Draft Basic Assessment: 4 self-catering units on the Kromme River estuary (Ptn 9, Farm 707 Osbosch)

The report states "No verified floodline delineation is available for the site" (p.13). The project architect indicated parts of the property may fall within the 1-in-100-year floodline, but this "could not be independently verified" (p.31). Ground levels are as low as 3.1 m above sea level (p.32).

Potential impact: the flood exposure of the units has not been independently established.

The nearest corner of the property is about 18 m from the Kromme River estuary bank, and roughly half the building footprint falls within 100 m of the high-water mark (p.13). The estuary is one of the largest in the Eastern Cape, with saltmarsh, eelgrass beds and a fish nursery.

Potential impact: pollutants, sediment or disturbance generated near the high-water mark can be carried into the estuary by tidal and seepage flows.

Each unit uses a 6,500-litre sealed conservancy tank that must be pumped out by truck (p.16 to 17). The report lists the consequences if a tank leaks or is not emptied: "contamination of seepage zones and the Kromme River estuary through leakage of untreated sewage," nutrient enrichment and public-health risks (p.76).

Potential impact: estuarine water quality depends on the tanks staying sealed and on regular emptying by the municipal service.

The national Screening Tool rates the site "Very High" for aquatic biodiversity and "High" for animals (p.46, p.48). It lies in a Freshwater Ecological Support Area, about 700 m from the Kromme River Mouth Nature Reserve, and the vegetation type, Humansdorp Shale Renosterveld, is Endangered. The report rates the impact on indigenous vegetation "Very High Negative" before mitigation (p.93).

Potential impact: development occurs in an area the assessment itself rates as highly sensitive.

The report records cultural and historical features as "NONE" (p.31), with no Heritage Impact Assessment, although the National Heritage Resources Act (Act 25 of 1999) is listed as applicable law (p.35).

Potential impact: if graves, old structures, shell middens or other heritage exist on or near this farm, they have not been assessed. A Heritage Impact Assessment and SAHRA or ECPHRA notification can be requested.

The report acknowledges the coastal-estuarine setting is vulnerable to sea-level rise, storm surge and more intense storms, which it describes as a "direct threat to infrastructure within flood-prone areas" and to "human life" (p.81 to 88).

Potential impact: flood and storm exposure may increase over the operating life of the development.

Most significant impacts are reduced to "low" or "negligible" only after mitigation (p.93). For example, the tanks being emptied, the 40 m buffer not being encroached, an Environmental Control Officer being appointed, and alien-plant control.

Potential impact: the low residual ratings assume these measures are maintained and enforced over the long term.

The report assesses cumulative impacts (p.94). The site adjoins the Tides of Kromme estate and other coastal homes (p.11).

Potential impact: individual developments each add incrementally to pressure on the estuary and surrounding habitat.

Much of the assessment is desktop-based, the site inspection was a single visit (October 2025), and strong wind was recorded as limiting the detection of birds (p.290). The floodline was not verified.

Potential impact: some findings rest on desktop data and a single seasonal survey.

The report records that storms in May and June 2026 caused "a significant rise in water levels and local flooding in the surrounding areas" (p.13). It states that no water entered this site, based on aerial photographs rather than a floodline study.

Potential impact: the site's flood behaviour is being judged from recent photos, not a formal study.

The site was rezoned Resort in 2010 (p.11), which the applicant relies on to permit the tourism use.

Potential impact: zoning and environmental suitability are assessed separately. DEDEAT may approve, refuse or impose conditions regardless of the existing zoning.

After mitigation, most impacts are rated Low or Negligible. The impact on indigenous vegetation is rated Very High Negative before mitigation, reducing to Low Negative after mitigation (p.93).

Not addressed

• An independent Environmental Control Officer (ECO) must be appointed before construction (p.65, p.377).
• ECO audits bi-weekly during construction, then every six months for two years (p.377).
• Compliance monitoring records kept on site and available to authorities on request, with penalties for non-compliance (p.375, p.377).
• Conservancy tanks serviced with proof of servicing provided to the ECO, and ongoing alien invasive control (p.76, p.77).

• The development footprint is placed on the highest, already-transformed part of the site, above the 5 m contour and outside the mapped Estuary Functional Zone and saltmarsh (p.13, p.23).
• A 40 m ecological setback is maintained from the estuary, with no pathways or landscaping permitted inside it (p.17).
• Sensitive and buffer areas are to be demarcated as no-go zones before construction (p.19, p.77).

• Sewage is handled by sealed conservancy tanks within a containment bund, not soakaways, to limit subsurface contamination (p.17, p.25).
• Engineered stormwater with controlled discharge onto grassed areas to reduce runoff and erosion toward the estuary (p.63).
• Vegetation clearance limited to the minimum required, with construction controls and an Environmental Control Officer on site (p.36, p.65).
• An ongoing alien invasive plant control programme (p.65, p.77).

• Disturbed areas rehabilitated with locally indigenous species, on a continuous basis during construction (p.65, p.77).
• Site rehabilitation is rated Low Negative before mitigation, reducing to Negligible after (p.90 to 91).

The report does not propose a formal biodiversity offset. It relies on the mitigation hierarchy and the 40 m buffer, arguing that the footprint avoids high-sensitivity habitat (saltmarsh and the Estuary Functional Zone) and that residual impacts are reduced to low or negligible (p.93 to 95).

Impact tables p.60 to 95; summary of significance p.93; recommended conditions p.97.