers from the community of Coega to help in the construction of
the houses.
o It appointed and paid for transport used for the relocation of families from the Coega
Area. PDI SMMEs were used to transport and move families.
o It wrote letters to each household indicating the date and the process of their physical
relocation.
• It provided a resettlement package to the resettled households, including:
o Training for a maximum of one year to at least one member of each family in preparation
for the Coega Project.
o Οne job per family. Other members would be able to go into the labour pool.
o Preservation of graves in the Coega IDZ, by means of fencing.
o R3000 to each household (also those not qualifying for a housing subsidy). This sum was
used to put extras on the houses, which makes them of a higher standard than the ordinary
RDP houses (See Appendix E for a copy of the resettlement package).
• Together with the NM3, it has been engaging in discussions with the Department of Education
for the provision of a school for the entire Wells Estate. In the interim it will assist with the
provision of a structure that is similar to the one currently used at Coega. The erf for the interim
school has been provided and the CDC and NM3 are providing services for the school.
• Together with NM3 (and before that the PETLC), the WDC and the local and regional
representatives from the ANC, it holds monthly meetings at which the resettlement process and
the development of the resettled area are discussed.
From the above list it is clear that the CDC’s three main tasks were, first, to negotiate a resettlement
area for the communities which needed to move out of the IDZ area, with the relevant local
authorities; second, to assist the NM3, the developer of the resettlement process, and third, to
augment the usual local government resettlement package of the resettled households.
4.4.2. THE WDC FULFILLED THE FOLLOWING ROLES AND TASKS:
The main role of the WDC was to assist the Coega community with a housing project in Phumlani.
When the need for physical relocation from the IDZ became apparent, it worked together with the
CDC to identify another resettlement area. It subsequently handed over the role of developer for the
Coega community’s housing project in Wells Estate to MN3, but provided some funds for the
earthworks. The WDC is still involved in some of the joint meetings of CDC and NM3.

4.4.3. THE PETLC/NM3 FULFILLED THE FOLLOWING ROLES AND TASKS
The NM3 accommodated the communities of the Coega IDZ area in a Phase I of Wells Estate on
request of CDC and has assumed the role of developer, which involves the following tasks:
• It identified and accredited the beneficiaries of the Housing Project in the King Neptune and
Council Ground communities.
• It allocated a special project team to Wells Estate to co-ordinate development. This team is
composed of representatives from NM3’s Housing, Health and Education departments and
focuses on issues such as the provision of water and electricity (in each house), a permanent
clinic and a school.
• It is involved with the provision of an interim school structure (see above: roles of CDC).
• It has promised R2million for the development of small business ventures in the Wells Estate
community.
ΝΜ3 is involved in ongoing meetings with CDC.
4.4.4. THE COMMUNITY REPRESENTATIVES FULFILLED THE FOLLOWING

ROLES AND TASKS
• Mr Mafana, in his various capacities as councillor, member of the WDC Executive Committee,
member of the PETRC and as chairman of the local ANC branch, took part in the various
discussions and decision-making processes at those levels.
• The Project Steering Committee, which was created by the community as per requirement of
NM3 under the guidance of the chairperson of the committee, liased between the community
and the building contractors during the period that the houses were being built.
4.4.5. THE COMMUNITY MEMBERS FULFILLED THE FOLLOWING ROLES

AND TASKS
• Ηouseholds identified their beneficiary for the housing subsidy.

• The Coega community presented the WDC and the CDC with a list of conditions/demands to
move to Colchester (see Appendix B for list of demands).
• Some community members were engaged by the builders to help build the new houses.
• Some households demolished their houses, as was requested and some did not (personal
observation).
The following information is based on the survey data:

• The large majority (95%) of the communities’ members interacted (to varying degrees) in
community meetings held around the resettlement process.
• Not all households were aware of the fact that they applied for housing subsidies. People
interviewed from the Coega community all indicated that they applied for subsidy and so did
67% of those interviewed from Council Ground. However, amongst those interviewed from the
King Neptune community, only 44% indicated that they had applied for a housing subsidy, the
others were not aware of having applied for a subsidy.
• All families packed their goods and monitored the physical relocation of their goods.
• Some of the resettled households signed certificates accepting responsibility of their houses
(‘happy letter’) while others did not seem aware of having signed such certificate. Amongst

those interviewed from the Neptune community, 59% of the people signed the certificate, 53%
from the Council Ground community, and 100% from the Coega community.
• Some signed water agreement letters and some did not, or were not aware that they had done
so*.
• Some signed letters of the removal company for the delivery of their goods and some did not, or
were not aware that they had done so*.
* No percentages can be given for the last two items since these issues were not part of the formal
survey and as such were not discussed at each household.
4.4.6. ANC REGIONAL AND NATIONAL STRUCTURES AND SANCO

NATIONAL, GOVERNMENTAL AUTHORITIES
Due to the high political profile of the Coega project and the controversy developed around the
resettlement process, discussions have been held at various levels of authority and government. The
researcher is aware of these discussions, but had no access to the specific nature and content of
those meetings.
4.4.7. OTHER STAKEHOLDERS
Besides the direct stakeholders involved in the resettlement process, the following parties have had
an impact on the resettlement process:
• SANCO PE
• Mandela Metropolitan Sustainable Coalition (MMSC)
• South African Human Rights Commission (SAHRC)
• Legal Resources Centre (LRC)
The MMSC opposes the Coega Development, including the resettlement process, which it criticises
on human rights grounds. SANCO, after discussions and co-operation with the SAEP (a member of
the MMSC) has lodged a complaint with the Human Rights Commission on behalf of the Coega
community regarding the nature and impact of the resettlement process. The Human Rights
Commission is currently investigating these allegations and has called upon the LRC to assist them in
this respect. To date the SAHRC has not released the results of their investigation.
4.5 THE RESETTLED COMMUNITIES’ EXPERIENCE OF THE

RESETTLEMENT PROCESS
The experiences expressed in this report are predominantly gleaned from the survey data and further
clarified using information from the interviews with other stakeholders and observations. It should be
noted that this information should be considered with caution. Due to the controversies around the
Coega resettlement and its high political profile, community members are anxious that any
information they volunteer may be used in the conflict between the various interested parties.
4.5.1. THE DECISION TO MOVE
The communities in the Coega IDZ area, more specifically Council Ground and Coega, were
already involved in a process of negotiation around housing, when the CDC announced its need to
relocate them from the IDZ area. As such a ‘mood of change’ was present amongst the

communities and there was a general acceptance, amongst the majority of the people, to move, and
an expectation of positive change in their standard of living. Although the researcher is not aware
that a similar development was underway in Neptune, there also seemed to be a willingness amongst
the Neptune community to be involved in a resettlement process.
The Coega community was initially disappointed about the need to move out of the IDZ area since
the surveying at the Phumlani area had already started. They accepted the need to move, but were
subsequently frustrated about the uncertainty and time consuming process of identifying a suitable
resettlement area for them. When Colchester was identified as a possible option, they were
disappointed that their conditions to move to Colchester were mostly not met. Eventually those
people who qualified for a housing subsidy accepted the conditions to move to Wells Estate.
However, not all people have moved to Wells Estate for a variety of reasons (some did not qualify
for housing subsidy, some people’s resettlement is tied up with their employment at the salt and
brick works, and some people did not want to move). This has created a division in the community.
The involvement of various interest parties with and on behalf of the two different parts of the
community (those who left and those who stayed) has enhanced that divide.
4.5.2. THE RESETTLEMENT PROCESS
With regards to the consultation process during the preparation period for the resettlement, varying
responses were gathered from the survey. Depending on how regularly community members
attended the community meetings, they would be more or less informed about the issues of
resettlement.
More than 90% of people interviewed emphasised that the various aspects of the relocation process
had been explained to them. People were informed about the decisions that had been taken. When
asked who addressed them at these meetings, the following agents were mentioned: CDC,
Councillors, Mr Mafana and the local ANC. Mr Mafana in his capacity of the local ANC
Chairperson seemed to have had the highest profile in those meetings. However, a large proportion
(more than 90%) of the people interviewed seemed unclear about the respective roles and
responsibilities of CDC, NM3 and WDC in the resettlement process. They mainly referred to Mr
Mafana as the one who informed them about resettlement issues. As a result, despite several
meetings, people still felt a degree of uncertainty about their situation and some had a fear that they
would not get a house.
More than 90% of those interviewed were very clear about the actual physical resettlement process
that was to unfold, including the letters sent to announce the physical relocation date and the
transport of their goods and themselves. A fair degree of frustration was experienced with regards
to the date of physical relocation. 12% were provided with the wrong date for their relocation and
two people said they did not get a letter. As a result trucks arrived several days before the
announced date and people could not pack their goods adequately. Others were anxious to be
relocated and insisted on being moved on dates earlier than indicated in their letters. 17% of the
people reported that they had their household goods damaged or stolen during the relocation.
There was unhappiness about the expected compensation of R50 that was to be paid out by the
different removal companies involved. It seemed that some companies paid out R50 to the people
they moved and others not. Twelve percent of the people indicated that they did not receive the
R50. The function of this R50 was understood in different ways. Some considered it as

compensation for the building material of the house, which they had left behind, others believed that
it was supposed to provide them with essentials for their first days in their new homes such as
candles, paraffin and meat.
.
There seemed to be a lack of understanding amongst the interviewed people about the signing of
different forms such as the ‘happy letter’ (letter resuming responsibility over the new house), the
water agreement letter, the letter for their physical relocation and a letter from the removal company
that their possessions had been removed. Many people said they did not sign such letters. Others
said that they are not sure about the different kinds of letters they had seen and/or signed.
4.6 THE IMPACT OF THE RESETTLEMENT ON THE

RESETTLED COMMUNITIES
What follows is an account of the estimated impact of the resettlement on the resettled communities.
The main source of information for this estimate is the survey conducted by the researcher with the
inhabitants of Wells Estate. Information from the previously conducted household baseline survey is
also included. It should be noted that the largest sample of people interviewed for the audit came
from the King Neptune area and the results are therefore skewed towards their perceptions. It also
needs to be reiterated that some respondents felt anxious about talking to the researcher and some
people declined to be interviewed. Observations of the original and resettled areas have been used
to corroborate the information from the survey.
In order to provide an assessment of the impacts of the resettlement on the resettled communities, a
comparison will be provided between the communities’ original living conditions, their expectations
for their resettlement conditions and the degree to which these expectations were met.
4.6.1. HOUSING
Original situation
The original housing situation of the community members interviewed varied considerably.
• In King Neptune families were housed in one- or two-roomed houses, which they described as
being of good and solid quality. Some were made from cement and others from brick, with
wooden floors.
• In Council Grounds, house sizes ranged from one to five rooms and the quality of the houses
was described, by all, as of very poor quality, being zinc shacks.
• At Coega community, the sizes of the houses ranged from one- to eight-rooms and the quality of
the houses ranged from bad quality zinc shacks to good quality brick houses.
The baseline survey data revealed that the majority of households have been in the area for 10
years. The majority of people do not pay for their housing at present and do not have disposable
income adequate to make up for additional housing costs.
Expectations
All community members expected to have a four-roomed house made from cement blocks with a
quality that was equal to (those who had a brick or cement house) or better than (those who lived in
shacks) their original dwelling.

Present situation
Almost all interviewees were happy with the size of their house but the large majority were
disappointed with the quality of their house. They complained about:
• Leaking roofs, windows and doors and, as a result, the coldness of the houses (70%)
• Dusty and rough floors (18%)
• Faulty door handles (7%)
• Doors and windows coming loose (4%)
• Unhygienic conditions because the toilet is next to the kitchen (2%)
4.6.2. EMPLOYMENT AND ECONOMIC STATUS
Original situation
The baseline survey revealed the following facts with regards to income and employment:
• The unemployment level is high.
• Salaries and wages are the primary sources of income.
• There is a low level of disposable income.
Amongst those interviewed from Council Ground, 33% of the people indicated that they were
unemployed or old age pensioners. Amongst the interviewees from King Neptune, 59% were
unemployed or old age pensioners. Amongst the interviewees from the Coega community, 46% of
the people were unemployed or old age pensioners.
Expectations
All respondents expressed the expectation of obtaining employment for one person in the household
with CDC once the project was developed.
Present situation
Currently the same employment situation prevails at Wells Estate. Several of the employed people
indicated that they are now closer to their workplace. Two people who had spaza shops said that
their business is better than before.
4.6.3. LAND FOR GRAZING AND CULTIVATION
Original situation
17% of the interviewees indicated that they had livestock and poultry, and a need for grazing.
The responses to the issue of availability of a yard for vegetable cultivation varied. 46% of the
people indicated that they had a small yard in their original settlement. 24% of the respondents said
they originally had a large piece of land to cultivate.
Expectations
92% of the people had no expectations about the availability of grazing land at Wells Estate and
indicated that they had to sell their livestock. However a few respondents had expected an area of
grazing land. Most interviewees expected a yard.
Present situation
78% of the people indicated that they were satisfied with the plot they were allocated at Wells
Estate, because they felt it was big eno ugh to keep some chickens or to grow some vegetables.

However, 28% of the respondents said that the community was promised a communal garden and
that they needed this. In the interviews with SANCO, it was said that some people were still grazing
their livestock in the Coega area, although they had been moved and that theft of livestock had been
a problem, since people cannot monitor their animals. Also, those people who are still living in the
Coega community indicated their reluctance to move away from their livestock, since it is a vital part
of their livelihood. The report from Matthew Angus also indicated the importance people attached
to livestock.
4.6.4. GRAVES
Original situation
People used a variety of sites for their graves. For all three communities the most often used sites
were Motherwell, Korsten and Coega.
Expectations
The interviewees did not expect a graveyard at Wells Estate, and intended to use Motherwell. They
felt assured that their existing graves at Coega would be preserved and protected. It was
understood that fences would be built around them.
4.6.5. HEALTH SERVICES
Original situation
The people from the Coega community used to be serviced by a permanent clinic in their
community. People from King Neptune and Council Ground were serviced by a mobile clinic or
traveled to the Coega clinic.
Expectations
All respondents expect a permanent clinic at Wells Estate. Some expected the clinic to be already
serviceable, others expect that the clinic will be built in the near future.
Present situation
The people at Wells Estate are currently being serviced by a mobile clinic or use the clinic at
Motherwell. In the interview with NM3 it was confirmed that as part of the Integrated Development
Plan, a clinic would be built at Wells Estate, but no date for its construction was provided.
4.6.6. EDUCATIONAL FACILITIES
Original situation
All three communities were serviced by a primary school at Coega. The Council Ground and King
Neptune communities paid between R50 and R100 per child per month for transport to the school.
Expectations
All respondents expect a primary and secondary school to be built at Wells Estate.
Present situation
The children at Wells Estate are currently still attending the school in Coega and transport is
provided by CDC free of charge. A site for an interim school building is currently being serviced and

a primary and secondary school are planned in the medium term as part of the Municipal Integrated
Development Plan.
4.6.7. ELECTRICITY
Original situation
The majority of respondents did not have electricity.
Expectations
It is the expectation of all respondents to have electricity inside their houses and in the street. People
expect to have electricity by the end of 2001.
Present situation
Currently there are high-mast lights in the streets of Wells Estate, but no electricity inside the houses.
In the interview with NM3 it was confirmed that electricity would be provided to Wells Estate, but
no date was provided.
4.6.8. WATER
Original situation
Respondents all made use of communal water provisions, except for three respondents from the
Coega community who had their personal taps. The baseline survey confirmed that the majority of
people used a communal tap.
Expectations
All respondents expected to have running water in their homes.
Present situation
In Wells Estate 25% of respondents had not yet been connected to the water supply. People have
to sign Water Agreement letters, indicating that they will pay for the water provision, and pay a
connection fee. Those not connected yet, may not have signed the necessary connection form.
4.6.9. SANITATION
Original situation
The sanitation provision in the original communities ranged from total lack of facilities, to pit latrines
and a bucket system (this is confirmed by the data from the baseline survey).
Expectations
All respondents expected a flushing toilet.
Present situation
The Wells Estate houses have flushing toilets, but those that do not have running water yet cannot
make use of this ‘flushing’ facility.

4.6.10. TRANSPORT AND ACCESS TO FACILITIES
Original situation
The King Neptune community was very far from available public transport. People had to walk
several kilometres to the road from where they hitchhiked to their destination. At Council Grounds
and at Coega taxis were available nearby.
Expectations
All respondents expected a taxi rank near Wells Estate and some indicated that the taxi
organisations had promised them to provide a taxi service.
Present situation
The taxi facility is nearby, but no specific service is organised for the Wells Estate community. A
considerable number of respondents expressed their happiness about being closer to PE City and
their work environment. Some respondents said that they were further away from their place of
employment and their livelihood activities (eg fishing).
4.6.11. SAFETY
The issue of safety was not part of the survey, but some respondents from Council Ground and
King Neptune indicated that they feel safer in their new environment.
4.6.12. NATURAL RESOURCES
The baseline survey report indicates that wood is used by about 25% of the households for heating
and cooking. Although no formal question was asked about the use of natural resources, two
interviewees said that they used to collect aloe juice for pharmaceutical purposes and the report of
Matthew Angus indicated that people collected medicinal plants. One respondent indicated that he
used to fish and no longer has access to the sea.
4.7 COMMUNITIES’ EXPERIENCE OF THEIR RESETTLEMENT

When asked to provide an overall assessment of their new living conditions and the degree of
fulfillment of their expectations, the following responses were given:
The majority of people are happier in their new environment. Two main factors were mentioned for
this:
• Owning their own house (43%).
• Being close to facilities and town (39%).
One person said she wanted to go back to Coega, because she was missing it, since she had lived
there for a long time.
Most of the respondents said that not all their expectations had been fulfilled. Those mentioned
were:
• The quality of the houses is not good (leaking roofs, no ceiling, faulty toilets etc) (30%).
• They did not receive the R50 they were promised from the removal company (25%).

• They had expected to receive the R3 000 from CDC in cash so that they could improve
their houses. 26% of the respondents are not aware that the R3 000 was used for the
construction of the houses.
• They are disappointed that the facilities such as electricity, schools, clinics, and communal
garden, which were promised, are not ready yet (18%).
5. AN ASSESSMENT OF THE RESETTLEMENT PROCESS

AND IMPACT IN RESPECT OF WORLD BANK
GUIDELINES
The World Bank policies, procedures and standards in terms of resettlement are contained in its
Operational Directives (OD) and, in particular, OD 4.30: Involuntary Relocation (June 1990).
Involuntary resettlement refers to any situation in which the resettled communities do not have an
option to stay in their original living environment, even if they willingly relocate. The three primary
objectives of OD 4.30 can be summarised as follows:
• To ensure that the population displaced by a project receives benefit from it (the project).
• To ensure that affected people benefit from development projects.
• To avoid and mitigate potentially adverse effects, on affected people, brought about by World
Bank-assisted activities.
Driven by the objectives of OD 4.30 several policy guidelines are identified. These are provided
below and the Coega resettlement process is evaluated against those guidelines:
Where resettlement is unavoidable, resettlement plans should be developed, and all

resettlement should be seen and executed as development programmes.
The resettlement process with regards to the Coega Project involved the merging of different
interests and plans. The CDC needed to have the communities removed from the IDZ, and the local
government was involved with a housing programme for which the Coega communities qualified.
The CDC’s role has been to speed up the process of resettlement, to facilitate the identification of a
relocation site outside the IDZ and to assist the NM3 as developer of the resettlement area. Plans
for the resettled communities were developed jointly by PETLC, CDC and WDC. The NM3 is
developing an Integrated Development Plan for Wells Estate, including educational, health and other
facilities as well as incentives for small business development.
However, the resettlement process for the Coega Project was not based on a comprehensive
relocation and compensation plan, which would have outlined all the different steps and aspects of
the resettlement and compensation before the resettlement took plac,e and which would have
outlined the organogram of decision making and responsibilities. As such it created a degree of
insecurity, disappointment and anxiety amongst the resettled people (see also baseline survey).
Displaced persons should be compensated for their losses at full replacement cost prior to
the move.
In the Coega resettlement process, no household survey took place to assess each individual
household’s assets and livelihood indicators, no individualised household compensation packages
were prepared and no mitigatory measures were devised and agreed upon for each household. All

households that qualified for accommodation at Wells Estate were considered equal for the purpose
of resettlement. They were all presented with the same resettlement package, regardless of their
original circumstances. As such, some community members benefited or lost more than others. For
instance those who had livestock or who had good quality houses with more than four rooms did
not benefit in the same way as those who were resettled from shacks, with no access to land.
Resettlers should be assisted with the move and provided with support during the
transition period.
The communities were assisted with the physical relocation to their new environment. As described
above, some problems were experienced during the resettlement process. It is also envisaged that
people may experience some problems during the transition period. People who used to have
vegetable gardens, or who intend to grow vegetables in their new location, will experience a period
during which they will not be able to harvest produce.
Resettlers should be assisted with their efforts to improve, or at least restore, their former
living standards, income earning capacity and production levels.
The Coega Project resettlement process is attempting to improve the living standard of the
communities by the following means:
• CDC promised to provide training and one job per family. However the fulfillment of this
promise depends on the nature of the development of the Coega Project. In any event the
provision of training and jobs is a medium or longterm prospect. No development has happened
to date and the controversies around the resettlement process may have a delaying effect,
holding up the community’s opportunities for employment.
• The Municipality provided housing with sanitation, water and other promised facilities
(Education, Health, Electricity) and has undertaken to provide incentives for the development of
small businesses.
The majority of the people interviewed seemed reasonably satisfied with their new living conditions.
However the resettlement is also potentially impacting negatively on the resettled community. The
following are some of the threats to people’s living standards.
• From the survey at Wells Estate it has become apparent that the people do not consider the
quality of their houses as adequate. The leaking roofs, dusty floors and the cold can create
health problems.
• Moving people from a rural or semi-rural environment to an urban environment cuts them off
from their rural resources. Economically vulnerable households that relied on cultivation,
livestock, use of firewood as fuel, fishing and ethnobotanical resources (see baseline survey)
have lost their rural livelihoods, and these have not been replaced. Some households may not be
able to purchase fresh produce to replace the produce they previously cultivated themselves.
This in turn may have an impact on their health. Furthermore, the change to an urban lifestyle
implies additional costs for water, electricity, paraffin etc, which may put further pressure on
their economic resources. It is noted that a more in depth study is needed to assess the extent to
which the communities relied on their rural and natural resources.
• Moving people from a rural or semi-rural environment to an urban environment can also create a
loss of ‘sense of place’ amongst the resettled people. In the survey at Wells Estate only one
person indicated such sentiments, while the others seemed to appreciate the advantages of an
urban setting. Sentiments of attachment to the land were more strongly expressed by the people
who had remained at Coega.

Community participation in planning and implementing resettlement should be encouraged.

Also, appropriate patterns of social organisation should be established, and existing social
and cultural institutions of the resettlers and hosts should be supported and used to the
greatest extent possible.
Community participation took place to a certain extent. People were informed about decisions made
and were given the opportunity to ask questions in community meetings. The Coega community was
involved to some degree in the selection of a resettlement area.
However some shortcomings with respect to community participation and social organisation can be
identified:
• The representation of the community on the various decision-making bodies seems to have been
mainly in the hands of Mr Mafana. Although it was the community who elected Mr Mafana, too
much responsibility seems to have resided in him and a wider representation may have been
beneficial. The fact that many interviewed people did not seem to understand the role of the
different stakeholders and the significance of the different forms suggests a shortcoming in
communication.
• With regards to the Colchester option for relocation people from the Coega community had
developed a list of demands. This list included some area-specific demands and some non area-
specific demands. Once the Colchester option became unviable, the list of (non area-specific)
demands was never revisited.
• The controversies around the resettlement and the involvement of the various interest groups
have caused a rupture in the affected communities and a feeling of unease amongst the
community members. The Coega community is divided into those who stayed behind and those
who moved to Wells Estate. At Wells Estate, there are those who are satisfied with the
resettlement and those who are not.
• To the researcher’s knowledge, households have been allocated houses without consideration
for the social patterns and community dynamics that may have existed in their original
communities. This may have caused a rupture in community support systems. More research is
needed to provide deeper insight into this.
There should be a detailed plan for monitoring and evaluating the socio-economic status of
resettled households over the duration of the project.
The existence of a monitoring and evaluation plan is not known to the researcher. However a
baseline report of the socio-economic status of the Coega community is available, which could be
used to develop a basis for a monitoring and evaluation plan.
Detailed plan, including the identification of responsibilities for the mitigation of

unforeseen negative impacts to households
The existence of a plan for mitigating unforeseen impacts is not known to the researcher.

6. CONCLUSION AND RECOMMENDATIONS

The Coega resettlement process as it unfolded has resulted in some positive impacts for the resettled
communities. Many of the resettled households now have access to housing and facilities (such as
water, sanitation, transport) which are of a better quality than in the original communities. An
Integrated Development Plan has been prepared by the NM3 for their resettlement area, which is
expected to address their needs for services, hopefully in the medium term future.
communities and has left those engaged in the process vulnerable to criticism.

• People with an economically weak status (a high percentage of unemployed people) have been
moved from a rural area, where they had developed a survival strategy, to an urban
such as water and electricity charges. This change in life style, coupled with a lack of financial
means to survive in an urban setting, may lead to marginalisation of the resettled people, resulting
in feelings of disempowerment and in decreased physical and mental well-being. It needs to be
acknowledged, however, that due to the contributions of CDC, people were relocated in Phase
I Wells Estate, instead of Phase II or III, which provided them with benefits, above those of a
normal RDP housing development.
do not meet the people’s expectations. The houses demonstrate many of the problems and
characteristics associated with low cost housing.
In order to mitigate these impacts, the following recommendations are made:

• In order to ensure that people are not worse off after the relocation, an authority approved
ongoing development plan should be established1, which ensures that people’s quality of life is
focus of such a plan. The implementation of the plan should be the responsibility of both the
CDC and NM3.
1
This plan must include, but not be limited to, those issues raised in this report, and should involve ongoing
independent review.

• A plan should be set up to monitor and evaluate people’s living conditions and to address
unforeseen problems..

22
Name Affiliation Involvement Interview issues Contact 7.
T. Khoza Environmental Resettlement process Resettlement process 041 507 9111
Manager Role of CDC and other stakeholders
Coega Development
Corporation
N. Sihlwayi NM3, Chairperson of Housing and resettlement Co-operation WDC – CDC and PE 041 506 3413
the Housing Integrated Development Plan Metropolitan
Committee Provisions for Wells Estate
community
PEOPLE CONTACTED
APPENDICES
History of resettlement process
B. Gxilishe Western District Housing Project and resettlement of Involvement in the Coega community 041 508 7911
Council Coega Community housing project and resettlement
Interaction with CDC and PEM
Committee SANCO Lodged a complaint about the process Allegations about the process and 041 453 4036
members and impact of the resettlement of the impact of the Coega resettlement
Coega community process
T. Mafana ANC local branch Community representative and Relocation process 083 314 434
Chairman of the facilitator in resettlement negotiations Community participation
PETRC and member of
APPENDIX A: SOURCES OF INFORMATION
the EXCO Western

District Council
Sarah Legal Resources Investigations of the allegations made Allegations about the process and 046 622 9230
Sephton Centre by SANCO impact of the Coega resettlement
process
Rosalyn Chairperson of the Resettlement process and impacts The resettlement process No contact
Matebele Relocation Project The impact of the resettlement process
Steering Committee on the people
Appendix E: Forensic audit of the Coega Resettlement Process

Ben Hiles Urban Services Group Involvement with Council ground Resettlement of Council Ground 041 585 4046
community Community
Matthew Honours student, Doing his project on Coega resettlement The Coega resettlement process and 046 603 8231
Angus Rhodes University impact on the people.
ISSUES INCLUDED IN THE SURVEY
• Basic biographical information

• Involvement of the community in the decision making process
• Process of resettlement as experienced by the community
• Awareness by the community of the tasks and responsibilities of the different stakeholders
• Expectations of the community and the level at which these expectations are met
• Level of satisfaction with the situation at Wells Estate
DOCUMENTS CONSULTED
CDC (July 2001) Response to a complaint lodged with the South African Human Rights
Commission by The South African Civic Organisation Port Elizabeth Against the Coega
Development Corporation (PTY )LTD. Report.
Coastal and Environmental Services (March 2000). Social Impact Assessment of proposed
Coega-kop quarry. Report.
Matthew Angus, (July 2000). Resettlement-related risks facing the Coega Community, Interim
Report. Dep. of Anthropology, Rhodes University.
Rossouw, A., Potgieter, F.E and Venter, D.J.L (1999) Social baseline report: Coega socio-
economic and health survey of households. University of Port Elizabeth.
23
APPENDIX B: RELOCATION CONDITIONS BY
COEGA COMMUNITY TO BE MET BY
DISTRICT COUNCIL AND NGQURA
IMPLEMENTING AUTHORITY
APPENDIX C: LETTER REGARDING
PHYSICAL RELOCATION TO WELLS ESTATE
APPENDIX D: HAND-OVER CERTIFICATE
APPENDIX E: RELOCATION PACKAGE IN
RESPECT OF THE COEGA COMMUNITY

Subsequent Port EIR

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Subsequent Port EIR

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THE SUBSEQUENT ENVIRONMENTAL

IMPACT REPORT FOR THE PROPOSED

(II) LOCATION AND GENERAL DESCRIPTION

Environmentally sensitive areas Phase 1 - port

Figure i: General layout of port and back-of-port areas.

(III) TERRESTRIAL ENVIRONMENT: DESCRIPTION AND

Executive Summary iii

SUMMARISED IMPACTS O N THE TERRESTRIAL EN VIRONMENT

Issue 1 – Loss and fragmentation of sensitive habitats

Issue 2 – Loss of biodiversity

IV) MARINE ENVIRONMENT: DESCRIPTION AND EXPECTED

Executive Summary vii

Issue 1 – Specific impacts on the nearshore environment

viii Executive Summary

(V) SOCIO-ECONOMIC DESCRIPTION AND EXPECTED IMPACTS

SUMMARISED IMPACTS O N THE SOCIO - ECONOMIC ENVIRONMENT

Issue 1 – Expansion of the skills base

Figure v: Positive socio-economic impacts associated with the Port of Ngqura.

xii Executive Summary

Ngqura Port - Sustainability

xiv Executive Summary

Ngqura Port - Equity

Ngqura Port - Efficiency

CHAPTER 1: INTRODUCTION ......................................................................................... 1

CHAPTER 2: ENVIRONMENTAL IMPACT ASSESSMENT PROCESS .................. 13

CHAPTER 3: PROJECT DESCRIPTION ....................................................................... 29

CHAPTER 4: DESCRIPTION OF THE TERRESTRIAL ENVIRONMENT.............. 53

CHAPTER 5: TERRESTRIAL IMPACTS AND MITIGATION .................................. 77

CHAPTER 6: MARINE DESCRIPTION........................................................................ 107

CHAPTER 7: MARINE IMPACTS AND MITIGATION ............................................ 119

CHAPTER 8: SOCIO-ECONOMIC DESCRIPTION ................................................... 143

CHAPTER 9: SOCIO-ECONOMIC IMPACTS AND MITIGATION ........................ 153

CHAPTER 10: FINAL DISCUSSION AND CONCLUSIONS ..................................... 183

CHAPTER 11: REFERENCE LIST................................................................................ 191

APPENDIX D: FINAL PUBLIC PARTICIPATION REPORT FOR THE

APPENDIX E: A FORENSIC AUDIT OF THE RELOCATION PROCESS AND

1b. Terrestrial Operational Issues ....................................................................................98

2a. Marine Construction Issues.......................................................................................120

2b. Marine Operational Issues ........................................................................................131

3a. Economic Issues..........................................................................................................155

3b. Social Issues................................................................................................................165

1.1.2 AREA COVERED BY THE EIR

Cape Town East London

Port Elizabeth Cape Recife

Landward port limits

Seaward port limits

Figure 1.1b: The seaward and landward gazetted Port Boundaries.

Existing tracks and paths

Environmentally sensitive areas Phase 1 - port

1.2 MOTIVATION FOR A DEEPWATER PORT 3

1.2.2 LOCATION AND GENERAL DESCRIPTION

1.3 OBJECTIVES OF THIS REPORT, THE SUBSEQUENT

In summary, this EIR aims to:

1.4 APPROACH AND STRUCTURE OF THE REPORT

1.4.1 APPROACH TO THE EIA

1.4.2 STRUCTURE OF THE REPORT

Chapter 2 - Environmental Impact Process

Chapter 3 - Project description

Chapters 4 & 5 - Terrestrial description and Terrestrial impacts and mitigation

Chapters 6 & 7 - Marine description and Marine impacts and mitigation

Chapters 8 & 9 - Socio-economic description and Socio-economic impacts and

Chapter 10 - Final Discussion and Conclusions

Appendix A - Plan of study for the EIR.

Appendix B - Coega Development Corporation Environmental Management Policies and