2 -5 -2007

While SWC welcomes the fact that the FSR admits to a need to further investigate deviations to the SANRAL ‘preferred’ route that would pose less of an environmental risk, and welcomes the call for more specialist studies in numerous fields, SWC cannot in any justification condone the report or its recommendations.

SWC are of the opinion that the report does very little to address major legitimate public concerns raised in the last EIA or in the Draft Scoping Report, and that the report is so full of contradictions and inconsistencies that it can hardly be taken seriously, and resembles more a poor quality justification process for SANRAL’s preferred route than a legitimate and neutral assessment of whether another EIA conducted along what is basically the same route would serve the best interests of the region or of state financial expenditure. SWC are of the opinion that unless the fundamental planning flaw that underlies the whole project is addressed (namely the lack of any regional development plan that supports the need for a toll road or major new highway through the Pondoland Centre of Endemism) a new EIA as outlined by the FSR would merely be an renewed process of covering old ground and hence would amount to nothing more than an attempt to plaster ‘cracks in a wall’, when it is ‘faulty foundations’ that need attention.

SWC opinion is based upon the following;-

Contradictions and inconsistencies of fact

1- The FSR makes recommendations about the need to investigate alternative minor deviations from the SANRAL preferred route through the PCE but dismisses, for various reasons (social functioning, economic, loss of access routes etc) further investigation into any proposed alternative routes. Yet the report also lists numerous specialist studies that it considers to have been inadequate in the last EIA and that need further investigation, or that have not been done and would no doubt have a bearing on impacts of the road.

These studies are listed as

vegetation and flora; fauna; aquatic eco-systems; soils land use and agriculture; social; tourism; cultural and historical, heritage; noise; air quality; visual; traffic; planning/development; impacts on by -passed towns etc

How then, when there is an acknowledgement of a huge dearth of information that could impact on environmental, economic and social effects of any planned route, does the FSR come to the conclusion that only a limited number of alternative options are feasible for further investigation, namely, ‘do nothing’, SANRAL’s preferred alignment, SANRAL’s preferred alignment with minor deviations, and SANRAL”s preferred alignment with a larger deviation named ‘Coastal Mzamba’ route?

As the FSR points out, key principles of NEMA are that development must be socially, economically and environmentally sustainable. But it is becoming increasingly clear in the current world situation, that unless the environmental base is secured and maintained in a sustainable manner, then the principles of social and economic sustainability are compromised to the extent that the environment is compromised. In order, therefore, to maintain any sort of sustainable development, a pre-requisite is that the environment is secured. With so many key questions and unknown factors affecting environmental (and social and economic factors) acknowledged by the FSC as needing further study, and pertaining to the effects of a Toll or national rd or any particular route on that environment, to make assertions as have been done in the FSR as to the ‘benefits’ or ‘negative impacts’ of any particular route over any other route is premature, to say the least, and was one of the biggest causes of public contention in the last EIA.

There are no indications whatsoever in the FSR as to how any adverse environmental impacts (and by implication adverse social and economic impacts) of any routes will be mitigated except for vague references to the WCCSDI and the Pondo Park. This despite one of the main concerns of public misgivings about the routing of a national road through the PCE being the question of how the environmental base will be secured from secondary effects of the road e.g. by encroachment, ribbon development, invasive species that commonly occur along road verges or as a result of disturbed habitats etc. Authorities to date have made very little leeway with either the Pondo Park proposal or implementing the WCCSDI, so to pre -suppose that these will provide adequate protection for the bio-diversity of the PCE when they do not yet exist beyond concept stage is entering the realms of fantasy. The WCCSDI in itself does not specifically approve of a toll road routed through the PCE. To maintain that measures to ‘mitigate’ adverse effects will be undertaken does not give any explanation whatsoever about how such measures will be implemented, though it is hardly surprising that the answer is not forthcoming considering the dearth of available information about the nature of the environment ( in its fullest sense) SANRAL is dealing with.

2 -Public consultation process

The FSR goes to great lengths to justify that the Public Consultation Process (PCP) of the old EIA was adequate and met legislative needs and therefore could inform the basis of a new EIA. However, the greatest number of public complaints pertaining to the PCP where not of quantity of response or inadequate number of meetings, but quality of unbiased information made available to the public, and willingness for Sanral to engage with public concerns. SWC cannot see any change in this attitude in the FSR by the simple fact that the FSR has not adequately addressed a large number of public concerns, namely protection of environment of the PCE, tolling, purpose of the road, neutrality of SANRAL in the issue i.e. satisfactory explanations to the debate of whether SANRAL is principally serving public interests rather than the vested interests of tolling and road building consortiums.

The large public interest and number of IAP’s registered in itself is indicative of public dissatisfaction with the whole process. Public do not generally go to much trouble to comment, protest and engage with issues if they are satisfied with the outcome.

3 -Unsolicited proposal process

FSR goes to lengths to explain that where there is an established need for a certain developments, i.e. ‘where proposal meets the requirement of policy’ then government agencies can award ‘scheme developer status’ to private consortiums to further develop proposals.

The contradiction is that in the case of the N2 toll THERE IS NO ESTABLISHED CRITERIA THAT REFLECTS THE N2 AS BEING IN CONFORMANCE WITH GOVENMENTAL PROPOSALS, AS THERE ARE NO ESTABLISHED GOVERNMENTAL DEVELOPMENTAL PLANS FOR THE REGION THAT REQUIRE a Toll road routed through the ‘Greenfield’s’ section. As there is no regional development plan that necessitates a toll road through the PCE, there can be no independent concrete proof other than SANRAL CLAIMS that it is in the best public interest, and there is therefore no justification to claim that N2 reflects environmental, social and economic sustainability, especially as the FSR acknowledges huge gaps in relevant information upon which to base such decisions.

In light of the above, it is difficult to support claims other than the view that the N2 toll road is nothing more than a business venture by consortium of private companies into whose thrall SANRAL appears to have fallen.

4 -Tolling

FSR goes to lengths to explain legislation that exempts tolling from EIA processes. However, this does nothing whatsoever to alleviate public concerns that by excluding effects of tolls from the EIA process, the full social and economic impacts of the road on communities cannot be quantified or assessed and is therefore in contradiction of the ethos of NEMA.

5 -Benefits of road

FSR makes sweeping statements about national road networks linking main cities and economic regions of a country. However, there is no assessment of specifics of how the N2 will realize regional economic growth i.e. no regional development plan that might maximize benefits of any new road. (See point 3)

FSR says the former Transkei has ‘few economically realizable natural resources’. This of course is a hugely subjective and debatable question (and other propaganda type statement), but it seems ironic that if one takes the statement as fact, then the one internationally recognized ‘natural resource’ that the coastal area does have, i.e. an unspoilt, species rich, scenically unparallel coastline, is now to be sullied and threatened by a national road whose purpose remains undefined.

The FSR again makes contradictory and unsubstantiated statements about ‘regional benefits’ while simultaneously alluding to the fact that the road is to serve as a high speed throughway linking major centres. It is difficult to see how the N2 toll rd can serve two conflicting purposes, i.e. high speed inter -city highways are not designed to serve the interests of small regional centres.

FSR maintains the N2 toll would ‘would enhance the region and would facilitate development of the eco-tourism of the region’. These are unsubstantiated claims which completely contradict evidence from major road developments elsewhere. No regional plans exist to underpin this and no evidence exists to support these statements.

6 -Empowerment strategy

FSR maintains that N2 toll would provide jobs and empower communities within the project area. So would a road along any other alternative route or upgrading of existing routes for the duration of the construction at least, so this can hardly be justification to select any particular route or SANRAL’s preferred route. What is of greater significance is the effects of the legacy that will remain once construction is complete, which information is acknowledged to be incomplete (see point 1)

7 - Environmental values in relation to economic consideration

FSR does not begin to address the key question of how the loss of eco-systems or biodiversity as a result of a road through the PCE is quantified. That is, what economic price is placed on the value of eco -systems and biodiversity in relation to other criteria used in the assessment of value of alternative alignments? (Table 11, 12, 13, 14).

This has a huge bearing on economic and social implications of the road and any economic, social and environmental assessment should be considered incomplete without it.

In conclusion, SWC maintains that in light of the above, to continue any further with the charade of pursuing another EIA along what is principally the same route, will do nothing more than compound an already fatally flawed process and waste further taxpayers money.

If SANRAL wish to pursue a national road through the Eastern Cape Province, they should start the process afresh and begin at base level by first ascertaining, (in collaboration with national and regional authorities) regional needs, and by gathering all relevant data in an unbiased process before determining what routes and which transport means would best serve the interests of the region. Without this baseline work, fully substantiated by factual analysis, the process is once again fatally flawed and a despicable waste of taxpayers money. The DEAT needs to halt this project immediately, and make it clear to SANRAL that the only process that will be considered further is to restart the process from a strategic regional transportation needs perspective. No further project level road proposals should be entertained without this.

Compiled on behalf of Sustaining the Wild Coast (SWC) by

Val Payn
Box 44
Harding 4680
Tel 083 -4416961
valpayn@gmail.com

Posted on May 3rd, 2007
Filed under: SWC Comments