APPLICATION FOR THE UNLAWFUL COMMENCEMENT OF LISTED ACTIVITIES FOR THE CONSTRUCTION OF THE SSK SILO COMPLEX AND PROPOSED CONSTRUCTION OF ADDITIONAL EIGHT (8) SILOS AND ASSOCIATED INFRASTRUCTURE ON PORTION 17 OF FARM KLIP BANKS KLOOF, PROTEM, WESTERN CAPE.

Guillaume Nel Environmental Consultants (GNEC) was appointed by Sentraal-Suid Co-operative (Pty) Ltd (hereinafter referred to as the proponent / SSK) to conduct the Environmental Impact Assessment for the rectification process in terms of Section 24G of the National Environmental Management Act (NEMA), 1998 for the unlawful commencement of listed activities for the construction of the SSK Silo Complex and proposed construction of additional eight (8) Silo’s and associated infrastructure on Portion 17 of Farm Klip Banks Kloof, Protem, Western Cape (hereinafter referred to as “the site”).
Sentraal-Suid Co-operative (Pty) Ltd operates in the Western Cape (Overberg, Langkloof and Karoo) with its head office located in Swellendam. The company was founded in 1931 and has been serving its members as a Co-operative for 90 years.
The nine (9) silo complexes of SSK (Protem, Swellendam, Heidelberg, Krombeksrivier, Karringmelksrivier, Ashton, Riversdale, Albertinia, Herold and the depot at Kleinberg) provide storage capacity of grain. The silos are fully equipped with modern equipment to render professional service to both clients and members of the Co-operative. The said property has been owned by the SSK since 1965.
The property is situated in Cape Agulhas Municipality, a Category B (Local) Municipality within the Overberg District Municipality.
The property is bordered by the SANRAL railway line to the west, Overberg Agri Silo’s to the northwest, a church directly north, a primary school to the east and the Silo bag depot of Overberg Agri to the southeastern side of the site.
The establishment of the Protem Silo Complex came about as an increased trend of harvesting in the surrounding area created the need for more bulk grain storage, hence the erection of more silos. The site, historically vacant, was cleared in 2014 in order to provide storage solutions for excess crops especially canola and wheat, in Silo ‘storage bags.
In order to address the dire need for additional storage space for crops prior to exportation within the local and regional context, SSK constructed the SSK Silo Complex during 2022. Currently the site comprises a manager house, eight (8) 2000-ton Silo’s, an intake pit canopy, bagging canopy, canopy and MCC and grading room, a 3000m2 bunker, an access road diverting trucks from the weighbridge around the complex towards the offloading bays and services infrastructure. Four (4) 2200 ℓ diesel tanks and a 550kVa generator are located on the western boundary adjacent to the site office / weighbridge.
The proposed use is therefore a much-needed agricultural service facility in this region. Sufficient site space to accommodate the proposed scale of the silo complex is available on the said property and a viable development has been established, however the proponent wishes to construct an additional eight (8) silos and associated infrastructure directly adjacent to the existing silo’s on site in future.

Civil Services
Water:
Existing water tanks are situated in the north-eastern corner of the property, south of the northern internal road. Another water tank is situated south of the weighbridge, in the south-eastern corner of the property.

Sewerage:
The septic tank is situated south of the water tank, south of the weighbridge, in the south-eastern corner of the property.
Stormwater:
Stormwater drainage management is managed on-site.
An area of artificial stormwater attenuation and associated wet response was identified within the southwestern corner of the study area. This system has been developed to safely convey stormwater to larger systems downgradient, thus the wet response is as a result of this formalisation and concentration of flow. As such, this area and the associated stormwater channels, were classified as “artificial features”. Furthermore, the agricultural drains and dams identified within the investigation area are also considered to be artificial features.
Roads and Access:
The site is serviced by an existing gravel road between Bredasdorp (south) and Riviersonderend (north). The Western Cape Roads Planning Department has three approved access points to the said property.
The said property is favorably situated in close proximity to key transport routes, namely south of the N2 highway and situated between the R317 and R319.
Electricity:
The generator is situated on the south-eastern part of the said property, next to the weighbridge. The planned future Eskom transformer will be situated south of the existing generator.

Botanical Impact:
Capensis Ecological Consulting Pty (Ltd) (Capensis) was appointed by Guillaume Nel Environmental Consultants to conduct a Botanical Impact Assessment to retrospectively determine the Botanical Impact of the current development on the site. It is important to note that an additional reference site was chosen west of the study area and railway in order to determine the retrospective state of the site to determine if 300m2 or more of an endangered or critically endangered vegetation type cleared; or more than 1ha or more of vulnerable vegetation type cleared, the original condition and species composition of the cleared area and were any sensitive species lost, What was the sensitivity rating of the cleared area and what is the impact significant rating of the activity.
The Vegetation of South Africa, Lesotho and Swaziland (VEGMAP) (SANBI 2024 Beta Version ) assigns a single vegetation type to the site, namely Central Rûens Shale Renosterveld. No vegetation map is provided since this vegetation unit is extensive in the region and only show this single ecosystem. The landscape and vegetation features of the aforementioned vegetation types appear below as described by Mucina et al. (2006)
“Moderately undulating plains and pans. Vegetation is open to medium dense cupressoid and small-leaved, low to moderately tall grassy shrubland, usually dominated by renosterbos. It is distinguished from the Eastern Rûens Shale Renosterveld by the absence of Aloe ferox. Shrubby Asteraceae increase as grazing reduces the palatable grassy component (mostly Hyparrhenia hirta) and subsequent erosion results. Heuweltjies not conspicuous, except in the south of the area.”

The Western Cape Spatial Biodiversity Plan (WCBSP)(CapeNature, 2024) is linked to the Western Cape Biodiversity Act 6 of 2021 (WCBA), which “identifies a province-wide network of biodiversity priority areas defined as Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs)” designed to meet conservation objectives. The WCBSP includes a map composed of multiple layers that “provides the relevant spatial data crucial to advise planning decisions that will result in both sustainable development and the conservation of important biodiversity and ecological infrastructure.” In the case of the study area, it is assigned as CBA1 Terrestrial whereas the reference site is assigned as CBA2 It is important to note that as previously stated, the entire study area has already been developed to the extent that no indigenous vegetation remains Only one small patch provide evidence of indigenous vegetation, where two individual shrubs were observed. These include common ribbed Khunirhus currantrhus Searsia pallens and sand olive Dodonaea angustifolia that were growing next to two exotic species (weeping bottle brush Melaleuca viminalis and Brazilian pepper Schinus terebinthifolius)
Historical imagery shows that the original condition of the vegetation within the cleared area was in a heavily modified state.
The assigned Low sensitivity implies that the clearing event would have had a Low or even Very Low Negative Impact significance for 1) loss of vegetation and ecological processes, and 2) loss of species. It is emphasized that this is based on the Botanist’s interpretation of the aerial imagery and the reference site that was most likely in a similar but better condition than the cleared site. It is further concluded that although more than 300m2 of a critically endangered vegetation type may have been cleared the heavily modified condition implies low restoration potential and low sensitivity. It is also likely that the correct interpretation under the NEMA definition of indigenous vegetation would have been that the vegetation is not naturally occurring and did not constitute indigenous vegetation. Based on the aforementioned interpretation, had the Botanist visited the site prior to the clearing event, there would be no justification from a botanical perspective not to support the development of the site.
Freshwater Compliance Statement
Freshwater Ecologist Network Consulting (Pty) Ltd (FEN) was requested to investigate Portion 17 of the Farm 7 Klip Banks Kloof for Sentraal-Suid Co-Operative Ltd (hereafter referred to as SSK), situated in Protem, Overberg Municipality, Western Cape Province. The study was conducted to determine the potential presence of freshwater ecosystems and to retrospectively determine the significance of impacts of the alleged unlawful construction and operation of storage facilities and outbuildings, as well as clearing of vegetation (hereafter referred to as the “development”) undertaken within the study area.
According to the Screening Tool Report a Low sensitivity rating was generated which prompted that need for an Aquatic Compliance Statement. The “low” freshwater biodiversity sensitivity is corroborated due to the results of the site investigation during which no natural watercourse/freshwater ecosystem were identified in the study area. The site verified freshwater sensitivity was therefore determined to be “low” and as such a Compliance Statement was compiled. The DFFE Screening Tool identified the entire study as being of low aquatic biodiversity sensitivity. However, the seasonal drainage line located in the western portion of the investigation area is considered to be of high aquatic biodiversity sensitivity. The site assessment concluded that the footprint of the development is located within an area of low aquatic biodiversity sensitivity. Accordingly, the provision of a compliance statement, as opposed to a full freshwater assessment that would be required if the development had been confirmed to be in an area of high aquatic biodiversity sensitivity, is considered acceptable in this context according to the Freshwater Specialists.