R300 Toll Road articles

Zandvlei Trust

Responses to the EIR for the R300 Toll Road

by Charlie Ward

I wish to add my voice to those concerned Cape Townians opposed to the construction of the SANAL / Penway toll road.

The area is crisscrossed by a network of road and rail services some of which do need upgrading.

I believe we do not need this development. What we need is an efficient public transport system. We should insist that Metro Rail improve their service. A bus service, perhaps similar to Durban's Myna small bus service, should be considered for those areas that are not served by the railways. The area serviced by trains could be extended by a safe, low cost Park and Ride system. This Park and Ride system could maybe be linked to monthly or even annual season tickets.

The destruction of any wetland makes no ecological or financial sense.

Wetlands play a vital role in restoring the quality of both surface water and seepage to the aquifers that many people are hoping will supply our future needs. Water running off tarred roads carries with it particles of oil, carbon and rubber all filtered out free of charge by the wetlands. This process could continue for the foreseeable future if the wetlands are protected. Given the fact that Cape Town does not have the water needed to supply its growing population no one should ever consider damaging the few existing wetlands.

This development would ruin two well-developed small Cape nature reserves and could jeopardize the proposed False Bay Park.

Both Zandvlei and Rondevlei are nature reserves with established (and important) educational facilities. They have both been developed to encourage tourism which helps finance the educational functions Together with the Strandfontein sewage plant this area is a bird watchers' paradise, with almost as many species as the St Lucia World Heritage Site.

The toll road would do nothing for tourism and increase noise pollution in both residential and recreational areas across the Cape Flats.

Overseas tourists are attracted to South Africa by our scenic beauty and uncluttered vistas. They all have multi-lane freeways at home. The False Bay Park and Table Mountain Reserve could be developed into a vast tourist Mecca - unique in its proximity to urban infrastructure, yet valuable in the peaceful retreat it provides from the stress and noise of city life.
Zandvlei is Cape Town's only functioning estuary, with its three wetlands. It is proposed that it be part of the Table Mountain Reserve, a world heritage site.

This unsolicited proposal is driven by greed.

The only people who will benefit from this toll road development will be the contractors and the backing investors. Any jobs they create will be strictly "short term." The true cost will be borne by the Southern Cape's residents who will be poorer in every way.

THE PEOPLE OF CAPE TOWN DON'T NEED OR WANT THIS TOLL ROAD.

by Ian & Sharon McCallum

Having read the EIA and the executive summary in some detail, we herewith lodge our written objection to construction of the proposed N21/R300 toll road, in principle and on the basis that the EIA is flawed. It is vague, misleading and incomplete for inter alia the following reasons :-

1. Motivation : This is stated to be the congestion of the current Cape Town road traffic system. Whilst acknowledging the congestion on the roads in central Cape Town, we believe that the new road will make matters far worse for us residents south of the proposed route. Our access roads are already impossibly congested on weekends and public holidays, particularly in the summer, and they are unable to cope with the existing traffic congestion. The increased traffic on the proposed road will have to be funnelled at its southern end into the narrow roads of Muizenberg, St James, Kalk Bay and Fishhoek or the winding mountain pass of Ou Kaapse Weg. In addition, there will be a substantial increase in daily traffic congestion on alternative routes as commuters, particularly those who can ill afford to pay tolls, are bound to choose less expensive routes to work. We envisage a worsening of the traffic congestion rather than a lessening as proposed.

2. Economics : It is well known that GDP is a macro-economic term and the issues surrounding this particular road need to be considered at a micro-economic level as well.
The information contained in the EIA is insufficient to properly assess the overall economic impacts of the proposed road, and therefore incomplete and misleading, as the impacts have to be weighed /measured economically taking into account the wealth or poverty of the affected persons. This does not appear to have been done.

3. Costs : Do we in South Africa have a system which allows people to make a profit at any cost? The developer has stated that the proposed new road is viewed as an investment opportunity. Other than the Chapmans Peak toll road, the proposed road will be the only toll road entirely through a metropolitan area. The company operating the toll road at Graskop recently reported a R18m profit in the last tax year. No wonder the developer considers this an investment opportunity!
It is important that the decision-makers in this process bear in mind the 'other' or hidden costs that come with a development of this nature - those costs which the developer does not bear as they are external to the business of running a toll road, but which will be borne to a great extent by our poor (and generally historically disadvantaged) sector. For example, a development such as the proposed road comes at a cost to the neighbours, or adjoining residents of the road - to their health, and additional medical costs as a result of deteriorated health; it comes at a cost to users of the air that gets polluted by such a road; it comes at an enormous cost to our enjoyment of the environment which is diminished and/or destroyed by the construction of the road; it comes at a cost to tourism as an industry when flora and fauna (in this extremely important area) may be irretrievably lost; how does one compute the cost of the loss of an endangered species, be it plant or animal - this is a loss to future generations - which comes at their cost, i.e. that of our children and grandchildren.
And these are costs that the Developer does not bear!

4. Environmental : The southern and Western Cape contains one of the major floral kingdoms of the world and is home to a wide variety of birds, mammals, reptiles and insects, many of which are endemic to the area and some endangered. A great deal of the natural vegetation has already been lost as a result of urbanisation and development and the continuing rate of destruction is high. The EIA admits the following negative impacts, which we consider to be of serious concern and not to be taken lightly, on the environment in Sector 1 (that sector which traverses Westlake, Zandvlei, Rondevlei etc), which impacts are predicted to be high, even after mitigation measures are in place:-

The sense of place in the affected conservation areas - Zandvlei, Zeekoevlei and Rondevlei; we would be interested to learn how it is envisaged to mitigate the impact to the sense of place, and if effective, how it will be ensured that this mitigation will continue.
A high impact on the character of the agricultural landscape through which the proposed road will traverse;
There will be reduced buffer width and terrestrial habitats between the wetland and residential areas and increased disturbance on the wetlands from the use of the road in the area;
There will be loss of wetlands (vitally important for the filtering of pollutants from our water systems besides supporting a variety of flora and fauna ) and the loss of the Cape Flats rarest species of plant (Passerina paludosa) plus "negative effects elsewhere in the system" which is not expanded on.
Species threatened by the construction of the road are said to include the Cape sand snake, the yellow-bellied house snake and the Western leopard Toad - as well as some butterfies - we cannot be permitted to drive any more species into extinction.
Over 100 indigenous plant species were found in the area and it has been rated as a high conservation area with a number of unique elements. It is admitted that there would be a loss of Cape Flats fynbos/thicket mosaic vegetation.

5. Constitution : Our constitution provides that every person has a right to an environment that is not harmful to their health or well being and our Government has a responsibility to prevent pollution and to promote conservation and sustainable development. The people living closest to this road will no longer have "an environment that is not harmful to their health" from an aesthetic point of view, as well as from air pollution, auditory and visual points of view.

6. Proposed False Bay Ecology Park : It is admitted that this issue is unresolved and that it is unlikely that the Park can co-exist with the new road in its present proposed form. This Park is stated to be important from a biodiversity point of view and an area where ecological corridors intersect - vital for the movement of species and ecological processes. It contains a number of rare and endemic plants and wetland systems, including the ponds of the Cape Flats Waste Water Treatment Works which is considered to be the 5th most important wetland bird habitat in southern Africa. It also offers socio-economic opportunities. It is vitally important that the future of this Park is not jeopardised by the construction of the new road.

7. Alternatives : We believe that alternatives should be explored, e.g. upgrading and streamlining the public transport system, particularly the railway and taxi services. Road users with more than one occupant per car can be rewarded, e.g. use of fast lane. We understand that it is an admitted policy of the City of Cape Town to develop the public transport system used mainly by the lower income groups, rather than construct new highways for use by the more affluent members of our society.

8. Road reserves : In several places the EIA mentions that portions of the proposed new toll road will traverse areas that are already road reserve, having been planned and approved by the relevant authorities some years earlier. It is important that we know whether the previously approved road areas catered for a road or roads with six lanes - were the EIA's and PPP's that were then undertaken, done so for a road of this size? If not, surely they would need to be redone and new authorisation received?

We look forward to being advised of the outcome of this process, and hope that ecological and financial wisdom (in the bigger picture) prevail.

by Rachel Puodzius

In my mind all my comments are as clear as a bell, but to put down on paper all these thoughts, is another matter. Suffice is to say, I am devastated by this proposed project and so saddened by mankind's greed and willingness to cause destruction and havoc for the sake of money. This road is not a necessity. The world is sinking under the weight of all the concrete, tar and junk we continually manage to justify, because it will make our lives more convenient or supposedly improve the lives of the impoverished… In fact, what a joke: The rich man says; "This will make your life better (…hee-hee, and mine too…!)". How will this Road make the life of the poor man better?

Every year, thousands loose their homes and possessions to flood and fire in informal settlements. We certainly don't see investors such as Penway flocking to alleviate the impoverished life-styles of these people who can, in most cases, barely afford their taxi fare but will manage to scrape a few more cents together for a Toll Fare! Because the rich man says so! There are too many people without an adequate roof over their heads (and enough is not being done, regarding this issue) and we must justify the expenditure of R1.2 billion on a road that will do what? Ease congestion. Really? How will this road ease the congestion of cars that must travel to Cape Town City Centre? Is this 6-lane highway going to have a fly-over from the N1 and N2 right into the City Centre? What about all the traffic (particularly seasonal) to Muizenburg, Fish Hoek and Simon's Town, will this road alleviate that congestion?

When will the issues of Public Transportation be addressed?
There are so many investment opportunities and employment opportunities here. We want to become a 1st world country, which has terrible Public Transportation but a massive Ring Road around our beautiful city. Tourists don't fly over to South Africa with their cars. They get here by plane and use our Public Transportation, which doesn't exist! Again, I ask, when will this be properly addressed? And is FIFA expecting a Toll Road or adequate Public Transportation? Get the Public Transportation sorted out first and then address the necessity of a Toll Road. Continue to spend money on upgrading existing roads (job creation). Improve traffic control and put more law enforcement manpower in place to anticipate and address traffic problems when they occur (job creation). Citizens should be encouraged not to use their vehicles in peak times.

Perhaps I don't understand the technicalities and "real-world" issues regarding this project. Perhaps I am selfishly concerned with my own agenda that the house I bought 2 years ago is going to devalue so much, I'll probably never afford another property again. Perhaps this road will not really affect the environment all that much. What's another Toad to the world? What is a bit of Fynbos and last Cape Flat Wetland vestige to the world? Perhaps, in time, I will get used to the sight of the concrete monstrosity I will have to stare at every day. And, people say, you get used to the noise pollution of busy highways. And when the road is built and the environment is destroyed and the road is NOT a success, what then? Can we destroy that too?

This road will not be built for the greater good of the nation or the environment we are here to protect. This road will not properly address issues of Public Transportation. This road will not sufficiently solve the problems of traffic congestion. This road will not improve the living conditions of the majority of South Africans. This road will not enhance or give justice to the beauty of our Mother City. This road will divide communities and destroy large portions of this magnificent place we call home.

This road will change the face of Cape Town and not for thebetter ...

by Eureta Rosenberg

SUMMARY OF MAIN COMMENTS
The Report and the environmental impact assessment (EIA) on which it is based, are not a valid basis for decision-making in the current context. The findings give little support to the proposed development, and include an unacceptable number of unresolved issues. Some of the conclusions - notably those on Economics - are misleading. Some findings are illuminating and should be noted. Their overall message (which is unfortunately not stated in the timid Executive Summary) is that the proposed development would be an inappropriate, inadequate and deeply damaging response to Cape Town's transport needs. Perhaps most critically, the Report is presented, two years after the initiation of the EIA process, in a changing policy environment. Rather than extend the EIA process in order to address its limitations, Government should review the Penway-SANRAL proposal itself in the light of this changed context.

1. The Policy Context Has Changed
The Report motivates the proposed development on the premise that Cape Town's roads need to be upgraded, that congestion needs to be alleviated, and that does not have adequate funds to improve the road network. The Report finds that building toll roads is not the most economically efficient way of improving the road network. It finds that, in a given policy framework and in the absence of alternatives, tolling is however the only available option. It finds that the tolling of the R300 will have significant negative impacts on the residents of Cape Town. It states that there are also significant positive socio-economic benefits, negative ecological impacts, and a number of "unresolved issues".

However, the policy context has changed since these findings were concluded. The President has announced an extended public works programme in which infrastructure development is a significant component. These funds present a new alternative for improving the road network; there are therefore more alternatives to tolling. There are also more alternatives than extending the road network, for alleviating congestion and facilitating development. One of them is the anticipated road-to-rail emphasis as part of better public transport, in the new national transport framework. The City of Cape Town is also now drafting a coherent transport plan for the Metropole; this was not available at the time of the EIA process, which is noted in the EIR as a significant unresolved issue which made it difficult to conclude on the appropriateness of the unsolicited bid. These national and local level policy developments necessitate a review of the proposal outside of the findings of the EIR, given that it did not take them into account.

2. The Economic Study Makes Misleading Deductions
The Economic Report finds that the proposed development will have significant negative socio-economic impacts, almost exclusively on the most vulnerable sectors of society. It furthermore finds that there are also significant socio-economic benefits to the project. This finding carries a lot of weight and should therefore be carefully examined.

Firstly, it should be noted that the projected economic benefits are based partly on savings (in time and money) effected by the upgrading of the R300, preventing future deterioration (and the indirect benefits of these savings making their way into the economy). These benefits are therefore not exclusive to the current proposal; they would derive from ANY upgrading of the road. Should road maintenance be partly supported by grants from the public works programme, for example, the same economic benefits would accrue (and more, if tolling is avoided).

Secondly, one needs to examine the calculations on which the estimated economic benefits (several billion rands) are based. These benefits are essentially projected savings, of two kinds: to road users who would be spared the projected costs of a deteriorating road surface on the R300, and to road users on the metropole's network as a whole, through an improved network speed (as a result of the extension of the R300 to connect major arterial routes) by an average of 2 km per hour. The assumptions underlying these calculations are questionable in a number of ways, and yet they are used to make imaginative statements on the project's contribution to the national GDP, greater income tax base, etc., and a potent conclusion about socio-economic benefits, which will undoubtedly be interpreted as off-setting negative socio-economic and ecological impacts.

To illustrate only one questionable assumption: The Economic Study assumed that each hour of network time is worth a certain amount of money to an individual or business. It added all the individual time savings to derive numbers of hours, then multiplied the number of hours saved each year across the network, with the amount that each hour saved would be worth to an individual/individual business. However, in reality no single business would be able to accumulate significant hours saved in the day, if the average network speed is only to be improved by 2 km per hour (reducing to 1,5 km per hour as congestion again increases, towards the end of the concession). In other words, while Joe Soap may be arriving 5 mins earlier on site each day, this small individual time saving is not going to measurably increase the productivity of his individual business; Joe's daily 5 min savings cannot be added to make that unbroken hour which would have increased productivity. The theoretical accumulation of the savings across the network and their translation into rands and cents, is therefore fundamentally flawed. Such flawed assumptions underpin weighty conclusions.

Thirdly, the projected job creation benefits should also be scrutinised. The EIR notes that the project will create employment. It finds that the project will at its peak create 2251 jobs. By Year 10 of operation, however, most of these jobs (73%) would be lost. So this multi-billion rand project can yield only 608 sustainable jobs, and this is presented as a significant benefit. To see this in perspective, one needs to compare it to the employment benefits of public partnership programmes driven by more than private profit; the EIR does not do this.

3. The Social Study Is Thin
The Social Report is inadequate in scope and depth. Issues raised in the scoping process, such as the devaluation of property, due inter alia to the loss of nature values and the increase in noise pollution, are not addressed in any significant way. The rippling socio-economic hardship caused by private drivers from Kayalitsha or Belville having to pay an estimated R193-R231 per month more on transport on a metropolitan toll road, is not discussed. The fact that children from low-income, high-violence areas benefit in intangible but noticeable ways from environmental education experiences in unspoilt natural areas, such as those which will be irredeemably damaged by the southern extension of the road, is not discussed.

4. The Executive Summary Lacks Direction
An Executive Summary is the most influential component of a report, as it is often the only component read by busy people in powerful positions. As the name suggests, it needs to take some 'executive' decisions in terms of what is recommended to the reader as worthy of notice and action. Unfortunately this particular Executive Summary is rather timid in tone and structure. The bulk of the first part seems aimed at establishing that the EIA has been carefully executed. Summaries of methodology can safely move to another part of the EIR. The Executive Summary should move swiftly to key findings and recommendations to the main parties which will peruse it, starting with the Minister of Transport and the Minister of Environmental Affairs & Tourism. In the current version, the Ministers and their assistants would have to search for and may indeed fail to find clear conclusions and recommendations. This is due to structural weaknesses but also an apparent lack of confidence and/or courage on the part of the contracted agency.

5. The Report Is Of Some Value And the Following Findings Should Be Noted:
While the motivation for the proposed development is said to be the alleviation (and prevention) of traffic congestion, the EIR indicates that it will fail to do so in any significant way: not in the long-term (increased network speeds relative to network speeds without the scheme = 1,5 km per hour), and not even in the short-term (increased network speed = 2 km per hour). Based on the findings of this EIR, the proposed road design is not a significant intervention in Cape Town's existing and anticipated traffic problems. Alternatives must be found and are surely been considered by the City of Cape Town and its partners, outside of this proposal. The following startling statement in the Economic Report is telling: "The fact that the proposed project is financially and economically desirable suggests that there is a need for the project". The proposed development cannot by any stretch of the imagination be regarded as more than a private investment for private profits.

The proposed project will have significant negative impacts on coastal wetlands and several species in the Cape Floristic Kingdom, an internationally acclaimed biodiversity 'hotspot' which attracts donor funding and tourists, and makes numerous economic contributions. Some of these impacts will take place in areas which were, under historic policy frameworks, designated as road reserves. Current policy frameworks which protect species and ecosystems include the National Environmental Management Act of 1998, provincial bio-regional planning frameworks aimed at supporting coordinated sustainable development, and the Integrated Metropolitan Environmental Policy of the City of Cape Town.

The proposed project will have significant negative socio-economic impacts on a wide front, and the brunt of the impacts will be borne by the city's poorer and more vulnerable residents. Such one-sided and some might say exploitative development planning is supposed to be a thing of the past. The ANC-led Government promised Western Cape voters a better life for all, with the emphasis on benefits to the most needy in order to correct the skewed planning of the past. Developments designed and driven by private investors are not shaped by Government's declared public-interest orientation which is set to characterise the next 10 years of policy implementation. The EIR recommends mitigation in the form of subsidies to road users on the R300. This remains an "unresolved issue" as neither the likely level of tolling, nor the likely source of the subsidy, could be identified.

The EIR finds that a high number of significant negative impacts are likely to result from the project, and recommends a large number of associated mitigation measures. It is clear that the profitability of the project would be threatened by the number and scale of these mitigation measures, which range from a complex subsidy systems to road users, to walls to reduce expected noise levels to within legal limits. The authority to ensure and enforce required mitigation measures is devolved from elected government to a private company acting on behalf of Government (SANRAL). The situation does not inspire confidence. The EIR also notes that some likely significant impacts have no possibility of mitigation.

SANRAL's experiment with unsolicited bids as a tool to develop the road network in the absence of adequate government funding, should be reviewed critically. The EIR on the N21/R300 bid shows that as a strategy for serving the country's needs, it is both inappropriate and inefficient.

RECOMMENDATIONS

This EIR should be noted for its sobering findings, judged to have some flawed assumptions and conclusions, and seen to have limited value in a changing policy context, which supersedes the proposal which it was tasked to assess. It is further recommended that -

National Government:

reconsiders unsolicited bids as a tool for serving the country's development needs;
rejects the N21/R300 Toll Road proposal as an inappropriate and inadequate response to Cape Town's transport needs;
rejects the proposed development on the grounds of its likely negative socio-economic and ecological impacts;
develops a national transport policy which will actually and sustainably alleviate road congestion, and serve the needs of the majority of South Africans, i.e. a public transport policy with a strong road-to-rail emphasis.

Provincial and Local Government:

develop a comprehensive transport plan for the Province and the Metropole;
focus this plan on how best to reduce congestion and improve access for the majority of the population, in ways which
benefit rather than burden citizens of limited means, and in ways which
protect as much as possible of the remaining lowland biodiversity and coastal wetlands, in keeping with international trends, national Acts and local policies.