The following will show you the techical side to
objecting against the Scoping Report. If you want to basically object it
can be done HERE and
there is a "Quick" way to do it. The objection made on this site will
automatically be sent to the Consultants and lodged on the site. There is
even a 'Top 5" reasons to object on the side of the page which can be cut and
paste in to the objection! Simple! Please add any personal comments
to your objection as well.
Guideline for Commenting on the EIA
process in Respect of the Proposed Baja Sardinia Development Proposal
1. The
Process:
It is important first and foremost to make the point
very clearly and unambiguously that we expect a full EIA process in terms of the
provisions of the National Environmental Management Act (NEMA) and the
regulations thereto promulgated in July 2006;
2. Adjudication of the Adequacy of the Scoping
Report:
The content Scoping Report must fulfill the
requirements as set out in Regulation 29 of 2006 (Government Gazette No. 28753
of 21 April 2006) as follows:
29. (1) A scoping report must contain all
the information that is necessary for a proper understanding of the nature of
issues identified during scoping," and must include - (a) details of - (i) the
EAP who prepared the report (i.e. the professional team that drew up the
report); and (ii) the expertise of the EAP to carry out scoping procedures;
(b) a description of the proposed activity and of any feasible and
reasonable alternatives that have been identified. We should indeed insist that
these alternatives should not merely reflect alternative development options on
the land in question but indeed engagement with the need for the development at
all against other alternatives available within the Greater Langebaan area such
as in-fill development and expansion of the town where necessary into less
sensitive areas to the north and east;
(c) a description of the property on which the
activity is to be undertaken and the location of the activity on the property,
or if it is - (i) a linear activity, a description of the route of the activity;
or (ii) an ocean-based activity, the coordinates where the activity is to be
undertaken;
(d) a description of the environment that may be
affected by the activity and the manner in which the physical, biological,
social, economic and cultural aspects of the environment may be affected by the
proposed activity;
(e) an identification of all legislation and
guidelines that have been considered in the preparation of the scoping report;
(f) a description of environmental issues and
potential impacts, including cumulative impacts, that have been identified;
(g) information on the methodology that will be
adopted in assessing the potential impacts that have been identified, including
any specialist studies or specialised processes that will be undertaken;
(h) details of the public participation process
conducted in terms of regulation 28(a), including -
(i) the steps that
were taken to notify potentially interested and affected parties of the
application;
(ii) proof that notice boards, advertisements and notices
notifying potentially interested and affected parties of the application have
been displayed, placed or given;
(iii) a list of all persons or
organisations that were identified and registered in terms of regulation 57 as
interested and affected parties in relation to the application; and
(iv) a
summary of the issues raised by interested and affected parties, the date of
receipt of and the response of the EAP to those issues;
(i) a plan of study for environmental impact assessment
which sets out the proposed approach to the environmental impact assessment of
the application (this relates to the second step in the process, namely the
drawing up of the Environmental Impact Assessment), which must include:
(i)
a description of the tasks that will be undertaken as part of the environmental
impact assessment process, including any specialist reports or specialised
processes, and the manner in which such tasks will be undertaken;
(ii) an indication of the stages at which
the competent authority will be consulted;
(iii) a description of the proposed
method of assessing the environmental issues and alternatives, including the
option of not proceeding with the activity; and
(iv) particulars of the public
participation process that will be conducted during the environmental impact
assessment process; and
(j) any specific information required by
the competent authority.
(2) In addition, a scoping report must take into
account any guidelines applicable to the kind of activity which is the subject
of the application.....
In drawing up your comment you
should therefore:
a. Comment on any
statements of fact or claims of fact contained in the report and indicate
clearly where you believe them to be incorrect or where you consider further
substantiation is required;
b. Take account of the requirements for scoping
reports as set out above and satisfy yourself that the requirements are in your
view met in all material respects. this applies particularly to the proposed
actions to be taken in respect of the EIA process to follow on the scoping
report and highlighted in bold above.
c. The following aspects are particularly
important and should be considered in your comment:
- The implications of allowing the contemplated
development on the area designated in the current spatial development
framework of Greater Saldanha (February 2004 - the plan currently in effect)
as buffer conservation land abutting the West Coast National Park. By
compromising the as yet relatively pristine tracts of the lagoon we are
compromising not only the biosphere but the essential ambience of this unique
lagoon that is also an Ramsar site;
- The fact that large tracts of land within
Langebaan representing nearly 50% of the erven within urban edge of Langebaan
(3300 erven out of roughly 6900) as yet lie vacant. The Spatial Development
Framework Guidelines of the Western Cape enjoin in-fill development rather
than urban sprawl represented by unwarranted expansion of the urban edge as
this renders service provision generally more expensive. Large tracts of
vacant serviced erven also represent a significant cost to ratepayers and an
effective subsidisation of property speculation. In addition we could
effectively double the present functional population of Langebaan without
setting out a single new erf!;
- The water issue. Whilst municipalities are
generally most concerned with the adequacy of water infrastructure to handle
the increased demand of development, it is the availability of the water
itself that needs to be questioned. The West Coast in particular stands to be
affected by climate change and is a water-poor area. This needs to be seen
against the fact that we already have erven sufficient to accommodate a
virtual doubling of the existing population of Langebaan. Is the proposed new
development therefore really feasible in terms of the availability of the
water itself?
- The economic impact issue. The usual promises
will be made that this development will deliver economic development and jobs.
We should however hold the developer to account for precisely how this is
proposed to happen. Experience elsewhere have shown that whilst some jobs
occur in the construction phase the sustained impact of residential
development such as this on jobs and incomes is considerably lower than
expectation. Will this development in fact draw additional visitors to
Langebaan that could not already be accommodated within existing business
environment of the town? The developers should be required to motivate their
claims in this regard in detail.
3. Where to Lodge Comment:
Your comment may be in your personal
capacity, or it may represent the comment of a collective of interests. The more
separate comment that is registered the more comprehensively we will be able to
engage with the process and oblige the consultants to address our concerns in
the EIA to follow.
Direct your comment to:
Doug Jeffery
Environmental Consultants
(Attention: Natalie Ritsch)
P.O. Box 44