The Preservation of Mkondeni Mpushini Biodiversity Trust (the
PMMB Trust) is a not-for-profit organisation in the process of being
registered as a Trust, and has registered as an interested and affected
party in this proposed development. The Lower Mpushini Valley Conservancy,
most of whose members live in the Mkondeni Mpushini Valley area, initiated
the formation of the Trust, is the initial donor to the Trust, and is also
registered as an interested and affected party.
The primary goal of the PMMB Trust is to preserve the
ecological and environmental integrity of the Bisley, Mkondeni and Mpushini
valley systems (the Biodiversity area) for the communities living in
the vicinity of Pietermaritzburg in KwaZulu-Natal.
Our objectives
are:
· To
rehabilitate, preserve and promote the environmental, ecological and
historical integrity of the Biodiversity area;
· To facilitate
and support sustainable community driven development initiatives within and
adjacent to the Biodiversity area;
· To establish
appropriate small, medium and micro enterprises and provide skills training
for the beneficiary communities;
· To promote the
Biodiversity area as an eco-tourism avenue;
· To act as a
fundraising, accountability, coordination and communication forum.
First and
foremost we have serious concerns in respect of the Public Participation
Process which we believe has, to date, been poorly advertised, provided us
with insufficient information to make or note any reasonable concerns, not
been participative, nor transparent, and not conducted in good faith,
blatantly ignoring the guidelines as stated in the National Environmental
Management Act, 1998 and as such insist that the process be commenced anew
with sufficient notice and advertising commensurate with a development of
this magnitude.
In particular, at the first
public meeting on 13th June 2006, which was poorly advertised and
poorly attended, the chairman of the meeting, Mr. Doc Louw, opened by
stating that the purpose of the meeting was for the developers to present
their proposal, and was not a forum for matters to be discussed and any concerns would have to be submitted in writing. The meeting is part
of the “Public Participation Process” and we understand “Public
Participation” to mean involvement of the public and getting their input as
much as possible. The information was sketchy at best, and any questions
raised to the presenters, especially Mr Rod Montgomery, were scantily
addressed and on many occasions we heard that “ideas were being thrown
around”. What then is being proposed and why has the process commenced?
There was also resistance
from the developers to extending the deadline from the 22nd to the 30th
June, and we feel that the EIA consultant, as an independent entity, in
consultation with the DAEA, should determine the time scale required, not
the developer giving permission for an extension of time for the Public to
make reasonable assessment of an “idea being thrown around”!
We were assured we would
receive minutes of the meeting within days. The appointed project manager
for the developer, again begrudgingly agreed to make minutes available,
bringing into question the transparency of the Public Participation process.
It should not the developers’ prerogative but that of the EIA consultant, an
independently commissioned entity, and the Chairman should have insisted on
this without reverting to the developer, in the interests of transparency
and good faith.
To date we are not aware of
any minutes having been circulated to any parties, despite the presence of
recording devices and an appointed secretary, we have had neither the
courtesy of a note or email to address this conspicuous lack of
transparency.
We are concerned that the
process will not remain open for comments and submission of concerns and
objections, by existing and new interested and affected parties, throughout
the process of development of the scoping reports and the subsequent
conducting of the Environmental Impact Assessment, and request that this is
allowed in the interests of openness and transparency.
We further wish to raise
concern that the application process is being taken on the fast track,
as indicated by the appointed project manager, which appears to fly in the
face of public participation, assuming that there would be no opposition to
the proposed development and that the proposed development is a fait
accompli. Again this smacks of lack of concern for proper procedure and
public participation, and a lack of transparency and good faith.
We also raise
concern, and question the validity of a process of engaging in Public
Participation for a proposed development on a proposed erf that has yet to
be determined. The erf number 9896, as advertised, does not exist, and in
the advertisement placed there was no indication of its location, and as
such, the process as conducted to date, if indeed valid, cannot be construed
as participatory, if persons reading the advertisement have no idea where
the development is proposed to occur, and therefore have no indication that
they may be interested and affected parties.
The proposed erf
9896, has furthermore, not been rezoned residential and is still subject to
a zoning hearing, which process requires public participation as well.
Commencement of
an environmental scoping process for this proposed development is therefore
in our opinion premature and pre-emptive.
Again we
reiterate our insistence that the process be commenced anew, and that proper
procedure be followed including a transparent and well advertised public
participation process.
Having received
insufficient information on the proposed developments, and in the absence of
minutes of the meeting held on 13th June 2006, we are hardly in a
position to raise concerns.
Notwithstanding
the above, and with substantial reservations regarding the validity and
transparency of the process and proposed development, we have serious
concerns that this proposed development might have an impact on:
- The rich
biodiversity (which includes several endangered species) that exists on
the property. Particularly in respect of
- Endangered
species within the Valley complex
- Endangered
landscape in context of urban sprawl
- Staff impact
on surrounding properties, and muthi plants
- Fauna
(including birdlife) and Flora,
i. Restriction of dogs and cats
ii. Larger mammals need larger areas to survive, what will happen
to the Eland herd and the other large mammals on the proposed development
site.
- Fencing
i. Restricting movement of fauna,
ii. Perimeter and internal fences
- Fire
Management – the valley has a history of rampant fires
- The Umsunduzi
River. If the primary water supply is to be drawn from the catchment area
of an important river, there will be a negative impact on the river, as
well as associated potential problems to ground water through waste and
sewerage management. Particularly;
- Cumulative
effect of developments occurring in the Valley systems as outlined above
(Bisley, Mkondeni and Mpushini, including Bishopstowe, and other
surrounding initiatives currently in process)
- Mkondeni/Mpushini
Catchment area – supply to Nagle Dam and impact on its supply publics
- Umgeni Water shortages – potential of undersupply to lower income facilities,
reallocation of resources may exclude this proposed development
- Oversubscription and shortage of supplies in existing housing
infrastructure
- Irregular
supply history in Ashburton (R175,000 in IDP allocated to repair?) vs
Bulk Water Supply from groundwater?
- Estimated
demand exceeding supply in the context of:
i. Fire fighting capability
ii. Study of defining buffer zones
iii. Study to determine Strategic Environmental impact considering
water requirements and agricultural requirements for food security
- Environmental
aesthetics. Mkondeni and Mpushini Valley immediate neighbours’ concerns
need to be respected in terms of visual degradation, overhead telephone
and powerlines, noise and nightlight pollution. Particularly;
- View from
Ashburton to Pietermaritzburg (and Pmb to Ashburton)
- Open space
before Pietermaritzburg (see recent Editors comments in Witness about it
being a unique entrance through natural bushveld)
- Continuous
development from Cato Ridge to Pietermaritzburg (can’t undo development
once done – We can preserve this entrance to Pietermaritzburg, and can
do something right from the beginning)
- The rural
character of the Valleys and its surrounds. The main reason most of our
members choose to live in the area is because of its natural beauty and
its rural character. The residences that have been mentioned far exceed
any natural, evolutionary growth, and form part of an unnatural cumulative
effect that will lead to the peri-urbaniztion of a rural, primarily
agricultural district, contrary to the intentions of the IDP of reducing
urban sprawl.
Without having
seen any detailed plans, and given the vagueness of the responses at the
first “Public” meeting however, it is impossible to assess what additional
concerns or objections will be raised.
We are concerned
with issues as outlined below and in our opinion, these issues that need to
be comprehensively addressed are:
- Cumulative
Effects of residential developments on Mkondeni Mpushini Valley system
- Opportunity
Points as defined in IDP, what about the Bisley Mpushini Mkhambathini
Reserve which was so comprehensively researched only a few years ago, and
is gaining momentum again with the interest of the KZN DEDT EU Gijima
programme in the Mkhambathini Reserve
- Development
Planning in context
- How does the
development align with Municipal Planning Principles?
i. Integration with IDP
ii. Prevention of Urban Sprawl
iii. Optimising existing resources
iv. Promotion of diverse land uses
- Layout and
Densities
i. “Lifestyle estate” of 5,500+ units on 50% of 500ha equates to
44 units per 5ha plot vs 1 dwelling per 2ha plot currently
ii. Conservation areas need buffer zones that do not make up part
of the conservation area itself.
- Need and
Desirability
i. Perceived need does not demonstrate a need. The developers
should show beyond a reasonable doubt that Pietermaritzburg can absorb the
demand, that the Municipality has capacity and have agreed in writing to
take on the responsibility to service the open spaces and maintain the
infrastructure, in the light of the other residential estates planned within
a 50 km radius, including city developments such as the Duzi Waterfront
development, the Greater Edendale Development Initiative, and various other
priority areas, which require upgrade and densification before a new “profit
based initiative” draining the stretched resources of Municipality, see
Cumulative Effects above
- Zoning: Is
this in line with original planning schemes?
i. Agricultural
ii. Protected areas
iii. Garden plots
4. Assessment of Alternatives
- Conflicting
Land Uses with Proposed Residential Middle Income Estate
- Agricultural
Options, tunnels, hydroponics, herb growing, etc
- Conservation
Incentives available within existing government Department systems
- Activity
Based Nature and Cultural Tourism Options
iv. The Bisley-Mkambathini Reserve
v. Capacity to expand existing services,
vi. Destruction of unique flora and fauna
- Previously
cultivated land, if not cultivated or managed in the last 10 years, may
be considered virgin land. When was the land last actually cultivated?
- Provision of
Services
- Sanitation
i. Septic tank systems, permeability of geophysical environment
makes dense residential estates environmentally unviable
ii. Impact on groundwater and existing water regime
iii. Disposal and impact of waste water
iv. Separate Waste and Effluent management system in the light of
failed systems in other developments in South Africa, and the impact on this
on the Duzi River, the Eco-tourism potential and the Municipal capacity
- Storm Water
Management
i. Concentration of rainfall from roofs into piped system
- Solid Waste
i. Volumes of waste from development
ii. Currently limited service from Pietermaritzburg Municipality
iii. No upgrade of service in Integrated Waste Management Plan for
Umgungundlovu
iv. Transfer station EIA with DWAF a separate process?
v. Integration of waste problem into surrounding communities
vi. Development in a small village with minimal amenities
- Electricity
Supply and Reticulation
i. No indications of upgrade in pipeline from Eskom
ii. Clear indication of electricity costs and visual impact
iii. History of irregular supply in Ashburton (see recent Witness
articles)
- Traffic and
Road Infrastructure Development
i. External Roads
1. Danger to fauna, residents
2. Traffic flow study
3. Impact on roads resurfacing and integration with Roads
Authority, budget restrictions of municipality, again allocation of
resources to new residential areas against current backlog of delivery in
underserviced areas?
ii. Internal Roads
1. Runoffs, impact on siltation and storm water system if not
surfaced or allowed to remain unsurfaced for any length of time
- Open Space
Maintenance: Who will be responsible for maintenance of the veld, the
open spaces, the burning programme, the alien weed eradication, the
invasive and riverine vegetation re-establishment. What happens in 5 or
10 years time? Who will pay for this programme then?
- Sense of Place
- Open Space
- Country
ambiance
- Incorporation of bridal trails in title deeds (and conservation
servitudes)
- Noise
Pollution (health impacts)
- Light
pollution (health impacts)
- Degradation
of lifestyle
- Development
impact on skyline
- Cultural
Historic Issues
- Shepstone’s Hunting Lodge
- Mkhambathini Reserve
- Traces of
early iron age artefacts
- Socio-Economic
Concerns
- Local
opposition by residents
- Increased
crime levels
- Increased
traffic flow, burden on Municipality and National Roads
- Ashburton as part of The Amble Tourism Initiative
- Tourism
initiatives already established
- Contributions to local economy, Cape Based Developer
- Address
labour, long term job creation (not just short term construction
related) and socio-economic factors (will impact on residents current
income earning potential which relies on the open spaces and
conservation)
- Conduct
Resource Economic study as alternative analysis
- Strict,
sustainable articles of agreement governing land-use and residents
rules.
- Decrease of
land value as a result of increased density
- Air Flow
implications for the Greater Pietermaritzburg city region given that the
Valley is acknowledged as a key cleaning mechanism (study done in 1970’s
- a new study should be commissioned to determine the impact of the
proposed developments on airflow)
- Shifting
Baseline Syndrome: Developments and residential estates, if this proposal
can be called that, are seen in the light of current densities and urban
sprawl, rather than taking cognizance of the environmental situation 20 to
50 years ago in respect of the landscape, the biodiversity, wetland
systems, water permeation, geophysical environment, fauna and flora, the
proximity of open spaces to Pietermaritzburg, and other factors that shift
our paradigms to account for our current observations.
- What about
densification within the city centre? There is ample space and flats can
be built within the city close to work opportunities.
In closing we
reiterate our concern that the process is flawed, not transparent, has not
been conducted in good faith, poorly advertised, is not a public
participation process, and insist on commencement anew, adhering and
following the guidelines as set out in the National Environmental Management
Act, 1998, and not the legal minimum, given the size and scope of the
development, and the far reaching implications for the Municipality and its
inhabitants as a whole.
Thank you for
the opportunity to submit our concerns. We do hope you will make an effort
to correspond timeously with us in future, and await the first draft scoping
report with interest.
Yours
faithfully,
Mike Jewitt
Chairman
CC
The Minister, National Department of Environmental Affairs and
Tourism
Mr S’bu Ndebele,
Premier of KZN
Mrs Kim van
Heerden DAEA
Mr Ian Felton
DAEA
Mr A.H.R. Louw,
Geyser, Liebetrau, du Toit and Louw
Mr R.Haswell,
Msinduzi Municipality
Mr S. Hillcove,
Hilcove Properties (Pty) Ltd
Mr L.Kinnear,
Pinnacle Point Developments (Pty) Ltd
Councilor S Lyne
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