Home   Forum   Downloads   Links   About Us   Contact Us 

Draft EIR May 2004 - comments

The report is full of half-truths and clever deception

In spite of over 1200 pages of consultant-speak, the draft EIR contains contradictions, misses important points and conveniently ignores many people most affected by the road. At no point does the report recommend that perhaps the cost of the road to the environment will be too high and that it should not go ahead.

At least the report now recognises that some impacts of the development can not be mitigated. This might be an attempt to appear unbiased - because many of these impacts are in the greenfields sectors and the report states that the area is a declared road reserve anyway.

Jump to:

Visual Impact Report

This report can be viewed here. I have several issues with this report:

This report is so bad that I wonder whether it is negligence, stupidity, or deliberate misrepresentation.

Mistakes in marking the location of views

Below we see the portion of the map that shows where the before and after images for sector 1 were taken. The black triangles show the location and direction of the photographs shown in the next section. The red arrows point to the correct location and direction.

Mistakes happen, but the issue is this:

Inaccurate Graphic Imagery

The pictures presented in Sector 1 of the Visual Impact Assessment are inaccurate in that the path of the proposed road does not correspond with the engineering diagrams for the area. This is made worse by the use of a wide-angle lens that makes the houses affected by the road appear to be far from the road itself, when in fact the road will be 23m away from the houses and the road surface will be at least 6m above the ground.


This view looking West neglects to show that the on-ramp from Main Road will be where the Cape Dune vegetation on the right is (see the cyan line drawn by myself). From where this picture is taken, and the area marked by the consultants with the red arrow, creates the impression that a flat road, out of sight of any houses, will have a minimal visual impact. The truth is completely different: the engineering diagrams show that the road will be 6m above the red arrow, and that the on-ramp from main road will be at a similar height and will replace the bushes that here create the illusion of a screen.

The mistake is even more inexcusable because the red-roofed house visible at the end of the cyan line is earmarked for destruction, so clearly forms part of the road.


In this picture, looking East, the cyan line on the left shows the actual boundary of the road - twenty metres away from the houses in Lake road, and not shielded from those houses by the bushes the way the consultants might want us to believe.

A further gross omission is that the road needs to go over the railway line - and the engineers have specified a bridge that has the road surface 12m above the level of the ground. Obviously this would have a huge visual impact, and the diagram showing a flat red arrow is misleading.

Unprofessional Presentation

To me, using vague wide-angle photographs and overlaying approximate arrows in an attempt to show the visual impact of the road is unprofessional. In this age of digital image processing you would expect the consultants to produce something a bit more realistic - especially because the current images do not convey the full impact of the road on the houses in Lake Road. I expected these specialists to be able to model/overlay/graphically represent a 4-lane highway with elevation of 6m above ground level, rising towards the bridges over Main Road and the railway line.

What will the bridge over Main road look like? How will the bridge over the railway line affect the views of the fish-eagles on their perch from the hides in the Zandvlei Nature Reserve? How will the elevated road affect the views and property values of the houses in Lake Road, Sheraton Park, Sea Winds and the Marina da Gama. I expect the visual impact report to be able to show me these things - not a half-baked, inaccurate and misleading snapshot.

my own mockup picture of my view without the road
My view without the road, and ...

my own mockup picture of my view with the road
my view with the road, using a graphics package to make a mockup out of digital photographs. Now we can see just how crucial the visual mitigation measures are in this area. However, even when the road is hidden, the view will be hidden too. This picture also shows that we will need alternative security arrangements, because the Mountain Men can no longer watch us from Boyes Drive.

If the consultants aren't able to simulate the true visual impact, how can they recommend mitigating factors? If these pictures are anything to go by, there doesn't appear to be a problem. Below is a photograph from my front gate that shows the full impact of the road on my view. The blue marker on the pole is the road surface level of the edge of the on-ramp that runs alongside Lake road. The road climbs from there towards the left (to cross the railway line by bridge) and to the right (to cross Main road by bridge). The red marker is two metres above the blue one, and would represent the top of a sound barrier or visual screen. Lamp posts would be higher than this and present further problems.

Lack of Alternatives

What does the 1.8m screen look like when used to hide the road? How can we decide that hiding the road behind a wall is adequate visual mitigation? Surely showing these alternatives would be part of the job?

How do the consultants propose to hide a road that is 6m up in the air? Glibly mentioning walls or berms is totally meaningless in this context - however, perhaps there hasn't been enough homework and the consultants don't realise that this is the problem in this area?

I want to know how my magnificent view of Muizenberg Mountain might be affected by the road. Just hiding the road is not enough, because if you do it using tall trees or a wall that hides the mountain the residents in Norfolk Park will justifiably be aggrieved.

Vague Mitigation

One of the mitigation measures that applies to the houses in Lake Road is to allow them to increase the height of perimeter walls in order to stop road users from being able to look in to them. Who pays for this? Why should a homeowner be liable for expensive fencing through no fault of his own? Most houses in Lake Road have low fences precisely so that they can enjoy the view of the nature reserve and wetland and Muizenberg mountain. How do they get compensated for this loss?

Knock-on Effects

If houses along Lake Road put up high walls to block out the Toll Road view, noise and pollution, Lake Road will become a dangerous alley: high walls on one side, toll-road on the other. This completely destroys the sense of place that Lake Road currently has. People living in Lake Road do so precisely because of this and because they eschew high walls and security complexes. This is a tangible destruction of the residents' environment.

With an elevated Toll Road, the security guards that monitor the suburb from Boyes Drive will no longer be able to see the houses in Lake Road. This will make them vulnerable to crime which will cost them money to mitigate. Who will reimburse these residents for the extra expenses of hiring armed security patrols in perpetuity once the road is built?

Bird Report

The bird report is at www.peninsula-expressway.org.za/draft_docs/Avifauna.pdf. The report provides helpful information about the legal requirements regarding the environment and wetlands but suffers from three shortcomings:

  1. The author's view that since birds can fly they will just move on and come back once road construction is over
  2. That most of the birds left are ones that have adapted to human disturbance anyway (so it is fine to disturb them further), and
  3. That road verges can be a useful source of conservation and species preservation

Please note that my opinions/comments will be marked in the same style as this text so that you can distinguish it from excerpts from the report,

which are marked like this

From Avifauna.pdf page 3:

Fragmentation of the natural habitats in the Cape Peninsula is the most serious threat to most species and in this context it can be argued that the proposed road will lead to further fragmentation and would thus be detrimental to most bird species. It can however also be argued that road verges, provided that they are correctly managed, can provide corridors between the isolated fragments of natural habitat (Yanes et al. 1995) and thus improve conditions for survival of some species. Various authors 3 (Gennard & Williams, 1975, Dickman & Doncaster 1989, Getz et al. 1977, Way 1977) have commented on this aspect but more detailed studies in respect of South African bird species are needed.

Road verges are a poor substitute for the corridors we already have, comprising unspoilt natural land and untouched road reserve linking the Westlake Wetlands to the False Bay Ecology Park and the Philippi farmlands. The reason road verges are touted in overseas literature is because in many cases the roads are in otherwise completely built up areas.

On page 16 under "Displacement of Game Bird Coveys":

  1. The fact that Greywing Francolin Francolinus africanus is still present in this area is surprising and exceptional. Generally, they are highly sensitive to disturbance and in this case it would seem that the remnant populations have become habituated to suburban disturbance. Every effort should be made to secure the future viability of these remnant populations, as was suggested in the scoping report.

    There is another interpretation to the presence of birds that are "highly sensitive to disturbance" - and that is that the area they are in right now is not disturbed. On what basis does the "surprising and exceptional" presence of these birds in an open, undisturbed wetland, lead to the conclusion that with some mitigation, putting a 6-lane highway through their habitat will lead to an increase in their number?

  2. Since Greywing Francolins feed mostly on the underground storage organs of geophytes, it is important to manage the area for the optimal production of such plants. The key to the sustained production of these plants is to keep the vegetation fairly short, either by burning or by mowing. Although burning is not usually considered a management option for road verges, it is strongly suggested that it be considered in the relatively contained area (2kms) between Lakeside and Lavender Hill

    As if the disturbance of the highway is not enough, these "highly sensitive" birds will be further encouraged by burning or mowing the road verges.

On page 30 of his document, Mr. Pepler lists these points about the benefits of road verges. By this logic, we should run a highway through Kirstenbosch Gardens in order to conserve (indeed improve) the environment there.

The positive outcomes of proper road edge management are complex and numerous (Pfisten & Keller 1995). A few such outcomes are listed below:

Economic Report

This report can be found at Economic-Impact.pdf

Summary

Overall, this report can easily stun you into believing that the economics have been well researched and that the road will benefit the city and the province. Pay attention to the following:

On a higher level, the reason the Toll Road is being proposed in the first place is because the R300 urgently needs to be maintained. The money for this maintenance has been paid by road users many times over in the form of fuel levies. These levies were first appropriated by the apartheid government to pay for the Angolan war, and since then has kept a general slush fund going that to this day is not being used for its intended purpose.

There is a R6-billion funding shortfall for road maintenance nationally. (Cape Argus of Thursday, 19 June 2003) According to an article in the Southern Mail of 23 October 2002, entitled, "Toll bid linked to misspent road cash." most recent figures (2000) - show that of R26 billion collected from fuel tax and traffic levies, including licence fees, only R3 billion was actually allocated for building and maintaining roads. R1 billion of that was spent on national roads. R2 billion went to the provinces but only 2,6% of that figure was actually used on roads - "The rest goes to salaries and administration," quoted an official of the SA Bitumen Association.

This Toll Road is the wrong solution to our problem. All we need is to allocate and spend the money intended for road maintenance in maintaining the R300 and we can enjoy all the benefits predicted here without incurring any of the costs.

Detailed Review of the Report

In order to ease assessment of local impacts these were done only for local areas adjacent to the existing R300. In addition to this the local impacts on the proposed False Bay Ecology Park and the impact on farmers of the greenfields section of the proposed road were also analysed.(Study Area, pg 16)

I would think that the change from having wetland in front of your home to having 6 lanes of highway elevated 6m above the ground would be a far bigger impact than the upgrading and tolling of the R300 would have on the suburbs adjacent to it.

An independent assessment of the financial viability of the project could not be undertaken because the only traffic projections that the project proponents made available to the Economic Study was for the existing sections of the R300. This was known at the start of the study and the approach specified in the terms of reference. In consequence resort was made to the financial assessment of the financial advisors of the project consortium. PriceWaterhouseCoopers, the financial advisors to the consortium have declared the project to be financially viable based on traffic projections, cost projections and projected toll tariffs that were supplied by the consortium.(Financial Viability, pg 31)

Ok, so we only have figures for the existing R300, and have to take the developers' accountants word for the rest. Sounds like another Enron to me.

there are no deterministic links between road infrastructure and economic development(Transport policy, Economic development and Toll roads, pg 32)

My point exactly. In this report the financial viability of the project (assured us by the auditors) is taken to mean that there is a demand for the Toll Road and that developing it will help grow the economy. The economic benefits touted in this report could be gained by other means - we are not stuck with our backs against the wall and doomed to build this road or die of starvation. Even the road developers see this as merely an investment. The issue is that it will cost us dearly, but this report does not show it.

The financial viability of the proposed project shows that there is a demand for the project and, in consequence, this is infrastructural development caused by economic growth rather than visa verse.(The role of transport infrastructure in economic growth, pg 34)

Circular Argument! The financial viability has not been established, having been assured to us by the auditors. So now we have the economics expert, basing his conclusion of an economic demand for the project, on the assurances of the company accountants and auditors. These people are not qualified to perform this function.

On the other hand, the R300 Ring Road could potentially harm economic development in Cape Town if it encourages urban sprawl; thereby lower the chances of reaping the benefits of densification. It would also not aid development if its cost could not be justified by the benefits it would provide. It is difficult to determine whether the lack of the Ring Road is a constraint to economic development as the above pros and cons are not easily comparable. In some cases they represent conflicting economic development policy objectives that can only be prioritised by the City and the Province.(Potential land use changes from the R300, pg 35)

Some road users would have increased costs in travelling on the tolled road relative to travelling on the untolled road. This occurs for journeys between the N2 and Vanguard Drive for all years during morning rush hour and for many years at off peak times. [The main reason for this is the increased traffic volumes on this section due to the new southern legs. (Individual road user costs and benefits, pg 63)

This shows that even more benefits might accrue to the economy if the greenfields sections in the South (where a lot of the environmental damage would occur) are omitted. It appears that the only beneficiary of the southern greenfields sections would be Penway itself.

Comparison of Road Benefits to Wetland Value

I have put this discussion in a separate section because the report is very long in this area, but ends up comparing the wrong things:

At one level the conclusion that can be drawn from these estimates is that the proposed project delivers more benefits than costs. It is not clear, at another level, that it is possible to compare the benefits of a transportation project to the costs of the impact on the wetlands. This conclusion is particularly important in taking into consideration of the proposed False Bay Ecology Park. (The proposed alignment and the False Bay Ecology Park, Pg 49)

To draw this conclusion by comparing overall contribution to the GDP of the whole project (calculated for Sector 2) to the conservative estimate of bare land value of the wetlands in Sector 1 is blatant manipulation of fact. An analogy would be comparing the cost of replacing the canvas, frame and paint of a Van Gogh to the GDP of a country and concluding that the country will be better off if the painting is destroyed. I notice too how the economic consultant does not shy away from making the comparison, but conveniently explains away the need for a proper contingent value analysis because it would be too expensive to conduct.

The areas south of Rondevlei and north of Capricorn Park can best be described as natural vegetation. With this in mind a value of R5 216 was used for them although this is probably an underestimation as it does not adequately capture the value of rare species found in natural areas. (Adaptation of values to the study area, Pg 47)

Quite right, a species is priceless - but that does not mean that its value is zero! Throughout this section the author pushes ahead assigning inadequate values to the wetlands and just leaving off the things he knows he can't put a price on.

However, Costanza's values include functions such as gas regulation (e.g. CO2 sequestration), which are not included in our values. (Validity of estimates, Pg 47)

Yet more essential services performed by the wetland that are conveniently omitted. Also omitted are the things the wetland does for us that we are not even aware of, and the potential medicinal or other uses of species in the wetlands that have not yet been identified (current estimates are that just over 10% of all species in the world have been identified).

The increased capacity of the proposed toll roads could attract additional traffic to the toll roads. If this occurs there would be less traffic on the rest of the road network generally. This would lead to reduced congestion and lower travel costs for road users and lower road maintenance costs for local authorities. (Road user costs and benefits (Sector 2), Pg 53)

The engineers on this project have repeatedly shown a severe lack of understanding of human nature: the average road user does not consider possible future car running expenses when deciding to use a Toll Road or not. The comparison is here and now: "do I pay R10 now to go on that big road, or should I take the route through the suburbs and save my money for something else?". Regardless of this report, most road users in the affected areas are cash strapped, concerned about daily issues and not able to consider long-term effects of their choices. According to one resident of the area that phoned in to a radio talk show, towards the end of the month many commuters hitch-hike to work because they have run out of money (will pedestrians be tolerated on the Toll Road?). Many taxi operators extend credit to their commuters at the end of the month for the same reason. Do you really think these people will choose to pay a toll when it appears cheaper to avoid it?

By the end of the concession period the combined schemes have the capacity to increase average network speed by 1.5km per hour relative to network speeds without the schemes. (Road network costs and benefits, Pg 83)

There is no indication that this so-called benefit includes the impact of knock-on effects of the road. Once a quick route to the airport or Northern Suburbs is provided, developers will build residences in the farmlands and the Southern Peninsula. More families will move away from town, acquire two cars and join the traffic. Within two years the traffic will stabilise to similar levels of congestion we enjoy currently, except that now we have irretrievably lost species, habitat, living environment, in favour of another traffic jam. Of course the developers can counter this by raising the toll fees during peak hours (they call it "congestion tolling") to make even more money perpetuating a system we should be getting rid of.

Some road users would have increased costs in travelling on the tolled road relative to travelling on the untolled road. This occurs for journeys between the N2 and Vanguard Drive for all years during morning rush hour and for many years at off peak times. [The main reason for this is the increased traffic volumes on this section due to the new southern legs. (Individual road user costs and benefits, pg 63)

This shows that even more benefits might accrue to the economy if the greenfields sections in the South (where a lot of the environmental damage would occur) are omitted. It appears that the only beneficiary of the southern greenfields sections would be Penway itself.

In Section 3.4.3 Table 34 it was shown that benefits to road users have a net present value of R2,751m. Benefits to other road users because of increased network capacity is estimated to have a net present value of R1,519m (based on calculations for Table 35 Section 3.4.4). Finally the overall contribution to GDP of the proposed project (which includes the two road user benefits) is estimated at R1,603, in the first three years of the project (Section 3.7.2 Table 45). The overall net present value of the contribution of the proposed project to GDP is estimated at R4,776m over the project lifetime. (Adaptation of values to the study area, Pg 48)

The R2,751m is for use of the existing R300 in Sector 2 and has no bearing on the benefits of a road through the wetlands in Sector 1 (in fact, the analysis seems to show that the benefit is reduced due to extra traffic from the link in Sector 1).

It is not clear how much of the R1,519m is due to the link in Sector 1, presumably not the full amount.

The overall contribution to GDP has very little to do with the road through the wetlands - the only portions one can include would be

  1. the construction costs of the road in Sector 1, and
  2. a portion of the R1,519m, and
  3. the operating costs of the portion of road in sector 1.

Similar benefits can be gained by revamping the beachfront at Muizenberg Corner, building a shopping mall, improving our parks and nature reserves to boost tourism, switching all business to open-source software to eliminate dollar-based license fees, rebuilding District Six, or even just fixing and maintaining the existing R300 without extending it. Without destroying globally significant biodiversity hotspot habitat or extinguishing endangered species.


It is proposed that a mitigation measure be adopted where taxis toll tariffs on the proposed projects are fully or partially subsidised by the fiscus. Such a subsidy would achieve a number of simultaneous objectives.

  1. First, it would help vulnerable communities and travellers.
  2. Second, it would help achieve the policy objective of moving more commuters to public transport.
  3. Third, it would subsidise the taxi industry without the need for an administrative infrastructure and reduces the potential for corruption compared to alternative ways of subsidising the taxi industry.
(Impact on public transport, Pg 103)

The third point implies that Penway is not corruptible, and puts Penway as the subsidy administrator. The fourth point that is omitted is this: Penway makes money by doing a job the government should be doing anyway, and the taxpayer pays anyway. Why doesn't Penway just pay the mitigation expense itself? Or should we interpret this to mean that they also won't be paying for other mitigation measures such as access tunnels for frogs, oil traps for spills, and compensation for loss of property values?

A second example of this is the impact of traffic diversions and their potential impacts on accidents, pollution and road maintenance. This could cause increases in demand if accidents result in more panel beating, pollution results in more medical care and there is more spending on road maintenance. In consequence while traffic diversions are a clear cost they could result in increases in measured GDP. (The Overall Macroeconomic Impact, Pg 129)

So, the GDP figure used to overwhelm the value of the wetlands is influenced by all sorts of economic activity, including worsening of the traffic situation. This is a further indication that the munificent figures quoted around the benefits of the road would also apply if we built a nuclear power station on Table Mountain.

A number of economic impacts could not be taken into account.

  1. First, in the case of the R300, changes in property values and environmental impacts as a result of the greenfields part of the project are not taken into account in these estimates.
  2. Second, the cost of traffic diversion was not included in this part of the study. This was the result of a lack of information about potential traffic diversion. " Technically the cost of traffic diversion would add to GDP when the secondary roads are repaired because this is an increase in demand for road repair services. This would be offset of course because the increased expenditure must either be financed by increased taxes/rates (which would result in a fall in demand) or by expenditure switching (which would also cause a fall in demand). Hence the overall macroeconomic impact of road repair as a result of traffic diversions would be the difference, if any, between the increased demand and decreased demand of the above choices Economic Specialist Study 130 " Other costs of diversion cannot be accounted for as macroeconomic impacts. Pollution and increased noise as a result of diversion clearly have social and economic effects but their macroeconomic effects must be reduced to changes in demand.
  3. Third, the macroeconomic impact of potential structural economic changes was not and could not be included in the macroeconomic estimates. It is very likely that the proposed toll road would bring about a variety of structural economic changes.
(The Overall Macroeconomic Impact, Pp 129,130)

So the benefits are further inflated by ignoring some of the costs and environmental services lost to the economy. Structural changes are ignored. No doubt they would improve the GDP too, but will cost businesses and individuals affected (almost a form of schadenfreude).

As with the contribution to GDP, the major contributor to jobs after construction and the potential savings in road user costs and their resultant impact on demand. These in turn lead to increased spending and the generation of indirect jobs. The proposed project has the potential to generate between 2,000 and 5,000 direct and indirect jobs over the concession period. (Job creation, Pg 135)

Many other possible projects can create an equivalent number of jobs. However, the results here are overstated in the summary and in the public press (Poens Venter talks about 7000 jobs being created in the Constantiaberg Bulletin of 13 May 2004). The table of data presented in table 47 shows that at the end of the concession period only 4179 jobs might be created. This is in 2034. Before then fewer jobs will be available: only 1974 jobs in 2012. Given the state of unemployment in Cape Town, this is a drop in the ocean and arguably not worth the sacrifices that are being brushed under the carpet in this report.

Similarly, there is an annual R250m contribution to indirect household income during the initial construction phase. After this time the demand effects of savings in road user costs could stimulate indirect household income by over R500m by the end of the contract period. Overall the proposed project has the capacity to add a cumulative total of R8 billion by the year 2037. (Other macroeconomic effects, Pg 136)

The table accompanying this text tells a different story. The large figures shown here translate to an annual average contribution to household income of R171 in 2012. I am sure the farmers, homeowners and businesses that stand to lose income, living environment, views, silence and fresh air will be happy to know that their loss is putting money on everybody else's table but theirs.

It will be appreciated that while the proposed toll road would make a macroeconomic contribution at a national level, the effect relative to the entire economy is modest. Nevertheless there is an effect and the effect is quantifiable. The contribution to South African GDP is 0.06% in 2003, dropping slightly to 0.05% in 2005. During the later years when the ongoing capital expenditure amounts reduce and the toll road is in full operation the contribution to GDP is in the order of about 0.03%. In the case of the Western Cape the toll road would increase GGP by about 0.1% during construction. The contribution to Western Cape GGP levels off at between 0.04% and 0.07% after the initial construction period. (Comparative Macroeconomic effect, Pg 137)

Reality Check: after the big numbers in the billions get thrown about here, we discover that in the global scheme of things the effect is practically un-noticeable. A letter to the newspaper could have a bigger effect on our GDP than this road.

In consequence the do nothing alternative would harm the prospects for economic growth in the Western Cape. It would reduce peoples spending power, force firms into financial hardship, reduce tourism spending and probably undermine investment. (Economic-Impact.pdf page 140 last paragraph)

The points that lead up to this conclusion do not actually support it. The truth is that merely upgrading the R300 using the usual government budget would realise all the benefits touted for the whole road, without harming the wetlands, the False Bay Ecology Park, or tourism. Are we actually going to cry over 0.03% of GDP?

Herpetofauna (Frogs & Reptiles) Report

This report can be found at Herpetofauna.pdf

Summary

This report is fairly accurate in terms of the effect the road will have on herpetofauna - it will have a negative effect on the frogs, snakes and lizards in the area regardless of mitigation measures.

While the author recommends culverts under the roads to allow frogs, lizards and snakes to pass under the road, he does not specify how many or how wide they must be in various areas. This gives the road engineers free reign to put in too few and make them too small or inadequate in other ways (in the interests of saving costs).

Consideration should be given [my emphasis] to the installation of culverts (tunnels under the road) to promote the interaction of terrestrial animal populations on either side of the road and help reduce road casualties. In suitable areas [my emphasis], culverts of more than 500 millimetres in diameter, and as many as possible, could [my emphasis] be positioned at appropriate intervals. The priority areas for culverts would be in the vicinity of wetlands and natural habitats, especially where the road bisects these areas. In particular, this would apply to the important leopard toad areas between the Main Road (M4) and Prince George Drive (M5), a two kilometre stretch from the CFWWTW eastwards to beyond Strandfontein Road (M17), and, to a lesser extent, between Prince George Drive (M5) and the CFWWTW. Sections of road raised off the ground on supports in the form of flyover bridges would also potentially allow for [my emphasis] the movement of terrestrial animals. The placement, number, design and size of the culverts needs to be decided upon with the road engineers [my emphasis]. (Herpetofauna.pdf Pg 3)

While the sentiment of the paragraph above sounds like it supports conservation and is recommending mitigation measures it specifies nothing. The engineers would still be within the recommended mitigation measures if their decision is to not put in a single culvert. They will give strong consideration but determine that there are no suitable areas. They would try to put in as many as possible, but cost and other engineering constraints would make it impossible to put in any. I expect the herpetofauna specialist to lay down the requirements precisely and not allow for deviation for any reason. Surely for the mitigation measure to be effective, we need a certain minimum number of culverts in well-defined areas. The specs of these culverts needs to be precise and invariant. Otherwise it is speculation and the expert actually knows nothing.

No solid wall type barrier should be constructed alongside the road such as the one along the N2 between Cape Town and Khayelitsha. A solid concrete barrier would obviously restrict the movement of terrestrial animal life. If such walls are envisaged, regular gaps of more than 500 millimetres in diameter should be made at the base to allow for the movement of wildlife. (Herpetofauna.pdf Pg 3)

What about a solid wall at the road edge? What stops the animals from straying onto the road surface? How come this obvious requirement has been overlooked?

Ideally, road reserves should be wide enough to allow for a wildlife sanctuary area which will not be destroyed by future road widening projects. In an urban environment, road reserves can provide important sanctuary areas for wildlife and also serve as corridor areas for the movement of terrestrial animals linking them to more important conservation areas. (Herpetofauna.pdf Pg 3)

How about specifying exactly how wide the road verge needs to be to fulfil the wildlife sanctuary role that is so glibly being envisioned for it? Why the concern over future road widening but no worries about the current road construction in an otherwise natural area? Does anybody actually know how willingly snakes, toads and other reptiles make use of a road verge to move around? What about the street lights denying nocturnal creatures cover of darkness for moving along their corridors?

The road reserve must be suitably landscaped and rehabilitated (with indigenous vegetation) following on road construction, and any wetland areas should be maintained and not filled in or drained. This will help encourage recolonization by amphibians and reptiles. (Herpetofauna.pdf Pg 3)

Although the report states here that any wetland areas should be maintained, the developers are planning to fill in the wetlands along Lake Road with fill over 6m high and 80m wide. Their justification is that the area is a "declared road reserve". True, the area was declared a road reserve decades ago, when the apartheid government needed a barrier between the whites and non-whites, and the natural environment of the Cape Flats was not a biodiversity hotspot. The road reserve is for a single-lane rural road with 80km/hr speed limit, NOT a 6-lane highway. We do not need a road from our apartheid past, nor a continuation of the dinosaur thinking that led to our environment being endangered in the first place.

The rest of the report is a repetition of the above for every sector.

Noise Impact Report

This report can be viewed here. I have several issues with the conclusions of this report:


This site's design is only visible in a graphical browser that supports web standards, but its content is accessible to any browser or Internet device. | Why we do this