PUBLIC PARTICIPATION REPORTnalisustainabilitysolutions.co.za/wp-content/uploads/... · 2017. 9....
30
1 PUBLIC PARTICIPATION REPORT PROPOSED AMENDMENTMENT APPLICATION: HELDERFONTEIN ESTATE GAUT 002/17-18/E0002 Prepared for: September 2017
Transcript of PUBLIC PARTICIPATION REPORTnalisustainabilitysolutions.co.za/wp-content/uploads/... · 2017. 9....
1
PUBLIC PARTICIPATION REPORT
PROPOSED AMENDMENTMENT APPLICATION:
HELDERFONTEIN ESTATE
GAUT 002/17-18/E0002
Prepared for:
September 2017
2
1. OVERVIEW
The public participation process has been conducted in accordance with the provisions of the EIA Regulations, 2014. In addition to notification of potential interested and affected parties (site notices, newspaper adverts and notification of occupiers/land owners within and adjacent to the site), Registered Interested &Affected parties were also notified of the application. Below is a brief on the process as well as evidence of various aspects of the process.
1.1. Process followed and related activities
1.1.1. Adverts
The application was advertised in the Citizen Newspaper on 28 July 2017. Besides notifying interested and affected parties of the application, the advert also invited submission of comments on both the application and draft Assessment Report. The process was open for 30 days. A copy of the advert is attached overleaf (Exhibit 1).
1.1.2. Notification
Notices were placed on site and at the boundaries of the site (Exhibit 2). In addition:
occupiers/owners of this and adjacent properties were notified via delivery letters and/or email;
email notification was sent to state organs, including the municipality and the councillor for the area informing them of the application as well as providing them with the Assessment Report (Exhibit 3).
1.1.3. Register
A register of interested &affected parties was opened and maintained as required. The Register is attached as Annexure 1.
1.1.4. Access to application documentation
The notices and adverts indicated that the Draft Assessment Report could be accessed from our website (www.nalisustainabilitysolutions.co.za).
1.2. Comments or issues raised by I&AP
Comments received during the public participation process are captured in the Comments and Response Report (Appendix 2). The main issues revolved around the acceptability of a Residential 3 development on this site, the impact of Lachlan Road on properties beyond the application site, services, legibility of maps and the impact of the development on the sensitive environment. All these issues have been responded to as seen in the attached Report.
Evidence of communication exchange with I&APs is provided as Exhibit 4.
3
Newspaper Advert
Exhibit 1
4
Site Notices
Exhibit 2
Notification of Government Departments, Entities as well as Registered Interested & Affected Parties
From: Pirate Ncube <[email protected]> Date: 4 August 2017 at 16:31 Subject: Notice -Application for amendment of Environmental Authorisation and invitation to comment on the application and Draft Assessment Report: Riverside View Ext.78 To: [email protected], Glen Barbour <[email protected]>, The William Estate Office <[email protected]>, [email protected], [email protected], [email protected], "Siwelane Lilian (PTA)" <[email protected]>, "Mathebe Tshepo (GAU)" <[email protected]>, [email protected], [email protected], [email protected], [email protected], Natalie Koneight <[email protected]>, [email protected], [email protected], [email protected], Etienne Allers <[email protected]>, [email protected]
Interested and Affected Parties As per the requirements of the EIA Regulations, 2014, please be notified that an application for amendment of the Environmental Authorisation has been submitted to the Gauteng Department of Agriculture and Rural Development for consideration. The details of the application and amendments required are as per the attached notices. Further, the Draft Assessment Report is available for review at www.nalisustainabilitysolutions.co.za
5
Please submit your comments on the application and/or Draft Assessment Report within 30 days of this notice. Kind regards Pirate Ncube
Tel: 012 676 8315
Cell: 0824517120
P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
From: Pirate Ncube <[email protected]> Date: 10 August 2017 at 13:22 Subject: Notification - Application for Amendment of Environmental Authorisation- Riverside View x78 To: Desendran Pillay <[email protected]>, [email protected], [email protected], Reemal Sing <[email protected]>, [email protected], Louise Netherlands <[email protected]>, Mike Ennis <[email protected]>, GEKCO Chair <[email protected]>, Anton van Niekerk <[email protected]>, [email protected], GRA INFO <[email protected]>, Nazeema Khan <[email protected]>, Sanette <[email protected]>, [email protected], Daryl van Rensburg <[email protected]>, Bob Broekman <[email protected]>, Colleen Nefdt <[email protected]>, HRAG <[email protected]>, [email protected], David Foley - Business Connexion <[email protected]>
Dear I&AP
As per the requirements of the EIA Regulations, 2014, please find attached herewith notification of an application for amendment environmental authorisation that has been submitted to the GDARD. The application has been issued with Ref. No. Gaut 006/17-18/E0002.
The Draft Assessment Report (DAR) and updated EMPr are available for review at www.nalisustainabilitysolutions.co.za. Please note that you may submit your comments on the application and/or DAR within 30 days of this notice.
Kind regards
Pirate Ncube Nali Sustainability Solutions
Exhibit 3
From: Pirate Ncube <[email protected]> Date: 6 September 2017 at 15:40 Subject: Re: Application for Amendment of Environmental Authorisation- Riverside View x78 To: Erica Faul <[email protected]> Cc: Ben Pretorius <[email protected]>, [email protected], Esther Schmidt <[email protected]>, "Keith Bush (Glenferness)" <[email protected]> Dear Erica Your objection is noted and will be included in the Issues Report and responded to at the end of the public participation process. Kind regards
Pirate Ncube
Nali Sustainability Solutions (Pty) Ltd
Tel: 012 676 8315
Cell: 0824517120
Fax: 086 694 1178
email: [email protected]
P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
From: Pirate Ncube <[email protected]>
6
Date: 6 September 2017 at 15:50 Subject: Re: Objection - Application for Amendment of Environmental Authorisation- Riverside View x78 To: Jassy Mackenzie <[email protected]> Cc: "boniswa.belot" <[email protected]>, David Foley - Business Connexion <[email protected]>, Esther Schmidt <[email protected]>, Adrian Clegg <[email protected]> Dear Jassy Your objection is noted and will be included in the Issues Report and responded to at the end of the public participation process. Kind regards Pirate Ncube On 5 September 2017 at 09:46, Jassy Mackenzie <[email protected]> wrote: Dear Pirate Ncube I would like to object to the application for the amendment of the EA, as sent out by yourself on 10 August. The reason for my objections are as follows and they have to do with the proposed extension of Lachlan Road as well as the proposed K56, which is why I am also copying in JRA. Extension of Lachlan Road I objected to the original application on the grounds that it showed a possible through road from Lachlan Road to Erling Road which would affect a number of properties and destroy our equestrian suburb. I note that in the updated application for the amendment of the EA, this proposed road is now on the map as if it already exists. I have attached an illustration from the original application below, and the updated public notice as a pdf attached, so that everyone can see this. This is totally misleading. The road does not exist, there are no servitudes for it, the landowners affected by it have not been consulted, and the creation of the road will destroy an established equestrian suburb. The Proposed K56 The route for the proposed K56 is not yet finalised. The EA company has said that they are unclear about which route has been approved and are still seeking clarification. There is no funding available for this road to our knowledge. I think it is extremely important that the proposed amendments to this development must be declined as they rely on two roads that do not exist. We are aware that developers will sometimes use this strategy in order to get a development passed, by making it seem as if the roads are a fait accompli when this is not the case. If higher density housing is built in Helderfontein it will create enormous traffic problems. We do not want to have new roads forced through our suburb because a developer has created a need for them, by developing as if they already existed. Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network. Regards, Jassy Mackenzie 14 Macinnes Road, Glenferness
On 5 September 2017 at 13:35, Bannerman, Lynn <[email protected]> wrote:
Dear Pirate Ncube,
I object in the strongest possible terms to this proposed application for the amendment of the EA, as sent out by yourself on 10 August.
This completely changes from the original application .I believe the developers are trying to force through an illegal and unapproved change in a deceitful way. We rely on you and your team as objective public servants to not be swayed by the interests of big money investors who will take their
7
money and run without investing back into the area in terms of infrastructure, green space, or preservign the green belt and country / equestrian nature of the suburb.
Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network.
My contact details are: Lynn Bannerman PO Box 31727, Kyalami, 1684 Lynn Bannerman Employee Communications Lead | Global Corporate Affairs SAP Africa, 1 Woodmead Drive | Woodmead | Johannesburg 2148 | South Africa M +27-83-643-13-54, mailto [email protected]
Join me online: Facebook, LinkedIn, Twitter, YouTube.
Forwarded message ---------- From: Pirate Ncube <[email protected]> Date: 6 September 2017 at 15:59 Subject: Re: Objection - Application for Amendment of Environmental Authorisation- Riverside View x78 To: "Bannerman, Lynn" <[email protected]> Cc: "[email protected]" <[email protected]>, "[email protected]" <[email protected]> Dear Lynn Your objection has been noted and will be included in the Issues Report and responded to at the end of the public participation process. From: Pirate Ncube <[email protected]> Date: 6 September 2017 at 16:05 Subject: Re: Objection - Application for Amendment of Environmental Authorisation- Riverside View x78 To: Nicky Jansen Van Vuuren <[email protected]> Cc: "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]> Dear Nicky Your objection has been noted and will be included in the Issues Report and responded to at the end of the public participation process. Kind regards Pirate Ncube Nali Sustainability Solutions (Pty) Ltd Tel: 012 676 8315 Cell: 0824517120 Fax: 086 694 1178 email: [email protected] P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
On 5 September 2017 at 13:11, Nicky Jansen Van Vuuren <[email protected]> wrote:
Dear Pirate Ncube, I would like to object to the application for the amendment of the EA, as sent out by yourself on 10 August. The original application showed a possible through road from Lachlan Road to Erling Road which would affect a number of properties, including a church, and destroy our agricultural lifestyle and equestrian industry.
8
In the updated application for the amendment of the EA, this proposed road is now on the map as if it already exists. This is not true. The road does not exist, there are no servitudes for it, the landowners affected by it have not been consulted, and the creation of the road will destroy an established equestrian suburb and the livelihoods of numerous employees. In addition, the route for the proposed K56 where the high density section of the development is located, is not yet finalised. The EA company has said that they are unclear about which route has been approved and are still seeking clarification. There is no funding available for this road to our knowledge. The proposed amendments to this development must be declined. They rely on two roads that do not currently exist and has not yet been approved. We are aware that developers will sometimes use this strategy in order to get a development passed, by making it seem as if the roads are fact when this is not the case. If higher density housing is built in Helderfontein it will create enormous traffic problems. We do not want to have new roads forced through our suburb because a developer has created a need for them, by developing as if they already existed. Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network. Your consideration will be much appreciated. Kind regards, Nicky Jansen van Vuuren
083 381 1695 From: Pirate Ncube <[email protected]> Date: 6 September 2017 at 16:09 Subject: Re: Objection - Application for Amendment of Environmental Authorisation- Riverside View x78 Ref. No. Gaut 006/17-18/E0002 To: Adrian Clegg <[email protected]> Cc: David Foley - Business Connexion <[email protected]>, Ben Pretorius <[email protected]> Dear Adrian Your objection has been noted and will be included in the Issues Report and responded to at the end of the public participation process. Kind regards Pirate Ncube Nali Sustainability Solutions (Pty) Ltd Tel: 012 676 8315 Cell: 0824517120 Fax: 086 694 1178 email: [email protected] P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
On 5 September 2017 at 12:03, Adrian Clegg <[email protected]> wrote: Dear Pirate Ncube, I object to the application for the amendment of the EA, as distributed by yourself on 10 August. Extension of Lachlan Road I have already objected earlier to this whole development because it is based on two roads that do not exist. Firstly, Lachlan Road extension for which there is no servitude whatever, is drawn on the below plan as if it exists whereas in actual fact it is drawn across private properties such as a church, residential property and a riding school/stud farm/equestrian stables etc.
9
As I have said the road does not exist, the landowners affected by it have not been consulted, and the creation of the road will destroy an established equestrian suburb. The whole Riverside View development in all its iterations cannot be approved as its existence depends on the destruction of the Glenferness area with its outdoor lifestyle. K 56. This road has not been approved, and probably will not be, so then a development without sufficient infrastructure cannot be approved until sufficient infrastructure in in place, (and such an infrastructure that doesn’t decimate an already existing greenbelt area.) I am personally one of the affected land owners, and I can confirm that no servitude for such a Lachlan Road extension exists, and I strenuously object to a development which will benefit developers financially, based on, and subject to, planning a road over my property. Regards Adrian Clegg 145 (plot 3/13) Macinnes Road, Glenferness. Adrian Clegg - Director Tel: 011 998 2600 Ext 103 Mobile: Fax: 086 504 3184 E-Mail: [email protected] Web: www.mazista.co.za Blog: http://blog.mazista.co.za
On 5 September 2017 at 20:05, Erica Faul <[email protected]> wrote:
Dear Mr Ncube,
I would like to object to the Application for Amendment of Environmental Authorisation- Riverside View x78, as sent out by yourself on 10 August.
The original application showed a possible through road from Lachlan Road to Erling Road which would affect a number of properties, including a church, and have serious consequences for our equestrian suburb.
This is a totally misleading application as in the applicaiton, this proposed road is now on the map as if it already exists. The road does not exist, there are no servitudes for it, the landowners affected by it have not been consulted, and the creation of the road will not only destroy an established equestrian suburb, but cause utter chaos in the area as it is not geared to being a high density area. You only have to drive down Chattan Road to see that most of the roads are too narrow for cars to pass each other effectively.
In addition, the route for the proposed K56 where the high density section of the development is located, is not yet finalised. The EA company has said that they are unclear about which route has been approved and are still seeking clarification. There is no funding available for this road to our knowledge.
The proposed amendments to this development should be declined as they rely on two roads, that do not exist. It is common knowledge that developers will sometimes use this strategy in order to get a development passed, by making it seem as if the roads are there, when this is not the case. Again I highlight the fact that if higher density housing is built in Helderfontein it will create enormous traffic problems. We do not want to have new roads forced through our suburb because a developer has created a need for them, by deceitfully getting plans for a development passed, through pretending that these roads already existed.
Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network.
Regards, Erica Faul
From: Pirate Ncube <[email protected]> Date: 5 September 2017 at 11:18 Subject: Re: Notification - Application for Amendment of Environmental Authorisation- Riverside View x78 (actually x87) To: R Wood <[email protected]> Cc: Nick Crow <[email protected]> Hi
10
The layout as well as other related documents are available on our website. I will suggest that you access the said layout and documents for your review. Kind regards Pirate Ncube Nali Sustainability Solutions (Pty) Ltd Tel: 012 676 8315 Cell: 0824517120 Fax: 086 694 1178 email: [email protected] P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
On 30 August 2017 at 14:26, R Wood <[email protected]> wrote: Afternoon Mr Ncube, Thank you. Kindly forward the high resolution layout diagrams called for. Kind regards, Robin Wood
On 30 August 2017 at 14:22, Pirate Ncube <[email protected]> wrote: Dear Mr Wood We have noted the content of your email and will include your name in the list of registered I&AP. Relative to the township extension number, i will update our documents if the information we have is incorrect. Kind regards Pirate Ncube Nali Sustainability Solutions (Pty) Ltd Tel: 012 676 8315 Cell: 0824517120 Fax: 086 694 1178 email: [email protected] P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
On 30 August 2017 at 14:13, R Wood <[email protected]> wrote:
Afternoon Mr Ncube, With reference to the below email, kindly ensure that I am listed as an interested and affected party to the above application. I am a resident member of the Helderfontein Estate. Please note that your reference to Riverside View Ext 78 is factually incorrect in that it should make reference to Riverside View Ext 87, an error kindly highlighted by Mr Crow of Century Property Developments. As it is not possible to view the low resolution layout properly, it would furthermore be appreciated if a high resolution PDF of the two attached diagrams would be forwarded to the writer. Regards, Robin Wood 0832340375 [email protected] Helderfontein Estate
11
From: Pirate Ncube [mailto:[email protected]] Sent: Thursday, August 10, 2017 1:22 PM Dear I&AP
As per the requirements of the EIA Regulations, 2014, please find attached herewith notification of an application for amendment environmental authorisation that has been submitted to the GDARD. The application has been issued with Ref. No. Gaut 006/17-18/E0002.
The Draft Assessment Report (DAR) and updated EMPr are available for review at www.nalisustainabilitysolutions.co.za. Please note that you may submit your comments on the application and/or DAR within 30 days of this notice. Kind regards Pirate Ncube Nali Sustainability Solutions Tel: 012 676 8315 Cell: 0824517120 Fax: 086 694 1178 email: [email protected] P. Bag X1, Stand 1829, Irene Farm Villages, PvR, 0045
Exhibit 4
12
APPENDIX 1: REGISTER OF INTERESETED AND AFFECTED PARTIES
NAME/INSTITUTION CONTEACT DETAILS
Council for Geo-Science [email protected]; [email protected] 280 Pretoria Road, Silverton, PRETORIA
SAHRA Gauteng [email protected]
PHRAG [email protected]
DWA
[email protected] Anna Malemela & Tshepo Mathebe 15th Floor, 285 Bothongo Building, Francis Baard Street Tel 012 386 1406, Fax:086 573 2897
Eskom [email protected] [email protected]
SANRAL [email protected]
Gautrans
Randwater
City of Johannesburg [email protected]; [email protected]
118 Jorrison Street; Traduna Building 6th floor; Bramfontein TEL:011 587 4201; FAX:086 627 7516
Spoornet [email protected]
PetroSA [email protected] Tel+27 21 929 3000; Fax: +27 21 929 3144
OTHER I&AP
Desendran Pillay Nethisha Pillay
Mobile: +27 82 997 7904; +27 82 277 6420 [email protected] Vodacom Corporate Park, 2nd Floor; 082 Vodacom Boulevard, Midrand 1685 [email protected]
Nicky Jansen van Vuuren [email protected]; 083 381 1695
Adrian Clegg
145 (plot 3/13) Macinnes Road, Glenferness. Tel: 011 998 2600 Ext 103 Mobile: Fax: 086 504 3184 E-Mail: [email protected]
Robin Wood 0832340375; [email protected]; Helderfontein Estate
Sonja Bohnsack Plot 43 Duncan Road Glenferness; [email protected]
Demi van Breda Crocus Road; Kyalami AH; [email protected]
Uris van Breda 129 Crocus Rd; Kyalami A H
Gill Whitbread [email protected]
Stacey Lee Weston [email protected]
Jassy Mackenzie 14 Macinnes Road, Glenferness
13
Erica Faul [email protected]
J Herman Potgieter [email protected] +27-(0)836310501; Stand 158, Ngwenya Drive.
Lynn Bannerman PO Box 31727, Kyalami, 1684; M +27-83-643-13-54, [email protected]
Reemal Sing [email protected]
Warener’s Attorneys (Alan Warrener)- [email protected]; Tel: 011 453 1370; Fax: 0866889930
Louise Netherlands [email protected]; 0828516093
John C Netherlands; Jason Grant Netherlands;
106 The Paddocks; [email protected]
Michael Ennis 440/164 Dunmaglass Road Glenferness: [email protected]
Kristin Kallesen: GEKCO chairperson Greater Kyalami Conservancy; 083 600 6091; [email protected]
Penny Van Asche Glenferness; [email protected]
Nazeema Khan 45 Duncan Road; Glenferness; 072 549 0688 [email protected]
Ioana Cioroiu
46 Newmarket Road; Randburg 2169, Südafrika Tel.: +27 10 222-7281, [email protected]
Sanette Monginho [email protected]
Michelle Horwood: Justin Horwood 2491 Shangani Close, Helderfontein Estate; [email protected]
Daryl Janse van Rensburg & Shelly Janse van Rensburg
6 MacInnes Road, cnr Mull Road, Glenferness Home Tel: 011 516 0089; Work Tel: 011 706 4253 | Fax: 011 706 4255 Email: [email protected]
Enderani Naicker [email protected]; Tel: 0726237190
Kirti Ramadhin Stand 192 of Helderfontein Estate [email protected]; 0820934168
JP Broekman 143 Berwick, Ferridge, Fourways; [email protected]
Colleen Nefdt +27 (011) 996 4060 Mobile: +27 (0) 82 461 8133; Fax: 086 614 5483 [email protected]; Block A, Regents Hill Office Park; Cnr Lesley and Turley Road; Lonehill
HELDERFONTEIN RESIDENTS ACTION GROUP
(HRAG)
Alois (Mike) Maier [email protected]; 46 Newmarket Road; 2169 Randburg, Südafrika
Michelle Burns 120 Helderfontein Estate; [email protected]
14
APPENDIX 2: COMMENTS AND RESPONSE REPORT
Name and Contact Issue Response
Jassy Mackenzie
14 Macinnes Road,
Glenferness
I would like to object to the application for the amendment of
the EA, as sent out by yourself on 10 August.
The reason for my objections are as follows and they have to
do with the proposed extension of Lachlan Road as well as the
proposed K56, which is why I am also copying in JRA.
Extension of Lachlan Road
I objected to the original application on the grounds that it
showed a possible through road from Lachlan Road to Erling
Road which would affect a number of properties and destroy
our equestrian suburb.
I note that in the updated application for the amendment of
the EA, this proposed road is now on the map as if it already
exists. I have attached an illustration from the original
application below, and the updated public notice as a pdf
attached, so that everyone can see that this is totally
Your objection has been noted. Unfortunately, this process cannot be used to address your objection to the ‘original application’ but only issues raised pertaining to this amendment application. Further, it must be noted that this application does not seek to extend what has already been considered in the original application or to include any aspects outside those identified in the application and assessment report. The extension of Lachlan Road beyond the footprint of the Helderfontein township does not form part of this application. It is therefore assumed that appropriate processes will be followed should the said extension of Lachlan Road be required.
15
Name and Contact Issue Response
misleading. The road does not exist, there are no servitudes for
it, the landowners affected by it have not been consulted, and
the creation of the road will destroy an established equestrian
suburb.
The Proposed K56
The route for the proposed K56 is not yet finalised. The EA
company has said that they are unclear about which route has
been approved and are still seeking clarification. There is no
funding available for this road to our knowledge.
I think it is extremely important that the proposed
amendments to this development must be declined as they rely
on two roads that do not exist. We are aware that developers
will sometimes use this strategy in order to get a development
passed, by making it seem as if the roads are a fait accompli
when this is not the case. If higher density housing is built in
Helderfontein it will create enormous traffic problems. We do
not want to have new roads forced through our suburb because
a developer has created a need for them, by developing as if
they already existed.
Our suburb is in a Green Zone and the development concerned
is on the urban edge. The developer should stick to the
originally planned densities which can be managed by the
existing road network.
The application is based on the original alignment of the K56 which has been part of the Gauteng Network for a very long time. It is our understanding, however, that the alignment of the road has been finalised. The availability of funding for the road is matter that the province and affected developers will need to resolve. It is common knowledge that the municipality will not approve a development where infrastructure is not available/adequate to accommodate the said development. Alternatively, developers are always required to pay for infrastructure upgrades in order to ensure that affected developments are serviced. This point fails to acknowledge that this is an application to amend a very small section of an approved township. Further, the Provincial Environmental Management Framework, 2015 (EMF), indicates that the site is located within Zone 1 which zone is intended to, among others, streamline urban development activities by promoting infill, densification and concentration of urban development that would allow for the establishment of a more effective and efficient city region that minimises urban sprawl into rural areas.
16
Name and Contact Issue Response
Erica Faul [email protected]
I would like to object to the Application for Amendment of Environmental Authorisation- Riverside View x78, as sent out by yourself on 10 August. The original application showed a possible through road from Lachlan Road to Erling Road which would affect a number of properties, including a church, and have serious consequences for our equestrian suburb. This is a totally misleading application as in the application, this proposed road is now on the map as if it already exists. The road does not exist, there are no servitudes for it, the landowners affected by it have not been consulted, and the creation of the road will not only destroy an established equestrian suburb, but cause utter chaos in the area as it is not geared to being a high density area. You only have to drive down Chattan Road to see that most of the roads are too narrow for cars to pass each other effectively. In addition, the route for the proposed K56 where the high density section of the development is located, is not yet finalised. The EA company has said that they are unclear about which route has been approved and are still seeking clarification. There is no funding available for this road to our knowledge. The proposed amendments to this development should be declined as they rely on two roads, that do not exist. It is common knowledge that developers will sometimes use this strategy in order to get a development passed, by making it seem as if the roads are there, when this is not the case. Again I highlight the fact that if higher density housing is built in Helderfontein it will create enormous traffic problems. We do not want to have new roads forced through our suburb because a developer has created a need for them, by deceitfully getting
Your objection has been noted. Refer to the response above. The application does not include the extension of Lachlan Road beyond the footprint of Helderfontein Estate. Refer to the responses above.
17
Name and Contact Issue Response
plans for a development passed, through pretending that these roads already existed. Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network.
Refer to the response above.
Lynn Bannerman PO Box 31727, Kyalami, 1684 M +27-83-643-13-54, mailto [email protected]
I object in the strongest possible terms to this proposed application for the amendment of the EA, as sent out by yourself on 10 August.
This completely changes from the original application. I believe the developers are trying to force through an illegal and unapproved change in a deceitful way. We rely on you and your team as objective public servants to not be swayed by the interests of big money investors who will take their money and run without investing back into the area in terms of infrastructure, green space, or preserving the green belt and country / equestrian nature of the suburb.
Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network.
Your objection has been noted It is not correct that this application is a complete change from the original application. For this, you are referred to the original authorisation which allowed for the development of Res 1, Res 2 and Res 3 for retirement village on the site. The retirement village has since been excluded from development and instead a school developed. Therefore, the inclusion of Res 3 is not a ‘new’ aspect in this development. Technically, it can be regarded as the substitution of the original concept (retirement village) although at a different locality within the approved township. The development site is not within a Green Zone, and it is believed that the pronouncement on densities and acceptability of the development from infrastructure perspective will be made by the City of Johannesburg.
Nicky Jansen van Vuuren [email protected] 083 381 1695
I would like to object to the application for the amendment of the EA, as sent out by yourself on 10 August.
The original application showed a possible through road from Lachlan Road to Erling Road which would affect a number of
Your objection has been noted. Issues pertaining to the ‘original application’ should have been raised during that application process. However, this application pertains to development within the boundaries of the approved township. We are not sure that how the change to the layout including a change from Res to Re3 on
18
Name and Contact Issue Response
properties, including a church, and destroy our agricultural lifestyle and equestrian industry.
In the updated application for the amendment of the EA, this proposed road is now on the map as if it already exists. This is not true. The road does not exist, there are no servitudes for it, the landowners affected by it have not been consulted, and the creation of the road will destroy an established equestrian suburb and the livelihoods of numerous employees.
In addition, the route for the proposed K56 where the high density section of the development is located, is not yet finalised. The EA company has said that they are unclear about which route has been approved and are still seeking clarification. There is no funding available for this road to our knowledge.
The proposed amendments to this development must be declined. They rely on two roads that do not currently exist and has not yet been approved. We are aware that developers will sometimes use this strategy in order to get a development passed, by making it seem as if the roads are fact when this is not the case. If higher density housing is built in Helderfontein it will create enormous traffic problems. We do not want to have new roads forced through our suburb because a developer has created a need for them, by developing as if they already existed.
Our suburb is in a Green Zone and the development concerned is on the urban edge. The developer should stick to the originally planned densities which can be managed by the existing road network.
a small portion of the township will have such an impact as spelled out. Should it be required that Lachlan Road is extended into the site, then appropriate processes will need to be followed. Refer to the previous response to this issue. Refer to the previous response to this issue. Refer to the previous response to this issue.
Adrian Clegg 145 (plot 3/13) Macinnes Road, Glenferness.
I object to the application for the amendment of the EA, as distributed by yourself on 10 August. Extension of Lachlan Road
Your objection has been noted
19
Name and Contact Issue Response
Adrian Clegg - Director Tel: 011 998 2600 Ext 103 Mobile: Fax: 086 504 3184 E-Mail: [email protected] Web: www.mazista.co.za Blog: http://blog.mazista.co.za
I have already objected earlier to this whole development because it is based on two roads that do not exist.
Firstly, Lachlan Road extension for which there is no servitude whatever, is drawn on the below plan as if it exists whereas in actual fact it is drawn across private properties such as a church, residential property and a riding school/stud farm/equestrian stables etc.
As I have said the road does not exist, the landowners affected by it have not been consulted, and the creation of the road will destroy an established equestrian suburb. The whole Riverside View development in all its iterations cannot be approved as its existence depends on the destruction of the Glenferness area with its outdoor lifestyle.
K 56. This road has not been approved, and probably will not be, so then a development without sufficient infrastructure cannot be approved until sufficient infrastructure in in place, (and such an infrastructure that doesn’t decimate an already existing greenbelt area.)
I am personally one of the affected land owners, and I can confirm that no servitude for such a Lachlan Road extension exists, and I strenuously object to a development which will benefit developers financially, based on, and subject to, planning a road over my property.
The amendments applied will not result in substantial deviation from the uses authorised in the initial EA. The issue of Lachlan Road has already been addressed above. Please refer to previous responses on this issue. Please note parts of Riverside View were approved a long time ago and have already been developed and occupied. Further, itserves no purpose to object to approvals granted more than 6 years ago as this amendment application does not re-open the initial authorisation process. K56 will not be the only road servicing the township. Further, it is a known fact that the township cannot be approved by the City of Johannesburg without provision of adequate road infrastructure to service the township and surrounding areas. The issue of Lachlan Road has already been addressed in other sections above.
Robin Wood 0832340375 [email protected] Helderfontein Estate
With reference to the below email, kindly ensure that I am listed as an interested and affected party to the above application. I am a resident member of the Helderfontein Estate.
We have noted the content of your email and will include your name in the list of registered I&AP.
20
Name and Contact Issue Response
Please note that your reference to Riverside View Ext 78 is factually incorrect in that it should make reference to Riverside View Ext 87, an error kindly highlighted by Mr Crow of Century Property Developments.
As it is not possible to view the low resolution layout properly, it would furthermore be appreciated if a high resolution PDF of the two attached diagrams would be forwarded to the writer.
Relative to the township extension number, please note that we have used the information provided by the applicant. We also note that Ext 87 is not the full extent of the area affected by this amendment application. We trust that the layout subsequently provided was legible and provided the information required.
Sonja Bohnsack Plot 43 Duncan Road Glenferness [email protected]
I wish to object to the application for the amendment of the EA, as sent out by yourself on 10 August. The reason for my objections are as follows and it they have to do with the proposed extension of Lachlan Road as well as the proposed K56, which is why I am also copying in JRA. Extension of Lachlan Road The original map shows a through road from Lachlan Road to Erling Road. This road does not exist and there are absolutely no servitudes for it. It will destroy an equestrian and country suburb, which has small roads and is a Green Zone. Therefore, I strongly object to this road taking place on the grounds of it being totally illegal and also on the grounds that it will bring high traffic volumes which will no doubt create the destruction of the equestrian and country lifestyle in Glenferness.
This application is not for the extension of Lachlan Road beyond the footprint of the Helderfontein Estate. Therefore, we cannot respond to the anticipated impacts or appropriateness of the road.
Kristin Kallesen Chairperson Greater Kyalami Conservancy 083 600 6091
Please see below the comments from the Greater Kyalami Conservancy (GEKCO) on the proposed amendment to EA GAUT 002/09-10/N0792 on the Helderfontein property for the proposed township Riverside View X78. As we understand, the proposed amendment is to allow for Residential 3 development (high density) instead of Residential 1 (low density) as was indicated on the initial layout plan. The proposal is to also encroach on the open space area which
The information pertaining to what was proposed and the exact location of the proposed amendments was provided in the Assessment Report made available to all interested and affected parties. We have also updated the maps in the assessment Report.
21
Name and Contact Issue Response
buffers the wetlands and dams on the site and to allow for Residential 3 (high density) development in this area. We note that no map has been provided that indicates exactly where this will occur, however we understand that this will be on the verge of the open space /wetland buffer. GEKCO strongly objects to this proposal for the reasons below: 1. The RSDF used as the motivation for this development no
longer applies. This property falls within the Consolidation Zone of the City of Joburg Spatial Development Framework 2040, which supersedes the RSDF. This does not allow for the Residential 3 densities being applied for. This must be rectified in the Draft Impact Assessment Report by Nali Sustainability Solutions (NSS).
2. The motivation also makes reference for allowances in the
Dainfern area as implying that the same should be allowed here. The Dainfern area is fully developed and falls well within the Urban Boundary and has been under development for more than 20 years. This property sits right on the Urban Boundary, on a property which is open farmland with no development present. The only impacts have been due to grazing of horses and recreational activities (horse riding, mountain biking) and traffic along a dust track that traverses the property.
3. Bulk infrastructure will need to be installed to service this
development. The Joburg SDF 2040 states that development within the Consolidation Zone should only be considered if no bulk infrastructure is required. This is to limit the burden on the City by expanding infrastructure
Further, the proposal is not to replace all Res 1 with Res 3 development. Res 3 will not be located close to the wetland areas as alleged here. The layout clearly shows that Res 3 will be located on the eastern portion which is separated from the wetland areas by the K56. Responses to each point raised area detailed below. 1. Cognisance must be taken that the proposal is not a
greenfield development but rather an amendment of a township authorized in 2011. Firstly, the 2040 SDF will not reverse decisions already taken for development. Secondly, the SDF does not advocate for monolithic low density development within the Consolidation Zone but rather aims …to create liveable lower to medium density suburban areas that are well-connected to higher intensity areas through transit infrastructure and to address challenges in areas of deprivation.
2. The fact remains that the property is within the Urban
Boundary and the proposed development will be similar to developments in Dainfern. Further, the Gauteng EMF, indicates that the site is located within Zone 1 which zone is intended to, among other things, streamline urban development activities in it so as to promote infill, densification and concentration of urban development in order to establish a more effective and efficient city region that will minimise urban sprawl into rural areas. Therefore, the proposal is aligned with the provisions of the EMF.
3. While we agree on the need for infrastructure provision, it is not correct that the SDF states that development within the Consolidation Zone should only be considered if no bulk infrastructure is required. Instead the SDF says
22
Name and Contact Issue Response
networks by rather promoting development where infrastructure exists. This and existing nodes is where densification is promoted. This property meets neither of these criteria. The bulk infrastructure that is required is a new bulk sewage main on the East side of the Jukskei River as well as a new road through the suburb of Glenferness which will have a very serious impact on the neighbouring equestrian properties deeming the surrounding properties unusable for equestrian purposes.
4. No socio-economic factors are considered in this report. It
states that the application is complementary to existing uses, however does not mention what existing uses are in the area. The Gauteng EMF highlights the importance of the Equestrian uses in the Joburg North Special Management Zone – Greater Kyalami Conservancy. This recognises the need to ensure the sustainability of the equestrian use in the Kyalami area as it provides unique sport, recreation and wellness opportunities to all of Gauteng with some programmes focusing specifically on neighbouring townships such as Diepsloot. These programmes provide rehabilitation for disabled persons as well as empowering youth with life skills. The high density residential component, associated traffic and loss of open space will directly and negatively impact on the viability of the adjacent equestrian areas. This will also result in the loss of equestrian jobs on the neighbouring properties. This has not been considered or studied in the report. We recommend that a detailed investigation be done as to the socio-impacts that this amendment will have rather than dismissing any possible impacts with vague statements.
5. The encroachment into open space is not in line with the Joburg Open Space policy which recognises the importance of open space corridors, specifically along
the city will therefore allow new developments that promote the goals and meet the requirements of the SDF, but do not require extensive bulk infrastructure upgrades. Further, it is not clear why it is believed that the proposed amendments will result in extensive infrastructure upgrades. In fact, the services referred to will be required even if the proposed amendment is not approved.
4. Important to appreciate that the application for the amendment of an approved township. This amendment affects a small section of the said township. Therefore, the small changes do not deviate from the initial authorization given. Further, there is no evidence provided that the proposed amendment will result into the stated impacts. From reading the objection, it would seem that the comment is directed at the development of the entire township rather than the proposed amendments. It must be noted that the initial authorization did allow for Res 3 on part of this township. However, the portion where Res 3 was to be developed has since been developed into a school. Therefore, technically, this amendment serves to re-allocate the Res 3 component from the site where the school has been built to the area previously set aside for Res 1 development.
5. The application affects a small area within an approved township which is as a consequence of the road system. The wetland and the connected open space system will not be affected by this proposal. This is because the
23
Name and Contact Issue Response
wetlands where endangered, red listed species are present. This site is located within a Critical Biodiversity Area.
6. The NSS report incorrectly states that the area has no
conservation value as further degradation of the property will occur from the construction of the K56 road when in fact, the alignment of the road has changed to „Alternative 1‟ and will no longer impact the area contained within this proposal. Environmental Authorisation was not granted on the initial alignment due to the sensitive nature of this area.
Alternative 1 (the final approved route) cuts through the bottom of Erling Road where it makes a 90 degree turn (circled in white):
Locality Map from NSS Report – you can see that bend is above the road (this time the circle is in yellow):
amendment proposed is outside the buffer zone of the wetland system.
6. The statement in the report refers to the area proposed for amendment and not the entire township site. In terms of the authorized alignment, our understanding is that the “preferred Alignment” (which means the alignment in the provincial Integrated Transport Master Plan) was approved.
Point noted, but we believe this is incorrect. This information is correct as per our understanding.
24
Name and Contact Issue Response
7. The NSS report misrepresents the conservation value of the property stating that the area is not deemed important in the C-Plan, however the area in question is a critical biodiversity area confirmed by the ecological assessment commissioned by NSS and all previous assessments of the site. The initial Environmental Assessment for this development and the Assessment for the K56 both spoke of the sensitive nature of this area and both have excluded a large portion of the property from development. This report by NSS makes no mention of these sensitivities as if they do not exist.
8. We have identified African Hedgehog on the study site
and the African Grass Owl has been photographed in the wetland areas.
9. No storm water plans have been considered. The
presence of dams on site is mentioned and the statement is made that the development will just discharge into these dams. They already provide attenuation for a wide catchment and should not be relied upon for this development. Attenuation should take place before the water reaches the dams.
Ecological Report: 10. The ecological assessment attached to the NSS report
was not done by a specialist qualified to conduct ecological assessments, but by a water and environmental engineer. The two professions are quite separate as environmental engineering deals with the manipulation of the environment in order to meet
7. There is no misrepresentation of information. The quoted statement refers to the parts of the site affected by the proposed amendment. The Ecological Report appended to the assessment report did indicate that the area is regarded as a Critical Biodiversity Area in terms of the C-Plan. Further, the proposed amendment will not affect the large portions of the site excluded from development except the small portion affected by the road.
8. It is not clear whether study site refers to the foot print
of the proposed amendment or the entire township area. According to the ecologist, the conditions of the affected portions make then unsuitable for the mentioned species due to activities occurring on site. However, the said species can still utilize the corridor for migration and foraging.
9. A storm water laypout has been included in the Assessment Report. However, the management plan will have to be approval by COJ. According to the stormwater layout included in the report, the stormwater discharge points will be outside of the buffer zones.
10. This argument is not relevant and or justifiable. For the
record, the specialist who prepared the report is a qualified and registered scientist in the field, holding a Bachelor of Science Honours in Zoology and Botany and Master’s degree in Water and Environmental Engineering. Further, it must be understood that the
25
Name and Contact Issue Response
specific objectives while an ecologist studies the ecosystem in order to understand the conservation value. This should also include mammal and amphibian assessments which have not been done.
11. This report again assumes construction of the road in this area which will deem the area of no conservation value. As stated above, the alignment of the road has been moved in order to protect the sensitivity of this area around the wetlands and dams. The report should re-assess the approved alignment of the K56 and the ability of the ecosystem to function under these circumstances. The eco-system will not be as fragmented and will thus have a higher conservation value.
12. This report does not make any recommendations for rehabilitation around the wetland areas where the existing dust road has made an impact or storm water discharge. It also does not make any recommendations as to the species that should be planted near to the wetlands. Around the Helderfontein School kikuyu sports fields have been planted right up to the wetland area. Kikuyu can easily invade wetland areas which is problematic. A species list should be provided for properties that abut the ecologically sensitive areas.
Further comments on the Ecological Report: o As in the other documents the marked area in Figure 1
(Locality Map) and Figure 2 (Proposed Amendment) are different. The first is an oval oriented SW – NE. The second an oval oriented W – E (page 5). However, the study area in later maps (pages 10 and 11) show the SW – NE orientation. It is impossible to relate any of these to the Proposed Amendment except in a very general way.
application is for amendment of a development which was approved following detailed assessment of the site.
11. Page 24 of the ecological assessment report addresses this matter and recommends that no development should occur within the sensitive areas. We are of the view that GEKCO has not interpreted correctly, the approved alignment of the K56.
12. It is indicated in the report that the wetlands should be buffered no recommended planting around the buffer unless authorised by the competent authority. It was further indicated in the report that the indigenous plant species around the area that will be affected should be relocated or used for landscaping.
Further comments
The locality map is meant to provide an indication is to where the site is. It is not meant to be a detailed representation of the proposed development. On the other hand, the layout Plan provides the details of the particular development. In this instance, we have updated the locality map so that it is not confused with the layout plan.
26
Name and Contact Issue Response
o The report says the area has only disturbed grasslands, yet list Themeda triandra in the species list on page 15. This species is generally not found in disturbed areas. It is noted on the SANBI site as being an indication of veld in good condition.
o The section on the impacts says that the 32m buffer is appropriate. The diagram on page 21 does not have a key. It is therefore not possible to see the riverine area and its buffer.
o The report mentions water loving plants as being part of that definition, but there is no mention of the Imperata cylindrica areas which are in this area. Imperata are water loving plants. So the report cites the definition, but then it isn‟t applied in their work. These can be found in the area marked as “medium” sensitivity in Figure 15 on page 25. Will this area be included in the development or is it part of the buffer?
o Because these maps are unclear, it is impossible to relate these findings with the proposed development. It is not clear how far away it is or whether it covers any of these features.
o The report says “ It is of the concern that the approved K56 traverses the wetlands and the Egoli Granite grassland. The road construction will destroy the riparian leaving the disconnection of small degraded unsustainable vegetation units which will not contribute towards the Gauteng conservation targets. The habitat area will be of low conservation importance …… Although the landscape is defined as an open space area, it cannot suffice the purpose of a corridor as there won’t be any ecological connection after K56 road construction. Taking the above into account, fragmentation is expected post K-56 development. From the ecological perspective conserving isolated habitats serve no bases for the ecosystem as it will be unable to sustain itself.” (pages 25 and 26). This is a completely
Themeda triandra was found within the broader area and not necessarily the application portion of the site.
The footprint of the proposed amendment is located outside of the 32m buffer area.
The development will be located outside of the area of medium sensitivity and outside of the buffer zone.
The maps have been updated to indicate the extent of the proposed amendments.
This is a misinterpretation and misrepresentation of the facts. The argument must be understood from the fact that part of the amendment affects a small area which previously formed part of the open space area but now, because of the road system, the affected area does not form a continuous and connected part of the open space hence the request to utilize it.
27
Name and Contact Issue Response
spurious argument – it is saying „because we’re developing the area and destroying it anyway, it doesn’t matter if we do that a bit more.‟
o The comment: “Should the amendment not approved, this will lead to the heavy alien vegetation infestations, infilling, dumping, littering and information settlement. Infilling and dumping is already occurring.” (page 26). We feel this is unlikely as Century would not let that happen within their property and the property has already been closed off to prevent further illegal dumping.
o In the conclusion it states “The only constraint to the proposed development is its proximity to the stream.” This is a severe understatement. This proposal will bring high density living into an area that currently provides homes for jackal, hedgehogs, grass owls, porcupines, Giant Bullfrogs and the like. There is no mention of any of these species anywhere in this report.
Additionally: None of the keys for any of the maps are legible, please may we request legible maps in order that we may expand on our comments if needed. We would also like to request an updated map with the approved K56 alignment and the ecological report to be re-assessed with the correct alignment. These should both be provided in the Final Report with an opportunity for public participation with the correct information.
Opinion noted
Again this is incorrect. The Res 3 development is proposed on 1 erf on the eastern portion of the site. The rest of the township is to be developed as a Res 1 township. In addition, this is not the first time that Res 3 has been proposed on this site. In the initial authorization, the portion now occupied by a school was to be developed into Res 3 units. The statement by GEKCO seems to suggest that the application is to convert the entire site into a Res 3 area, yet the application is very clear on what portions of the approved township are proposed for Res1 and 3 developments.
Maps have been included in the final report. We believe that the K56 alignment indicated in the layout plan is the approved alignment.
Demi van Breda Crocus Road Kyalami AH [email protected]
As a resident I formally object to the proposed higher and extended density of Riverside View
The surrounding Kyalami/Glenferness area is built on the equestrian industry, supporting local employment opportunities and creating a country lifestyle. This area cannot support further development, from an infrastructure perspective as well as maintaining the equestrian industry.
The proposed amendments do not introduce densities which were never anticipated in the initial application. In fact, the authorization allowed for the development of Res1-3 on this site. The proposed amendments will not have adverse impacts on the surrounding areas as the amendments applied for are very small and are within an approved township.
28
Name and Contact Issue Response
Uris van Breda 129 Crocus Rd Kyalami A H
To whom it may concern The proposed increase in residential density should be opposed as it relies on a road infrastructure which is not yet in place NOR approved. The roads and infrastructure in this GREEN BELT AREA are already under strain from continuing development which is threatening the safety of its residents as well as of the people who work there, as many of the developments are unchecked and ahead of approval. Kindly take consideration of the objection of current residents who are increasingly forced out of the area ... They also take with them the job opportunities for those who the develioers would like to lure to the area.
The proposed change from Res1 to Res 3 only affects I erf in the township. This cannot be regarded as increase in the density of the township. Further, the necessary upgrades to roads and other infrastructure will be as directed by the municipality.
Gill Whitbread [email protected]
Refer: SUPPORT Application for Amendment of Environmental Authorization – Riverside View x 78
I wish to voice my support for this application. As the owner of the ONLY property in Glenferness that is affected by both the K56, which expropriates almost a third of my property and this new proposed extension of Lachlan Road which will take a further piece of my land, I think we are in a good position to voice an opinion.
It is my view that whatever proposals are put forward for development, especially in this area will be met with objections from the same group of Naysayers. It is the same group of individuals who Objected to the Sewer Line put in for the new development, on the corner of Kyalami Main and Bryanstan Main and yet the bulk of these individuals are quite happy to have septic tanks some of which are dysfunctional draining and Polluting the underground water. These are the same group of self-appointed environmentalists that had this area proclaimed a conservancy through an organization called Gecko without consulting all of us that are affected by these roads or the
Comments noted
29
Name and Contact Issue Response
impact this would have on the inevitable developments in the area.
Unfortunately, this group of objections although in the minority, will continue to stonewall any possible developments that are proposed for this area, as it infringes on their comforts zones. These delay tactics are only delaying the progress that many of us want to see for the benefit of multitudes of people, rather than the benefit of a few elitists, and for the council to make a real difference in our Municipality.
I believe that the area is surrounded by developments and that anything that will assist in having the area developed in a planned and sustainable manor should be welcomed which includes the Upgrading of Lachlan Road. We have come to terms with these developments and I think if anyone should have had strong objections it would us the only property affected by both road developments.
I hope that some sanity will prevail and some rational decision will be made rather than the emotional rhetoric emanating from this small group of privileged self-proclaimed environmentalists.
Stacey Lee Weston [email protected]
I am objecting to the application for the amendment of the EA that was sent out on 10 August.
We live in a Green Zone and the proposal will increase the traffic in the area. This is a problem for me as it will negatively impact on the equestrian community. We do not need any more roads in the area or any other factors that will increase the density of the area as it will no longer support our equestrian community. There are not enough roads or amenities to increase the density in the area – I am actually astonished that this proposal is even on the table.
According to the EMF, the site and its environs, except for the area further north, is within the Urban Development Zone 1 (not a Green Area). The amendments applied for will not affect the equestrian community as the amendments are confined to a small portion of the approved township and the density proposed on a small section of the layout was considered in the initial authorization.
30
