ESKOM LEEUWBOSCH SUBSTATION PROJECT VISUAL & HERITAGE IMPACT ASSESSMENT WITH RECOMMENDATIONS FOR MITIGATION. August 2014

Transcription

1 ESKOM LEEUWBOSCH SUBSTATION PROJECT VISUAL & HERITAGE IMPACT ASSESSMENT WITH RECOMMENDATIONS FOR MITIGATION Rheenendal, Western Cape DEA Reference: LSA August 2014 Applicant Eskom Holdings Limited: Eskom Distribution Western Operating Unit Eskom Road, Brackenfell, Western Cape PO Box 222, Brackenfell, 7561 Contact Person: Ms Justine Wyngaardt / Ms Barbara van Geems Tel: Fax: Wyngaajo@eskom.co.za / vgeemsb@eskom.co.za Pretoria (Head) Office 91 Wenning Street, Groenkloof, Pretoria, 0181 PO Box 947, Groenkloof, Pretoria, 0027 Cape Town Office 6 La Hey Close, Steynsrust, Somerset West, 7130 Central Contact Detail Tel: / Fax: / info@landscapedynamics.co.za agrobler@landscapedynamics.co.za Polokwane Office 40 Juno Street, Sterpark, Polokwane, 0699 PO Box 5977, Pietersburg-Noord, Polokwane, 0750 Emalahleni (Witbank) Office 13 Delft Street, Die Heuwel Proper, Emalahleni, 1035 PO Box 8772, Die Heuwel, Emalahleni, 1042

2 LIST OF CONTENT Section 1: Background Section 2: Public Participation Section 3: Specialist studies o Heritage Impact Assessment o Visual Impact Assessment Section 4: Final mitigation plan balancing public recommendations, VIA & HIA input as well as Eskom s technical requirements and financial constraints Section 5: Comments & s Report Section 6: Closure ADDENDA Appendix A Environmental Authorisation for the Blanco-Knysna powerline, 20 February 2009 Environmental Authorisation for the Blanco-Knysna powerline, 26 October 2009 (amended) Appendix B Appeal decision from the Department of Environmental Affairs, 14 November 2014 Appendix C - Public Participation C1) Proof of advertisements / notices for the public open day: o a) Advertisement in the Knysna-Plett Herald o b) Photographs of the onsite notices o c) Article published in the Eden Express o d) Invitations sent to Interested & Affected Parties C2) Attendance Register C3) Comments received after the open day C4) Registered Interested & Affected Parties Appendix D - Specialist Studies Heritage Impact Assessment Visual Impact Assessment

3 Section 1 BACKGROUND Environmental Authorisation (EA) for the ±100km Blanco-Knysna 132kV Eskom powerline was issued by the Department of Environmental Affairs (DEA) in February 2009, and amended in October 2009 (both EA s are attached in Appendix A). The Eskom Leeuwbosch Substation was included in the Environmental Authorisation as a project component of the Blanco-Knysna powerline and approved by DEA as part of this project. The substation was thereafter legally constructed. Numerous objections from the public were however received after completion of the substation and DEA requested in November 2013 that a Visual Impact Assessment as well as a Heritage Impact Assessment be undertaken. A public participation programme is also required to discuss the findings of these studies and to obtain input from the public. The Appeal Decision from DEA is attached in Appendix B. Please note that permission was granted by DEA to extend the deadlines as stipulated in this appeal decision. Landscape Dynamics Environmental Consultants was thus appointed by Eskom Distribution Western Operating Unit to ensure compliance with these DEA requirements. Section 2 PUBLIC PARTICIPATION PROCESS In order to comply with the DEA requirements, it was necessary to hold a public open day during which the main findings of the Visual Impact Assessment (VIA) and the Heritage Impact Assessment (HIA) could be communicated and discussed. An opportunity to address questions to the VIA and HIA specialists as well as Eskom personnel were also be provided. The open day was advertised as follows (proof thereof is attached in Appendix C1): The Knysna-Plett Herald An article about this project was published in the Eden Express, a local newspaper for Rheenendal Four onsite notices were placed at strategic places in relative close proximity to the substation. Invitations to attend were ed / posted / faxed to the landowners on the Interested & Affected Party Register as per the Eskom Blanco-Knysna 100km 132kV Project as well as to various government departments, municipalities and other interested and affected parties. The public open day was held on 8 May 2014 at the Totties Farm Stall in Rheenendal. The attendance register is attached Appendix C2. Written comment received after the open day is attached in Appendix C3. A summary of these comments and the Consultants responses thereto is provided in Section 5 of this Report. This report is being made available to all registered Interested & Affected Parties (the register is attached in Appendix C4) for a 40 day commenting period. Landscape Dynamics will not respond to comment received during this period. However, these comments will be included in the Final Report which will be submitted to the Department of Environmental Affairs for their perusal and final decision regarding the mitigation for the Leeuwbosch Substation.

4 Section 3 SPECIALIST STUDIES The Heritage Impact Assessment, undertaken by Perception Planning as well as the Visual Impact Assessment, undertaken by VRM Africa is attached in Appendix D. A short summary of the findings of these studies are provided below. HERITAGE IMPACT ASSESSMENT This report is an Integrated Heritage Impact Assessment (HIA) and includes historical background research and cultural landscape analysis. SYNTHESIS OF THE HISTORICAL BACKGROUND Records for early farms situated within the proximity of the site, namely Leeuwenbosch, Portland, Westford, Lawn Wood, Elands Kraal, Quarry Wood and Zuur Vlakte, also known as Sour Flats Woodcutters Location, now known as Bibbey s Hoek, were examined and the following was concluded: o Portland, Lawn Wood, Elands Kraal and Quarry Wood each have a family history of land ownership that relate to general farming activities, each with rich and personal history. The early Portland homestead, known as Portland Manor, is of high local historic, architectural and aesthetic cultural significance and is 2.3km east of the subject site. o In contrast, heritage themes identified on Leeuwenbosch and Bibbey s Hoek have wider social significance and are both intrinsically linked to the expansion of the local wood industry, the gold mining theme and consequent social history. o Tangible and intangible heritage resources include the Millwood Gold Field site to the north; the hectare Gouna Forest east of Portland; Portland Manor mentioned above; as well as the Thomas Bain road between George and Knysna which traverses the Homtini River to the west. o No Provincial Heritage Sites have yet been registered within the boundaries of the study area. HERITAGE RESOURCES AND ISSUES Built environment No structures, ruins or foundations of any kind were noted on or within the direct proximity of the proposed development site. Inter-visibility between the Portland farmstead and the substation is very limited due to (a) established vegetation within the landscape separating the two localities as well as (b) mature vegetation within the proximity of the historic farmstead itself. Landscape setting Rural landscape context The property forms part of an undulating rural landscape located on a higher-lying plateau along the foothills of the Outeniqua mountain range. The landscape character within the direct proximity of the subject property is mostly defined through agriculture and forestry. Cultural landscape context The term cultural landscape refers to the imprint created on a natural landscape through human habitation and cultivation over an extended period of time. The fact that natural and cultural landscape components in the region are distinguished means that the cultural landscape is likely to be very vulnerable to the cumulative impact of inappropriate large-scale development.

5 Analysis of early aerial photography for the study area reveals a number of traditional (i.e. Pre-Modern) cultural landscape patterns of Portland 187/36 and its direct environs: o Subject property located right along the shared boundary between early farms Portland and Leeuwenbosch; o Agriculture and cultivation evident within the landscape mostly along level and moderate slopes; o Remnants of indigenous vegetation occur within steeper sloping river valleys and its tributaries; o Present alignment of the Rheenendal Road mostly coincides with that of the historic road through this landscape; o The historic Portland Manor House is clearly legible - the importance of this precinct is emphasised by various access roads; o Intensive forms of land use evident within proximity of historic Homtini Outspan as well as Portland Manor house; o Forestry land use not evident within the landscape; o Linear planting of trees apparent - initially planted as windbreaks, these features left an impression of landscape framing, which contributes to the overall rural cultural landscape; o The occurrence of landscape framing appears to coincide with areas of intensive cultivation, the latter of which can be distinguished through a patchwork of smaller cultivated fields. The cultural landscape patterns identified are primarily associated with agriculture and cultivation, while forestry occurred further to the north. Intensive land use patterns occurred within the proximity of Portland Manor and Homtini Outspan but not within direct proximity of the subject property, save for what appears to have been non-intensive agriculture. Prior to construction of the substation and related infrastructure the rural cultural landscape within the direct proximity of the site is considered to have been of moderate local historic and aesthetical cultural significance. By reason of the severity of the impact of the substation, post-construction grading of the same heritage resource results in it no longer being of any cultural significance. Linear planting of trees as windbreaks are still evident within current landscape - which relates to a continuance of this cultural landscape pattern, though not necessarily in the same location or orientation as in the above 1942 aerial imagery. The practice of planting windbreaks, whilst functional, also results in landscape framing, thus contributing to the overall landscape quality and sense of place. There is a strong tendency towards use of exotic tree species (e.g. pine, bluegum, blackwood, etc.) for wind breaks and landscape framing. The substation is highly visible along a ±2km stretch of the Rheenendal Road as well as surrounding area, thereby eroding the rural cultural landscape character within this proximity. The intrusion caused through construction of the substation and overhead lines within this landscape is not reversible and cannot be fully mitigated. Visual Spatial Issues The Draft Visual Impact Assessment fully interrogates the above issues and proceeds to propose and assess the implications of the proposed mitigation measures. HERITAGE INFORMANTS AND INDICATORS Built environment The proposal does not have a negative impact on significant historic structures within its direct environs. Cultural landscape issues

6 o While little or no cultural landscape elements remain within the direct proximity of the site as a result of construction of the substation and associated infrastructure, introduction of linear planting aimed at enhancing the overall development through landscape framing must be considered; o In keeping with traditional landscape patterns, it is recommended that appropriate (non-invasive) exotic vegetation be used for landscape framing as meant above. Visual spatial issues o That the various mitigation proposals, as articulated through the Mitigation Alternative 3 Concept Plan by VRM Africa (June 2014), be implemented. RECOMMENDATIONS It is recommended: o That mitigation proposals set out in the Draft VIA (June 2014) as well as further response to comments from the PHNC, be implemented; o That the recommendations of this HIA be submitted to the Department of Environmental Affairs. VISUAL IMPACT ASSESSMENT The objective of the VIA is to generate mitigations to reduce the visual intrusion of the existing Leeuwbosch substation. LANDSCAPE CONTEXT The first step in the VIA process is determining the existing landscape context of the region and of the site where the project is proposed. Landscape character can be defined as the distinct and recognisable pattern of elements that occurs consistently in a particular type of landscape, and how this is perceived by people. It reflects particular combinations of geology, land form, soils, vegetation, land use and human settlement. It creates the specific sense of place or essential character and spirit of the place. Knysna and Rheenendal Tourist context Knysna falls within the Garden Route region which encompasses the world renowned Tsitsikama and Wilderness sections, the Knysna Lake section, a variety of mountain catchments, Southern Cape indigenous forest and associated Fynbos areas. Existing rural Rheenendal residential context Rheenendal is a pastoral country district about 10 km west of the town of Knysna and a popular tourist destination. The existing rural sense of place reinforces the value of the landscape. Existing agricultural sense of place The area surrounding the substation has an agricultural sense of place. There are well established dairy farms and the surrounding land is mainly made up of cultivated fields predominantly for dairy grazing. Topography The Rheenendal area is a hilly tree covered landscape. The substation is located on a plateau and the flat gradient results in water logging due to the clay nature of the soil. Vegetation The Rheenendal area is home to intensive agricultural plantations, critical biodiversity areas as well as ecological support areas and rural residential areas.

7 Road Infrastructure The N2 Highway runs though Knysna and the Rheenendal Road links the N2 and Rheenendal, which is the main access route to the hilly plateau area above the Knysna River Valley. The receptors using this road are of an agricultural, residential and tourist nature. Existing powerline infrastructure The existing substation and powerlines are part of the Blanco-Knysna Eskom powerline. There are two powerlines running parallel to each other through this area. Landscape character within a 500m buffer of the powerlines is degraded as the strongly undulating terrain often results in skyline intrusion which dominates the attention of the casual observer. SITE LANDSCAPE CHARACTER Landscape character is derived from a combination of scenic quality, receptor sensitivity to landscape change, and the distance of the proposed landscape modification from key receptor points. The Rheenendal Road at its nearest, passes within 50m of the substation, with initial views from westbound receptors taking place at a distance of approximately 200m, and eastbound receptors taking place at approximately 100m. The substation site was assessed and it was determined that the total value for scenic quality of the site was 6, which is defined as low. The receptor sensitivity was assessed in terms of type of users; amount of use; public interest; adjacent land users and special areas and it was determined to be high. VISUAL RESOURCE MANAGEMENT CLASSES Visual Resource Management Classes are representative of the relative value of the visual resources of an area: i. Classes I and II are the most valued; ii. Class III represents a moderate value; and iii. Class IV is of least value. The site was identified as having a low scenic quality but with high receptor sensitivity and high proximity to Rheenendal Road (MR355). Due to the significance of the MR355 as a tourist view corridor, it is recommended that Class III visual objectives be maintained. The current visual status of the substation as seen from the MR355 and surrounding receptors is more a Class IV due to the industrial nature of the substation. KEY OBSERVATION POINTS Key Observation Points (KOPs) are defined as the people (receptors) located in strategic locations surrounding the property that make consistent use of the views associated with the site where the landscape modifications are proposed. Three KOPs were identified for the site, all from the Rheenendal Road (eastbound, westbound and at the entrance to the substation). IMPACT ASSESSMENT OF STATUS QUO Extent Duration Intensity Probability Confidence Significance Local Permanent Medium to High Definite Medium to High Medium to High

8 Motivation for rating above The existing substation is an intrusive manmade structure in an otherwise pastoral landscape. The existing substation is situated on an exposed plateau and is visually stark. The site is already degraded by the existing two transmission lines. The existing tree screening along the road is showing signs of stress and many of the trees have died due to waterlogging. Without mitigation and the location on a plateau with high exposure to sensitive tourist related receptors, there is medium to high visual impact. MITIGATION Three mitigation alternatives were identified to lessen the visual impact of the existing Leeuwbosch Substation. Mitigation Alternative 1 This option uses a combination of a simple effective tree screen planted around the building platform as well as a system of berms, ponds and marsh under the powerlines on the north-western boundary. This particular tree screen is fast growing and will effectively break the visual impact of the substation as viewed from Rheenendal Road and adjacent farmlands except under the powerlines of the NW boundary. This is not the preferred option because Eskom will not create wetlands that will invite birding and nesting in close proximity to electrical infrastructure. The proposed mitigation also falls outside of the boundaries of the land belonging to Eskom. Mitigation Alternative 2 This soft option highlights a creative way of reconciling manmade structures in a pastoral landscape. The re-vegetation should enhance the local ambience as well as create screening of the structure. In order to create vegetative screening the waterlogged soil needs to be attended to. This option creates an effective biodiversity system achieved through community co-operation between Eskom and local landowners. Berms are to be created from soil excavated from ponds and marsh areas between the NW boundary and the building platform and on adjoining farmlands. This is not the preferred option because Eskom will not create wetlands / biodiversity hotspots that will invite birding and nesting in close proximity to electrical infrastructure. The proposed mitigation also falls outside of the boundaries of the land belonging to Eskom. Mitigation Alternative 3 The VIA preferred this mitigation alternative in that it extends and re-emphasises the initial mitigation measures by Eskom. This mitigation is also preferred in that it aligns with the Heritage Assessment findings which re-emphasises the importance of recreating the existing precedence for windrows which define the local cultural landscape PLEASE REFER TO THE SECTION HEREUNDER FOR THE FINAL RECOMMENDATIONS REGARDING MITIGATION MEASURES

9 Section 4 FINAL MITIGATION PLAN BALANCING PUBLIC RECOMMENDATIONS, VIA & HIA INPUT AS WELL AS ESKOM S TECHNICAL REQUIREMENTS AND FINANCIAL CONSTRAINTS The mitigation preferred by the Visual Impact Assessment incorporates recommendations made by the public into the original Alternative 3. The sketch below shows the mitigation as described hereunder: It restores and re-entrenches the initial tree screening mitigation adjacent the MR355 road undertaken by Eskom. Creation of a landscaped entrance consisting of a low berm planted with indigenous plants and shrub species at the entrance to screen views of the substation as seen from the road. Creation of a split pole fence and farm gates at the road entrance to tie into the agrarian landscapes. The gates would need to be stepped back from the road. Creation of a low berm with imported topsoil and planting of an indigenous hedge-row type screening shrubs on all four sides of the substation to break up the base views of the substation and security fence from all sides Planting of screening trees (at 3 metre intervals) to extend the existing north-south aligned pine windrow to the road (pending permission from landowner) Planting of trees (at 3 metre intervals) to the west of the substation entrance to assist in screening the views as seen from road receptors travelling southeast

10 However, this alternative is not acceptable to Eskom and cannot be implemented due to the following: The construction of a soil berm around the substation will not be allowed (not even on one side): from a technical point of view, soil berms are not allowed due to drainage problems it inevitably causes. A hedge and/or trees may only be planted if no part of the hedge and/or trees are within 2m from the kerbing (the kerb extends 1.2m from the fence) and if it can be of such a nature that it causes no security risk for personnel visiting the site at night. Should such a hedge and/or trees fall outside of the Eskom owned property, additional land will not be purchased by Eskom for screening purposes. With regards to the construction of a soil berm around the substation, the visual specialist responded as follows: We concur with the issues raised by Eskom with regard to no berming around the substation. As the five metre servitude around the substation is space constrained and is utilised for drainage, we recognise that if altered, the lack of drainage could jeopardise the substation founding which would be unacceptable. Please note that this was a requirement for the planting of the mitigation 'hedge-row' around the substation which will now fall away as it is unlikely that the soil conditions in the servitude will be conducive for the proposed planting. With regards to the construction of a soil berm around the substation, the heritage specialist responded as follows: Exclusion of the raised landscaped berm surrounding the site is regrettable as this means the site would remain highly visible from the surrounding landscape (i.e. further north and east of the site/ other than the Rheenendal Road). We note the reason for exclusion of the raised berm as previously recommended is due to a technical reason(s) and then assume there is no feasible technical solution to avoid deletion of this former mitigation measure. FINAL MITIGATION PLAN Taking into consideration public recommendations, findings from the VIA and HIA as well as Eskom s technical requirements and financial constraints, the following final plan is proposed: Plant trees in the road reserve as per the sketch below: o Planting of screening trees (at 3 metre intervals) to extend the existing north-south aligned pine windrow to the road (pending permission from landowner) o Planting of trees (at 3 metre intervals) to the west of the substation entrance to assist in screening the views as seen from road receptors travelling southeast Creation of a landscaped entrance consisting of a low berm planted with indigenous plants and shrub species at the entrance to screen views of the substation as seen from the road. Creation of a split pole fence and farm gates at the road entrance to tie into the agrarian landscapes. The gates would need to be stepped back from the road. Due to a high water table at certain areas along the road, much of the initial tree growth has been compromised due to water logging. It is unlikely that indigenous trees can be successfully planted as a windrow due to these wet and clay soil factors. To increase confidence in the mitigation, it is recommended that the proposed windrow mitigation be planted with a combination of pin oak (Quercus palustris), water oak (Quercus nigra) and Chinese popular (Populus simonii). In certain areas it might be possible to plant water berry (Syzygium cordatum) but with lowered confidence and possible reduced growth (discretion should be placed on the Landscape Architect to determine which trees would be best suited for the particular site to facilitate the required screening effects). The cultural landscape is strongly defined by alien tree windrows, thus this proposed combination of nonindigenous trees would tie into the cultural landscape context.

11 Repaint the existing palisade fence: Eskom is willing to paint the fence, but only as a once off. Eskom stated that they cannot maintain the paint and the paint may become faded and flaky with time. This could lead to enhance negative visual impact and it is therefore not recommended by Eskom. However, the visual specialist responded as follows: We would like to re-emphasise that the security fence around the substation should be repainted a forest-green colour and that the painting of the fence be incorporated into Eskom's maintenance of the substation. This is especially emphasised in lieu of the fact that the 'hedge-row' mitigation to reduce the visual intrusion of the security fence around the substation will not be implemented. The heritage specialist responded as follows: It is our view that palisade fencing will be highly intrusive within the landscape - particularly (a) when viewed from areas adjoining the site other than the Rheenendal Road and (b) left unpainted. Painting said palisade fencing in a non-reflective dark green or black would be preferable to keeping it in exposed metal/ silver. FINAL MITIGATION PROPOSAL

12 Section 5 COMMENTS AND RESPONSES REPORT The following people / organisations submitted written comment (attached in Appendix C3): The Phantom Homtini Nature Conservancy, Mr Barry & Ingrid Young, Mr Gerhard de Beer and Mr Mike Morris. Their comment are grouped and summarised below and the consultants response thereto follows: The most suitable way to mitigate the visual impact would be to form a berm, planted with trees and shrubs as discussed at the open day Eskom responded that the construction of a soil berm around the substation will not be allowed (not even on one side): from a technical point of view, soil berms are not allowed due to drainage problems it inevitably causes. Lattice fencing / poles should be erected around the substation to disguise the visual intrusion from the existing galvanised palisade fencing Lattice (wood) fencing surrounding a substation is not feasible due to the following: It increases the fire risk for the substation as it is easy to catch fire and would add fuel in the event of a veld fire. It would not be strong enough to withstand strong winds. Lattice structures do rot with time, so it is not a feasible long term solution. This is an artificial beautifying measure, and can very easily draw attention to the substation which is not desirable. A wooden / lattice fence is also not in keeping with the natural and/or cultural landscape. This recommendation will not be implemented, mainly due to the unacceptable increase risk for fire. A fire break should be constructed around the substation as per legal requirement It is not a legal requirement to construct a fire break around a substation, because the stone kerbing of 1.2m from the fence suffices to act as a fire break. Additional land should be purchased to allow for a wider frill of land around the substation to facilitate affective mitigation Eskom will not purchase additional land. VRM Africa, the visual specialists, responded as follows: It is our opinion that the purchase of extra land by Eskom would not justify the expense, as intensive planting of indigenous forest type vegetation is not conducive to the modified and harsh soil conditions, does not relate to the agrarian cultural landscape and will only offer partial visual screening with lower implementation confidence.

13 The water logged soils should be transformed into a creative biodiversity system and ponds and marsh areas should be created (as per the VIA Mitigation Alternative 1 & 2) Eskom will not create wetlands / biodiversity hotspots that will invite birding and nesting in close proximity to electrical infrastructure due to the risk associated with birds and nesting in close proximity such structures. The proposed mitigation also falls outside of the boundaries of the land belonging to Eskom. A berm should be constructed on three sides of the substation and should be planted with shrubs / trees to disguise the metal fencing The construction of a soil berm around the substation will not be allowed (not even on one side) from a technical point of view, due to drainage problems it inevitably causes. A hedge and/or trees may only be planted if no part of the hedge and/or trees are within 2m from the kerbing (the kerb extends 1.2m from the fence) and if it can be of such a nature that it causes no security risk for personnel visiting the site at night. Should such a hedge and/or trees fall outside of the Eskom owned property, additional land will not be purchased by Eskom for screening purposes. The land on which the Leeuwbosch Substation has been built must be rezoned from Agricultural Zoning to Industrial Zoning Eskom is a statutory body and is exempted from Chapter III of the Land Use Planning Ordinance Act, 1985 (LUPO). Section 22 of Chapter III of LUPO further states that Zoning precedes Subdivision. Knysna Municipality endorsed the Surveyor-General Diagram No.1125/2012 which allows transfer of the property to Eskom. Leeuwbosch Substation is not industrial land use ; the land use is utility. The substation would never have been built at its current location if a Visual and Heritage Impact Assessment had been carried out during the EIA processes. The substation was included in the EIA application for the Blanco-Knysna Powerline and was approved in the subsequent Environmental Authorisation (EA). Eskom acted within their legal rights when the substation was constructed. None of the mitigation measures proposed will adequately restore the heritage landscape or spirit-ofplace which was destroyed by Eskom. The proposed mitigation (planting of trees along the Rheenendal Road) will only serve to further deface the backdrop view of the historic Knysna Woodcutter area and gold-mining historic sites. It further does not address views from other minor roads used by local inhabitants. The only adequate mitigation will be to relocate the substation to a suitable site having lower impact on the landscape and environment. The substation was included in the EIA application for the Blanco-Knysna Powerline and was approved in the subsequent EA. Eskom acted within their legal rights when the substation was constructed.

14 Section 6 CLOSURE The recommended mitigation as per the Final Mitigation Proposal (windrow tree planting within the road reserve as well as entrance landscaping) will reduce the visual impact from the Rheenendal Road to some extent and will be a definite improvement on the current situation. This windrow is also in line with recommendations in the Heritage Impact Assessment. However, this will only benefit users of the Rheenendal Road and does not address the visual impact from other viewpoints. The 'hedge-row' mitigation to reduce the visual intrusion of the security fence around the substation as suggested in the Visual Impact Assessment would have adequately minimised the visual impact from most viewpoints. However, as explained in this report, the construction of a soil berm around the substation is not possible due to technical constraints. After lengthy, in-depth discussions between Eskom, the VIA and HIA specialists as well as Landscape Dynamics, the following was agreed upon: Eskom agreed to implement the Final Mitigation Plan as described on page 10 of this report. Eskom agreed to, as recommended by both the visual and heritage specialists, repaint the security fence around the substation a forest-green colour and to incorporate the maintenance thereof into the general maintenance plan for the substation. The painting of the fence, and the regular upkeep thereof, will definitely assist in lowering the all over visual impact of the substation. ***************************************************************************************