Transcription
Project: EnvironmentalReference: 503399Audit for GardenMossel BayPrepared for: Garden RouteCasinoComplianceRoute Casino,External Environmental Compliance Audit Report ionandOperationalEnvironmentalManagement ProgrammeRevision: 06 February 2019Audit Report Number: 04
Document Control RecordDocument prepared by:Aurecon South Africa (Pty) LtdReg No 1977/003711/07Suite 2012nd FloorBloemhof Building65 York StreetGeorge 6529PO Box 509George 6530South AfricaTFEW 27 44 874 2165 27 44 873 5843george@aurecongroup.comaurecongroup.comA person using Aurecon documents or data accepts the risk of:a)b)Using the documents or data in electronic form without requesting and checking them for accuracy against the original hardcopy version.Using the documents or data for any purpose not agreed to in writing by Aurecon.Document controlReport TitleExternal Environmental Compliance Audit Report for the Garden Route Casino’s EnvironmentalAuthorisation and Operational Environmental Management ProgrammeDocument ID111908File PathN:\Data\PROJECT\ENVIRO\PROJECTS\503399 Garden Route Casino\3 Project delivery\4Audit 2018\For review\Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docxClientGarden Route CasinoClient ContactRevision Details/StatusPrepared byAuthorReviewerCorlie SteynCorlieSteynWynandLoftusRevDate17 January 2019Current RevisionProject Number503399Verifier0ApprovalEAP SignatureNameCharles NormanTitleManagerThis report is to be referred to in bibliographies as: AURECON. 2018 External Environmental Compliance AuditReport for the Garden Route Casino’s Environmental Authorisation and Operational Environmental ManagementProgramme. Report No. 111908Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019 Revision 0
nmental Authorisation61.3.Operational Environmental Management Pr ogramme61.4.Objective, Scope and Methodology of the Audit6REQUIREMENTS AND OUTCOMES82.1Environmental Authorisation (EA):82.2Operational Environmental Management Programme9AUDIT SUMMARY293.129Assumptions, Uncertainties and/or Gaps in Knowledge4.COMPLIANCE WITH ENVIRONMENTAL LEGISLATION305.AUDIT STATEMENT AND CONCLUSION345.1Refreshed / Updated OEMP345.2Conclusion34Index of FiguresFigure 1: A portion of Management Zone 1.10Figure 2: Open area in front of the green belt in Management Zone 110Figure 3: Indigenous vegetation present in Management Zone 110Figure 4: Various indigenous species are present in the gardens surrounding the parking area.11Figure 5: The Garden Route Casino is currently removing all Kikuyu grass.11Figure 6: Owl boxes have been introduced to parts of Management Zone 2 to enhance the environmentalqualities of the site.12Figure 7: Landscaped areas with various indigenous species typical to the South Coast.12Figure 8: Rehabilitated area that was previously used to keep building materials during the constructionphase of the Casino.14Figure 9: New traps were installed in the parking areas to capture for e.g. cigarette butts.20Figure 10: Oil leaks from cars can create environmental pollution.20Figure 11: Generator.22Figure 12: Silencer22Figure 13: General waste.24Figure 14: Separating procedure for general waste.24Index of TablesTable 1: Requirements of an Environmental Audit Report as detailed in Appendix 7 of the NEMA EIARegulations 2014 (as amended).3Table 2: Approximate area of Management Zones.5Table 3: Audit rating matrix.7Table 4: Summary of Audit Findings29Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 1
Table 5: Regulations contained in Chapter 5 of the 2014 NEMA EIA Regulations (as amended) withcomments relating specifically to this environmental audit report and the Garden Route Casino’sOEMP.30AppendicesAppendix A: Decision on EA Amendment Application and Current Garden Route Casino EAAppendix B: Supporting InformationAppendix B1: ChecklistAppendix B2: Milkwood permitsAppendix B3: Landmark ContractAppendix B4: Environmental PolicyAppendix B5: Internal AuditAppendix C: Landmark Audit 2018Appendix D: Snake ManagementAppendix D1: Snake handler appointmentAppendix D2: Snake handling certificateAppendix E: EAP CVsAppendix F: EAP DeclarationsAppendix G: Map of Management ZonesAbbreviationsDAFFDepartment of Agriculture, Fisheries and ForestrydBADecibel A-weighted filterDEA&DPDepartment Environmental Affairs & Development PlanningEAEnvironmental AuthorizationELCEnvironmental Liaison CommitteeEMPrEnvironmental Management ProgrammeGRCGarden Route CasinoOEMPOperational Environmental Management ProgrammeORMSOrganisational Resilience Management SystemPPHOAPinnacle Point Home Owner’s AssociationSAHRASouth African Heritage Resource AgencySANSSouth African National StandardsProject 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 2
REQUIREMENTS OF ENVIRONMENTAL AUDIT REPORTSTable 1: Requirements of an Environmental Audit Report as detailed in Appendix 7 ofthe NEMA EIA Regulations 2014 (as amended).RequirementReferenceThe environmental audit report must provide for Sections 4 and 5.recommendations regarding the need to amendthe EMPr, and where applicable, the closure plan.Objectives of the Environmental Audit ReportThe objective of the environmental audit report isto:(a)Section 2 and 4report on—(i)the level of compliance with theconditionsoftheenvironmentalauthorisation and the EMPr, and whereapplicable, the closure plan; and(ii)the extent to which the avoidance,management and mitigation measuresprovided for in the EMPr, and whereapplicable, the closure plan achieve theobjectives and outcomes of the EMPr,and closure plan;(b)identify and assess any new impacts andrisks as a result of undertaking the activity;(c)evaluate the effectiveness of the EMPr, andwhere applicable, the closure plan;(d)identify shortcomings in the EMPr, andwhere applicable, the closure plan; andidentify the need for any changes to theavoidance, management and mitigation measuresprovided for in the EMPr, and where applicable,the closure plan.Content of Environmental Audit ReportsAn environmental audit report prepared in terms ofthese Regulations must contain—(a)(b)details of the—(i)independent person who prepared theAppendix Eenvironmental audit report; and(ii)expertise of the independent person thatcompiled the environmental audit report; Appendix Ea declaration that the independent auditor isindependent in a form as may be specified Appendix Fby the competent authority;Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 3
(c)an indication of the scope of, and the Section 1purpose for which, the environmental auditreport was prepared;(d)a description of the methodology adopted inSection 1.4preparing the environmental audit report;(e)an indication of the ability of the EMPr, andwhere applicable, the closure plan to—(i)sufficiently provide for the avoidance,managementandmitigationofenvironmental impacts associated with Sections 2, 3 and 4the undertaking of the activity on an ongoing basis;(ii)sufficiently provide for the avoidance,managementandmitigationof Sections 2, 3 and 4environmental impacts associated withthe closure of the facility; and(iii)ensure compliance with the provisions ofenvironmental authorisation, EMPr, and Sections 2, 3 and 4where applicable, the closure plan;(f)a description of any assumptions made, and Section 3.1any uncertainties or gaps in knowledge;(g)a description of any consultation processthat was undertaken during the course of No consultation process undertaken.carrying out the environmental audit report;(h)a summary and copies of any comments that No consultation process undertaken.were received during any consultationprocess; and(i)any other information requested by thecompetent authority.Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 4
1.INTRODUCTIONThe Garden Route Casino appointed Aurecon South Africa (Pty) Ltd (Aurecon) on 22 October2018 as External Environmental Auditor. The assignment entails the following: Reporting on the compliance with the requirements of the Environmental Authorisation(EA) dated 25 November 2010 (Ref: EG12/2/3/6/D6/27/1539/09); and Reporting on the requirements prescribed in the approved Operational EnvironmentalManagement Programme (OEMP1).This report presents the Environmental Audit as per: Site visit conducted on 22 November 2018; Photos taken during the site visit dated 22 November 2018; Status Quo update email dated 7 December 2018. Various information documentsattached in said email were received from the Security Duty Manager Craige Else atthe Garden Route Casino; andCompliance with the requirements of Appendix 7 of the National EnvironmentalManagement Act (NEMA) 2014 Environmental Impact Assessment (EIA) Regulations(as amended). 1.1.LocalityThe Garden Route Casino is located approximately 4km southwest of the coastal town ofMossel Bay on the south coast of the Western Cape Province. The site is on the top of a steepcoastal platform at an altitude of 150-185 m above sea level. The Garden Route Casino abutsthe Pinnacle Point Golf Estate.The approximate size of the various management zones as per the OEMP equatesapproximately to the following2 sizes in Table 2.Table 2: Approximate area of Management Zones.Management ZoneSizeManagement Zone 1 East 2 742m2Management Zone 1 West 9 075m2Management Zone 2 67 160m21The Operational Phase Environmental Management Programme (OEMP) was compiled by Planning Partners to deal with thelong-term management requirements of the Garden Route Casino. This OEMP was updated by Aurecon in conjunction with anApplication for Amendment of Authorisation(s). The decision on the EA amendment application as well as the current EA areincluded in Appendix A.2Craige Else, Security Duty Manager, Garden Route Casino, email corr. December 2018.Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 5
1.2.Environmental AuthorisationThe amended Environmental Authorisation was granted to Garden Route Casino on 25November 2010. Various environmental requirements listed in the Environmental Authorisationmust be complied with, including the following: 1.3.The holder of the authorisation must submit an Environmental Audit Report to theDirectorate: Land Management (Region 3) six months after construction has beencompleted and one year after the commencement of operations.The audit report must indicate the date on which the construction was completed, anddetail compliance with the conditions of the authorisation and the status of therehabilitation plan.Operational Environmental Management ProgrammeThe Environmental Management Programme was compiled by Planning Partners and isreferred to in the above mentioned Environmental Authorization. The OperationalEnvironmental Management Programme (OEMP) provides environmental managementrequirements under the following sections: 1.4.Management Zones;Ecological and Heritage Management;Management of Infrastructure;Visitor Management; andImplementation of OEMP3.Objective, Scope and Methodology of the AuditThe objective of the audit is to determine Garden Route Casino’s compliance with theEnvironmental Authorisation and OEMP on site.The audit and site visit were conducted on Thursday, 22 November 2018 and comprised ofdetailed site inspections, personal communications as well as verification checks of existingreports and documents.The Environmental Audit site inspection and compilation of the Audit Report (this report) wasconducted by:Me Corlie Steyn (Senior Environmental Assessment Practitioner - Aurecon)The Audit Report was reviewed and verified by:Mr Wynand Loftus (Senior Environmental Assessment Practitioner - Aurecon)Mr Charles Norman (Manager - Aurecon)3Garden Route Casino appointed Aurecon South Africa (Pty) Ltd (Aurecon) on 22 October 2018 to update the current OEMP toinclude the latest logo.Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 6
Audit findings are reported as the ratings referred to in Table 3.Table 3: Audit rating matrix.Audit ratingFull complianceAspects complying fully with the applicable EA and OEMPrequirements.Partial complianceAspects complying partially with applicable EA and OEMPrequirements.Non-complianceAspects not complying with the applicable EA and OEMPrequirements.No findingNot possible to assessProject 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 7
2.REQUIREMENTS AND OUTCOMES2.12.1.1Environmental Authorisation (EA):Refer below for the requirements and outcome relating to the EA.Requirements and Outcome: EARequirements:Section 20 of the Environmental Authorisation for the Garden Route Casino, datedNovember 2010: “The holder of the authorisation must submit and Environmental Audit Reportto the Directorate: Land Management (Region 14) six months afterconstruction has been completed and one year after the commencement ofoperation”. The audit report must indicate the date on which the construction wascompleted, and detail compliance with the conditions of the authorization andthe status of the rehabilitation plan.Observations:A copy of the checklists dated December 2012 and September 2015 for the first and secondenvironmental audits can be found in Appendix B1.Construction of the Casino was completed on 14 December 2011.Audit rating 2.1.1:Full Compliance4Previously Region 1, now Region 3: Central Karoo and Eden District Municipalities.Project 503399 File Enviro Audit 2018 Garden Route Casino FOR SUBMISSION.docx 6 February 2019Revision 0 Page 8
2.2Operational Environmental Management Programme2.2.11.Refer below for the requirements, outcome and photos relating to Management ZoneRequirements and Outcomes: Management Zone 1Management Zones: Requirements: Management Zone 1Two management zones are distinguished within the Casino site, namely disturbed fynbos(Zone 1) occurring in the north western and south eastern corners of the property, and theremainder (Zone 2) containing the casino building and associated facilities. A map indicatingthe Management Zones is included in Appendix G.Section 2.2 of the OEMP for the Garden Route Casino, approved November 2009: “This natural vegetation, which can be described as disturbed fynbos, is in a recoveryphase from previous disturbances/too-frequent fires. All fynbos, including individualmilkwoods and lance-leaf sugarbushes, is to be retained, protected and managed.All aliens are to be cleared on an on-going basis. No ad hoc access must be allowedinto this area, which is to be unmistakably demarcated and prominent signagedisplayed to clearly convey this requirement. Should low impact fencing be theCasino’s choice of demarcation, it is recommended that the fencing be raised fromground level in sections, by approximately 200mm, at appropriate intervals to allowthe through movement of smaller faunal species such as tortoises. The Casino mayalso consider modifying all fencing surrounding their property in a similar way tofurther encourage smaller faunal species to move between the individual propertiescomprising the greater Pinnacle Point developmentObservations: Management Zone 1Appendix B2 provides the licence (dated 18 July 2011) obtained from DepartmentAgriculture, Forestry & Fisheries (DAFF) to transplant 27 Sideroxylon inerme (whitemilkwood) saplings and you
The environmental audit report must provide for recommendations regarding the need to amend the EMPr, and where applicable, the closure plan. Sections 4 and 5. Objectives of the Environmental Audit Report The objective of the environmental audit report is to: (a) report on— (i) the level of compliance with the
