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Rob Munro
Posts:39
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| 04/20/2009 6:53 PM |
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The Editor 20 April 2009
Weslander
Attention: Alida Buckle
BAJA SARDINIA NOW RENAMED SHARK BAY: THE SAGA CONTINUES
The “Final” Scoping Report on the Shark Bay development proposed by Ricardo Scarpelini appears not to be “final” at all. By their own admission the compilers concede that there is still work to do. Indeed, as a basis for a comprehensive and objective EIA process to follow the current report falls woefully short of the mark. Having been sent back to the drawing board in mid 2008 on procedural issues the proponents of this development still have not got it right.
Where before there was an attempt to circumvent the full implications of the National Environmental Management Act, (NEMA) in a rush to judgement on this proposal, the fatal flaw of the current “Final” Scoping Report amongst many others is that it still does not fulfil the requirements of the EIA regulations to the National Environmental Management Act, (NEMA) promulgated in Government Gazette No: 28753 of 21 April 2006. These relate especially to the scoping of alternative development options to those preferred by the Prospective Developer, including a feasible “no-development” option as required by Law to provide a basis for comparison in performing impact assessment. Whilst the Prospective Developer’s interests are generously reflected in the “preferred” alternatives presented in the report, the comments of Interested and Affected Parties opposing the proposed development submitted in earlier rounds of consultation, including those of SANParks, appear largely merely to have been recorded and summarily dismissed.
Considerations of viewshed and sound coastal management as contemplated in the Coastal Management Act, 2008 as well as the comments of SANParks notwithstanding the only scoped alternative proposed to be taken forward into the EIA process involves the construction of 109 units on the property, including a significant element to within a setback of 50 meters along the Klein Oostewal/Shark Bay lagoon- and beach front. Of course this contains development of the prime lagoon front property and it would have been surprising indeed had there been any other conclusion but that this should constitute the “preferred” development option. The justifications advanced for this “preferred” option in the report are however totally inadequate, superficial and contrived and prima facie therefore must be suspect. The Coastal Management Act, 2008 is outspoken on the matter of setback, defining a coastal protection zone to include land closer than 100 meters of high water mark but providing for far greater setback where justified by other considerations. Recognition of the sensitivity of the coastal frontage in the Klein Oostewal/Shark Bay case is evident amongst others from the fact that per Item 52/09-02 dated 23 September 2002 the Council of Vredenburg-Saldanha itself had resolved to reject a previous developer’s proposal for development of land on the Oostewal site to the West of Park Avenue. This includes a significant element of the prime land currently slated for development in the “preferred” alternative advanced in the current “Final” Scoping Report.
If it is to represent a credible basis for an EIA the present “Final” Scoping Report needs to be comprehensively reviewed. Not least the requisite range of feasible development alternatives for objective comparison must be properly engaged and scoped. In addition the justifications for the “preferred” development proposals advanced in the report must be reviewed and adequately and professionally motivated, given the sensitivity and importance of the site and the implications of a development decision.
Without a real and credible commitment in the EIA process objectively to addressing the fundamental questions as to whether, in the light of objective analysis, development of this site should be approved at all and, if so what form that development should take, the integrity of the EIA process will remain suspect as it has been from its very inception.
As the Langebaan Action Group we remain firmly opposed on well considered spatial developmental and environmental grounds to the proposed gratuitous and selfish development of the Shark Bay site and the destruction of yet more of our remaining lagoon heritage.
Visit the website at www.savesharkbay.org, stay informed and send your inputs and comments to the EAP Team at lindsay@dougjeff.co.za before 29 April 2009.
Johan Ackron:
Convener: Langebaan Action Group
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