This letter is in response to those to Village News by Mr Michael Green (24 April), Mr Craig Saunders of the Kleinmond Wildlife Sanctuary (KWS) and Dr Brian Slade (both 1 May) regarding the proposed Lamloch development.

As Mr Saunders notes, it is important to base comment, critical or otherwise, of any proposed development on sound research rather than on “hearsay and emotive rumour”.  This has been WCC’s approach over our past 15 years of submitting numerous objective contributions on various development proposals to the Department of Environmental Affairs and Development Planning (DEA&DP) within the public participation processes of environmental impact studies.  In doing so, WCC’s focus is on assessing whether development proposals comply with environmental law and processes in order to ensure that our unique and highly endangered environment is protected.

Our comment on this proposal is accordingly based on careful study of the contents of the Pre-Application Basic Assessment Report (PBAR) for the proposed development; preparation of the PBAR is part of the process required by law to assess any development with environmental implications.  The detailed, 193-page PBAR document on this proposal, supported by over 600 pages of specialist reports and supporting documents, was prepared in accordance with requirements of the National Environmental Management Act (NEMA) by independent environmental assessment practitioners commissioned by KWS.  It contains a detailed description of the proposal, the professional opinions of independent specialists on what the environmental impacts of the proposed development will be, and what they suggest can be done to mitigate those impacts. By law, the PBAR must be made available for public scrutiny, and comments must be accepted and made available to DEA&DP, which is the authority that will decide whether environmental authorisation will be given or not – and if given, under what conditions.  

WCC respects the expertise of the specialists responsible for the studies that form part of the PBAR.  However, reading the full PBAR and the studies reveals several issues raised by the botanist and freshwater ecologist that suggest they had different understandings of what the final preferred alternative would entail.  These experts agree that the land:

  • falls within the Kogelberg Biosphere Reserve,
  • is classified as a Critical Biodiversity Area,
  • has part of the Bot River Estuary within its cadastral boundaries,
  • is part of a RAMSAR site,
  • forms a part of the Important Birding Area declared by Birdlife SA, and
  • is home to highly endangered Micro and Cape platanna frogs.  

As such the property is considered by the specialists to be highly sensitive and conservation-worthy.  

The botanist goes as far as to conclude that “areas that have been previously cultivated have recovered relatively well and contain some of the best-condition vegetation on the property.  This indicates that much of the site could be rehabilitated to a near natural condition if the alien vegetation is controlled.” The only positive environmental impact that is regularly quoted from any of the specialist reports is that invasive alien vegetation (IAV) has been brought under control.  In this regard, it should be noted that as Working for Water spent taxpayer’s money on the initial and first follow-up IAV clearing, a directive will have been issued by the Department of Agriculture to do follow-up IAV clearing and maintain the property to be clear of IAV (this applies to neighbouring properties as well).

Sadly, the removal of IAV on the property is indeed the only positive environmental impact of the development in its proposed form; all other impacts are negative, some seriously so, and there are many inconsistencies.  For example, Mr Saunders states that “The development of a tented camp built in a sensitive environment has been thoroughly considered. Research, planning and expertise have been employed so that it will be done in a responsible manner so as not to affect the watercourse.” The freshwater specialist, however, warns that the tented accommodation camp “will lead to a loss or deterioration of wetland habitat”, that the associated sewage system presents a serious eutrophication risk to the estuary and that “the impact cannot be mitigated” and recommends that the tented camp be moved beyond the 5 metres above mean sea level contour line.

The Bot River Estuary area in which Mr Saunders proposes to build the tented camp on stilts over the water should not be within the fenced area of the property.  The Bot River Estuary is defined within the Integrated Coastal Management Act as “Coastal Waters” and all parts of it are, therefore “Public Coastal Property”. Mr Saunders’ attempt to justify fencing this area by comparing it with fencing around properties in Eastcliff and Voelklip is invalid.  Those urban properties are not in Coastal Waters and are not Coastal Public Property (nor are they in Fernkloof Nature Reserve as he states). A better analogy would be those properties in the riparian areas of the Klein River Estuary, the cadastral boundaries of which extend to the middle of the estuary.  An outcry could be expected if those property owners were to fence in half of the width of the Klein River Estuary as their private domain and build tented accommodation over the fenced-in water.

The botanical expert raises concerns about the unknown effect of trampling on the sensitive vegetation on the property.  He specifies that detailed annual studies of the effects on the vegetation with potential reduction or removal of animals if degradation occurs must be a condition attached to an environmental authorisation.  However, this adaptive approach is inconsistent with the “precautionary principle” prescribed by NEMA; applying the precautionary principle would require that animals should not be introduced at the outset if there is any risk of degradation.

Mr Saunders notes that elephants walk with soft and rounded soles on selected paths and thus do not trample.  This is true when elephants traverse between areas; however, when they are foraging elephants walk to wherever they see food.  Who of us has not seen the barren areas around the water holes frequented by buck, buffalos and elephants in game parks in South Africa?  If the animals wallow in the Lamloch wetland pools, will they remain viable habitats for endangered frogs and sensitive vegetation or turn to muddy wastelands devoid of life?  There is no herpetologist’s report informing the PBAR about the likely effects of the animals wallowing in wetland areas that are known habitats for the highly endangered Micro and Cape platanna frogs.

There are also worrying inconsistencies between the specialist reports and the PBAR which suggest that the specialists have different perceptions about what is being proposed.  For example, although Mr Saunders states that “At KWS wild animals will forage; they will not be enclosed in camps”, the animal management plan speaks of a 10 Ha buffalo and a 20 Ha elephant camp, enclosed by electrified fences, and shows their location.  However, these camps are not shown on the diagram of “preferred alternative 3” of the PBAR. Neither the botanical nor freshwater specialist reports mention a buffalo camp or an elephant camp, or the proposed lion enclosure, nor do they make any attempt to assess the impact of confining animals in these limited areas.  The botanical and freshwater reports identify the area proposed in the animal management report for an elephant enclosure as a sensitive wetland, whereas the animal management report says that area is infested with alien vegetation and suitable for an elephant camp.

Arguments in the newspapers will not decide the future of the Lamloch wetlands. DEA&DP will consider the contents of the environmental assessment documents and the comments submitted by those who study and respond to them.  Personal wishes and subjective opinions won’t count one jot.



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