Environment Minister Barbara Creecy’s appeal decision on the giant Boulders wind farm project on the West Coast Peninsula near Vredenburg is expected by 8 July at the latest.

This was the message from Creecy’s Department of Environment, Forestry and Fisheries (DEFF) to acclaimed wildlife photographer and environmentalist Peter Pickford, who has been appealing the proposed project on behalf of more than 1,200 members of three property-owning associations on the neighbouring coastline.

DEFF had in January approved the proposed Boulders project that will consist of 45 turbines standing 165m high and generate up to 140 megawatts of power.

The deadline for appeals was in mid-February, and Pickford had posted a comprehensive appeal ahead of that cut-off. Part of this appeal was based on the argument that the new wind farm would blight the important scenic landscape of the West Coast that is a major tourism and lifestyle attraction.

But in May Pickford also asked the department to allow him to supplement the original appeal with an “urgent” new proposal: that the wind farm should rather be constructed on an alternative site at the recently mothballed ArcelorMittal’s Saldanha Steel plant that is just 14.5km to the south-east.

DEFF refused Pickford’s request, telling him in a letter dated 11 June, and signed by the director of appeals and review Mokete Rakgogo, that it was legally constrained from allowing any additional appeal considerations to be submitted after the formal closing date.

“The 2014 Appeal Regulations sets out stringent timelines for the appeal process. Importantly, these regulations make no provision for the substituting or supplementing of an appeal after the lapsing of the appeal period. In the administration of appeals.”

The department was guided by, among other considerations, a Constitutional Court judgment in this regard, Rakgogo’s letter added.

Pickford told Daily Maverick that he understood the department’s legal obligations and was grateful for its response. “Now we will wait for the appeal outcome,” he said.

But in addition to Pickford’s comments on behalf of the property owners, there is another significant appeal against the Boulders project that Creecy is having to consider.

This is an appeal from the West Coast One wind farm that has been operating on the West Coast peninsula since 2015, and that is an immediate neighbour of the Boulders facility.

West Coast One says the huge turbines of Boulders will be situated immediately upwind of its own slightly smaller turbines and will thus deplete its access to the wind resource because of the physical phenomenon of “wake effect”, potentially causing annual energy production losses from its own turbines of between 1,5% and 2.5%.

(The wake effect is the term for changes in wind speed caused by the mutual interaction of wind turbines sited close to each other, and wake losses are energy production losses caused by a wind energy deficit downstream of wind turbine rotors.)

Because it has signed a 20-year supply contract with Eskom, West Coast One says power losses caused by Boulders will represent “significant” revenue losses for them of somewhere between R7-million and R11-million a year based on the current tariff – “and potentially as much as hundreds of millions for the remainder of the Power Purchase Agreement, based on estimated operational data”.

In his most recent appeal letter, Pickford argued that the Boulders wind farm project should be moved to the Saldanha Steel site because, among other reasons, this was an industrial site within the proclaimed Saldanha Steel Industrial Development Zone and was totally surrounded by vacant land already declared as an industrial development zone.*

However, Saldanha Bay Industrial Development Zone communications associate Senzwa Gum has pointed out that ArcelorMittal’s steel plant is not located within the current 365-hectare designation of the IDZ, nor is it surrounded by this zone.

Pickford acknowledged his mistake but added: “It seemed reasonable to assume that ArcelorMittal and the several surrounding large industrial enterprises were part of the IDZ. And even if they are not, the precedent remains for large industrial development on and surrounding the now-abandoned steel factory.” DM

* Some of the information in this piece was first published in GroundUp.