SUBMISSION TO SIVEST – ENVIRONMENTAL IMPACT ASSESSMENT - St Francis Bay Residents Association

SCOPING EXERCISE: PROPOSED NEW ESKOM 400KV TRANSMISSION POWER LINES BETWEEN THYSPUNT AND PORT ELIZABETH ( DEAT 12/12/20/1211 & DEAT12/2/29/1212)

1. This Association is opposed to any nuclear installation at Thyspunt, for a variety of reasons, which have been articulated in our submissions to Arcus Gibb in connection with the Thyspunt site itself. One of the major reasons for our opposition is the visual pollution and degradation which will inevitably affect this region in the form of transmission lines. In our view, the “No go” option is the only appropriate one.

2. Transmission lines have to be among the most unsightly and obtrusive products of the technological era. Necessary as they may be, they visually pollute huge tracts of land throughout the country. This being the case there is a major responsibility on the part of utilities and decision- makers to exercise extreme circumspection in the placing of these eyesores. They should, wherever possible, be kept to an absolute minimum, by placing power stations close either to points of consumption, or to the existing transmission network. Where this is not possible, they should be placed in areas which have minimal visual impact. What should never be permitted in a responsible society is the permanent visual degradation of areas of outstanding natural beauty through injudicious positioning of power generation plants, and their accompanying transmission lines.

3. In the case of Thyspunt, the visual impact of transmission lines would be huge, entirely negative, and at the expense of some areas of exceptional natural beauty. The proposed plant will be double the current size of Koeberg, which suggests that the transmission lines will also be double the size. Anyone who has driven past Koeberg and observed Table Mountain through the rows of power lines will be aware how obtrusive these installations can be.

4. If a nuclear plant is installed at Thyspunt, and the southern corridor is selected , this will involve taking the transmission lines across the unspoilt section of the Oyster Bay By-pass Headland Dunefield (one of the finest examples of such a phenomenon in the world), across the tidal portion of the Kromme and Gamtoos Rivers, and through parts of the Baviaanskloof Mega Reserve. All of these are features of outstanding natural beauty, and all will be hugely visually degraded in perpetuity. Such an action would be an unmitigated disaster for the Kouga region, and an act of environmental vandalism, which ought to be unthinkable under current environmental legislation and conservation culture.

5. We do not dispute the need for additional electricity generation in South Africa, or for a reduction in dependence on fossil fuels, or that there is a case for a power station in the Eastern Cape. However, this does not justify wholesale and permanent visual pollution of areas of outstanding natural beauty, and of high conservation status, without due consideration of the long-term implications. It is inconceivable that a Department of the Environment could approve of any such proposal.

6. The Background Information Document (BID) indicates two possible directions for the transmission lines, both of which are five kilometres in width! This is unacceptably vague, and indicates that the entire EIA process is premature. Before any responsible EIA can even be contemplated, it should be based on a specific route, which will have a specific environmental impact. To expect the public to respond to two five-kilometre-wide strips is completely unreasonable, and is tantamount to asking them to sign a blank cheque. We propose, therefore, that this EIA be discontinued until such time as Eskom is able to identify one or more specific routes for comparison and comment. Alternatively, it should be made clear that this is a preliminary EIA, to identify the preferred route(s), prior to a full-scale EIA on those routes, with further opportunity for public participation at that stage.

7. One of the major environmental hurdles is the traversing of the Oyster Bay By-pass Headland Dunefield – an area of shifting sands, and a major obstacle to any proposal to use transmission lines. It is not clear whether this particular problem is being addressed by the EIA on Thyspunt itself, or in the EIA which is the subject of this submission. One of the issues to be addressed is how it is acceptable at all to place transmission lines across such a feature.

8. In the event that the arguments against any transmission lines at all in such an area are rejected, we would strongly favour the Northern Corridor. This could minimise the impact on the Oyster Bay dunefield; avoids crossing the Kromme River along its tidal reaches, which is extremely popular for all manner of water activities. It would also affect the siting at the Gamtoos River, and it might be possible to find a crossing point which is less offensive than close to the river mouth. However, the map is so vague that it is impossible to state where the Gamtoos would be crossed. It is difficult to conceive of anywhere that would be visually acceptable.

9. Both corridors fail to address the problems of the Oyster Bay By-pass Headland Dunefield and intrusion on the Baviaanskloof Mega Reserve.

10. The BID indicates (Fig 2, p.4) that a Guyed Suspension type tower will be used. This is hugely superior to those used at the time when Koeberg was built. However, recent travel from Cradock to Port Elizabeth has revealed another even less intrusive design, where two separate towers are erected and linked by overhead cable. We would suggest that these would be preferable to the type indicated in Fig 2.

We thank Sivest for the opportunity to contribute to this process. We trust that our comments will be reflected in the Draft Scoping Report, and will be addressed seriously, and not in the generalised and superficial manner, which appears to be the norm in such processes.