Misrepresentation of N3 De Beers Pass route wetland specialist findings

13 July 2015


The De Beers Pass route is essentially untransformed and characterized by pastoral tranquillity and seclusion…

During 2013 we (DH Environmental Consulting, DHEC) undertook a significant body of work assessing numerous wetlands along the route of the proposed De Beers Pass N3 Toll Road (DBPR) between Warden and Keeversfontein.  Our final report, detailing our assessment of the impacts that would be incurred by the new road, was submitted in October 2013. We have not received any feedback thereon since that time.

We have recently learnt, via reviews of our and other specialist environmental impact assessment work conducted for the proposed new road, that our findings were not carried over into the Draft Environmental Impact Report (DEIR) or for the Draft Integrated Water Use Licence application (DIWULA) (these reviews may be found here).  One of the reviews concludes as follows:

The Draft EIA Report does not adequately reflect the findings of specialist studies. There have been material omissions and in general specialist findings have been watered down, with the exception of those relating to economic impacts. This is particularly true of those studies which show significant adverse impacts – these have been summarised to the extent that their significance is under-stated and preferred mitigation measures involving avoidance of impacts discarded. Accordingly, the obligation to conduct work in an objective manner as required in terms of regulation 18(c) of the 2006 NEMA EIA Regulations has not been achieved. Economic benefits, which are beneficial to the application have been fully stated (e.g. Chapter 11 of the Draft EIA Report) whereas the same cannot be said for significant adverse impacts as is demonstrated by some examples in Table 2 in this review.

DH Environmental was not provided with a copy of the DEIR or the DIWULA.  Had we been, we would have strongly contested the manner in which our findings were not carried over into these documents.

We are also extremely concerned to learn that, at public meetings, which we were not invited to attend or present our work at, the impression was allegedly created that all of the project specialists concurred with the content of the presentations being made by the Environmental Assessment Practitioner (EAP).  Furthermore that, inter alia,  the presentation of findings by a colleague wetland specialist were prevented from being shown at the public meetings (see report found here). Other alleged client intervention in the process is also documented.  We also find, from one of the reviews, that the opinion of the client – to wit casting doubt on the specialist findings – were included in the EIR.  This is wholly inappropriate and suggests a new low for EIAs.

A summary of our findings, which indicate the proposed route to be ill-advised, are provided below.  We strongly recommend that oversight by specialists become a mandatory component of the EIA and associated licensing processes – this to ensure that their findings have been correctly interpreted and included.  We can only wonder as to how many other EIAs have followed this practice and got away with it.

In our opinion, there is sufficient evidence to indicate that the EIA process for the DBPR is sufficiently flawed for it to be set aside as being materially deficient.  We hereby disassociate ourselves with the process that appears to have been followed in deriving the DEIR and the DIWULA.


Executive Summary from DH Environmental Consulting Report 619 dd October 2013

This assessment has evaluated a series of wetlands along the De Beers Pass and Alternatives A and C, these proposed for the upgrading of the existing N3 alignment between Warden (Free State) and Tugela Plaza (KZN). A series of deviations to the De Beers Pass route were also considered. The assessment has provided input to a resource economics evaluation, in the form of Ecological Importance and Sensitivity (EIS) scores assigned to each wetland, as well as indications of the likely mitigation efficacy associated therewith.

Although substantially constrained by an absence of primary biotic information, it has been possible to rate the affected watercourses using the indicated methodology. As such a framework exists to amend the scoring as and when additional, pertinent information becomes available. The conclusions are as follows:

  • This assessment has allocated ecological importance categories to all of the wetlands identified by the wetland specialist. Additionally, scores reflecting the level of mitigation required for each wetland have been provided;
  • With the possible exception of the pan environments (Lincoln Pan and Alex Pan), there is insufficient information on biota within the study area, at both micro- and macro-scales, to inform or derive mitigation measures;
  • The Study Area is under-described (=Data Deficient) for both abiotic and biotic features, characteristics and sustainability needs. The information that is available, for example from the Free State Government, indicates that the Study Area has a High to Very High ecological importance, especially in the area east of Harrismith and across the escarpment;
  • The individual wetlands have not been sufficiently delineated to determine the full impact of their being intersected by the proposed road, nor to inform the wetland-specific geohydrological needs;
  • The wetlands encompass very large areas of shallow seepage environments contained within the upper two meters of the substrate. With the exception of the rivers sensu strictu, the road build will comprise an end-to-end series of cut and fill construction which, in this authors opinion, will substantially impact on and homogenize said flows, with resultant and undesirable negative alteration of wetland character and ecosystem services downslope of the road. Such a situation is intolerable in terms of the global need to conserve wetlands and prevent any further loss thereof;
  • The proposed route intersects more wetlands than have been identified by the wetland specialist, i.e. the assessment underestimates the aggregate impact. It is estimated that the undervaluation is of the order of 10-20%;
  • This assessment concurs with the findings of the wetland and flora/fauna studies, viz. that mitigation will have negligible effect on the identified impacts. Likewise it is apparent that the deviations proposed for the De Beers Pass route provide little or no relief in terms of overall impact. As such the best possible mitigation would be to not build the road on the proposed alignment.


It is the opinion of this author that the DBPR route, as proposed, will result in substantial, sustained, repetitive and cumulatively-high levels of impact on the watercourses, and their associated terrestrial environments. These impacts predominate in the eastern half of the route, although ecologically-important nodes also exist in the western portion. It has also been taken into account that the ecological impacts associated with the road extend and increase throughout its lifetime, imparting an aggregate and negative legacy impact from, inter alia, increasing landuse, landscape fragmentation, environmental pollution and the spread of alien species.

The A Route offers some relief from the aforementioned impacts. However, severe, repetitive impacts occur at the eastern end of the route, as well as in the vicinity of Harrismith. These will require additional consideration based on a higher level of detail.


With respect to mitigation, this analysis finds that there was insufficient information of a specific nature on which to base any attenuation of ecological impacts. The proposed road will carry a traffic volume that already exceeds identified limits at which substantial road corridor impacts will occur. At a minimum analysis, the road usage will impact on a corridor almost a kilometer wide, for the entire route. The extent and nature of the impact will be exacerbated by landscape fragmentation and other factors that will increase over the age of the road.

Insofar as mitigating the impacts of the road on wetland geohydrology, the indications are that the road will have a permanent and substantial negative impact thereon. This will result in homogenization of wetland flows and alteration of wetland character downslope of the road. Levels of mitigation efficacy suggested by the wetland specialist are so low (~30%) as to be completely unacceptable for wetland protection in such an ecologically-important area.


In itself, the eighty-meter wide footprint of the road will result in the total and permanent loss of a large area of wetlands, in the main bisecting existing and intact wetland systems.

The confidence level of the analysis is reduced by the high level of environmental uncertainty, this being a function of the lack of comprehensive primary biophysical information, alternatively the inability to source same within the scope of this assessment. It is, however, deemed unlikely that were such information available, that it would alter the findings in favour of constructing the De Beers Pass alignment, with or without its deviations.

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