AGRICULTURE, CONSERVATION, ENVIRONMENT AND LAND AFFAIRS
Diamond Corner Building, 68 Eloff & Market Street, Johannesburg
P O Box 8769, Johannesburg, 2000
Telephone: (011) 355-1900
Fax: (011) 337-2292
Email: dace@gpg.gov.za
 
EIA ADMINISTRATIVE Guideline
Guideline for the Construction and Upgrade of
FILLING STATIONS AND ASSOCIATED TANK INSTALLATIONS
MARCH 2001
  1. INTRODUCTION
This guideline document is intended to provide a framework of Departmental requirements for the construction and upgrade of filling stations and associated tank installations. The guideline is further an attempt on part of the Department to reduce the evaluation/ review period but simultaneously ensuring that all impacts have been addressed through commitment of the petroleum industry.

With these guidelines, the Department wants to implement and maintain minimum requirements for the development of filling stations that will contribute to sustainable development and a measurable improvement in the quality of life of all the people of Gauteng, while considering the shortfalls in available data/ scientific knowledge about the cumulative impacts on the environment as a result of the development of such facilities.

1.1 LEGISLATIVE BACKGROUND

The Department of Agriculture, Conservation, Environment and Land Affairs is the authority responsible for authorising developments which may have an impact on the environment, while keeping the needs and rights of the people of Gauteng in mind. In fulfilling its function, the Department is subjected to and guided mainly by three pieces of legislation.

The Bill of Rights of The Constitution (Act no. 108 of 1996, Chapter 2), South Africa's supreme law, makes specific reference to the people's right to a safe and healthy environment. Section 24 states that everyone has the right to an environment that is not harmful to their health or well-being. Everyone has a right to have the environment protected for the benefit of present and future generations through reasonable legislative and other measures. These measures must aim to prevent pollution and ecological degradation, promote conservation, and secure sustainable development and use of natural resources while promoting justifiable economic and social development.

The National Environmental Management Act (NEMA, Act no. 107 of 1998) established, amongst others, an extensive list of principles for decision-making on matters affecting the environment. These principles, which are based on the environmental and other fundamental rights in The Constitution, apply to the actions of all organs of state that may significantly affect the environment. These actions include authorising certain developments.

Principle 2 states that "environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably". Principle 3 states that "development must be socially, environmentally and economically sustainable".

Principle 4(a) of Section 2 of NEMA requires the consideration of several factors to ensure sustainable development. The most important consideration, with specific reference to these regulations for the development of filling stations, is that "a risk averse and cautious approach must be applied, which takes into account the limits of current knowledge about the consequences of decisions and actions". Other relevant considerations include:

On 5 September 1997, the EIA Regulations (GN R. 1182 and 1183) were promulgated in terms of Sections 21, 22 and 26 of the Environment Conservation Act (Act no. 73 of 1989). GN R.1183 stipulates that authorisation must be obtained from the relevant authority, this Department, before commencement of any activity listed in GN R.1182. In terms of Schedule 1, Item 1(c) of GN R.1182, "the construction or upgrade of transportation routes and structures, and manufacturing, storage, handling or processing facilities for any substance which is considered as dangerous or hazardous and is controlled by national legislation", legally requires authorisation from this Department. Filling stations and associated tank installations are included.

 

    1. KEY ENVIRONMENTAL ISSUES
There is a significant environmental risk associated with the development of filling stations. The Department has therefore been guided by several factors in developing this guideline: Some of the metropolitan local councils already require that all developments of Item 1(c) activities comply with specific requirements before approval thereof will be considered. One of the guiding principles of the EIA Regulations are to ensure the public is involved and aware of decisions taken with regard to identified activities before authorisation/ exemption can be considered. During the past year, a large number of applications were received, of which many were in non-sensitive areas. The Department received applications for general exemption for certain facilities, and has to make sure that dealing with this identified activity constitutes an effective use of resources. There is a potential danger and environmental risk associated with the above-mentioned developments. The construction and operation of such an activity can furthermore have a substantial negative impact on the environment, in relation to its sensitivity.

 

Past experience has shown that filling stations are major sources of pollution in Gauteng and unless appropriate measures are in place, severe environmental impacts can be expected. Filling stations have a potential significant impact on: Indications are that filling stations also have significant social impacts on the environment, which may detrimentally affect the social well-being of citizens. These include:   Filling stations are a source of Disturbing Noises (noise levels that cause the ambient noise level to rise above the designated zone level, or if no zone level has been designated, the typical rating levels for ambient noise indicated in districts in table 2 of SABS 0103) associated with motor cars and trucks braking and accelerating to and from such facilities. For example, it appears that even a single heavy diesel truck leaving a road during the small hours of a morning, could within a few minutes of coming to a halt with its engine running, contravene the provisions of the Gauteng Noise Control Regulations (GN R.5479, 20 August 1999). The effects of noise on the environment are particularly relevant for filling stations in urban/ built-up/ residential areas. Due to a substantial increase in the number of filling stations in Gauteng over the last 12 months, the Department is following a precautionary approach in accordance with Section 2(4a)vii of NEMA to ensure that cumulative impacts are addressed or avoided. The following significant cumulative impacts could result due to the proliferation of filling stations in proximity to each other: Filling stations may have significant irreversible impacts where the character, diversity or reproductive capacity of the environment is permanently lost within a given area or space. A filling station also has specific infrastructure, and alternative uses if a filling station is decommissioned are virtually non-existent. Rehabilitation of a site will require substantial funding, which may be problematic. As a result of financial constraints when a filling station is closed due to it not being sustainable (refer to next point - Feasibility / Sustainability), owners/ developers fail to show a dedication towards an adequate environmental rehabilitation programme after decommissioning thereof. The feasibility of new developments is currently questionable, taking into account the extreme economic pressure experienced by existing filling stations. Recently filling station owners demanded an increase of their profit margin on the sale of fuel in order to prevent thousands of job losses. Recently, the South African Fuel Dealers Association (SAFDA) indicated that more than half of South Africa's filling stations is operating below the break-even point and face closure.

Based on the above, it appears that:

Feasibility studies submitted to this Department in the past indicated that filling stations do not cause an increase in traffic volume. The fact that there is no increase in traffic has a serious implication in terms of the feasibility/ sustainability of existing filling stations in the area due to loss of income. Although the rights of a developer must be protected, those of the public at large are equally if not more important. To date, applications for filling stations have only focussed on the needs of the developer, while the needs of society (i.e. the need for more filling stations) have not been considered. This is in contravention of Section 2(2) of NEMA which requires the needs of people to be put at the forefront. Developers neglect to inform the public adequately on a possible need for a filling station, and affected communities are therefore unable to make a significant input regarding the desirability of a filling station which will impact on their natural and social environment. Current indications based on objections from the public are that the people of Gauteng do not support, and therefore do not need, the development of new filling stations in close proximity to each other, particularly in existing urban/ built-up/ residential areas.

 

    1. DEFINITIONS
In this document, unless the context requires otherwise —

Agriculture and temporary tank installations : - means tank installations for agricultural purposes on farms or tank installation for projects of temporary nature such as road works, construction activities and other civil projects.

Commercial site: - means a site where tank installations are used for the storage of hazardous or dangerous substances and which do not fall under the definition of filling stations below.

Cumulative impact: - refers to impacts on the environment that take place so frequently in time or so densely in space that the effects cannot be assimilated by the environment;

Environmental authority: - means the designated relevant authority, which receives all applications for consideration.

Industrial area: - means an area zoned as industrial as defined under the town planning scheme.

In proximity of existing filling stations: - means within five (5) kilometres of an existing filling station (urban/ built-up/ residential area), or within twenty-five (25) kilometres of an existing filling station in other instances (e.g. rural areas, and along highways and national roads).

 
Filling stations: - means petrol facilities, service stations, public garages, highway filling stations, petroports, and fuel depots.

Sensitive area: - refers to the areas listed in Annexure 5. 

Synergistic effect: - refers to the impacts from one activity combined with those of another to produce a greater impact or different impact.

Upgrade: - means the relocation of existing storage tanks, installation of additional storage tanks, replacement of storage tanks where there is an increase in total storage capacity, total demolition and rebuilt of filling station where there’s either increase in capacity or change of location of a filling station.

============================
  1. CLASSIFICATION OF ITEM 1(c) APPLICATIONS
All applications will be categorised on receipt and listed against the following categories:
    1. New filling stations in proximity of an existing filling station, or within sensitive areas;
    2. Upgrade of filling stations in proximity of existing filling stations or within sensitive areas, resulting in a capacity increase of more than 25%;
    3. New filling stations within industrial/ non-sensitive areas, or
    4. upgrade of filling stations in proximity of existing filling stations or within sensitive areas, resulting in a capacity increase of less than 25%;

    5. • Tank installations for agricultural or temporary purposes (eg. civil and road works);
• Tank installations at commercial sites in industrial areas;

• Upgrade of filling stations within industrial or non-sensitive areas.

============================
  1. DEPARTMENTAL REQUIREMENTS
In adopting the following approach, the Department has been influenced by various factors as explained in Section 1.2. The following requirements should be applied as a minimum, and the Department reserves the right to request additional information as required. 3.1 New filling station in proximity of an existing filling station, or within sensitive areas

The Department will not authorise any filling stations within,

  1. five (5) kilometres of an existing filling station(urban/ built-up/ residential area), or
  2. twenty-five (25) kilometres of an existing filling station in other instances (e.g. rural areas, and along highways and national roads).
 
    1. Upgrade of filling stations in proximity of existing filling stations or within sensitive areas, resulting in a capacity increase of more than 25%
Where the upgrade of a filling station in proximity of an existing filling station or within a sensitive area will result in an increase in total storage capacity of more than 25%, the following will be required:  
    1. New filling station within industrial/ non-sensitive areas, or
    2. upgrade of filling stations in proximity of existing filling stations or within sensitive areas, resulting in a capacity increase of less than 25%

      Partial exemption may be considered for this category. Exemption will not be considered where cumulative impacts are likely to occur as a result of the proximity of the proposed filling station to existing filling stations.

      1. New filling station within industrial/ non-sensitive areas
3.3.2 Upgrade of less than 25% in proximity of existing filling stations or within sensitive areas  
    1. General Exemption
The aim of considering a General Exemption is to streamline the administrative process of handling the vast number of applications and to accommodate industry in meeting their market demands within a reasonable time. An applicant or oil company must apply with the Department for General Exemption, which can be considered for the following: The requirements outlined in Annexure 3 must be met. The General Exemption will be subject to a pre-approved generic Environmental Management Plan (EMP). This EMP must address mitigation measures for impacts associated with this type of installation, throughout the construction, operational and decommissioning phases of the facility. Further information may be requested at any stage. Once the General Exemption has been granted, details of each project and their scope must be submitted to the Department on a quarterly basis.
============================
SUMMARY OF DEPARTMENTAL REQUIREMENTS FOR the Construction and Upgrade of
FILLING STATIONS AND ASSOCIATED TANK INSTALLATIONS

 

 
 
Activity
Process in terms of EIA Regulations
Guideline Requirements 
1
  • New filling stations in proximity of existing filling stations or within sensitive areas.
Authorisation will not be granted. 

Refer to list of sensitive areas (Annexure 5).

2
  • Upgrade of more than 25% in proximity of existing filling stations or within sensitive areas.
Follow the application process as in the EIA Regulations. Complete the checklist (Annexure 4). 

Follow the requirements outlined in Annexure 1. Also refer to list of sensitive areas (Annexure 5).

3
  • New filling station within industrial or non-sensitive areas.
  • Upgrade of less than 25% in proximity of existing filling stations or within sensitive areas.
Exemption could be considered. Should Exemption be considered, the requirements outlined in Annexure 2 must be met. The Checklist, marked Annexure 4 must also be completed in full.
4
  • Tank installations for agricultural and temporary purposes.
  • Tank installations at commercial sites in industrial areas.
  • Upgrade within industrial or non-sensitive areas.
General Exemption will be considered. Follow the requirements outlined in Annexure 3.
 
============================

 

 

 

 

____________________

Dr. P. Hanekom

Head of Department

Agriculture, Conservation, Environment & Land Affairs

Gauteng Province

 

ANNEXURE 1

Requirements for activities specified in 3.2 of this guideline:

 
  1. An application form and Plan of Study for Scoping should be submitted.
2. The following specific requirements, amongst others, must be addressed or provided in the Scoping Report before authorisation can be considered:
  1. A locality map, including a site development plan with a clear indication of the location of the site in relation with / and the distance of the tank/s from council boundaries, major roads, railways, open spaces, places of cultural importance, seep lines, channels, dams, rivers and other water bodies and existing filling stations in proximity.
  2. A description of the geology of the site with a description of soil types in terms of compatibility.
  3. A motivation on the desirability of the proposed development.
  4. Details on the establishment of a rehabilitation fund.
  5. The depth of the water table should be provided with a baseline reference of the ground water quality of the site and surrounding areas.
  6. The location of wells and boreholes on the site and neighbouring properties with an indication of the level of reliance of the neighbouring properties on ground water resources.
  7. A description of other environmental issues (eg. socio-economic aspects related to the sense of place, visual impact, etc.) as a result of the construction, upgrade or the operation of the filling station.
  8. A description of the public participation process prescribed by the EIA regulations.
  9. Method of waste disposal from the premises.
  10. Specific site design and recommendations for installation of underground tanks in relation to the receiving environment.
  11. If the proposed filling station will include a car wash, the following must be taken into account:
  12. Water recycling practices.
  13. Quality of the effluent discharged into the sewer must be determined in consultation with the relevant local authority.
  1. In the case where there are existing filling stations in proximity, an assessment of the cumulative impacts on the environment, as a result of combined impacts from all filling stations in the applicable radius (5 or 25 km), must be undertaken.
The above assessment must address amongst others:
  1. the ability of the natural and social environment to assimilate cumulative stresses placed on them;
  2. the likelihood of negative synergistic effects;
  3. whether the proposed development have a significant impact on, or be constrained by existing or future developments rights in the area;
  4. the feedflow and anticipated traffic volume;
  5. a feasibility study which includes the information in 3.4, but not entirely based upon it;
  6. the demand (necessity) and desirability of the proposed development; with an indication of the potential of the proposed filling station in terms of fulfilling the need of the targeted consumer;
  7. impact on the feasibility of existing filling stations;
  8. the no-go option as an alternative.
ANNEXURE 2

Requirements for activities specified as points 3.3.1 and 3.3.2 of this guideline:

The Checklist marked as Annexure 4 must be completed in full and submitted as application.
  1. In considering the partial exemption, the following information must be provided:
  1. A locality map, with a clear indication of the location of the tank(s) and the distance of the tank(s) in relation to the identified sensitive area(s), where applicable.
  2. The expected location, extent and depth of surface subsidence of the area where the tank will be located.
  3. The location of wells and boreholes on the site and neighbouring properties with an indication of the level of reliance of the neighbouring properties on ground water resources.
  4. Precautionary measures to prevent accidental spills.
  5. Information on the means of disposal of old fuel tanks.
  6. Proof of compliance to the following SABS standards:
  1. The number of tanks to be installed and upgrade capacity, if applicable, in relation to the total storage capacity of all tanks on site.
  2. A brief motivation on the need and desirability of the proposed development. in the case of a new filling station.
  1. Indication of the feed-flow and anticipated traffic volume in relation to similar existing facilities along the road within 5km if in urban/built-up residential area, and within 25km if in other areas, in the case of a new filling station. Any possible increase in traffic flow due to the proposed facility must be provided.
 
  1. The following notification must be done to ensure consultation with I&AP’s:
  1. The proposed filling station/ upgrade must be advertised in a local newspaper and on site.
  2. Interested an Affected parties (I&AP's) must be given a thirty (30) day period in which to lodge any objections to the proposed development.
  3. A list of the I&AP's (such as land owners, residents association, ratepayers' association and environmental groups, etc.) in the area must be submitted together with the proof of advertisement to the Department.
  4. After the thirty (30) day period, the Department must be informed of any objections raised by any I&AP's regarding the proposed filling station/ upgrade.
  5. All conflicting issues emanating from objections must be addressed by an independent consultant before exemption will be granted.
 

 

 

ANNEXURE 3

Requirements for the activities specified as point 3.4 of this guideline i.e.:

  1. The following notification must be done to ensure consultation with I&AP’s:
  1. The proposed upgrade must be advertised in a local newspaper and on site.
  2. Proof of such advertisement must be submitted to the Department.
  3. Interested and Affected parties must be given a thirty (30) day period in which to lodge any objections to the proposed development.
  4. After the thirty- (30) day period, the Department will be informed of any objections raised by interested and affected parties regarding this project.
 

 

  1. Once the general exemption has been granted, details of each project and their scope, will be requested and must be submitted to the Department on a quarterly basis. Information requirements are specified as follows:
  1. A locality and site maps.
  2. The number of tanks to be installed and the upgrade capacity in relation to the total storage capacity of tanks on site, if applicable.
  3. List the names, the usage, the characteristics of substances and their quantities in the case of tank installations at commercial sites.
 

 

 

 
ANNEXURE 4
DEPARTMENT OF AGRICULTURE, CONSERVATION, ENVIRONMENT AND LAND AFFAIRS
Information checklist for Item 1(c) activities.
SECTION A: GENERAL INFORMATION
 
Project Applicant  
Contact Person  
Postal Address  
Telephone   Facsimile  
E-mail   Cell  
 
Project Consultant  
Contact Person  
Postal Address  
Telephone   Facsimile  
E-mail   Cell  
 
Registered Owner  
Contact Person  
Postal Address  
Telephone   Facsimile  
E-mail   Cell  
 
Local Authority      
Contact Person      
Postal Address      
Telephone   Facsimile  
E-mail   Cell  
 
Project Title      
       
Property Description 

(Farm Portion)

 
 

SECTION B: ENVIRONMENTAL FRAMEWORK

  1. Are any of the following located on the site earmarked for the development. If so, give an indication of distance from the proposed development tank installations.
 
ENVIRONMENT
Located on Site
Distance (m)
YES NO In meters
  1. A river, stream, dam or wetland (including pans and seasonal vleis). 
     
  • A conservation, reserve or open space area etc. 
  •      
  • A ridge or other prominent landscape feature.
  •      
  • An area that is of cultural importance, e.g. historical site, graveyard, place of worship.
  •      
  • A hospital or school. 
  •      
     

     
     
    ENVIRONMENT
    Located on Site
    Distance (m)
    YES NO In meters
  • An area of archaeological or paleontological value.
  •      
  • Any Red Data or other protected plant or animal species.
  •      
  • Power lines, water pipes or servitudes.
  •      
     

     

    1. Where the development involves the re-zoning of agriculture land, please answer following questions.
    1. What is the soil potential of the site earmarked for development?
    2.  
       
       
    3. What is the climatology in the area?
    4.  
       
    5. What is the vegetation cover in the area?
    6.  
       
       
    7. Is the land currently cultivated?
    8.  
       
       
    9. When was the land last cultivated if it is not currently cultivated?
    10.  
       
       
    11. Is the area contoured?
    12.  
       
       
    13. Do any soil conservationist works exist?
    14.  
       
       
    15. Does the area have irrigation rights or has the area in the past had irrigation rights?
     
     
     
     

    SECTION C: FACILITY INFORMATION
     
    Please answer the following questions YES NO
    1. Are the existing tank/s being replaced with same capacity tanks?
       
    If replaced as a result of leaks, has a contamination assessment and remediation taken place.    
     
  • Are the existing tanks being replaced with larger capacity tanks?
  •    
    Capacity of replaced/ new tanks?    
    If replaced as a result of leaks, has a contamination assessment and remediation taken place.    
     
  • Are new additional tanks being installed at an existing site?
  •    
    Number and size of tanks?    
    Combined capacity?    
     
  • Are the tanks being installed at a new site?
  •    
    Number and size of tanks?    
    Combined capacity?    
     
     

    SECTION D: FACILITY SPECIFICATIONS
     
    Will the tank installations mentioned above meet compliance with: YES NO
    1. SABS 089, Part 3- with reference to the following:
    • Observation wells
       
    • Pipes slope back to tank
       
    • Non-return valve on suction line
       
    • Leak detection on pressure lines
       
    • Shear valve under dispenser
       
    • Overfill protection
       
    • Gravity fill tanks
       
    • Filler point containment
       
     
    1. SABS 1535, GRP-coated steel tank standards.
       
     
  • SABS 1830, non-corrosive piping standards.
  •    
     
    1. Specify any other additional construction specifications.
       
     
  • Specify management practices
  •    
     

     

    SECTION E: PROJECT DETAILS

    1. Is the project significantly different from surrounding land-uses e.g. a factory in a residential area, or a housing development in a conservation area etc? Please give brief details.
    2. YES/ NO
       
       

    3. Is the proposed development within a 5km radius to any existing filling stations within an urban/ built-up/ residential area or within a 25km radius of any existing filling stations in other areas?
    4.      
      Residential Area   Rural Area
      YES/ NO   YES/ NO
           
           
    5. How many filling stations presently exist within either the 5km radius within an urban/ built-up/ residential area or within a 25km radius of any existing filling stations in other areas?
    6.      
      Residential Area   Rural Area
      Number of existing filling stations?   Number of existing petrol facuilities?
           
           
    7. Give the distance (in meters) from the proposed filling station to the closest existing filling station in all directions (irrespective of distance):
    8.      
      North: Meters   West: Meters
      South: Meters   East: Meters
    9. Will the project be considered as noisy or an intrusion by neighbours to the site?
    10. YES/ NO
       
       

    11. Will the project be considered a visual intrusion e.g., on a ridge or creating light pollution in a dark area?
    12. YES/ NO
       
       

    13. Will there be any emissions into the atmosphere? If yes, please give brief details:
    14. YES/ NO
       
       

    15. Solid Waste:
    16. (i) What solid waste products will be generated? Please give brief details including estimates of quantities:
       
       
       

       

      (ii) How will these waste products be disposed of?
       
       

    17. Effluent:
    18. (i) What effluent will be generated? Please give brief details including estimates of quantities:
       
      (ii) How will this effluent be treated (if applicable) before disposal?
       
       
      (iii) How will this effluent be discharged and when?
       
       

    19. Will any hazardous substances be produced or utilized? Please give brief details including estimates of quantities:
     
     
     
     
    1. How will the site be serviced and who will provide the service? Please confirm that the service provider has the additional capacity for the project. (e.g. Rand Water):
    1. Electricity
    2.  
       
    3. Sewage
    4.  
       
    5. Solid waste
    6.  
       
    7. Water
     
     
     
     
     
     
     
     
     
     
     
     
     
     
    FOR DEPARTMENTAL USE ONLY
     
    Date received:  
    Reference No:  
       
    Classification
    X
    Requirements
    1. New filling station in proximity of an existing filling station   
    Authorisation 
    will not be granted
    2. New filling station within a sensitive area  
    3. New filling station within an industrial or non-sensitive area   Exemption could be considered. The requirements outlined in Annexure 2 must be met. The Checklist must be completed in full.
    4. Upgrade of more than 25% in proximity of existing filling station or within sensitive area   The Checklist must be completed in full. The requirements outlined in Annexure 1 must be met. 
    5. Upgrade of less than 25% in proximity of existing filling stations or in sensitive areas   Exemption could be considered. The requirements outlined in Annexure 2 must be met. The Checklist must be completed in full.
    6. Upgrade of more than 25% not in proximity of existing filling station or within sensitive area     

      

      

      

    General exemption could be considered. The requirements outlined in Annexure 3 must be met.

    7. Upgrade of less than 25% not in proximity of existing filling stations or in sensitive areas  
    8. Tank installations for agricultural / temporary purposes  
    9. Tank installations at commercial sites in industrial areas  
       
    Is exemption applicable:
    COMMENTS
    Yes 

     

    No 

     

       
    if yes above, Are the requirements listed in Annexure 2 SATISFACTORILY addressed? 
    Yes  
    No  
    IF NO, LIST ADDITIONAL REQUIREMENTS:
       
       
       
       
       
       
       
     

     

    ANNEXURE 5
    LIST OF SENSITIVE AREAS

     

     

    1. Within 1km of rivers, streams, wetlands and pans.
    2. Within the 1:100 year floodline. (This is not considered as a suitable location by the Department of Water Affairs and Forestry and location alternatives must be taken into account).
    3. Within 5km of Bird Sanctuaries or adjoining properties.
    4. Within 5km of Proclaimed Nature Reserves, protected natural environments or adjoining properties.
    5. Within 5km of properties subject to any statutory conservation status or similar, including, but not restricted to, National Parks, Provincial, Local or Private Nature Reserves, Protected Natural Environments, or adjoining properties.
    6. Within 1km of any area that is of cultural importance e.g. historical sites, as proclaimed by the National Monuments Act.
    7. Within 1km of any Environmental Protected Area including zoned open spaces or adjoining properties
    8. Within 2km of any areas identified as areas of high ecological, cultural or social environmental importance in Gauteng, as defined by this Department (Gauteng Open Space Project, 2000).
    9. Within 250m of ridges (the term refers to hills, koppies, mountains, kloofs, gorges etc.).