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ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
1 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW
ROUTE P166-1/2 IN NELSPRUIT
COMMENTS & RESPONSE REPORT FOR SCOPING PHASE
SEPTEMBER 2013
INDEX TO ISSUES IN THIS TABLE
ECONOMIC ISSUES
LAND ISSUES & AGRICULTURE
ECOLOGICAL ISSUES
TECHNICAL ISSUES
WETLAND
SOCIAL ISSUES
GENERAL ISSUES
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
2 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
ITEM
ISSUE
SOURCE
RESPONSE
ECONOMIC ISSUES
The proposal affects the viability of some farm portions, or
the existing investment made on properties, or the
development potential
Mr. Hennie van
Rensburg, Nuplan
Development Planners,
Comment & Registration
Form
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary.
Mr. Riaan van Doorn has a manufacturing business that is
located across the road from Casterbridge and below
Bagdad Cafe. The new road P166-1/2 as shown on the
aerial photos is going to pass right in the middle through
the business. 24 people are employed at the factory. What
do I stand to do regarding these employees future and my
business?
Mr. Riaan van Doorn,
Spectacular Concrete
Works, Comments
Emailed
The manufacturing business on Remainder of
Portion 9 of Nooitgedacht 62-JU is inside the
declared road reserve. If the route running
through the business is approved by
authorities, SANRAL will engage in
negotiations with the affected owners in this
matter.
Alternative 1 will run through my property and will affect the
value of my property and influence our daily lives
negatively.
Agriculture is our livelihood and we give work to many
workers.
If this project goes ahead, many productive trees are in the
way of the P166 route.
Mr. Gehardus
Engelbrecht Comment &
Registration form,
Emailed
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary.
Total water supply in jeopardy to a Sawmill, a Transport
Company & Forestry Harvesting & Transport Company with
the total employment of 450 workers and housing 150
tenants.
We receive our only supply of drinking water from a natural
Carel Jacobsz,
Comments and
Registration form,
Emailed
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on how water supply will be
maintained to ensure that it will still be
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
3 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
spring exactly in line where option 1 alternative is due to
pass over.
Our only industrial water supply from a canal for our above
needs are pumped from 3km away which will now be
inaccessible for maintenance & control and maybe totally
cut-off as a supply source. This will enforce a shutting
down of the entire above-mentioned facility.
available for the company.
(Note Phumlani Alternative 1 will not be
assessed further in the EIAR phase of the
project )
The proposal affects the viability of some farm portions, or
the existing investment made on properties, or the
development potential.
Hennie van Rensburg,
Comment & Registration
form Emailed
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary, if this has not already
been done as part of earlier declaration and
compensation. however some farmers were
already aware that that the servitude has been
proclaimed and this is stipulated in their leases
LAND ISSUES & AGRICULTURE
The proposal affects our primary dwelling directly (locality
and other information not in detail and clear) as well as
our farming activities. We oppose the current proposal and
alignment
Jurie Piso, Comment &
Registration Form,
Emailed
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary, if this has not already
been done as part of earlier declaration and
compensation.
This route would destroy a significant amount of irrigable,
valuable, productive farm land, which in a country which is
battling to produce enough food, is not acceptable.
Allan Luus, Mercy Air
Comments Emailed
The potential impact of certain of the project
alternatives, in particular Phumlani Alternative
1 is recognised, and is reflected in the
agricultural potential study. It should be noted
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
4 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
Farmer's fields will be physically cut into smaller un-
economical parcels, that will result in destruction of irrigible,
usable land that will be in excess of the actual land
destroyed by the road.
The original, declared servitude runs through an area that is
poor farm land, that has no irrigation, and therefore a far
smaller amount of arrable land will be destroyed. The fact
that the Msholozi illegal settlement will have to be disrupted
is a problem, but how can an illegal settlement disrupt the
legal, planned law abiding processes of the country?
Property values in the whole valley will be negatively
effected by the "Alternative 1 " running through the valley.
We carefully investigated these sort of servitudes before
buying our land, and find it un-acceptable that a road can
now be moved right onto our doorstep because of an illegal
settlement that has sprung up in the past 2 years, in the
middle of your planned, declared route. There are many
servitudes and rights-of ways across different farms in the
Heidelberg valley and these would all need to be carefully
considered to make sure nobody is accidentally cut-off.
The Sand River Irrigation Scheme would be seriously and
negatively impacted by the road. The scheme has
registered servitudes, surely you cannot just disrupt these
servitudes?
that for environmental reasons, the Phumlani
Alternative 1 has been discarded and will no
longer form part of the project scope as
investigated in the EIAR phase.
The potential impact of the proposed road on
agricultural activities is recognised, and as
such an agricultural potential study was
commissioned for the scoping phase of this
EIA. The social study has also identified the
potential impact of a loss of income due to
sterilisation of agricultural land. These issues
will be further assessed by the respective
studies in the EIAR phase of the project.
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani settlement
were allegedly “illegally” settled. Nonetheless a
housing development & community now exists
within certain parts of the servitude and wider
area (in which alternatives to the existing
servitude in the Msholozi area are being
considered) and as such the potential social
impact of the proposed road on this community
needs to be considered by this EIA and
compared with the impacts of the alternative
alignments.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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What will happen if a truck carrying hazardous chemicals
crashes off this road and the chemicals are spilled into the
canal and are inadvertently pumped onto hundreds of
hectares of farm land, permanently contaminating the land?
will SANRAL pay for this?
The existing servitude for the P166 is the shortest route with
the slowest gradient and makes the most sense from a road
point of view.
Increased run-off during periods of high rainfall resulting in
erosion and further loss of farmland.
Potential pollution of surface water receptors
and agricultural infrastructure by spillage from
vehicles is an important environmental issue,
and will be further investirgated in the EIR
phase of the project, and particularly in the
context of the EMPr that will be compiled in the
EIR phase. The risk of such an event
transpiring in the Heidelberg valley would be
greatly lessened by the discarding of the
Phumlani Alternative 1 as an alternative in the
EIR phase of the project.
Run-off from hard surface of the road and
associated stormwater outflows into adjacent
land (including agricultural land) is an
important potential issue in the context of the
agricultural potential aspects of the affected
environment. Accordingly this issue has been
flagged as an issue for further investigation
during the EIR phase, and relevant mitigation
measures will be identified for inclusion in the
EMPr.
Seriously affected party by P166 - it cuts through our farms.
Huge disruption – how will evaluation be conducted to
determine compensation?
Try to identify another alternative as P166 cuts through
valuable commercial, agricultural property.
P van Rooyen,
Comments, Emailed
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary.
Impact of the proposed project on agricultural clients Stefan Scheepers, If the route running through these properties is
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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banking with FNB. Comments, Emailed
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary; however some farmers
were already aware that the servitude has
been proclaimed and this is stipulated in their
leases.
ECOLOGICAL ISSUES
The contents of the draft scoping report is concerning as the
Mpumalanga Biodiversity Conservation Plan, does not
appear to have been consulted in this initial, mostly desk-
top based Scoping assessment.
The protected area expansion areas must also be
considered.
The presence of existing bird sanctuaries has not been
considered.
The presence (possibly destroyed) of Aloe simii populations
in the Phumlani and Impala Road area need to be
considered. Focus should be on habitat preservation, not
species.
There are KNOWN Aloe simii populations in the proposed
routes.
Andrew Rossack,
Comments ,E-mailed
The Mpumalanga Biodiversity Conservation
Plan, POSA, SARCA, SABAP1 and SABAP2
data was consulted in the preliminary scoping
assessment which was based mainly on a
desktop survey as well as a single site
visitation.
The protected area expansion areas will be
considered as well as the presence of any
existing bird sanctuaries or nature reserves
within the final ecological report.
The presence (possibly destroyed) of Aloe
simii populations in the Phumlani and Impala
Road area need to be considered.
In relation to the Aloe simii populations, he
consultant observed several specimens along
a valley bottom wetland within White River
during a recent survey. We would appreciate
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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The assessment must be based on sound data collection,
not subjective opinion and species lists.
The assessment must be repeatable
The assessment must conform to the MTPA guidelines for
ecological assessments.
It is suggested that past EIA ecological and wetland studies
from the area, e.g. Pumlani and Fiddlewood, should be
consulted and incorporated.
any additional information regarding the
Critically Endangered Aloe simii populations.
This information will be confidential and only
forwarded to Professor Leslie Brown who
undertook the vegetation aspect and
highlighted within the final sensitivity map.
The assessments are based on sound data
collection, not subjective opinion and species
lists and are repeatable. The proposed route
was analysed prior to the field survey for
available literature and database information
pertaining to the vegetation and threatened
species of the study area. The Braun-Blanquet
survey technique to describe plant
communities as ecological units was used for
this study. It allows for the mapping of
vegetation and the comparison of the data with
similar studies in the area.
Previous EIA ecological and wetland studies
from the area, e.g. Pumlani and Fiddlewood,
will be consulted and incorporated if
information is readily available. The ecological
specialist study will include the likely habitat
fragmentation and provide mitigation
measures for the road.
It is acknowledged that there is a high reptile
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
8 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
The ecological specialist study must include the likely
habitat fragmentation and provide mitigation measures.
Various Red List species such as rock python and plated
lizards are known to occur in the area.
diversity between Nelspruit and White River
with 81 species recorded during the South
African Conservation Assessment (SARCA).
This will be further assessed in the EIAR-
phase biodiversity study.
Judy De Villiers has read through the draft scoping report,
and has already found a problem with section 5.5.6, with
regards to the amphibians.
In the report it is mention that NO THREATENED FROG
SPECIES were found.
I live next to the wetland North of White River where the
proposed road must run through the wetland. I live next to
the White River Bird Sanctuary, and have found the Spotted
Shovell Nose Frog on a few occasions. This frog is listed as
to only be found in the Northern Region of the KwaZulu
Natal Coastline, but yet has found its way to White River. I
have e-mail Professor Louis Du Preez of the North West
University who is the writer of the book Frogs & Frogging in
South Africa (STRUIK), to notify him that I have found this
rare and sensitive frog in my garden. I attach to my mail
photos of the last frog I found in my swimming pool in
February 2013.
Judy De Villiers,
Comments E-mailed
The frog has been identified as a Mottle
Shovel-nosed Frog (Hemisus guttatus) by
Prof. Louis du Preez and ecological specialist.
This is the first record of the species in White
River with the nearest locality being
approximately 180 km away around Piet
Retief.
The biodiversity report will be amended to
include this red listed species in the report.
The wetland area was identified as highly
sensitive due to the presence of the red listed
Gunnera perpensa as well as the ecological
and hydrological functions of the wetland. The
wetland has been heavily impacted on by
recent high density residential developments
as well as small-scale agricultural activities
(ploughing of soils) within the seasonally
inundated zone.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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I also find no mention of the fact that the road on the
Northern side of White River is going to run next to the
White River Bird Sanctuary.
If you could please pass this information on to the person
who is doing the further Ecological Studies.
The protected area expansion areas will be
considered as well as the presence of any
existing bird sanctuaries or nature reserves
within the final ecological report.
The response was provided by the ecological
specialist, as this information had been passed
onto him for comment.
It takes no brains to see that the proposed route through
White River Creek would carry severe consequences to
humans, plants and wildlife in the White River Nature
reserve.
Peter Doble, Comments-
Emailed
An ecological study has been identified as one
of the studies to be undertaken for this study
and the specialist will provide
recommendations based on his finding during
the EIA phase.
TECHNICAL ISSUES
This route would destroy a significant amount of irrigable,
valuable, productive farm land, which in a country which is
battling to produce enough food, is not acceptable.
Negative Impact on wetlands and wildlife.
Farmer's fields will be physically cut into smaller un-
economical parcels that will result in destruction of irrigable,
usable land that will be in excess of the actual land
destroyed by the road.
The original, declared servitude runs through an area that
Mark Attwood,
Comments, Emailed
The EIA study will look at all possible impacts
that may be caused by the proposed project
and mitigation measures will be proposed in
order to ensure that the environment is
protected.
All alignment alternatives have been designed
to limit the impact of fragmentation of land to
the minimum. Agricultural and soils potential
study is being undertaken and a more detailed
study will be undertaken in the EIA phase and
mitigation will be proposed.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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is poor farm land, that has no irrigation, and therefore a far
smaller amount of arable land will be destroyed. The fact
that the Msholozi illegal settlement will have to be disrupted
is a problem, but how can an illegal settlement disrupt the
legal, planned law abiding processes of the country?
Property values in the whole valley will be negatively
affected by the "Alternative one" running through the valley.
We carefully investigated these sorts of servitudes before
buying our land, and find it un-acceptable that a road can
now be moved right onto our doorstep because of an illegal
settlement that has sprung up in the past 2 years, in the
middle of your planned, declared route.
There are many servitudes and rights-of ways across
different farms in the Heidelberg valley and these would all
need to be carefully considered to make sure nobody is
accidentally cut-off.
The sand river irrigation scheme would be seriously and
negatively impacted by the road. The scheme has
registered servitudes; surely you cannot just disrupt these
servitudes.
What will happen if a truck carrying hazardous chemicals
crashes off this road and the chemicals are spilled into the
canal and are inadvertently pumped onto hundreds of
hectares of farm land, permanently contaminating the land?
Will SANRAL pay for this?
The existing servitude for the P166 is the shortest route
with the slowest gradient and makes the most sense from a
Due to the issues associated with the P166
servitude in the White River area as identified
by specialists and various stakeholders alike, a
new alternative has been created (to be fully
assessed in the EIAR phase of the project) in
the White River area as a way of potentially
mitigating environmental impacts associated
with the P166 servitude in the White River
area.
It should be noted that for environmental
reasons, the Phumlani Alternative 1 has been
discarded and will no longer form part of the
project scope as investigated in the EIAR
phase. As a result, social-related issues of a
potential loss of property value in the
Heidelberg value are unlikely to materialise
due to the proposed road development.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
11 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
road point of view.
Increased run-off during periods of high rainfall resulting in
erosion and further loss of farmland.
I hereby notify yourselves that I am an interested and
Affected Party
I object strongly to the proposed road running through the
Heidelberg Valley for the following reasons:
Additional Noise pollution to our area
Additional pollution from vehicles and industry which may
develop as a result of the road
Detrimental effects on our natural wetland systems which
we have been trying so hard to conserve
Disruption to our wildlife in the area, it has only been
recently that we are starting to see an increase in endemic
species such as Grey Rhebok, Porcupines, Mountain
Reedbuck, jackal, Cape Hares, Striped Polecats and
Bushpig.
The road will bring with it criminal elements to the area as
with all other areas flanked by a major road
The pollution will disrupt crops and live stock which are
grown and reared on organic principles by introducing
foreign chemicals into the environment
Lloyd Turck, Managing
Member, Medical
Fundamentals,
Comments, Emailed
In the context of noise-related impacts one of
the most sensitive receptors are the noise-
sensitive residential areas, and these areas
will be the main focus of the noise impact
assessment study in the EIAR phase. The
noise levels from the projected traffic volume
will then be compared with the prevailing
ambient noise level to determine the intrusion
level at the different noise sensitive areas and
mitigation measures will be suggested.
Air pollution controls will be provided as
mitigation measures in the EIA phase.
The potential impact of the proposed road on
wetlands has been assessed in the scoping-
phase wetland report, and will be further
refined in the EIAR-phase study.
Agricultural and soils potential study is being
undertaken and, more detailed study will be
undertaken in the EIA phase and mitigation will
be proposed.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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The risk of major Hazmat spills increases exponentially
further threatening our conserved areas and our live stock
The proposed route would also reduce the production
capacity of the area significantly, which based on the
current food status in the country is detrimental to the
economy.
I join my fellow residents of the valley in stating that the
original route through the Msholozi area should be followed
as this was earmarked at the beginning of the project, the
area was illegally settled and the occupants were officially
and legally served eviction notices by the state, it is now the
state‟s responsibility at state expense to relocate these
settlers and route the P166 through its original route. I am
confident that should the P166 still route through the
Heidelberg Valley the residents will band together and take
up legal action.
I am not willing to have my home, my view and my
livelihood ruined for the sake of government convenience.
It should be noted that for environmental
reasons, the Phumlani Alternative 1 that runs
through the Heidelberg Valley has been
discarded and will no longer form part of the
project scope as investigated in the EIAR
phase. As a result, social-related and
biodiversity-realted issues as highlighted
above in the Heidelberg value are unlikely to
materialise due to the proposed road
development.
I am a resident at 22 Tafelberg Street, Colts Hill, in White
River and am concerned about the considerable increase in
traffic noise from the road which will pass right through an
established residential area.
I know that road noise is a consideration for any such
developments and in this case it will have a disastrous
impact. The enormously negative impact this will have on
the future value of my property also cannot be
underestimated.
Neil Malherbe,
Headmaster Penryn
Preparatory School and
Resident of White River
Comments Emailed
In the context of noise-related impacts one of
the most sensitive receptors are the noise-
sensitive residential areas, and these areas
will be the main focus of the noise impact
assessment study in the EIAR phase.
The noise levels from the projected traffic
volume will then be compared with the
prevailing ambient noise level to determine the
intrusion level at the different noise sensitive
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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It concerns me too that the proposed road will pass through
a wetland area, which is a space of natural beauty, with
numbers of species of wildlife which depend on the area for
their survival.
areas and mitigation measures will be
suggested.
The socio-economic study has identified the
potential negative effect of the road through
the White River area on property value. This
will be further assessed in the EIAR-phase
social study.
The sensitivity and potential impact of the
proposed road on the wetland running through
White River has been identified as a key issue,
to be assessed further by the EIAR-phase
wetland study.
.
It is interesting that three alternatives are being proposed
because of the informal housing which has sprung up near
the Rocky‟s Drift area, yet no others have yet been
proposed for the White River valley, where the road would
be most detrimental.
It is my suggestion that an alternative route be found further
to the east, which would allow a bypass of the White
River/Nelspruit urban area.
Neil Malherbe,
headmaster Penryn
Preparatory School and
Resident of White river
Comments Emailed
Due to the issues associated with the P166
servitude in the White River area as identified
by specialists and various stakeholders alike, a
new alternative has been created (to be fully
assessed in the EIAR phase of the project) in
the White River area as a way of potentially
mitigating environmental impacts associated
with the P166 servitude in the White River
area.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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The proposed route down the valley in White River through
the "Bird Sanctuary" passes right by my two town houses in
Impala Street: the restricted width of the valley and the
standard road reserve of 80 m would result in the road
being right up against my property's boundary;
The noise, vehicle fumes and general traffic disturbances
would be extremely unpleasant and would also greatly
reduce the value of these properties, should I wish to sell;
The ground structure in this valley is certainly quite
unsuitable to any road construction;
The valley is a natural storm water drainage system: any
road construction here would be extremely dangerous and
unwise, especially should we have a repeat of the type of
storms experienced in the last two years;
More importantly, I cannot see the justification of routing
this road through White River from the West: it would make
more sense to take the expected heavy traffic on the East of
White River, along the Spioenkop road, down through to
Plaston, past the KMI Airport and then on to Karino to join
A R McQueen,
Comments, Emailed
Due to the issues associated with the P166
servitude in the White River area as identified
by specialists and various stakeholders alike, a
new alternative has been created (to be fully
assessed in the EIAR phase of the project) in
the White River area as a way of potentially
mitigating environmental impacts associated
with the P166 servitude in the White River
area.
The socio-economic study has identified the
potential negative effect of the road through
the White River area on property value. This
will be further assessed in the EIAR-phase
social study
The design of the road in this area if this part
of the route was authorised for development,
SANRAL would need to take into account
stormwater inputs and drainage issues, as well
as the suitability of founding material. It should
be noted that there are a number of
biodiversity and social-related issues
associated with the development of the road
through the White River wetland which need to
be further assessed in the EIAR phase.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA
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the N4; it would also serve to give access to important
industrial zones envisaged in this area;
It would be much wiser to upgrade the present R40 and a
lot less expensive: this road, in any case, is in urgent need
of upgrading;
The traffic on the R40 originates and terminates mostly from
either White River and surroundings or from traffic that
needed to do some business in White River even if it did
come from Hazyview; this does not include the heavy
vehicles currently coming from Phalaborwa
Since this latter traffic (the heavy trucks) will continue and
need the road bypassing White River, all efforts should be
made to upgrade the Plaston alternative as soon as
possible;
I do not believe the traffic between Hazyview and Barberton
is so great that it needs a new, expensive road such as the
P-166; rather the direct connection between White River
and Nelspruit is far more important; the relatively little tourist
traffic this road would take is also not a justification for the
road as most of the tourists would, in any case, want to stop
in either Nelspruit or White River.
I cannot see the residents of White River using the P-166 in
preference to the R40 as it would mean going out of your
way to join the road and to exit it to go to town: the route is
only advantageous for out of town business;
The routing of the P-166 would exclude trade for both
The project need and desirability under
Section 1.2 of the scoping report addresses
the issue of why R40 cannot be upgraded in
detail.
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Nelspruit and White River businesses: not a good thing.
At the end of the day, I simply cannot see the justification
for this road on its presented suggested route. Yes, such a
road would be progressive but only if it directs heavy vehicle
traffic away from the towns and if the present road R40
were seriously upgraded. Are you aware that there are,
currently, intersections on this R40 between the outskirts
only of Nelspruit and White River? Some of these will soon
be so busy that they will be causing extremely dangerous
crossings.
Please take a note of these objections: they are all very
real!!
Need and Desirability
I find this section to be, at best, very sketchy, with a lack of
any indicators of need or desirability.
Please explain the significance of reference to the N2 in this
section? “In addition the R40 link to the other National Road
2 (N2) route is important as it is the main corridor from the
Richards Bay and Durban harbours.”
Please explain how the P166 will “relieve future N4 traffic
congestion”. This statement makes no sense as the
proposed P166 is a north-south alignment and the N4 is
east-west.
The Need and Desirability seems to be loosely based on
highly subjective opinion and contains no factual data at all.
Andrew Rossack,
Comments, E-mailed
The need and desirability section 1.2 in the
scoping report have addressed the issue in
details
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani were allegedly
“illegally” settled. Nonetheless a housing
development & community now exists within
certain parts of the servitude and wider area
(in which alternatives to the existing servitude
in the Msholozi area are being considered)
and as such the potential social impact of the
proposed road on this community needs to be
considered by this EIA.
The Phumlani Alternatives were introduced
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Furthermore it appears to contain numerous errors.
Based on the provided Need and Desirability, there is
clearly no need for the proposed road.
No evidence was presented of there being significant traffic
from the Hazyview area desiring to travel to Barberton.
The need for a direct route from “the south” to the north of
White River for tourism and goods transport via Badplaas /
Barberton is perplexing. The need for tourism is from KMIA
(airport) to Hazyview and destinations north. The need for
heavy transport is from Carolina / Machadodorp on the N4,
or from Hazyview to the N4 travelling east / west.
The planned route for the P166 undermines potential to
create an industrial zone near KMIA and to the east of
White River.
The planned route does not take into account existing
authorisations for business and residential developments in
the Karino area of White River – to the east.
Phumlani alternative
a. The report does not mention that the Msholozi settlement
is likely to be an illegal settlement (according to papers and
statements from Public Works and the municipality, and
lack of any EIA or authorisation).
The report and presentation at the public meetings indicate
a reluctance to move or alter the illegal informal
during scoping in order to allow for an
alternative solution to (mitigation for) the social
impacts relating to the relocation of a number
of households from the servitude and other
social issues such as the bisecting of a
community by a high-speed road. It is
recognised that the alternatives to the
servitude would be associated with other
environmental issues, especially social and
agricultural potential issues. In comparatively
assessing alternatives, all environmental and
technical parameters have been taken into
account. From an environmental perspective
Phumlani Alternatives 1 and 3 have been ruled
out and will not be considered in the EIAR
phase of the project. This means that the
existing servitude and Phumlani Alternative 2
will be assessed in greater detail in the EIA.
It should be noted that due to environmental
issues Phumlani Alternative 1 has been
discarded and will not be considered in the
EIR phase.
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settlements, established in the servitude, and this is the
motivation for alternative routes. The provided alternatives
are through unproclaimed areas of high productivity
agriculture and on land where owners are existing
employers, rate and tax payers and whose industry is food
security and export. This appears to be unjust and morally
indefensible.
Phumlani alternative 1 is directed through an area of
irreplaceable habitat (see later regarding ecology). This
area was proposed and accepted in an RoD as an offset for
wetland and biodiversity loss caused by the Phumlani
development. (The RoD was appealed, but the MEC has
failed to address the appeal). I would like to know if this
assessment is able to „override‟ the past EIA‟s in terms of
this and other set aside areas.
Other alternatives
The report and proposals contain very little in the way of
alternatives. I do not feel that alternatives to small sections
of the road are a proper alternative. Does this meet the
requirements of NEMA? The entire routing should be
examined for alternatives, both on the east and west side of
the R40.
Alternative activities should also be considered. It is
suggested that the improvement of intersections and fly-
over‟s on the R40 would achieve considerable better traffic
flow and traffic safety.
Through the conducting of the P166 EIA the
proponent SANRAL has stated that the
authorisation of a route based on the existing
planning is being sought. However alternatives
have been identified in areas of identified
environmental sensitivity in order to allow for
the mitigation of significant environmental
issues associated with the existing servitude.
The identification of issues and impacts is an
iterative process and as such so is the creation
of alternatives – as a result of issues raised in
the scoping-phase public participation process;
a new alternative, the White River North
Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
The application for environmental authorisation
is for confirmation of an existing planning and
partial declaration (“servitude”), whilst
considering adjustments for specific identified
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Scoping study
The question of tolling needs to be considered in the
assessment. It is well documented from other toll roads in
the country that heavy vehicles often choose to avoid the
toll roads. Thus if tolling is applied, it is possible the road will
not carry the traffic intended. The tolling options need to be
modelled and included in the risks and need and desirability
sections. The current situation regarding the transport of
stone aggregate for the Spring Grove Dam on the N3/ R103
between Howick and Mooiriver has relevance here.
The history and development of White River needs to be
considered in context of the proposed routing. There has
been comment from municipality in the past that the wetland
sections would never be suitable for a road – this may have
affected decision making and subsequent township
development. Dating back at least 10 years, efforts have
been made by various parties, through the Mpumalanga
Wetland Forum, to have the servitude through the wetlands
de-proclaimed. The Department of Water Affairs (Then
DWAF, now DWA) commented in this connection, that the
construction of the bypass would never be allowed to go
ahead through the wetlands.
environmental concerns. The purpose of the
route, route alternatives and upgrading of R40
are all addressed in the need and desirability
section.
Tolling is a funding consideration, which will
only become relevant once construction of the
route is being considered. Issues related to
possible toll avoidance will be part of the
considerations at that stage. The current
application is limited to definition of an
acceptable route and accurate determination
of the road reserve required for the road.
Need and desirability has been expanded in
the document, including issues raised. The
need for both R40 and P166 is confirmed
therein. Traffic between Nelspruit and White
River can make use of P166 via the
interchanges proposed at all major road
crossings. Upgrading of connecting roads may
be considered during detail design, but does
not affect need for P166 route in principle.
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Fatal Flaws
Access to road. Should the road be constructed as
proposed, it is felt that it is unlikely to alleviate any of the
existing traffic congestion.
This is for the following reasons:
i. (from a local view point it seems that) Traffic congestion is
largely time sensitive (mornings and evenings) and much of
this traffic is short distance within town (mostly school
related) or between the towns (White River, Kanyamazane,
Nelspruit). It is unlikely that anyone wishing to travel north
from Nelspruit to White River will travel south first to link into
the proposed P166.
ii. The current linkage to the N4 bypass is through a maze
of traffic circles and poorly utilized.
iii. The internal road network is congested prior to linking in
with any part of the proposed P166. The access roads to
the proposed P166 are likely to be inadequate for
reasonable access or preference over the existing R40.
Without considerable road development and improvement
within White River and Nelspruit, it is likely that the P166
would never carry the envisaged traffic. There has been no
evidence presented to suggest otherwise.
Landscape
It is likely that the development of the P166 would destroy
much of the existing landscape. Many landowners
purchased and developed in the peace and tranquillity
A number of I&APs have raised visual-related
issues. This comment refers specifically to the
potential impact of the proposed road on the
„sense of place‟ in the area. In order to
address these concerns, a visual impact
assessment study will be undertaken in the
EIAR phase of the project.
The conducting of an integrated transport
assessment is being proposed to the applicant
to consider the issues relating to traffic flows
and potential growth / change in traffic streams
in the future. This will examine issues relating
to the wider area, as raised by this comment.
The existing road proclamation covers a short
section at the southern start of the project, the
completed section between the old N4 and the
new N4 bypass, as well as the full section from
Rocky‟s Drift up to the northern end of the
project. The transport and economic study will
be conducted in the EIA. This should be
adequate to cover the need for this route.
Development and needs of the region, as well
as alternatives, have been addressed in the
expanded “Needs and Desirability” section.
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offered in the agricultural environment. Many rely on their
properties for income. There would be no possible
compensation for the changes the P166 would make on
their enjoyment of their land or their ability to continue
farming etc.
Access and existing servitudes to various properties will be
destroyed or made inaccessible in some sections of the
proposed P166. These are not considered, but must be
extensively investigated.
Proposals
The principals of NEMA must be addressed and considered
in their entirety in the assessment. This is in addition to the
regulations. All mitigations and options MUST meet these
principals. The EIA must endeavour to record the entire
baseline environment (all aspects) in a repeatable method.
The proposed routing of the P166 appears to be guided by
some short existing servitudes, and not the development or
needs of the region. The correct need determination and
siting should be undertaken through and EMF and SEF.
Alternatives to the east of the R40 should be fully
considered and included in the EIA.
All specialist and EAP‟s CV‟s must be included in the
scoping and EIA documents.
Access to all affected properties will be
reinstated or alternatively compensated.
The EIA 2010 regulations guidelines are being
used to undertake this study.
CV‟s will be included as an appendix to the
Draft final scoping report.
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Since WESSA has had no feedback regarding other areas,
such as the Maggiesdal alternatives, WESSA has no
comment to make on these issues.
Regarding Umsholozi, and the alternatives discussed, it is
our understanding that the entire township is illegal and
that an eviction order has been granted, but is unlikely to
be enforced. Therefore WESSA has no view on which is
the best alternative.
Regarding the alignment of the P166 through White River,
SANRAL should reconsider its designated route. Further it
should not try to bend environmental legislation in its favour
by failing to be totally honest about the route along the
wetland and its effect on that wetland. It is accepted that a
by-pass for White River has potential benefit but not as
currently proposed.
The route was planned in the 1980s. At the time there was
no environmental legislation in place, covering the
protection of wetlands and in any case the route was
outside White River, rather than through it. The wetland
area was once declared as a bird sanctuary by the then
White River authority.
Simon Evered, Wildlife
and Environment
Society of South Africa
(WESSA) Lowveld
Region, Comments
Emailed
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani were allegedly
“illegally” settled. Nonetheless a housing
development & community now exists within
certain parts of the servitude and wider area
(in which alternatives to the existing servitude
in the Msholozi area are being considered) and
as such the potential social impact of the
proposed road on this community needs to be
considered by this EIA.
The potential significant impact of the
proposed road on the wetland in the White
River area is acknowledged, and will be further
assessed in the EIAR-phase wetland
assessment.
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The road was planned as a by-pass, and therefore should
not go THROUGH the town now that the town has grown.
According to feedback provided by the
applicant on this comment “Bypass” is
somewhat of a misnomer, as it is not
necessarily intended to bypass a town like
White River. The issue really is to define a
mobility road along a corridor that is viable
(technically and environmentally) and
affordable, and because a route through
already built-up areas is in most cases neither
environmentally nor financially viable, a route
is often defined around the developed area.
That is why the P166 planning was done pro-
actively in the 1980‟s, to define a route that
would be viable and could be implemented
when required, and this planning was intended
to guide and inform development accordingly.
If the route is moved northwards, the same
“bypass” argument may likewise be raised
against such realignment in 20 or 30 years
time. That is the nature of development – it
targets new areas that become attractive as
circumstances change, and development will
therefore over time straddle any route. Many
examples exist where mobility roads were
planned and eventually implemented through
erstwhile rural or semi-rural areas that have
since been fully developed all along the route
(e.g. N1 through eastern areas of Pretoria or
the N1 Johannesburg ring road, and more
recently the N1 at Polokwane). The Mbombela
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Residential dwellings along Impala Road are close to the
proposed alignment, some actually adjoining. This
includes the new township in Kingsview Extension, where
homes will be bordering the servitude.
There will therefore be a huge noise impact all along the
2km of wetland that SANRAL plans to invade. This is
unacceptable for residential townships.
Two additional townships are planned for the north west
side of the wetland valley, each of which will effectively
adjoin the planned route.
Property values will be seriously affected negatively all
along Impala Road and in the Kings view Extension. This
is in spite of the fact that the existing plan has been known
about for some time.
NEMA and the regulations explain what conditions and
measures must be considered when CROSSING a
wetland. Nowhere in any environmental legislation is the
concept of routing a road ALONG a wetland, as SANRAL
seem to think is acceptable, considered. SANRAL is being
Spatial Development Framework, which
includes White River, has recognised and
accepted the P166 concept and proposed
alignment over many years, and defined the
spatial planning accordingly.
Residential development abutting any major
route will be subject to noise impacts. As the
route has been public knowledge for many
years, this factor should have been taken into
consideration in developments like Kingsview
Extension. Noise mitigation will be considered
during detail design of the road. THE EIAR-
phase noise study will consider the potential
impact of the proposed road on the noise-
sensitive receptors in the White River area.
The socio-economic study has identified the
potential negative effect of the road through
the White River area on property value. This
will be further assessed in the EIAR-phase
social study
The potential significance of the impacts due to
the proposed alignment of the P166 road
longitudinally through the wetland in White
River has been raised in the scoping-phase
wetlands study, and it is acknowledged that
roads that traverse wetlands longitudinally
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stubborn in trying to run the road "alongside the wetland" in
order to preserve their paid-for servitude and to save
themselves work in a redesign.
SANRAL admits to a required servitude of 80 metres to
build such a road, which will eventually have four lanes.
They also say this can be reduced to 60 metres in special
circumstances. Since the valley is not more than 150
metres wide, the building of a road even of 60 metres width
“along one side” will reach the stream at the bottom of the
valley, considering that a large amount of fill will be
required to level the roadway itself, and construction
vehicles will need room the operate. Thus all wetland
features on the south east side including the valley bottom,
will be destroyed.
It is accepted that at the lower end of the valley the wetland
has been considerably compromised by micro farming
activities, presumably by residents of the new township.
This is NOT the case for the remainder.
From a purely ecological point of view, there exists in the
wetland a rare species of shovelnose toad, and rare Aloe
simii exists there. These alone are good reasons to
reconsider the alignment.
rather than crossing them perpendicularly are
likely to be associated with much greater
impacts. This issue will be further assessed in
the EIAR-phase surface water study, and is
one of the considerations in the creation of a
new alternative to this section of the existing
servitude in the White River area.
The actual footprint of the road will be
determined by the vertical and horizontal
alignment of the road as well as the width of
the road. At this stage the ultimate design is to
provide for a 6 lane divided road. This can
however be mitigated by special designs
which we believe will need to be provided in
due process and as required.
The presence of these 2 species is
acknowledged and has been considered by
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SANRAL must therefore recognize that the road as
planned is entirely out of date and environmentally
unacceptable, in spite of their servitude and expropriations
in place. Another route must be considered.
It is therefore counter-proposed that the road be re-aligned
further to the north-west, past all existing smallholding and
through forest land next to Uplands. It is accepted there is
water there and this must be properly studied to mitigate
impacts and decide the best route.
The Hazyview to Barberton kind of thinking is also out of
date. Traffic coming from the northern Lowveld mostly
wants to get onto the N4 and go to Maputo. It is thus also
counter-proposed that a White River by-pass be routed to
the east of the town, using existing roads such as the short
section connecting the Karula-Plaston road to the Numbi
the biodiversity study. Biodiversity issues
relating to the wetland were one of the key
factors in the consideration and creation of a
route alternative to the existing servitude in the
White River area.
Through the conducting of the P166 EIA the
proponent SANRAL has stated that the
authorisation of a route based on the existing
planning is being sought. However alternatives
have been identified in areas of identified
environmental sensitivity in order to allow for
the mitigation of significant environmental
issues associated with the existing servitude.
The identification of issues and impacts is an
iterative process and as such so is the creation
of alternatives – as a result of issues raised in
the scoping-phase public participation process;
a new alternative, the White River North
Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Please refer to response above regarding
route planning.
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section of the R538. Thereafter the R538 to Karino can be
widened and straightened to the required standard.
WESSA thus insists that a full ecological examination of the
wetland through town and any other water bearing land, be
carried out without bias to the SANRAL plan. Further traffic
studies must be updated so that the destinations of traffic
through White River are understood. I can assure you that
Barberton is not high on that list. The noise impact on those
homes adjoining the existing alignment must be fully
reported in the scoping report and the residents so affected
should be advised of their future expectations.
An integrated transport study is being
proposed to address the traffic flow issues
relating to the proposed road and the future
traffic flow needs. The R538 as an alternative
has been discussed in the „Needs and
Desirability” section of the Draft Final Scoping
Report.
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A major concern for me is the process by which this
recommendation was reached, as well as the
recommendation itself. The previous proposal to follow the
servitude was made available before the scheduled meeting
at Bundu Lodge, and many landowners in the Heidelberg
valley expected the impact to be relatively small for them.
No mention was made of a road to go through the actual
valley. So many landowners did not attend the meeting as
they regarded themselves as being not greatly affected.
It seems to me that a recommendation was reached that the
Heidelberg Valley route was to be preferred, and that further
“alternatives” were designed in such a way as to justify that
recommendation. So they are not really alternatives at all.
This is at best disingenuous. To give an example: part of
alternative 3 is shown cutting in a straight line through a
number of smallholdings from the R537 Sabie road thus
exaggerating the impact there. If the route south from the
servitude between Kosmos Macadamia and the complex
opposite on the R537 Sabie road were to follow a gentle
arc, to the point where the proposed route continues as a
long sweeping arc around the koppie to the Rocky Drift -
Heidelberg road, the impact is dramatically reduced. It
would appear that 4 or landowners would be affected. The
impact on the number of farms, and property owners would
appear to be fewer than the Heidelberg Valley route should
this small deviation be followed.
Of course this does not include illegally occupied land. But
why should property owners in Heidelberg Valley suffer
Dave Goodwin ,
Comments, Emailed
Phumlani Alternative 1 affects the Heidelberg
Valley. The Phumlani alternatives were
introduced early in the scoping process, as a
result of potentially significant issues raised by
certain project team specialists. These were
then scoped by all of the specialists as part of
their scoping-phase specialist studies, and
these alternatives were included in the draft
scoping report that was released prior to the
meetings alluded to.
The comparative assessment of alternatives
has been undertaken by considering inputs
from all of the different specialist disciplines in
terms of a preferred alternative from their
specialist perspective. Technical
considerations have also been taken into
account. In the case of the Phumlani
alternatives 1 and 3 that traverse the
Heidelberg valley and the smallholdings
respectively have been ruled out from an
environmental perspective by the proponent
and will not be taken further into the EIR phase
of the project.
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani settlement
were allegedly “illegally” settled. Nonetheless a
housing development & community now exists
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when they have followed correct legal procedures,
purchased their properties, and invested in the
infrastructure and improvements to these properties and
paid levies and municipality rates for many years to the
benefit of the wider community?
Alternative 3 skirts a large, established, growing industrial
area (Rocky Drift) and then follows an existing peri urban
corridor for a significant part of the route. A relatively small
amount of isolated agricultural land would be affected, and
this land is so positioned that it is likely to become part of
the peri urban corridor in the not too distant future. One
would expect that this alternative road would not be out of
place as part of the infrastructure and development of an
industrial and peri urban area: the fact that the original
proposed route followed a series of established or proposed
townships, or informal settlements, was used previously to
justify its close proximity to these. The impact of this
alternative should be reassessed in the context of the
industrial and peri urban environment and development,
and deviations to the shown route explored.
There are many other issues that come to mind -
Proposed alternative 1 will destroy a large area of existing
highly productive agricultural land, far more than either of
the two other alternatives. In addition, it would also fragment
much land so as to become unviable agricultural holdings.
It will impact badly on wildlife habitat and natural wetlands,
which are particularly precious as they are so close to urban
within certain parts of the servitude and wider
area (in which alternatives to the existing
servitude in the Msholozi area are being
considered) and as such the potential social
impact of the proposed road on this community
needs to be considered by this EIA and
compared with the impacts of the alternative
alignments. As stated above, the Phumlani
Alternative 1 has been discarded.
The current EIA aims to find a solution that is
as environmentally sustainable as possible,
taking into account the impact on all affected
parties, including factors such as capital
expenditure into properties, and their
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and industrial areas.
There will be no benefit to the residents of the valley, in fact
it would badly affect the environment, with increased noise
and air pollution, and would also affect the property values
of those who have paid for their land and not illegally
occupied it. It would appear that more property owners will
be impacted by alternative 1 than by either of the other
alternatives.
The proposed “alternative” routes, along with the original
servitude route, should be revisited in an open, transparent
and inclusive forum; with a view to assessing their viability
as alternatives, not merely manipulated as justification for a
suspect decision that appears to have been already made.
associated value.
The social study has considered such factors
in the comparative assessment of the
Phumlani alternatives. These factors have also
been taken into account in the technical
evaluation of the alternative by the proponent –
these factors have contributed to this
alternative being ruled out from an
environmental perspective entailing that it will
not be taken further in the EIR phase of the
project.
This EIA has attempted to comparatively
assess alternatives in an equitable and fair
manner that takes all environmental and other
factors into account. For environmental
reasons two alternatives (Phumlani Alternative
1 & 3) have been ruled out for consideration in
the EIR phase of the project.
We reside at Mount Anderson Street, W/River, & the
proposed alignment will be directly adjacent to our
complex.
The route will go through a wetland area.
The current sense of place would be disturbed.
Leandri Joubert,
Comments &
Registration form
Emailed
The potential impact of the road on wetlands
has been scoped in the wetland study, and a
number of potential impacts have been
identified. These impacts will be further
assessed in the EIR-phase wetland study.
A number of I&APs have raised visual-related
issues. This comment refers specifically to the
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potential impact of the proposed road on the
„sense of place‟ in the area. In order to address
these concerns, a visual impact assessment
study will be undertaken in the EIAR phase of
the project
Effect on water source (borehole).
Safety & security, noise pollution and wild life in the area.
Is this project economically viable – most traffic on R40 are
commuters working in Nelspruit.
Route & number of affected properties.
Linda Liversage,
Comments and
Registration form
Emailed
Residential development abutting any major
route is subject to noise impacts, but the route
has been public knowledge for many years.
Noise study has been undertaken and detailed
assessment will be undertaken during the EIA
phase.
The socio-economic study has identified the
potential negative effect of the road through
the White River area on property value and
other social issues such as safety and security.
This will be further assessed in the EIAR-
phase social study
An integrated transport study is being
proposed in order to examine transport-related
issues regarding the proposed route and how it
relates to existing arterial routes such as the
R40 road
I wish to object to the proposed route in its entirety and
suggest the plan is anachronistic, unnecessary and ill-
considered. I would submit that the whole plan be dismissed
as a waste of time and public money and that an inter-
departmental think tank be established to look at the best
Peter Doble, Comments
E-mailed
The need for the route, and the alternative to
upgrade R538, have been addressed in the
updated “Needs and Desirability”‟ section of
the Draft Final Scoping Report. An integrated
transport study is proposed in order to address
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way of meeting the challenges of economic growth,
transport management, traffic volumes for the future.
I would further suggest that more time and effort goes into
reinforcing, redefining and developing the current road
systems than spending vast sums on parallel routes which,
in current form, will totally destroy and disrupt the
communities on which they encroach.
There is absolutely no evidence that a new north/south road
is required and it should be incumbent on SANRAL and the
national and provincial departments of roads and transport
to conclusively prove that a case exists before even
allocating funds or going through the public participation
process.
As outlined in the White River Residents Association
response, with which I concur, there is no actual or
economic reason for the link between Hazyview and
Barberton. The redeveloped Port of Maputo is the entrepot
of choice for the northern hinterland and has been
championed by Mathews Phosa through the MCLI. Most
major transport is diverting to the north of White River to
Karino and the N4 eastbound. The pressing issues are the
misuse of smaller provincial roads and the future congestion
of the N4 especially at the Crocodile Gorge. There is no
economic or certainly environmental benefit to linking with
Richards Bay and Durban.
The effect of a north/south bypass – in any form close to
the traffic flow-related issues that have been
raised.
A social study has been undertaken which
highlights issues related the potential
presence of an arterial road through the White
River area. These issues will be further
investigated in the EIAR-phase social study
and mitigation measures will be provided if
relevant.
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habitation - will be devastating to White River and its
population, fragmenting the community and ruining its
surroundings.
Having lived in Europe where traffic volumes hugely exceed
South Africa, it has proved obvious that increasing roads
and their capacity simply breed more volume and greater
problems. The human cost to mental and physical health is
incalculable.
The noise factor and stress levels have not in my opinion
been addressed in the slightest, particularly as there is
nothing remotely comparable in the ambient environment.
While the route(s) through the illegal township of Msholozi
effectively dismisses the destruction and loss of vital
wetlands, it painfully struggles to find a way through the
morass of congested human habitation which has been
allowed to grow unchecked. If Sanral and government
authorities were so keen to preserve this planned roadway
route perhaps earlier and stronger action should have been
taken to secure it. Now it just becomes a series of
expensive twists to minimize the mess to which it has
contributed.
The proposal as it stands makes a joke of the words
“environmental impact.” It should not even have been
submitted but returned to the proposer as an affront to
intelligent planning and human dignity. It breaks every rule
The preliminary noise sensitivity analysis of the
study area was conducted on the proposed
P166 main route and its alternatives. The
results of the preliminary analysis are
discussed in section 8.2.2 of the scoping report
and more detailed assessment will be
undertaken in the EIA phase.
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in the environmental handbook.
In conclusion, I would propose that the question of the P166
in any guise should be returned to the drawing board and
re-assessed with vision and a collective responsibility to
construct a form of integrated planning without historical
fixations, financial constraints or detriment to the
established communities. Any future route which can be
justified simply needs to use the enormous external space
beyond the current area of residential development.
Notwithstanding the above, and with due consideration of
the fact that the above township is a proclaimed and
developed township for industrial purposes, residential
purposes and special uses, the aforesaid township and
development is directly and extensively affected by the said
road proposal.
Our client strongly objects to the said proposal for the route
determination as it is currently presented for the following
reasons:
Since 1988 the circumstances and conditions relating to the
property on which Stonehenge Extension 4 was proclaimed
have changed extensively to the extent that the
Mpumalanga Department of Public Works, Roads and
Transport supported the said township confirming the
expectation that the by-pass road will never be constructed.
The township was subsequently approved and proclaimed.
The erven in the township has been developed for
industrial/commercial and business related uses which
Hennie van Rensburg,
Nuplan, Comments
Emailed
SANRAL, being the applicant in this project,
have obtained legal opinion on the validity of
the existing declaration. According to this
legal opinion, the declaration of the road
across Stonehenge Extension 4 was never
rescinded and is therefore still valid. The land
owner at that time was compensated for the
impact of the declaration. Any further dispute
in this matter will need to be resolved through
legal processes.
SANRAL, being the applicant in this project,
have obtained legal opinion on the validity of
the existing declaration. According to this
legal opinion, the declaration of the road
across Stonehenge Extension 4 was never
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constitutes income generating properties of high value.
Further information obtained from the above consultants
confirmed that Stonehenge Extension 4 is extensively
affected by the current proposals, especially the proposed
Cromdale Intersection which will probably result in the
following:
i. Total ignorance of the legal status of the township
and the developed state thereof as confirmed by
the capital investment made in respect of buildings
and structures.
ii. A legal process with regard to the validity and
legality of the township as supported by the former
custodian of the then provincial road namely the
Mpumalanga Department of Public Works, Roads
and Transport.
iii. A valuation process to determine the value of the
investment made in terms of buildings,
infrastructure, improvements, including possible
relocation factors to relocate what currently
comprises the township. This may amount to a
value that will be detrimental to the present route
determination.
The alternatives as presented in the Environmental Scoping
Report dated February 2013 (Fig 4: Locality Map with
Alternatives) does not present any alternatives for the
Cromdale Intersection. In terms of the general requirement
for alternatives this requirement should also apply to the
Cromdale Intersection as it have an extensive and drastic
rescinded and is therefore still valid. The land
owner at that time was compensated for the
impact of the declaration. Any further dispute
in this matter will need to be resolved through
legal processes.
Through the conducting of the P166 EIA the
proponent SANRAL has stated that the
authorisation of a route based on the existing
planning is being sought. However alternatives
have been identified in areas of identified
environmental sensitivity in order to allow for
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financial and practical impact on Stonehenge Extension 4
and the surrounding areas. The aforesaid alone justifies the
presentation of alternatives for the said intersection in
relation to the township. Our objection is therefore also in
respect of the lack of alternatives for the Cromdale
Intersection.
According to information relating to the Cromdale
Intersection no indication is given as to how the township
will obtain access should the Cromdale Intersection
proposals be implemented. The lack of proposals in respect
of access to the township, of which ease and convenience
of accessibility, including visibility and exposure is extremely
important, is disturbing to say the least.
It cannot be expected from an affected land owner to
positively or otherwise comment or react on the route
determination process when detail lacks.
Although a route determination process is followed, it is
flawed in the following manner:
i. The route determination process is of a holistic
nature without sufficient detail as to how individual
properties are affected; meaning that in certain
instances fatal flaws may not have been identified
or determined yet. What if flaws are found in the
future?
ii. If the route has been determined and authorized by
the relevant authority, this authorization is followed
by further environmental impact assessment
the mitigation of significant environmental
issues associated with the existing servitude.
The Maggiesdal Alternative was created to
address soci-economic issues related to the
existing servitude in the sout-western part of
Mbombela. The issue relating to the potential
socio-economic impacts on Stonehenge
Extension 4 will be further assessed in the
EIAR phase study.
The identification of issues and impacts is an
iterative process and as such so is the
creation of alternatives; should fatal flaws be
identified by the further aspects of the study in
the EIAR phase, potential mitigation and ways
in which to avoid the impact will be examined
by the study.
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processes and detail designs with a view to
construction. What if fatal flaws are found then and
a re-determination of the route or sections of the
route is required? This is a very important aspect
and should not be ignored as far as it relates to the
Cromdale Intersection and Stonehenge Extension 4
as potential impacts and implications cannot be left
for future environmental impact assessment
processes relating to the design phase. It creates
an element of uncertainty.
iii. The lack of sufficient detail does not allow affected
land owners to appropriately comment on the route
determination process and to assume that detail
aspects and future implications will be dealt with in
the future where and when further opportunity for
participation and input may be too late.
You are therefore informed by this letter of presentation that
the registered owner of Erven 799, 800 and 801 is not in
support of the route determination process for the proposed
P 166-2 by-pass road as the proposals, and especially the
proposed Cromdale Intersection have an extreme impact
and implication on the properties and development
comprising Stonehenge Extension 4.
I am a resident at 22 Tafelberg Street, Colts Hill, in White
River and am concerned about the considerable increase in
traffic noise, from the road which will pass right through an
established residential area. I know that road noise is a
consideration for any such developments and in this case it
Neil Malherbe,
Comments E-mailed
The potential impact of the road on noise-
sensitive receptors has been highlighted in the
scoping-phase noise specialist report. The
White River area has been highlighted as a
noise-sensitive receptor location, and as such
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will have a disastrous impact. The enormously negative
impact this will have on the future value of my property also
cannot be underestimated. It concerns me too that the
proposed road will pass through a wetland area, which is a
space of natural beauty, with numbers of species of wildlife
which depend on the area for their survival.
Its interesting that three alternatives are being proposed
because of the informal housing which has sprung up near
the Rocky‟s Drift area, yet no others have yet been
proposed for the White River valley, where the road which
would be most detrimental.
It is my suggestion that an alternative route be found further
to the east, which would allow a bypass of the White
River/Nelspruit urban area.
will be further investigated in detail in the EIA
phase.
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Devaluation of property
This property, at the moment, is defined as an agricultural
property and the proposed road would be cutting the
property in half. Unfortunately, this property is not of a size
that can handle this and would have major drawbacks not
only in the day to day running of the property but also
should we wish to sell. A small portion of this property has
already been cut off by the present White River / Hazyview
Road and the proposed new road would be again cutting
the property but this time more drastically.
John Millett, Comments
Emailed
The study takes into account the rights of all
landowners, as well as taking into account
factors such as capital expenditure into
properties, and their associated value.
In addition, the socio-economic study has
identified the potential negative social and
economic effects of the road, in particular on
property values. This aspect will be further
assessed in the EIAR-phase social study. This
issue raised will be further investigated by the
social specialist in the EIR-phase social study.
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Environmental Impact
The proposed new road would interfere with a present
wetland and no proper research has been done as to
whether there are any endangered species either of plant
or animal.
Fire Hazard
As mentioned earlier the proposed new road would be
cutting this property in half and should a fire occur amongst
the timber both traffic and people would be in danger of
If this issue is determined to be
environmentally significant, mitigation
measures to prevent the impact will be sought.
This may include the consideration / revision of
alternatives. It should be noted that the
creation if alternatives is an iterative process
that is not necessarily restricted to the scoping
phase of the project.
It should be noted that a new alternative to the
existing servitude in the White River area has
been created, and this alternative would have
a different impact on the said property.
The scoping-phase wetland and biodiversity
studies have identified high-level impacts on
wetlands and the biodiversity contained within
them. Certain areas have been identified for
further more detailed assessment; this
includes areas of high sensitivity and in a
biodiversity context where endangered species
are known to occur.
Safety and fire issues will also be considered
in the EIAR phase and mitigation will be
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losing their lives.
When a fire breaks out in the area all the surrounding
neighbours come to help and it would mean a lot of traffic
crossing to and from on your proposed road. I am sure you
will know how dangerous fires are in this area. Very often
the helicopters are called out to help extinguish the fires
and traffic on the road could by accident have a bucket of
water thrown on them. Smoke from the fires could also be
a hazard.
Timber
This property has a fair amount of timber and this would
mean that labourers, tractors and lorries would be
constantly crossing your proposed road in order to carry
out their duties. This, of course, could be a major problem.
Should a bridge be built either over or under the proposed
road this could become a fire hazard as should the fire be
too close to the bridge the appropriate vehicles would not
be able to attempt to contain the fire which could then run
amok causing untold damage.
Run off water
One wonders what the contamination of agricultural land
would be as a result of the proposed road.
provided including those that are raised by the
I&APs.
Runoff of contaminated stormwater could be
an issue with the new road, especially if storm
water containing pollutants such as oils or
other hydrocarbons were to be discharged into
adjacent agricultural lands. The EMPr which
will be developed in the EIAR phase of the
study will specify mitigation measures relating
to stormwater issues and effect on adjacent
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Noise pollution
The amount of noise experienced from the White River /
Hazyview road is phenomenal and with the proposed new
road on the other side of the present dwellings this could
become a problem.
Safety of the present buildings
I would like to point out that my present dwelling was built
80 years ago (and has been in the family for three
generations) since when the quantity of traffic has
considerably more than doubled during that period. The
effect of the number of passing vehicles could be
responsible for a number of cracks appearing in the walls
and floor. Should the vibrations from vehicles commence
from the opposite side of the house (as per the proposed
new road) this could do immense damage to the dwelling.
Having pointed out the dangers of the route of the
proposed road I would now like to propose alternative
routes.
From looking at the map I would suggest that the proposed
road continues on the N4 and then branches off towards
Plaston onto the R538. This route could then have a flyover
agricultural land. The EMPr will specify
procedures for remediation of spills of
hazardous materials as well as for sustainable
storm water drainage.
The noise-related issues in this area are also
recognised in this area. These issues will be
further investigated in the EIAR phase
specialist studies, and potential mitigation
measures sought.
The issue of the R538 road as alternative has
been addressed in the updated “Needs and
Desirability” section of the Draft Final Scoping
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towards the KMIA airport which would be advantageous to
the tourist industry. This route is also the most direct route
to Hazyview and would be utilized by the trucks carrying
magnetite which are at present doing so much damage to
the White River district roads which were not built for this
purpose. An added advantage would be a well built road to
the Numbi gate, again an advantage for tourists and income
to the area.
Another suggestion would be for the proposed road to join
the Hazyview road at the new Casterbridge roundabout.
However, the former alternative proposed route seems to
me the most sensible one and I feel that there would be far
less objection from the local community. This is also the
shortest route to Maputo harbour which would save the
country foreign exchange from the consumption of fuel.
Report.
An integrated transport planning study has
been proposed to examine issues relating to
traffic flows and how the proposed
development will affect the baseline scenario,
and to assess whether it satisfies the future
network planning requirements of the area.
We also would like to emphasise that the route of the P166
through the northern suburbs of White River is undesirable
and unacceptable. This would create a major impact on the
wetlands and declared reserved areas of the town,
especially during the construction period. Apart from the
noise of general traffic, as a general nuisance, the
congestion on the limited access points at peak times would
be equally undesirable. The planned route is neither serving
the White River community nor far enough removed from it
to be acceptable.
We reiterate the desirability of our preferred eastern bypass
of White River, to reinstate the R538, devastated by heavy
traffic. This restoration will reinstate access to tourist lodges
Robin Clanahan, White
River Ratepayers
Association, Comments
E-mailed
The open area to the north of White River
through which the existing servitude passes
has been identified as an area of potential
impacts in a number of contexts by a number
of the EIA project team specialists, including
the biodiversity, wetland, and social specialist.
The noise-related issues in this area are also
recognised in this area. These issues will be
further investigated in the EIR phase specialist
studies, and potential mitigation measures
sought.
The R538 road as an alternative has been
addressed in the updated “Needs and
Desirability” section of the Draft Final Scoping
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in the area, which have been critically impacted by this, to
the extent of some being forced to close.
The DSR addresses alternatives as being alternatives to the
selected route within sections of the route. This is neither
the letter nor the intention of the law – alternatives to the
whole route and the necessity for the development have to
be addressed, as is acknowledged in the DST by the short
discussion on the “No Go” alternative.
Report. Alternative routes have been
addressed in the updated “Needs and
Desirability” section of the Draft Final Scoping
Report. Although it has been considered in
the draft scoping report, the No Go alternative
will be explored in further detail in the EIR
phase An integrated transport study has been
proposed in this context to examine issues
relating to traffic flows and how the proposed
development will affect the baseline scenario,
and to assess whether it satisfies the future
network planning requirements of the area.
It should be noted that due to the above-
mentioned environmental issues associated
with the existing servitude through the White
River area, have resulted in the creation of an
alternative to the north of White River, to be
assessed in the EIAR phase of the project.
The construction of the P166 as a non-toll road is in
general supported.
The purpose of the P166 road should be revisited. It should
not mainly be a by-pass road for traffic around Nelspruit
and White River but provide a meaningful alternative route
for traffic between Nelspruit, Rocky Drift and White River.
Sufficient and functional accesses onto and from the P166
must be provided along the alignment. Feeder roads to and
from the P166 must also be upgraded as part of the scope
of work for the P166 to ensure easy utilisation of the road.
Kruger Lowveld
Chamber of Business
and Tourism, Comments
E-mailed
Tolling is a funding consideration, which will be
fully investigated once construction of the
route is being considered.
Regular access via interchanges is planned
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The alignment of the road along the originally planned
servitude through White River is not supported. The
environmental and socio-economic costs of this proposal
will be unacceptably high.
An alternative alignment north-west of White River, linking
the Sabie road with the R40 near Caster Bridge should be
investigated. This alternative must be included in the
Scoping Process and not only during the EIA evaluation
Alternative 2 (just west of original alignment) for alignment
pass Phumlani is supported. Alternatives 1 and 3 are not
seen as viable and will have significant socio-economic
implications.
The original planned alignment for the southern section
(Maggiesdal) is likely the most viable. Further consultation
with land owners is however required. A targeted
consultation meeting with the Members of the KLCBT is
requested.
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to
where the servitude runs directly through a
wetland. Accordingly a new alternative, the
White River North Alternative has been
created, and will be comparatively assessed
against the existing servitude in the EIAR
phase of the study and the identified I&AP will
be consulted.
In the case of the Phumlani Alternatives 1 & 3
these have been ruled out from an
environmental perspective by the proponent
and will not be taken further into the EIR phase
of the project.
The scoping-phase public participation period
has passed. However the Kruger Lowveld
Chamber of Business and Tourism is
recognised as being an important stakeholder
and will however be encouraged to submit
their comments in writing and the EAP will
ensure that the Kruger Lowveld Chamber of
Business and Tourism is fully involved in the
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EIR-phase public participation process.
I object to the current proposed route for the P166 Road
from where it crosses the road to Sabie and passes through
the wetland and joins up to the R40 next to the Casterbridge
Lifestyle Centre.
My objections to this part of the proposed route is on the
following grounds:
This route will have a massive negative impact on the
precious wetland which it is going along - not through or
across. Not only is this a green lung for White River and a
Nature Reserve much used by the community, but all
wetlands are vital to the health of our precious rivers. There
is no design possible that could keep the road going
through that Wetland without irreversibly destroying it.
In addition I am aware that it is one of the few places that
Aloe simii are still found in their natural habitat. Plus there is
a Rare frog inhabiting the wetland. These are very
significant facts that should immediately prevent this route
Kate Barnett, Chairman
of the Environmental
Committee of Uplands
College, Comments e-
Mailed
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to
where the servitude runs directly through a
wetland. Accordingly a new alternative, the
White River North Alternative has been
created, and will be comparatively assessed
against the existing servitude in the EIAR
phase of the study.
The potential significance of the impacts of the
road on the wetland running through White
River has been raised in the wetlands report.
This is one of the primary reasons for the
creation of an alternative route to the existing
servitude for consideration in the EIAR phase.
The presence of Aloe simii in the wetland has
been noted in the scoping-phase biodiversity
report, and the presence of the threatened frog
species has been included based on I&AP
input.
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46 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
being used and any other route that passes along a
wetland.
This route is proposed as a BYPASS of White River and
Nelspruit, however the route is not a bypass of White River
at all. It is cutting between a number of suburbs and a large
number of houses that lie not only adjacent to the wetland
route, but also the large number of Estates and houses that
have been developed slightly further to the North and North
West of White River since the road was originally proposed.
I suggest that since there has been significant development
to the west of White River the number of people being
affected by this road is much larger that originally realised.
The Estates I am referring to are WHite River Country
Estate - a suburb of White River, Sheffield, Summer
Breeze, Pomeshana, Recoletta, Sonyaka, Longmere
Estate.
From the Public Meeting held at White River Primary , I
gathered that it was originally intended that this route link up
with the road to Numbi Gate and the Masoyi area as that
road was thought to become the main route to Hazyview
etc. The R40 is now the planned main arterial road to
Hazyview and beyond and so the P166 no longer needs to
rejoin the R40 at that intersection next to Casterbridge.
Therefore many other options further west and north
become available if you are still seeking a Westerly or
Northerly route around White River and can join the R40
further north. I urge SANRAL to consider alternative routes
Potential visual issues relating to the road
have been raised by a number of Interested
and Affected Parties, and as such the need to
undertake a visual study has been raised in
the plan of Study for EIA.
An integrated transport study has been
proposed for the next phase of the EIA in order
to address issues relating to traffic flow needs
and whether the proposed P166 route satisfies
the needs of the wider area in this context.
The potential impact of the road on noise-
sensitive receptors has been highlighted in the
scoping-phase noise specialist report. The
White River area has been highlighted as a
noise-sensitive receptor location, and as such
will be further investigated in detail in the EIA
phase.
The current proposal maximally utilises the
existing proclaimed and compensated road
reserve. The alternative avoiding the wetland
may however link up with R40 further to the
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that are actually bypasses.
We are already affected by the massive number of haul
trucks on the R40 in terms of noise pollution and reduced
safety on the roads into and through Whiter River and so I
object to a road that increases both these aspects.
There is already a proposed plan and route for a bigger
road to the east of White River for which landowners were
also already paid. The area around the KMIA airport is
proposed or even scheduled as an industrial area and the
Kabokweni Industrial area is spreading west. For this
reason SANRAL should be investigating moving this bypass
to the East of White River not insist ondeveloping it through
the residential suburbs of White River.
north. Connection of R538 to Numbi with
P166 will however still be required.
The proposed road is planned as a mobility
road, which would improve accessibility and
mobility between the White River and
Mbombela / Barbeton areas. As such the road
is proposed to reroute long haul traffic off the
local accesses through White River, and the
road may have a positive impact in this
context.
R538 as alternative has been addressed in the
updated “Needs and Desirability” section of the
Draft Final Scoping Report
Consultants to liaise with Sembcorp Silulumanzi regarding
future services – sleeves are to be provided for this
purpose.
Existing services within the reserves are to be identified, if
relocation is required service drawings are to be submitted.
Way leaves are to be submitted for sections inside the
Nelspruit Town Area
Aneesa Haroon,
Scientific Services
Department, Comments
E-mailed
SANRAL will utilise a proclaimed road reserve
for the road, or proclaim a new road reserve if
necessary services protection or relocation
and way leaves will be addressed during detail
design.
My concern is with the proposed portion between R537 and
the R40, which passes just north of Ext 18, then between
the two portions of Ext 16 and below Kingsview extensions
Mr. Llewellyn Hunt,
Faxed letter:
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
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48 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
2 & 3 and below Sondersog. The original planning of this
route was done before 1983 and as far as I could ascertain
it was a political decision also influenced by vested
interests.
This portion of the route is in a region of extremely
unsatisfactory ground conditions for building anything on, if
I were to be asked to value the portion, I would most
probably decline.
An excellent example of the type of terrain is to be seen at
Erf 21 Parkville, at the corner of Elands & Impala Streets
and the unimproved land opposite.
There is a spruit running the length of the route and it
would need to be crossed a few times at narrow angles.
There are also a number of dams in the spruit which are
shown on the 1:50000 topoadastrial map which would be
adversely impacted by such a road.
Concerning the soil conditions, I need to draw attention to
the book by Dr. A.B.A. Brink, Engineering Geology of
Southern Africa, pages 72 to 77, where he records the
leaning of the old water tower due to the fact that the
residual granite had a collapsible grain structure and the
measures made to correct this.
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
The alignment of the existing servitude through
the White River wetland and the channel
(spruit) contained therein has been highlighted
by the scoping phase wetlands study as an
issue of potential significance that needs to be
assessed in greater detail, due to the
significance and high intensity of the potential
impact.
The nature of the substrate in the area around
and within the wetland in White River is
acknowledged as a potential issue. The
comparative assessment of the existing
servitude through the White River area and
the newly created White River Alternative will
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These conditions are encountered all along the valley from
the water tower at the top end of Frank Townsend Street in
the west, to and beyond the White River in the east and to
build a road along this route would require the removal of
millions of cubic metres of these thixotropic soils and
importing many more suitable to build up to the levels
required.
Such a road could be built by constructing an elevated
highway, but to construct such a double carriage way wide
enough and strong enough to handle the heavy ore trucks
heading for Maputo, would be greater in great cost than the
elevated railway sections of the Gautrain, and then it would
still not Bypass the town.
take into account environmental, as well as
cost and technical issues such as are raised
here.
The project affects resale of my property. Cannot see the
benefits of this road. Not justified in light of the alternatives.
Rob McQueen,
Comment & Registration
Form: White River Public
Meeting,
• The socio-economic study has
identified the potential negative effect of the
road through the White River area on property
value. This will be further assessed in the
EIAR-phase social study
I support that Phumlani 2 Alternative should be selected.
Cllr. Kenny Khoza
Comment &
Registration Form:
Phumlani Public
Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental
assessment and comments from the public. It
should be noted that Phumlani Alternatives 1
and 3 have been discarded for the EIAR
phase due to environmental issues associated
with them.
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Unsuitable soil conditions along K.V. (Kingsview) X3.
To build anything along this spruit is economic insanity.
Llewellyn Hunt,
Comment &
Registration Form: White
River Public Meeting
Feedback from SANRAL on this point
indicates that construction methods and costs
associated with the existing servitude through
the White River area are regarded as
acceptable, but this will be assessed in more
detail during detail design. Nevertheless a new
alternative, the White River North Alternative
has been created, and will be comparatively
assessed against the existing servitude in the
EIAR phase of the study.
It is better to select a safe road alternative, i.e. Phumalni 2
Alternative. The original proposed route will have a
negative impact to the public.
Amos Ndlovu, Comment
& Registration Form
The environmental team will assess all the
identified alternatives and will recommend
those that are feasible based on the
environmental assessment and comments
from the public. Safety as a social issue in the
context of an arterial road passing through a
community will be assessed in the context of
both the existing P166 existing servitude and
Phumlani Alternative 2 in the EIAR-phase
social study
If the proposed road is constructed through the Heidelberg
Valley I fear that there might be:
Destruction of wetlands
Disruption to functioning of irrigation canals
Difficulty for farmers to access sections of their
farms
Traffic noise
Traffic pollution
Sheila Tebbit, Comment
& Registration form
It should be noted that for environmental
reasons, the Phumlani Alternative 1 that runs
through the Heidelberg Valley has been
discarded and will no longer form part of the
project scope as investigated in the EIR phase.
It is thus highly unlikely that any of these
issues raised in this point will materialise, and
these potential impacts in this part of the study
area have been avoided
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Destruction of good farmland and property de-evaluation in
the immediate area.
The original proposed route is far better suited and
generally disruptive/damaging.
Negative impact on wetland and wildlife.
Farms will be cut into smaller uneconomical parcels that
will result in destruction of irrigable, usable, land that will be
excess of the actual land destroyed by the road.
The fact that the Msholozi illegal settlement will have to be
disrupted is a problem, but how can an illegal settlement
disrupt the legal, planned law abiding processes of the
country.
Property values will be negatively affected by the
alternative 1 running through the valley.
The sand river irrigation scheme would be seriously and
negatively impacted.
Servitudes and rights of-ways across different farms in the
Heidelberg valley need to be carefully considered.
Increased run-off during periods of high rainfall resulting in
erosion and further loss of farmland.
Allan Luus, Comment &
Registration form
The potential impact of certain of the project
alternatives, in particular Phumlani Alternative
1 is recognised, and is reflected in the
agricultural potential study. It should be noted
that for environmental reasons, the Phumlani
Alternative 1 has been discarded and will no
longer form part of the project scope as
investigated in the EIAR phase.
Thus all issues pertaining to the Heidelberg
Valley and Phumlani Alternative 1, as raised
here are unlikely to materialise.
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani settlement
were allegedly “illegally” settled. Nonetheless a
housing development & community now exists
within certain parts of the servitude and wider
area (in which alternatives to the existing
servitude in the Msholozi area are being
considered) and as such the potential social
impact of the proposed road on this community
needs to be considered by this EIA and
compared with the impacts of the alternative
alignments.
It should be noted that for environmental
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reasons, the Phumlani Alternative 1 has been
discarded and will no longer form part of the
project scope as investigated in the EIAR
phase. As a result, social-related issues of a
potential loss of property value in the
Heidelberg value are unlikely to materialise
due to the proposed road development.
The property owners dispute the right of the South African
National Road Agency and /or any other entity to construct
a road as proposed under route P166-1/2 or otherwise
Major portions of the proposed route are environmentally
sensitive and will irreparably harm wetlands and sensitive
environmental areas
Wiekus Petrus du Toit,
Wiekus du Toit
Attorneys, Comments
Emailed
Based on feedback from the proponent Sanral,
the route has been declared through White
River. Further legal verification will follow later
as part of land acquisition and compensation
process.
The scoping phase study has been based on a
number of specialist studies that have
identified areas of particular environmental
sensitivity in the context of one, or more
disciplines. In such areas alternative routes
have been created in order to allow the
mitigation of the issues.
I live in Magaliesberg Street, right on wetland nature
reserve. The road will be 5m away from my garden fence.
How can you build a road through a wetland nature reserve
as an environmentalist?
What happens to the property values when the house we
bought on a nature reserve suddenly changes to a house
Tracy Brooks,
Comments Emailed
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to
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53 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
on a toll road? where the servitude runs directly through a
wetland. Accordingly a new alternative, the
White River North Alternative has been
created, and will be comparatively assessed
against the existing servitude in the EIAR
phase of the study, as a mitigation measure to
avoid the potentially significant biophysical
effect of the proposed road on the wetland,
and certain socio-economic issues such as
impact on property value.
I represent the owner of Portions 18, 20 and 21 of the farm
Cromdale 453-JT situated south of Nelspruit and affected
by the proposed road P 166-2.
It has come to the attention of the owner and ourselves that
an EIA process commenced in respect of which land
owners were informed of the process and who were invited
to register as interested and affected parties. Applications
for registration apparently closed on 21 September 2012.
In terms of the Regulations you are required to:
1. Inform all land owners that are directly affected by
the proposal of such a proposal and include such
owners as a participant in the process. Proof of
such notification must be submitted to the
Department.
2. PLEASE provide us with acceptable proof that the
registered owner, or his representative, or
occupiers of the said properties have been informed
of your process.
3. Notice of the process must also publicly be given by
means of notices in the daily or weekly press, and
Hennie van Rensburg,
Nuplan Development
Planners, Comments
Emailed
A site visit was conducted on the 31st July
2012 and site notices were placed.
Thereafter, RHDHV started receiving
enquiries about the project and started
distributing project background information
documents. There was a closing date on the
registration form to encourage people to
complete the registration form and send back
to us at their earliest convenience so to start
establishing the database.
We also aimed that by Mid September 2012
we would have identified all the landowners
and I&AP‟s affected. You are welcome to
register as an I&AP on the database.
It is very important to note that registration of
I&AP‟s does not stop until the project ends.
The EAP is aware of all of the regulations and
guidelines for conducting public participation,
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preferably the local press.
and will comply with these throughout the EIA
process.
.
Why do alternatives have to be considered and is this due
to recommendations from the screening phase process?.
Mr Peter Sonemann,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Da Cruz responded that the process was
to identify the feasible route, and it is a legal
requirement to have alternatives to the main
route to be assessed. He explained that each
specialist had to identify significant impacts
along the main route and along the
alternatives in order to come up with
mitigation measures for each. A number of
significant potential issues relating to the
social environment, wetland, surface water
environment, and biophysical environment in
terms of fauna and flora, have been identified
in the area through White River. The
comments from the public also raised some
concern regarding their properties relating to
potential loss of value, damage to the wetland
and the presence of threatened species that
would be lost in that area. These brought
about the potential need of considering an
alternative to the identified servitude.
Wwhichever alternative will be considered, great care
should be taken that they are technically feasible before
presenting these to the public.
Why there no alternative proposed for the White River area
Mr Peter Sonemann and
Mr. Frans Greyling
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Da Cruz responded that alternatives
identification through the EIA process is an
iterative process. When a proponent puts
forward a route for environmental
assessment, that proponent would not
necessarily be aware of all environmental
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55 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
as compared to other areas?
issues that maybe associated with the
proposed route.
Mr. Da Cruz explained that a screening
exercise undertaken at the start of the scoping
phase of the project has identified the
environmental issues in the White River area;
an alternative may be considered which will
be assessed in detail in the EIAR phase.
It is important to note that based on specialist
inputs as well as public comment and
feedback relating to areas of environmental
sensitivity, a number of environmental issues
were identified in the area where the P166
servitude traverses the White River area, in
particular relating to where the servitude runs
directly through a wetland. Accordingly a new
alternative, the White River North Alternative
has been created, and will be comparatively
assessed against the existing servitude in the
EIAR phase of the study.
When the EIA report will be submitted?
Mr Frans Greyling
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Ms. Ntseketsi Lerotholi informed the meeting
that if all goes well the report should be
finalized in six months from now.
Mr Frans Greyling commented that they will need to see
this report submitted as soon as possible so that the
municipality should be able to approve some of the
Mr Frans Greyling
Minutes of the Focus
Group Meeting,
Mr. Da Cruz responded that it is possible that
some of the suggested alternatives may be
withdrawn based on the assessments that
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developments that have been applied for along the
proposed route. He informed the meeting that he prefers
Phumlani option 2 and that Phumlani option 3 is not
feasible and should be withdrawn. He wanted to know if all
alternatives will be assessed in the EIA phase
Mbombela Local
Municipality
have been carried out during screening
process.
It should be noted that for environmental
reasons, the Phumlani Alternative 1 and 3
have been discarded and will no longer form
part of the project scope as investigated in the
EIAR phase.
An attendee enquired if the alternatives have been tested.
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
It should be noted that all alternatives are
technically feasible.
From an environmental perspective this EIA
has attempted to comparatively assess
alternatives in an equitable and fair manner
that takes all environmental and other factors
into account.
The Phumlani alternatives were introduced
early in the scoping process, as a result of
potentially significant issues raised by certain
project team specialists. These were then
scoped by all of the specialists as part of their
scoping-phase specialist studies, and these
alternatives were included in the draft scoping
report that was released prior to the meetings
alluded to.
The comparative assessment of alternatives
has been undertaken by considering inputs
from all of the different specialist disciplines in
terms of a preferred alternative from their
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specialist perspective. Technical
considerations have also been taken into
account. In the case of the Phumlani
alternatives 1 and 3 that traverse the
Heidelberg valley and the smallholdings
respectively have been ruled out from an
environmental perspective by the proponent
and will not be taken further into the EIR phase
of the project.
The current EIA aims to find a solution that is
as environmentally sustainable as possible,
taking into account the impact on all affected
parties, including factors such as capital
expenditure into properties, and their
associated value.
He commented that time should not be wasted by
investigating non-feasible alternatives as this will be a
waste of money. He recommended that costs should also
be considered for each alternative in order to try to be cost
effective.
Mr. Stephan Pienaar,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
All alternatives have been determined to be
technically feasible.
The Environmental scoping process has
comparatively assessed all alternatives and
two alternatives (Phumlani Alternatives 1 and
3) have been determined to not be
environmentally feasible, and will not be
subject to further, detailed studies, and have
thus been discarded.
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Mr. Greyling said if there is going to be a deviation from the
existing servitude, there would be problems which will be
encountered and another concern is that not all these
alternatives can be considered as there are already
development applications in place.
Mr. Greyling commented that Phumlani 2 Alternative would
be feasible at this time. He further commented that
Phumlani 3 Alternative should be discarded and time
should not be wasted on it.
Mr Frans Greyling
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
The Phumlani alternatives and Maggiesdal
Alternative were introduced early in the
scoping process, as a result of potentially
significant issues raised by certain project
team specialists. These were then scoped by
all of the specialists as part of their scoping-
phase specialist studies, and these
alternatives were included in the draft scoping
report that was released prior to the meetings
alluded to.
The comparative assessment of alternatives
has been undertaken by considering inputs
from all of the different specialist disciplines in
terms of a preferred alternative from their
specialist perspective. Technical
considerations have also been taken into
account. In the case of the Phumlani
alternatives 1 and 3 that traverse the
Heidelberg valley and the smallholdings
respectively have been ruled out from an
environmental perspective by the proponent
and will not be taken further into the EIR phase
of the project.
Referring to the bottom (southern) section of the map, he
enquired if the road was still going to be constructed as per
map as there have been applications received to develop
the area into a rural residential area.
Mr. Frans Greyling,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
The existing P166 servitude in this part of the
study area is being considered for
development; however there is an alternative
the Maggiesdal Alternative which has been
created to avoid a number of new
developments.
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Mr Frans Greyling commented that there are alternatives
for the development of the R40 around Hazyview and
enquired why officials responsible for Hazyview have not
been invited to the meeting.
Mr. Frans Greyling,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Klaus Schmid responded that the route
through Hazyview will be considered in a
separate EIA process and is part of this
application
Mr Frans Greyling enquired why is it still necessary to
conduct an EIA studies for a servitude that has been
proclaimed.
Mr. Frans Greyling,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Da Cruz said the existing servitude was
proclaimed in 1980s before the implementation
of the environmental regulations and
subsequent NEMA regulations. He explained
that the route determination of P166 falls
under one of the listed activities of the
regulations whereby an EIA need to be
conducted and authorization sought.
Mr. Frans Greyling wanted to know how long it takes for the
authorities to grant an authorization once the EIA
application for authorization has been submitted to the
department.
Mr. Frans Greyling,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Da Cruz responded that it would take
approximately 2 to 3 months to get
authorisation.
Mr Frans Greyling enquired as to how long the
authorization is granted for.
Mr. Frans Greyling,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Da Cruz responded that typically the EIA
authorization is valid for about 5 years and that
construction would need to commence within
that period. The timeframe of validity of the
authorization depends on the conditions set
out by the department in the authorization.
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Mr Frans Greyling asked as to where the final report will be
submitted to or if it first goes to SANRAL to make final
decision of the route.
Mr Frans Greyling expressed the municipality‟s support for
the project and indicated that they will not be submitting
written comments.
Mr. Frans Greyling,
Minutes of the Focus
Group Meeting,
Mbombela Local
Municipality
Mr. Da Cruz responded that the final report will
be sent to the DEA for the final decision.
Ms. Vivien Rossack asked that clarification be provided in
respect of the declared and undeclared land section from
the maps.
Ms. Vivien Rossack,
Minutes of the
Landowners Focus
Group Meeting, Bundu
Lodge
Mr. Klaus Schmid from SANRAL explained
that some areas of the existing route are
declared and some are not and that he does
not know why this was the case as the P166
route was inherited from the Transvaal
Provincial Administration (TPA).
Ms. Vivien Rossack wanted to know if the team has
considered widening the R40 instead of building a new
road.
Ms. Vivien Rossack,
Minutes of the
Landowners Focus
Group Meeting
Mr. Schmid responded that SANRAL have
realized that there is a need for the proposed
bypass road as traffic is increasing in the area.
He mentioned that this is proposed to be a
mobility road for longer distance traffic, and
that the purpose of the proposed road is to
reduce the time taken to travel between
Barbeton and White River. This would be
different to the R40 which accommodates all
traffic that goes into/out of town. He informed
the meeting that there is concern about the
increase in truck traffic from Phalaborwa to
Maputo that uses the R40.
Alternatives, including upgrading of the R40,
have been addressed in the updated “Needs
and Desirability” section of the Draft Final
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Scoping Report
Andrew Rossack commented that they have been asked to
submit their comments regarding the draft ESR. He wanted
to know if the same would be done with the final ESR
before submission to the authorities
Andrew Rossack,
Minutes of the
Landowners Focus
Group Meeting
Paul Da Cruz said in terms of the EIA
regulations, the final ESR will be made
available to the public for 21 days. The public
should check if their comments made on the
draft scoping report had been captured and
responded to in the issues trail.
He said that Mr. Da Cruz had earlier stated that SANRAL
has a legal right to develop the road whereas SANRAL has
no legal rights to do this and secondly there was no
alternative suggested for White River. Has wanted to know if
any alternative has been considered for White River.
Mr. Wikus Du Toit,
Minutes of the
Landowners Focus
Group Meeting
Mr. Da Cruz responded that SANRAL was
undertaking the EIA to determine a route for
the proposed P166 road, and to determine the
environmental feasibility of the existing
servitude. He further assured the meeting that
due to comments received, mitigation
measures for the issues identified in the White
River area, including the possible identification
of a route alternative in the White River area
will be assessed.
It should be noted that due to the issues
associated with the P166 servitude in the
White River area as identified by specialists
and various stakeholders alike, a new
alternative has been created (to be fully
assessed in the EIAR phase of the project) in
the White River area as a way of potentially
mitigating environmental impacts associated
with the P166 servitude in the White River
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area.
Mr. Heinrich Kammeyer commented that some of the
issues are not mentioned in the report. He mentioned that
the footprint of the road in the White River area hosts
known communities of the endemic Red data aloe species
Aloe simii which should be taken into consideration during
this process. He mentioned that there are also small
streams feeding into the wetland. He informed the meeting
that the management of the Lowveld Chambers will be
having a meeting within the coming week and written
comments will be sent to the consultants.
He further commented that if an alternative for the White
River area is not considered, this will be definitely a fatal
flaw in the scoping report. Mr. Kammeyer recommended
that an alternative be provided before going to the EIA
phase of this project as the area is sensitive. He
recommended that SANRAL should identify an alternative
further to the west which will go through the plantation area
as this would not be close to the residential area. Although
the alternative would have to cross wetlands, rivers, water
supplies, etc, it would be preferable as it would cross these
water resources at a 90 degree angle, thus affecting a
small area of the wetland, as opposed to the current
servitude that runs through the wetland.
The socio-economic impact associated with the road on the
properties in White River adjacent to the servitude would
be significant and noise has been one of the indentified
Mr. Heinrich Kammeyer,
Minutes of the
Landowners Focus
Group Meeting,
The presence of Aloe simii in the wetland has
been noted in the scoping-phase biodiversity
report.
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
The socio-economic study has identified the
potential negative effect of the road through
the White River area. This will be further
assessed in the EIAR-phase social and noise
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impacts. studies
Mr. Kammeyer commended that it is good to avoid the
Phumlani area by considering alternatives but one of these
alternatives is running alongside a wetland that will be
destroyed by the construction of the road if this alternative
is developed.
Mr. Kammeyer, Minutes
of the Landowners
Focus Group Meeting,
Mr. Da Cruz informed the meeting that he has
been to this area in Phumlani and found that
the community has dug trenches in the
wetland to try and drain the water away and
make the area less inundated.
Mr. Andrew Rossack commented that this road would only
benefit the Hazyview people travelling to Barberton. But for
people staying in White River travelling to Nelspruit, this
road will not have value. He mentioned that the
intersections at Casterbridge, near Impala Street, or at
Bahadi there are already major problems. He commented
that this road will be a white elephant as there will be no on-
ramps and people from White River will not be able to use
this road to travel to Nelspruit.
He further commented that it would not be easy to get to
the Casterbridge interchange from this road due to the
existing traffic. It would not solve the problem experienced
by R40 beyond (north of) White River. Even if this road can
be constructed, problems will still exist on either side of it.
He emphasized that no problems would be solved by this
P166 road. He cautioned that this road is going to upset a
lot of people.
He requested that more data on the need and desirability
be provided.
Mr. Andrew Rossack,
Minutes of the
Landowners Focus
Group Meeting
Mr. Schmidt responded by saying that the road
is not only to serve people travelling from
White River to Nelspruit but mainly to take the
long distance traffic like the trucks from
Maputo to Phalaborwa off the R40. There will
be an interchange at Casterbridge where the
major roads connect.
He commented that the final decision will be
made by the authorizing department based on
the need and desirability of this road. He
mentioned that the same comments came up
during the EIA for construction of the N4 and
N1 roads.
. The project need and desirability issues have
been subsequently updates and are
addressed under Section 1.2 of the scoping
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64 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
report
Mr. Eduard Mellaart commented that this road will not be
user friendly as the proposed on/off-ramps make it
impossible to take the most convenient road.
Mr. Eduard Mellaart,
Minutes of the
Landowners Focus
Group Meeting
Mr. Da Cruz responded that this will be
directed to the social specialist who will be
looking at social issues.
The conducting of an integrated transport
assessment is being proposed to the applicant
to consider the issues relating to traffic flows
and potential growth / change in traffic streams
in the future. This will examine issues relating
to access, as raised by this comment.
Mr. Robin Clanahan raised a concern that they would be
providing their comments in writing. He further said he was
not satisfied with the need and desirability for the project as
presented in the slides.
He asked if the proposed road will be tolled or not,
expressing his view that that if the road were to be tolled
trucks will still use the old road as they would avoid paying
the tolls.
He mentioned that should Phumlani 3 Alternative be
selected, much harm will be done to the industrial area
adjacent to the R40 as the proposed road would take up a
huge area of this development. The access for the
Mr. Robin Clanahan,
Minutes of the
Landowners Focus
Group Meeting
Mr. Schmidt responded that the issue of tolling
has not been decided.
Tolling is a funding consideration, which will
only become relevant once construction of the
route is being considered. Issues related to
possible toll avoidance will be part of the
considerations at that stage. The current
application is limited to definition of an
acceptable route and accurate determination
of the road reserve required for the road.
It should be noted that for environmental
reasons, the Phumlani Alternatives 1 and 3
have been discarded and will no longer form
part of the project scope as investigated in the
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65 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
Phumlani residents would be disrupted, and the area could
be better used to accommodate school/shops etc.
He wanted to know the width of the servitude and how
much it will cost to build the road.
He raised a concern that areas for sourcing of construction
material should be adequately determined as sometimes
material is sourced out from Pietermaritzburg or Estcourt
and this results in huge impact on the roads and people.
EIR phase.
Mr Schmidt responded that the servitude width
is a nominal figure of 80m depending on filling
and cutting. Mr. Schmid explained that it is still
too early to determine the cost of the road
construction.
Mr. Schmidt responded that this will be
considered in future EIAs that would be
undertaken for listed activities relating to
construction of the road.
Mr. Hennie van Rensburg reminded the meeting that the
authorization applied for is for determination of the route.
Planning and design would have their own processes. He
said after the road has been determined, there would be
another fatal flaw regarding the properties and the property
owners that will be affected.
He asked whether the land owners would be provided with
more information especially in the Maggiesdal area where
an intersection is proposed in order for them to comment
on the road alignment before it is too late.
Secondly the meeting speaks about the servitude that was
declared in the 1980s and road proclamation. He was
concerned that these are two separate issues in his mind
Mr. Hennie van
Rensburg, Minutes of
the Landowners Focus
Group Meeting
Mr. Da Cruz informed the meeting that one of
the objectives in conducting the EIA process
for route determination of the proposed road is
to adequately assess the issues and how
people will be affected.
SANRAL will receive an authorization for a
certain route alternative or servitude. Should
the designers in the design phase identify a
problem with this authorization, they will have
to apply for the route amendment in this regard
subject to what the department has stipulated.
In spite of this, the EIA is being conducted at a
level at which issues regarding property; in
particular certain areas of concern have been
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and do not want to confuse the two.
raised.
The social specialist has identified particular
problem areas where there are structures that
may be affected by the servitude. The detailed
EIA study and the social study will consider
these issues.
Mr. Schmidt responded that this was a legal
question but the way he understands it is that
“declaration” means “to define and reserve the
strip”. This was only published in the Provincial
Gazette and that is where the process ended
apart from the land compensation. It was not
registered on the title deed up until in the
1990s, and also when SANRAL transferred
and registered ownership.
Mr. Rossack informed the meeting that the Phumlani
development underwent an EIA process and a RoD was
issued. One of the conditions of the authorization was that
there was an offset for a certain part of the developed
area as part of the impacted area is classed as
irreplaceable under the Mpumalanga Biodiversity
Conservation Plan (MBCP). This is not reflected anywhere
in the scoping report by Dr. Brown. By putting an
alternative through the area protected as part of the offset
for the Phumlani development it means the previous EIA
is no longer valid. This portion is put under the protection
of the Municipality and classed as an offset that is
Mr. Rossack, Minutes of
the Landowners Focus
Group Meeting,
Mr. Da Cruz promised that Mr. Rossack‟s
comments will be addressed in the detailed
studies during the EIA phase.
The Mpumalanga Biodiversity Conservation
Plan, POSA, SARCA, SABAP1 and SABAP2
data was consulted in the preliminary
biodiversity assessment which was based
mainly on a desktop survey as well as a single
site visitation. It should also be noted that the
Mpumalanga Biodiversity Conservation Plan
has been consulted in the revised draft Final
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67 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
irreplaceable by the Mpumalanga Biodiversity
Conservation Plan. He was concerned that Dr. Brown, the
ecological specialist, did mention a rare species such as
rock python and plated lizards that are known to occur in
the area. This emphasized that a detailed ecological study
should be undertaken and this should be specific to the
site as proper management measures will have to be
implemented during the construction of this road.
He further said one of the important things why wetlands
are important is ground water discharge and that this
issue was not covered adequately in the scoping report.
He raised a concern that some alternatives traverse
wetland areas and this will create problems to the road as
it will fall apart causing potholes. He mentioned that most
of the wetlands in the area are sources to the White River
or to Nels River which feeds to the Komati and the
Crocodile Rivers and that the wetlands are critically
important in the area. He mentioned that close to 50% of
these have already been lost due to developments either
legal or illegal. He raised the concern that this proposed
road is going to destroy another 50% of what is left such
that in 15 years time they will have lost about 75% of the
wetlands in the area. He recommended that cumulative
impacts need to be addressed in the wetland study.
Scoping Report, and implications for the route
and proposed project scoped.
In the context of the offset referred to, It should
be noted that due to technical and
environmental issues Phumlani Alternative 1
which would have affected this offset area has
been discarded and will not be considered in
the EIR phase.
It is acknowledged that there is a. high reptile
diversity occurs between Nelspruit and White
River with 81 species recorded during the
South African Conservation Assessment
(SARCA). This will be further assessed in the
EIAR-phase biodiversity study.
Linda Liversage informed the meeting that there was an
archaeological site and graves within the proposed route
Linda Liversage,
Minutes of the
Mr. Da Cruz thanked Ms. Liversage for her
comments and promised to see to it that these
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68 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
alternative that also needs attention.
Landowners Focus
Group Meeting
issues are assessed by the heritage specialist.
This issue has been flagged and will be
considered in the EIAR-phase heritage study
Mr. Rossack requested for a copy of the specialists CVs
and a decent map showing the alignment in full.
Mr. Rossack, Minutes of
the Landowners Focus
Group Meeting,
CV‟s will be included as an appendix to the
Draft final scoping report.
Mr. Mellaart commented that Phumlani 3 Alternative was
going to divide some properties and the Phumlani
community will not be able to access the R40 due to this
road.
Vivien Rossack commented that one of the alternatives
would be running close to her property, or even cutting it
into half. She pointed out that they will be impacted by the
fumes and noise from fast moving vehicles. She wanted to
know if there would be compensation paid to landowners.
She also informed the meeting that some people in
Phumlani were warned that they were occupying the land
illegally at their own risk. She was concerned that now
SANRAL wants to penalize people who legally own land
has spent a lot of money to purchase land with no
assistance from the state, in order to accommodate those
that are illegal.
Mr. Rossack, in addition to the above comment, said
SANRAL is trying to promote illegal activities by
accommodating the residents of Msholozi who are
Mr. Mellaart, Minutes of
the Landowners, Focus
Group Meeting
Mr. Da Cruz informed the meeting that the
situation with respect to the Msholozi
settlement was complex. He explained that
irrespective of whether the settlement was
legally or illegally settled, they are settled in
the area and relocation of people is associated
with a raft of social issues that will need to be
considered.
It should be noted that due to environmental
issues Phumlani Alternative 3 has been
discarded and will not be considered in the
EIAR phase, thus the potential for access to
the Phumlani community being disrupted by
the proposed road will not occur.
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani settlement
were allegedly “illegally” settled. Nonetheless a
housing development & community now exists
within certain parts of the servitude and wider
area (in which alternatives to the existing
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occupying land illegally. servitude in the Msholozi area are being
considered) and as such the potential social
impact of the proposed road on this community
needs to be considered by this EIA and
compared with the impacts of the alternative
alignments.
Mr. Da Cruz responded that Phumlani
Alternative 1 has been identified as cutting
through an area of high agricultural potential.
This has been taken into account. SANRAL
does not favour this alternative from a
technical perspective because it is longer than
the other two alternatives and there are
steeper slopes that would result in a more
costly road to build.
Mr. van Rensburg asked as to when the road will be built.
Mr. van Rensburg,
Minutes of the
Landowners, Focus
Group Meeting
Mr. Schmid responded that time frame is not
yet known as they will have to wait for the
authorization of the route determination before
making any decisions regarding
implementation. Under the best case scenario,
should it happen, the construction will not start
earlier than the end of next year (2014). This
construction can take a period of about 2
years. To have this road functional would
therefore take in excess of 3 years from now.
Linda Liversage raised a concern that this road will affect
her property negatively yet she was not informed about the
development. She was concerned about the noise during
Ms. Linda Liversage,
Minutes of the
Landowners, Focus
Mr. Da Cruz thanked Ms. Liversage for her
input and reminded the meeting that the social
specialist should be looking at these social
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construction and that some of her property will be part of
the road. She also raised a concern that people who will
benefit are those who would be driving on this road around
town not the property owners. She wanted to know how
compensation will be undertaken and if this will be
negotiated with landowners or if SANRAL will just decide
on how they will compensate landowners.
Group Meeting, issues and that SANRAL will negotiate with
landowners on the compensation to be
granted for each property affected.
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary.
In the context of noise-related impacts one of
the most sensitive receptors are the noise-
sensitive residential areas, and these areas
will be the main focus of the noise impact
assessment study in the EIAR phase. The
noise levels from the projected traffic volume
will then be compared with the prevailing
ambient noise level to determine the intrusion
level at the different noise sensitive areas and
mitigation measures will be suggested.
Mr. Leon van Zyl commented that he obtained the property
from his father and has just received a title deed for this
property. He wanted to know if there could be other
alternatives rather than the one that cuts through his
property.
Mr. Leon van Zyl,
Minutes of the
Landowners Focus
Group Meeting
Mr. Da Cruz said the alternatives are not yet
final and that alterations could be made to the
proposed route in further areas of
environmental sensitivity.
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Mr. Rossack enquired as to why SANRAL wants to use the
servitude rather than looking for a new area in which to
construct the road.
Mr. Rossack suggested that SANRAL should use the
available money to rehabilitate the existing provincial roads
rather than to construct the P166 which does not benefit
the community.
Mr. Rossack, Minutes of
the Landowners Focus
Group Meeting
Mr. Da Cruz responded that being the
environmental consultants‟ responsibility is to
assess the provided route and alternatives and
provide recommendations so that SANRAL
can make a decision if this is feasible or not to
proceed with their intention of developing the
road.
The application for environmental authorization
is for confirmation of an existing planning and
partial declaration (“servitude”), whilst
considering adjustments for specific identified
environmental concerns. The purpose of the
route, route alternatives and upgrading of R40
are all addressed in the need and desirability
section.
Mr. Simon Evered enquired if the meeting was going to
look at the route in detail as he had comments regarding
the White River area.
Mr. Simon Evered,
Minutes of the
Stakeholders Meeting,
Mr. Paul Da Cruz suggested that the meeting
should look through the White River map to
address the concern.
Mr. Evered informed the meeting that the map at hand did
not reflect the new developments in the area. The
proposed route was going to cut through household
properties which are not indicated on the map.
Mr. Simon Evered,
Minutes of the
Stakeholders Meeting
Mr. Da Cruz informed the meeting that the
1:50 000 cadastral map has been used as a
background on the map and there is a
possibility that the date of publication of the
map entailed that subsequent developments
would not be reflected on this layer. He
promised to look at the last update of this map.
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He informed the meeting that he could not understand why
the proposed route still stands as it was proposed before
the implementation of the environmental laws in the early
1980s. He informed the meeting that he does not
understand why a wetland should be destroyed to
accommodate this route as this wetland is treasured by the
people of White River and that the previous council has
designated the area as a bird sanctuary. Mr. Evered
warned the meeting that there would be strong objection to
this road in the White River meeting the following day.
He informed the meeting that another set of
maps had been developed using aerial /
satellite images as a background. He promised
that clearer maps would be made available in
the website. He informed the meeting that the
topo-cadastral maps are used as they indicate
the location and farms affected. A good
example is that they showed the Dingwell
Farm in the Phumlani/Msholozi area. He
informed the meeting that they have
developed the maps using the aerial image
background to show a more up-to date picture
of development in the area.
He explained that the road servitude was
proclaimed in the 1980s and this does not
automatically allow SANRAL to proceed with
development without authorization from the
National Department of Environmental Affairs
under the National Environmental
Management Act EIA Regulations thus
SANRAL is seeking the authorization to
proceed.
Mr. Schmidt informed the meeting that the land
as defined in the declaration was reserved for
the road and that land owners were
compensated for their land. He informed the
meeting that he understands the concern
shown regarding the wetland but commented
that he has seen subsistence farming taking
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place in the wetland and he wanted to know
how pristine the wetland is as he wanted to
understand the issues relating to the wetland.
He also explained that if this is not feasible
SANRAL will have to start all over again with
road planning, land acquisition and all these
have financial implications. He informed the
meeting that they are aware of the challenges
of the wetland, Phumlani and the area south of
Nelspruit.
Mr. Evered thanked Mr. Schmidt for the explanation and
commented that a 2-3km stretch of the wetland will be
affected by this road. He also commented that the road will
be built within the flood line and noise will also be an impact
in this area. He recommended that this should be
addressed in details in the EIA phase of the project.
Mr. Simon Evered,
Minutes of the
Stakeholders Meeting
Mr. Schmidt confirmed that part of the wetland
would be affected. He explained that the
proposal was to minimize and mitigate the
impact on the wetland as much as possible.
He further explained that the road would be
crossing the wetland where the stream turns
towards the bridge and then lower back to the
R40
Mr. Da Cruz responded that the wetland issue
is a significant potential issue. What the
specialists look at in terms of the wetlands is
how roads cross them. The optimum crossing
of the wetland is at the shortest point and it
should be perpendicular to the flow of water.
The issue relating to this wetland is that the
road will be running longitudinally to the flow
and a large area could thus be impacted. This
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74 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
has been flagged for further investigation in
the EIA phase.
Mr. Da Cruz thanked Mr. Evered for raising
this concern and indicated that they are aware
of the social (i.e. noise, safety) and
environmental issues (such as existence of
vulnerable sensitive frog) raised by the I&AP
and these will be addressed in details in the
EIA phase.
Mr. Da Cruz promised the meeting that once
the EIA phase is complete, feedback meetings
will be organized whereby the public will be
informed about the investigations undertaken
and the mitigation measures that will be taken
to address these impacts.
Mrs. Mary Evered wanted to know what the situation is
regarding the Environmental Law because the road reserve
was declared before the EIA Regulations had come into
being.
Mrs. Mary Evered,
Minutes of the
Stakeholders Meeting
Mr. Da Cruz responded that if the road was
constructed prior to 1997, the 1997 EIA
Regulations would have not been applicable
but since that EIA regulations under NEMA
have been promulgated which require that
certain listed activities need to be authorized,
such authorization needs to be granted before
the road can be constructed. He informed the
meeting that the same principle would also
apply to the water use license.
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Mrs. Evered asked if there is a chance that the project can
be rejected by the authorities.
Mrs. Mary Evered,
Minutes of the
Stakeholders Meeting
Mr. Da Cruz responded that the authorities
have a duty to consider the impacts that would
be caused by the proposed development and
their decision will be based on these.
Mrs. Lerotholi (RHDHV) reminded the meeting
that the department can either accept or reject
the application based on the studies that were
undertaken.
Mr. Evered raised a concern that consultants most of the
time (99.5%) are biased towards their clients as they are
remunerated by the proponent and that they thus ignore
comments from I&APs. He informed the meeting that he
was not against the road as it is a necessity but he is
against it running through the wetland.
Mr. Simon Evered,
Minutes of the
Stakeholders Meeting
Mr. Da Cruz responded that the purpose of
the public participation process is to record all
the comments raised and submit this to the
authorities so that informed decision can be
made. He also assured the meeting that the
environmental team is independent. He
responded that it is difficult for an alternative
in the White River area in that there are a
number of environmental, physical and
constraints in terms of placing a road either to
the east or west of the town. He however
assured the meeting that the EIA team will
look at this in detail and come up with a
feasible way of mitigating the identified
impacts that may include the creation of a new
alternative
It should be noted in the context of this
comment Based on specialist inputs as well as
public comment and feedback relating to areas
of environmental sensitivity, a number of
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76 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Mr. Louis Sidubela commented that Phumlani 2 Alternative
was most preferred as it has shown little negative impacts
to the area and will not affect any households from the
community. He further enquired if there would be access
roads to this bypass.
He raised a concern that this road would have no value for
the Phumlani community as there will be no access to
Phumlani Village.
Mr. Louis Sidubela,
Minutes of the Phumlani
public meeting,
Mr. Wihan Venter of Endecon explained that
according to SANRAL, the bypass would have
no access road to Phumlani Village. This will
serve as a freeway access only at the planned
interchanges, and no further intersections or
traffic lights would be provided as the road is
planned to shorten the travelling time between
Nelspruit and White River.
Mr Venter said should the declared reserve be
used, under- or over-pass bridges may have to
be built to help the community to move
between either sides of the bypass.
It should be noted that due to environmental
issues Phumlani Alternatives 1 and 3 have
been discarded and will not be considered in
the EIR phase.
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Cllr. Mkhonto commented that this was still a study in
progress. SANRAL should be informed about the wishes of
the community in gaining access to this road. He also
made an example of the access road constructed on the
N4 bypass. This could also be possible for this project.
The community felt that the Phumlani 2 Alternative was
best preferred as no residential buildings would be affected
Cllr. Mkhonto, Minutes of
the Phumlani Public
Meeting
The detailed EIAR-phase socio-economic
study will examine the issues relating to the
potential routing of a highway (arterial road)
through, or alongside a settlement such as
Msholozi.
It should be noted that due to environmental
issues Phumlani Alternatives 1 and 3 have
been discarded and will not be considered in
the EIR phase.
Mr. Hein Guile enquired if it is possible to have an
alternative in White River and where this could be located.
Mr. Hein Guile, Minutes
of the White River Public
Meeting
Mr. Da Cruz responded that one of the issues
that made it difficult for an alternative in the
White River area is that there are a number of
environmental, physical and technical
constraints in terms of placing a road either to
the east or west of the town. He however
assured the meeting that the EIA team will
look at this in detail and come up with a
feasible way of mitigating the identified
impacts that may include the creation of a new
alternative
Mr. Wihan Venter informed the meeting that
initially, no alternative was considered for
White River but this will be looked into.
In the context of this comment, based on
specialist inputs as well as public comment
and feedback relating to areas of
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environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Mrs. M Evered informed the meeting that there is a
threatened plant species identified at the bird sanctuary.
She wanted to know how this plant would be protected.
(Post meeting note – this refers to Aloe simii)
Mrs. M Evered, Minutes
of the White River Public
Meeting
Mr. Da Cruz responded that the plant has
been identified to be an aloe species in the
Fauna & Flora report. The Environmental
Management Programme might prescribe the
need for plant rescue and relocation plan. The
threatened species will be protected but if
there is a need for relocation, this will be done
as a last resort. A number of potential
mitigation measures such as avoiding areas
where populations of that species occur would
be considered. He explained that the
ecological specialist will carry out detailed
investigations in the EIA phase of such
species and identify in which areas they exist.
Mr. John Millett enquired if all land/farm-owners were
informed about the road that will affect their farms.
Mr. John Millett, Minutes
of the White River Public
Meeting
Mr. Da Cruz responded by saying that the
Public Participation Process Team have used
a deeds search to identify as many land-
owners as possible that appear on the system,
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and that the team visited the area to identify
the land owners along the proposed route. Mr.
Da Cruz mentioned that although the team has
done its best to identify as many landowners
as possible, it is a difficult task on a linear
project to initially acquire the contact details of
all potentially affected landowners. He asked
the meting that should it be the case that there
are some land-owners that were not
contacted, it would be appreciated if these
could be brought to the attention of the project
team so as to make necessary arrangements
to consult with them.
Mr. Millett further informed the team that there were people
pegging his property about 100 meters away from his
house, and that he believed that this was to do with the
proposed P166 project, but that he had not yet been
consulted.
Mr. John Millett, Minutes
of the White River Public
Meeting
Mr Wihan Venter confirmed that SANRAL was
undertaking no such pegging of any properties
along the route.
Mr. Llewellyn Hunt informed the meeting that this route was
planned approximately 30 years back without
environmental studies for the proposed road having been
undertaken. He added that the soil conditions along the
P166 servitude in the White River Area are not suitable for
construction of the road. It will be economic insanity to build
the road along this road as it has collapsible structure.
Millions of cubic metres of the soil will have to be removed
and replaced by the building material
Mr. Llewellyn Hunt,
Minutes of the White
River Public Meeting
Mr. Da Cruz responded that the engineers will
consider this issue during planning. Mr. Da
Cruz confirmed that he is aware that there is a
chance that there were hydric soils along
certain portions of the road. He thanked Mr
Hunt for raising this issue.
Feedback from SANRAL on this point
indicates that construction methods and costs
associated with the existing servitude through
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the White River area are regarded as
acceptable, but this will be assessed in more
detail during detail design. Nevertheless a
new alternative, the White River North
Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Mrs. Judy de Villiers wanted to know how far the road
would be constructed from her home as she can see that
she would be affected. She also wanted to know if there
would be a buffer zone from the road for safety reasons
and what the size of the buffer zone is.
Mrs. Judy de Villiers,
Minutes of the White
River Public Meeting
Mr. Venter informed the meeting that the
road reserve is 80m wide and the edge of the
road reserve falls on the edge of the
boundaries of some properties. He explained
that buffer zones will be provided and issues
of the buffer zones will be taken into
consideration for example that the reserve
can be reduced to 60m width, as to provide a
20m wide buffer zone .
Mrs. De Villiers raised a concern that should 80m be the
width of the road reserve that the road reserve was going
to run through the wetland area. The road will be flooded
during the first rains of summer.
Mrs. De Villiers, Minutes
of the White River Public
Meeting
Mr. Da Cruz responded that the engineers‟
designs would have to consider how the
existing storm water outlets would be
incorporated into the road design. Mr. Da
Cruz commented that there is an engineering
and environmental issue on how this storm
water will be attenuated. He confirmed that
there is seepage in the area and promised
that this issue will receive detailed attention
in the EIA phase of the project.
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Mr. Alastair Nachil wanted to know if this was going to be
an elevated road and how the road would be constructed in
relation to the Danie Joubert crossing across the wetland
area that was already elevated itself – would the new road
be elevated above this existing road. He commented that
the road should be built to the west of the residential area.
Mr. Nachil asked for a more detailed need and desirability
for the proposed road.
Mr. Alastair Nachil,
Minutes of the River
Public Meeting
Mr. Da Cruz responded that the details of the
road are not available at this stage but will be
provided during the environmental studies for
the construction of the road. He explained that
the public is allowed to object to the proposed
project through DEA and submissions should
be done with reasons. The EIA has a
responsibility to consider what the need and
desirability in order to explain why the project
is required.
This comment refers to the potential visual
and noise impacts related to a raised road. In
the context of visual impacts a number of
I&APs have raised visual-related issues. In
order to address these concerns, a visual
impact assessment study will be undertaken in
the EIAR phase of the project, and this study
will take into account the visual intrusion that
would be caused by such a potentially raised
road.
In the context of noise-related impacts one of
the most sensitive receptors are the noise-
sensitive residential areas, and these areas
will be the main focus of the noise impact
assessment study in the EIAR phase. The
noise levels from the projected traffic volume
will then be compared with the prevailing
ambient noise level to determine the intrusion
level at the different noise sensitive areas and
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mitigation measures will be suggested.
In the context of need and desirability, it
should be noted that the project need and
desirability issues have been updated
addressed under Section 1.2 of the draft final
scoping report
An attendee asked why the route is not developed on the
road running to the Kruger Mpumalanga International
Airport and then cut through on the existing roads.
An attendee, Minutes of
the White River Public
Meeting
Mr. Da Cruz commented that this point has
been raised by a number of parties in other
meetings however SANRAL‟s approach was
that the P166 servitude had been in
existence since 1983 and was carried forth
by the Mbombela Local Municipality spatial
planning. He responded that SANRAL will
look into the mitigation of these concerns
looking at the developments in the area.
An integrated transport study is being
proposed to address the traffic flow issues
relating to the proposed road and the future
traffic flow needs. The R538 as an alternative
has been discussed in the „Needs and
Desirability” section of the Draft Final Scoping
Report.
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Mr. Simon Evered, commenting on behalf of the Wildlife
and Environment Society of South Africa (WESSA),
commented that the proposed road should not go through
the wetland within White River; SANRAL should realize that
opposition is very strong and should listen to this
opposition. He commented that by SANRAL not suggesting
an alternative for White River, it appears that SANRAL
have made up their minds that they are going ahead with
the existing servitude and that attitude will not work. He
mentioned that he was leaving this matter in the hands of
the consultants to make a case to preserve the wetland. He
advised that an alternative should be considered for the
wetland in order to ensure that this wetland is conserved.
He believes that there are rare species within the wetland
that need to be protected in the area.
Mr. Evered suggested that there is a need for traffic study
to be conducted in the area. It was also mentioned that an
eastern alternative was recommended to cater for heavy
vehicles travelling from the Northern Lowveld to Maputo,
which currently use this easterly route. He suggested that a
western alternative in the White River area which would not
affect residential areas be considered. He was concerned
that noise will be one of the impacts associated with this
development, hence a detailed study should be provided.
Mr Evered commented that wetland delineation should be
undertaken for all alternatives.
Mr. Simon Evered,
Minutes of the White
River Public Meeting
Mr. Da Cruz responded by saying that the
wetland issue has been identified as a
significant issue. In most cases, roads would
cross the wetland area / river perpendicularly
to the direction of flow but the P166 road will
be running longitudinally through the wetland
and will have the potential to transform large
areas of the wetland. He thanked Mr. Evered
for raising this point and informed the
meeting that wetland delineation will be
conducted which will be part of the EIA-
phase wetland study in order to identify the
percentage of the wetland that will be
impacted.
Post meeting note:
Alternatives, including upgrading of the R538,
have been addressed in the updated “Needs
and Desirability” section of the Draft Final
Scoping Report. An integrated transport study
is being proposed to address the traffic flow
issues relating to the proposed road and the
future traffic flow needs.
Further to this comment and others, based on
specialist inputs as well as public comment
and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
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area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Mr Hilton Ford, from the White River Rate Payers
Association, asked as to why the team did not consider the
route from Karino to Hazyview bypassing White River to
the east, going past the KMIA Airport. He commented that
he suspects this proposed development has suddenly
come up because of the truck-related issues which are
causing problems all the way from Bushbuck Ridge to
Karino. He was concerned that this road was not going to
be beneficial to the community but to the truck companies.
Mr. Ford also enquired if there was any indication that this
would be a toll road.
Mr Hilton Ford, Minutes
of the White River Public
Meeting
Mr Da Cruz informed the meeting that the
question of tolling was raised in one of the
previous meetings and that a SANRAL
representative, who was in that meeting but
not present at the current meeting, responded
that it, was too early to determine if the road
will be tolled or not as they were still in the
planning stage. He informed the meeting that
tolling was still a heated issue in a national
context at this stage.
Mr. Da Cruz responded that the process was
still to obtain authorization for the proposed
project, which is focused on route
determination. Should the project receive
authorization from DEA, there will be a
separate EIA process conducted for
construction at which time the more detailed
designs will be available.
Mr. Wihan Venter commented that there were
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issues regarding the e-tolling system that
SANRAL has to address. He made an
example about the N17 which also have
problems about the tolling and informed the
meeting that an EIA process separate to this
one would be a necessity before tolling could
be implemented.
Alternatives, including upgrading of the R538,
have been addressed in the updated “Needs
and Desirability” section of the Draft Final
Scoping Report. An integrated transport study
is being proposed to address the traffic flow
issues relating to the proposed road and the
future traffic flow needs.
Mr. Rob McQueen expressed concern about the road going
through the wetland next to the bird sanctuary as he
resides just opposite this sanctuary. He wanted to know if
the study relating to the need for the road was done.
Currently there is need to take trucks down to Phalaborwa
and Maputo and running through town is not going to solve
this problem.
He recommended that the alternative of taking this road
through past Uplands College is a viable option but still
questioned whether the road was really necessary. The
existing R40 has at least 11 take offs between the Nels
Mr. Rob McQueen,
Minutes of the River
Public Meeting
Mr. Venter responded that SANRAL looks at
accessibility and continuity. Mr. Venter further
said that SANRAL is looking at the future
scenario in which SANRAL would not want
people driving from Hazyview through to
Barberton to have to pass about 20 traffic
lights and/or stops, similar to the current
situation for a motorist driving from
Johannesburg to Potchefstroom, as an
example. The stretch of the R40 between
Nelspruit and White River is the busiest road in
Mpumalanga and will be severely congested in
the near future. SANRAL does not want such a
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River bridge and Casterbridge. The money that SANRAL is
going to use on the proposed P166 should be taken to
improve and expand the R40 by introducing bridges and
fly-overs, making it accessible for people who are willing to
use it.
Mr. McQueen raised a concern that he does not believe
that the number of people travelling from Hazyview would
warrant the need to develop this road.
He suggested that taking the heavy traffic around to the
eastern side of White River would make sense.
situation to materialize. This P166 was
declared road servitude by the old Transvaal
Provincial Administration (TPA) and SANRAL
wishes to utilize this existing servitude to
alleviate the increasing traffic in the area.
An integrated transport study is being
proposed to address the traffic flow issues
relating to the proposed road and the future
traffic flow needs.
Further to this comment and others, based on
specialist inputs as well as public comment
and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
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Mr. McQueen informed the meeting that the Mpumalanga
Newspaper has indicated that the amount of traffic coming
from Hazyview side is about 300 vehicles per day and this
will increase to between 500 & 700 a day. Should this road
be built, all this traffic will be diverted onto the new road
and the noise level impact will increase in the part of White
River traversed by the new road.
He suggested that SANRAL upgrade the Plaston road
which is already proclaimed as this will cost SANRAL less
money than what will be spent on a new road. He
commented that when the road was proclaimed in 1983,
there were no developments that are currently in place
such as the KMIA Airport and Maputo corridor. The road
should be linked to these areas as well as to the Ka-
Bhokweni Industrial Area (which is not yet operational). He
mentioned that there are already applications for different
developments along the route such as the mine application
in the Heidelberg area, applications for the up-market
developments and approximately 2748 houses depending
on the availability of water and electricity in the area which
are also going to affect this project negatively
Mr. McQueen, Minutes
of the White River Public
Meeting
See response above.
The potential impact of the road on noise-
sensitive receptors has been highlighted in the
scoping-phase noise specialist report. The
White River area has been highlighted as a
noise-sensitive receptor location, and as such
will be further investigated in detail in the EIA
phase.
Alternatives, including upgrading of the R538,
have been addressed in the updated “Needs
and Desirability” section of the Draft Final
Scoping Report. An integrated transport study
is being proposed to address the traffic flow
issues relating to the proposed road and the
future traffic flow needs.
Mrs. Judy de Villiers wanted to know if people would still be
getting notification about the planned road as it seemed
that there were people who are still not informed about this
road, such as schools and businesses. She stated that this
road is going to cause job losses because tourists would be
taken away from White River.
Mrs. Judy de Villiers,
Minutes of the White
River Public Meeting
Mr. Da Cruz responded that an effort would be
made going forward on the project to reach as
many I&APs as possible by using existing
channels such as mail distribution networks of
the Rate-Payers‟ Association, & Chamber of
Commerce (if there is one). Going forward into
the EIR phase Royal HaskoningDHV will
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advertise the EIA process. In addition the BID
and flyers were distributed to the properties on
the boundary of the wetland that are directly
affected. The advert was also placed in the
local newspaper. Going forward the EIA
comment process will also be advertised in the
newspapers.
Mr. Riaan van Doorn mentioned that his business will be
directly affected by the road and wanted to know what will
happen to the business.
Mr. Riaan van Doorn,
Minutes of the White
River Public Meeting
Mr. Da Cruz responded that the social
specialist would look at these issues, and she
will be notified of social issues such as this
that have been flagged as part of the public
participation process
In terms of compensation, Mr. Venter
responded by saying that there is an
expropriation policy in place and this will be
followed. He informed the meeting that this
expropriation is a legal issue that involves
negotiations with affected people and this will
be a transparent process.
If the route running through these properties is
approved by authorities, SANRAL will engage
in negotiations with the affected owners in
order to agree on the compensation and
relocation if necessary.
Mr. De Villiers enquired from Mr. Venter about time frames
of the project going forward.
Mr. De Villiers, Minutes
of the White River Public
Meeting
Mr. Da Cruz responded that environmental
authorization is only likely to be issues by late
2013/early 2014.
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Mr. Venter responded that after receiving the
authorization, SANRAL would go into the
design phase. He explained that affected
individuals would also be contacted in order for
SANRAL to negotiate declaring of the
servitude etc. Mr Venter advised that the
affected individuals should check if the road
servitude appears on their title deeds. He
informed the meeting that this would take
another period of about 5 or more years before
the road is constructed.
Mr. Mike Chankin commented that the servitude should be
moved about a kilometer to the west from the wetland to
avoid the road construction causing damage to the wetland.
He suggested that SANRAL should be persuaded to
undertake engineering planning properly, having considered
all the issues raised in the meeting and to come up with a
much better solution to the problem.
Mr. Mike Chankin,
Minutes of the White
River Public Meeting
Due to the issues associated with the P166
servitude in the White River area as identified
by specialists and various stakeholders alike,
a new alternative has been created (to be fully
assessed in the EIAR phase of the project) in
the White River area as a way of potentially
mitigating environmental impacts associated
with the P166 servitude in the White River
area where the wetland is located..
Mr. John Millett wanted to know where exactly the
proposed road would join the Hazyview Road (R40).
Mr. John Millett, Minutes
of the White River Public
Meeting
Mr. Da Cruz responded that the planned
intersection would be just to the south of
Casterbridge and indicated this point on the
map.
Mr. Millett explained that he lives close to Hazyview road
and there are lots of accidents on this road. He was
concerned that this is going to push more traffic on the
already existing road which has lots of accidents. He
Mr. Millet,Minutes of the
White River Public
Meeting
Mr. Venter responded that originally, the P166
road was meant to link with the R538 road
that heads east from Casterbridge towards the
Numbi area, but that under the current
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suggested the road be moved to the east of Hazyview to
avoid accidents.
situation this is not considered optimal as the
R538 cannot function as a high mobility road
operated by SANRAL. The P166 would thus
join with the R40 Hazyview road at Caster
Bridge.
Mrs. Candy Guile raised a concern about the size of the
notices that were displayed alongside the area regarding
the EIA process for this proposed project. She has sent
some comments to the PPP team and did not get
response. She also asked if SANRAL would compensate
the affected property owners and how long the affected
people would be given before being moved from the
affected areas.
Mrs. Candy Guile,
Minutes of the White
River Public Meeting
Mr. Da Cruz apologized if the size of notices
placed was considered to small to be
practically visible and said this would be
looked at for the PP process going forward.
Mrs. Kate Barnett commented that there is no major need
for the P166 to connect to the R538 and to the R40 in the
Casterbridge / Baghdad Café area as a bypass. She
suggested that this bypass can be connected to the R40
further away from White River. She also informed the
meeting that there would be another wetland that would be
damaged if the road moved 1 kilometer to the west.
Mrs. Kate Barnett,
Minutes of the White
River Public Meeting
Alternatives, including upgrading of the R538,
have been addressed in the updated “Needs
and Desirability” section of the Draft Final
Scoping Report. An integrated transport study
is being proposed to address the traffic flow
issues relating to the proposed road and the
future traffic flow needs.
Further to this comment and others, based on
specialist inputs as well as public comment
and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
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Accordingly a new alternative, the White River
North Alternative has been created, and will be
comparatively assessed against the existing
servitude in the EIAR phase of the study.
Mr. Da Cruz responded that due to the nature
of drainage in the area, it is difficult to develop
a road without affecting any wetlands. He
however informed the meeting that the team
will considered all suggestions regarding
alternatives in detail.
Mr. Alastair Nachij raised a concern that the ESR refers to
economic growth and population growth but did not say
exactly where this is happening. He informed the meeting
that the population density in the area is highest in the
townships to the north that extend all the way to
Bushbuckridge, and in the areas to the east to Ka-Bhokweni
and along the Airport road. These areas thus present the
highest traffic flows, thus the proposed road should be
routed down to the eastern side of White River.
Mr. Alastair Nachij,
Minutes of the White
River Public Meeting
Alternatives, including upgrading of the R538,
have been addressed in the updated “Needs
and Desirability” section of the Draft Final
Scoping Report. An integrated transport study
is being proposed to address the traffic flow
issues relating to the proposed road and the
future traffic flow needs.
Mrs. Disington from the White River Ratepayers‟
Association mentioned that she has seen all the EIAs
being carried out against the communities‟ objections.
She advised that South Africa is a dry country that needs
water hence wetlands should be conserved. She
suggested that an alternative should run within the area
covered by plantations.
Mrs. D Disington,
Minutes of the White
River Public Meeting
Based on specialist inputs as well as public
comment and feedback relating to areas of
environmental sensitivity, a number of
environmental issues were identified in the
area where the P166 servitude traverses the
White River area, in particular relating to where
the servitude runs directly through a wetland.
Accordingly a new alternative, the White River
North Alternative has been created, and will be
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comparatively assessed against the existing
servitude in the EIAR phase of the study.
Mrs. Shareen reminded the meeting that when the R40
was constructed in Nelspruit, they commented and
objected to the crossings of big wetlands. She informed
the meeting that people from overseas paid a lot of
money to stay in areas with a beautiful view from their
houses but government has undertaken developments
destroying wetland and birds habitats. She commented
that what the community is saying will not make any
difference at all as SANRAL will go ahead with the
proposed project.
Mrs. Shareen, Minutes
of the White River Public
Meeting,
Mr. Da Cruz responded that the community
has the right to object and to appeal, but
should put forward their reasons for objecting
to the proposed developments
WETLAND
Please note – the wetland area as traversed by the existing road servitude in the area between White River and Colts Hill is referred to as the “White
River Wetland” in the responses below
One of the alternative routes is through part of our
scheduled rateable areas, i.e. areas with an existing water
allocation from the water distribution scheme. It is all high
productivity farmland. Removing some of this land out of
the scheme has the potential to upset the viability of the
affected farming enterprises, which will result in impacts all
water users from the scheme as it is funded by all irrigators.
Removing some will place a greater financial burden on
remaining irrigators.
There is no indication how the Board‟s servitudes may be
impacted. This proposed road of roughly 80 meters wide
will severely impact on the waterworks as well as the
Barry Carlse, Sand
River Irrigation Board,
Comments E-mailed
The potential impact of the proposed road on
agricultural activities is recognised, and as such
an agricultural potential study was commissioned
for the scoping phase of this EIA. The social
study has also identified the potential impact of a
loss of income due to sterilisation of agricultural
land. These issues will be further assessed by
the respective studies in the EIR phase of the
project.
The EIA project team does not have the
servitudes of the Board in order to determine
how these would be affected. A request has
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maintenance and management of the water works owned
and managed by the SRIB.
The location of a major road close to the water works can
lead to potential damage to the canal system, pollution of
the water; either during construction or during road use
(consider spills). Responsibilities and losses incurred by
irrigators using polluted water needs to be accepted by the
road operator and sound mitigation measures need to be
included in the EIA report.
The proposed P166 impacts on many wetlands - travelling
the length and not crossing in most cases. These wetlands
are critical components of the various catchments of the
White River, Nels River and Sand River, all draining into the
Crocodile River. The importance and critical function of
these wetlands for flood attenuation, ground water
recharge, sustained water release, ecological flows and
river health are well recognized.
The Crocodile River is currently over allocated by ± 200 000
cubic metres per annum (120%). Shortages of water will
severely impact municipalities (and residents) of White
River, Nelspruit, KaNyamazane, Matsulu, Malelane,
Hectorspruit, Marloth Park, Komatipoort as well as
Mozambique, the neighbouring country. It is therefore
essential that the loss of these wetlands be considered on a
much broader scale - and particularly in respect of river
been made to the board to acquire these. It
should be noted that Phumlani Alternative 1 has
been discarded for the EIR phase of the project,
and this may have implications for whether these
servitudes are affected or not.
If relevant (based on the final proposed
alignment and whether canals could potentially
be affected), these mitigation measures will be
included in the EMPr.
The ecological and hydrological functioning of
wetlands in general, and in the context of the
study area is recognised, and is discussed in the
scoping-phase wetland report.
The Catchment Management Context is
recognised, especially the role that wetlands
perform in ensuring quality, and in some
respects quantity of water available. The scope
of this EIA is to consider the impacts that would
result from the proposed road, if developed, but it
is fully acknowledged that cumulative impacts
need to be taken into account. Although it is
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health and impact on downstream water users. It is
suggested that a complete modelling of the wetland losses
be undertaken to predict the impact associated with high
and low rainfall years and the loss of the wetlands. There
has already been a significant loss of wetland functionality
through the development of informal settlements in the area
and the P166 will only compound the situation.
The SRIB has not seen, or is aware of, any mitigation
measures to address these critical factors and therefore
strongly opposes this development.
beyond the scope of this study to undertake a full
catchment-level hydrological modelling exercise,
the cumulative impacts in terms of potential
wetland area loss related to the proposed road
will be investigated in the EIR-phase wetland
study
If relevant (based on the final proposed
alignment and whether canals could potentially
be affected), these mitigation measures will be
included in the EMPr.
“The valley is a natural storm water drainage system: any
road construction here would be extremely dangerous and
unwise, especially should we have a repeat of the type of
storms experienced in the last two years”
(Note – the valley referred to is the White River Wetland)
Rob McQueen
Comments E-mailed
It is acknowledged that storm water from the
adjacent suburbs of White River is discharged
into the wetland area, as evidenced by a number
of storm water outflow pipes into the wetland.
The management of this storm water if a road
were to be developed through this area is not a
specific wetland-related issue, but the design of
the road through the wetland (if the road is
approved to pass through this wetland) will have
to consider storm water implications. Potential
impacts of the road in terms of storm water
creation and the resultant impact on wetland
hydrology will be one of a number of potential
impacts of the road that will be further
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investigated in the EIA-phase wetland report.
I am concerned about wetland encroachment and
traffic routing.
Robin Clanahan
Comments &
Registration form
Emailed
The importance of wetlands in terms of their
ecological functionality, especially in terms of
being located in a landscape transformed to a
large degree by agricultural activities is
supported. The ecological importance of
wetlands as movement corridors is discussed in
the scoping-phase wetland report.
The potential impact of the proposed road on
wetlands along alternatives considered in the
EIR phase will be further assessed in the EIR-
phase wetland study.
The route through White River: Planned to pass through a
wetland, “bird-sanctuary” and too close to my properties.
Rob McQueen,
Comments Emailed
The significance of the potential impact of the
proposed road on the White River wetland is
recognised. In this context, due to the issues
associated with the P166 servitude in the White
River area as identified by specialists and
various stakeholders alike, a new alternative has
been created (to be fully assessed in the EIAR
phase of the project) in the White River area as a
way of potentially mitigating environmental
impacts associated with the P166 servitude in
the White River area.
“There are many other issues that come to mind
It (Proposed alternative 1) will impact badly on wildlife
habitat and natural wetlands, which are particularly precious
as they are so close to urban and industrial areas.”
Dave Goodwin,
Comments Emailed
The importance of wetlands in terms of their
ecological functionality, especially in terms of
being located in a landscape transformed to a
large degree by agricultural activities is
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supported. The ecological importance of
wetlands as movement corridors is discussed in
the scoping-phase wetland report.
The potential impact of the proposed road on
wetlands along alternatives considered in the
EIR phase will be further assessed in the EIAR-
phase wetland study.
“My points of concern are as follows
Negative Impact on wetlands and wildlife.”
Mark Attwood,
Comments Emailed
The potential impact of the road on wetlands has
been scoped in the wetland study, and a number
of potential impacts have been identified. These
impacts will be further assessed in the EIAR-
phase wetland study.
“My points of concern are as follows
2) Negative Impact on wetlands and wildlife.”
Alan Luus, Comments
Emailed
The potential impact of the road on wetlands has
been scoped in the wetland study, and a number
of potential impacts have been identified. These
impacts will be further assessed in the EIR-
phase wetland study.
Scoping study
The history and development of White River needs to be
considered in context of the proposed routing. There has
been comment from municipality in the past that the
wetland sections would never be suitable for a road – this
may have affected decision making and subsequent
township development. Dating back at least 10 years,
efforts have been made by various parties, through the
Mpumalanga Wetland Forum, to have the servitude through
the wetlands de-proclaimed. The Department of Water
Affairs (Then DWAF, now DWA) commented in this
connection, that the construction of the bypass would never
be allowed to go ahead through the wetlands.
Mr Andrew Rossack
Comments E-mailed
We cannot comment on previous comments
made by the Department of Water Affairs made
on matters not directly related to the current EIA.
Nonetheless the point made is recognised, that
the proposed road servitude through the White
River wetland has the potential to result in a
significant impact on this wetland as a large area
of wetland could potentially be affected. This has
been flagged as an important issue in terms of
the scoping-phase wetland study, and will be
further investigated in the EIR-phase scoping
study, which will include a delineation to
determine the extent of the wetland area affected
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Wetlands
The importance of wetlands in the area cannot be over
emphasized. With the establishment of the Phumlani and
Msholozi areas, large wetlands have been impacted,
channelized, and degraded. The study MUST look seriously
at the CUMULATIVE impacts of the wetland impacts for the
whole area.
The wetlands must be fully delineated, including all the
common hill seeps as well as the wetland catchments (and
impacts therein).
The flood attenuation and ground water recharge are critical
functions of wetlands in the White River area. Many
by the servitude.
The cumulative historical and recent loss of
wetlands in the wider area is recognised. As
such cumulative impacts related to the proposed
development, especially in terms of wetland
transformation and loss will be assessed in the
EIR-phase wetland assessment.
The scope of this EIA relates to the route
determination of the proposed road. The
proponent has stated that separate processes
(Basic Assessment studies) will be undertaken
for other listed activities associated with the
construction of the road. Detailed delineations of
all wetlands along the finalised route will be
undertaken as part of this process. However in-
field delineation is being undertaken as part of
the present wetland studies where required in
order to determine the degree of impact on
affected wetlands and in order to characterise
the wetlands potentially affected. As such in-field
delineation will be focussed on prioritised
wetlands in order to determine the degree of
impact of the road on these key systems.
The ecological and hydrological function of
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residents are dependent on groundwater due to limited
municipal supply.
The wetlands largely feed the Nels and White River – both
tributaries of the Crocodile River. The Crocodile River is
under extreme stress, being over 120% allocated. Wetland
report must therefore consider carefully their function in the
ecosystem, importance of maintaining ecological flow.
Wetland assessment must model the impact of their loss on
stream flows and flood attenuation.
Wetland assessment must consider climate change and the
function and risks of wetlands and downstream activities
under climate change scenarios.
wetlands has been addressed in the scoping
phase wetland study.
The Catchment Management Context is
recognised, especially the role that wetlands
perform in ensuring quality, and in some
respects quantity of water available. Functionality
of potentially affected wetlands will be
considered in the EIR-phase report.
The scope of this EIA is to consider the impacts
that would result from the proposed road, if
developed, but it is acknowledged that
downstream impacts need to be taken into
account (downstream impacts are discussed in
the scoping-phase wetland study). Although it is
beyond the scope of this study to undertake full
catchment-level hydrological modelling exercise,
potential downstream impacts in terms of
potential wetland transformation related to the
proposed road will be investigated in the EIR-
phase wetland study
The scope of this study is limited to a
consideration of the impact of the proposed road
development on wetlands and other surface
water resources within the affected area. The
effects of climate change are long term and there
is much uncertainty attached to climate change
scenarios. Due to the difficulty of applying the
effects of possible climate change at such a fine
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scale, a consideration of climate change
scenarios is not possible as part of the current
study.
“Almost the whole of the section through White River
northern suburbs is in wetlands that would be moderately to
severely impacted. The “spot” water course / wetland
crossing points on the DSR maps are a poor representation
of the extent of these impacts. The geological formation in
the conservation area and wetlands is most unsuitable for
the construction of a heavy duty road.”
Mbombela Ratepayers
Association – White
River Branch
The extent of the potential wetland area that
could be affected / impacted by the proposed
road servitude through the northern part of White
River is acknowledged. This area has thus been
highlighted as a priority wetland for further
assessment.
The ““spot” water course / wetland crossing
points” as referred to in the comment were used
on the maps in the report to provide an indication
of the number of wetlands crossed per
alternative at a high-level scale. Boundaries of
wetlands along the alternatives being assessed
in the EIR phase will be indicated in the EIR-
phase wetland study maps.
“I object to the current proposed route for the P166 Road
from where it crosses the road to Sabie and passes through
the wetland and joins up to the R40 next to the Casterbridge
Lifestyle Centre.
My objections to this part of the proposed route is on the
following grounds:
I. This route will have a massive negative impact on
the precious wetland which it is going along - not
through or across. Not only is this a green lung for
White River and a Nature Reserve much used by
the community, but all wetlands are vital to the
health of our precious rivers. There is no design
possible that could keep the road going through that
Kay Barnett,
Comments
E-mailed
The first point in 1) raised is an important one, as
the way in which a road crosses a wetland is
very important in terms of the nature and
intensity of the impact on the wetland. This
relates to the relative spatial area of the wetland
that is impacted upon / transformed by the road;
when crossed perpendicular to a typically linear
wetland / drainage feature, the area transformed
is much smaller than if the road runs through the
wetland area obliquely or along the feature. In
the context of the White River wetland, this issue
has been noted as a very important potential
issue that will need to be further investigated in
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Wetland without irreversibly destroying it.
II. In addition I am aware that it is one of the few
places that Aloe Simii are still found in their natural
habitat. Plus there is a rare frog inhabiting the
wetland. These are very significant facts that should
immediately prevent this route being used and any
other route that passes along a wetland.”
the EIR-phase of the study to determine the
nature of the impact of the proposed road on the
wetland along the entire stretch of the road as it
traverses the wetland.
The critical functionality of wetlands in ensuring
river health is acknowledged, and has been
discussed in the scoping-phase wetland report.
In response to point 2), The ecological
importance of the wetland has been raised by a
number of parties. The presence of threatened
species and the provision of habitat for these
species within the wetland increase the
importance of the wetland in terms of an
assessment of its functionality (in terms of
ecosystem goods and services provision) and its
current state.
In the context of this comment, based on
specialist inputs as well as public comment and
feedback relating to areas of environmental
sensitivity, a number of environmental issues
were identified in the area where the P166
servitude traverses the White River area, in
particular relating to where the servitude runs
directly through a wetland. Accordingly a new
alternative, the White River North Alternative has
been created, and will be comparatively
assessed against the existing servitude in the
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EIAR phase of the study.
“While the route(s) through the illegal township of Msholozi
effectively dismisses the destruction and loss of vital
wetlands, it painfully struggles to find a way through the
morass of congested human habitation which has been
allowed to grow unchecked.”
Peter Dobble,
Comments Emailed
It should be noted that wetland impacts across
all of the Phumlani Alternatives, including that
along the existing servitude, have been
considered, and will be further considered in the
EIR-phase wetland study.
Please register me with the project in my personal capacity.
I suggest you also ensure that the Rate Payers association
is also registered and WESSA Lowveld.
I have briefly looked at the BID map - it is much too small
and lacks necessary detail. Please re-issue the BID with
maps that clearly identify the proposals. It is unclear what
section of road the application is for.
You need to provide more information.
Your BID does not make any reference to alternative
activity or alternative locations
You need to consider additional activities in 544.
I am very familiar with the area. I suggest that as an
absolute minimum, and prior to the scoping report being
released, you undertake the following regional studies:
Current wetlands
2. Current wetland functionality.
Mr. Andrew Rossack,
Comments Emailed
You have been registered on the project
database and you will receive all information
regarding the project.
The Rate Payers Association WESSA has been
registered on the project database.
The information provided in the BID document is
basic and not too technical to ensure that people
of all level of education can understand the
message. The Scoping Report will provide much
detailed information required. Should you
require any technical information which is not
covered in any of our public documents Kindly
request it and it will be sent to you.
A separate Basic Assessment process/es will
be undertaken to address GNR544 activities (this
EIA is only route determination and only the
route determination activity will be authorised by
DEA)
In answer to your request for regional wetland
studies, the project team would like to point out
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3. Wetlands lost since 2000
4. Wetlands lost since ECA and NEMA acts were signed
into force.
I suggest you will find that mapping the wetlands and
joining them will follow the road route almost exactly. You
may also be able to confirm my initial studies that indicate a
greater than 60% wetland loss since 2000 for the greater
White River area, as well as significant losses of
irreplaceable habitat (as per the MBCP).These factors have
to seriously be considered as part of the cumulative
impacts.
The existence of servitude, acquired prior to an
understanding of wetland function (1960's) and the
desirability of such is not a basis for failing to seek out a
more favorable route. In this respect, we are dealing with a
lasting footprint, and thus cost is the least concern.
the scope of this project in terms of being an EIA
for the route determination of a proposed road
that would be operated by SANRAL. The EIA is
focused on the alternative routes that have been
proposed for the road routing and the areas
traversed. As part of the surface water study, all
wetlands potentially affected by the proposed
road have (and will be) considered by the
surface water study. This includes the wetlands
within the proposed road servitude footprint, but
also downstream and other immediately adjacent
surface water features. The study will include a
high level examination of the functionality of the
affected wetlands using the framework provided
by the WET-EcoServices Tool.
Unfortunately it is not part of the scope of this
EIA to determine or quantify regional trends of
wetland loss, and how many wetlands have been
lost since 2000 or since certain laws were
passed into effect. Any EIA focuses on the
spatial scale of the proposed development and
as EAPs and specialists we are mandated to
examine all possible impacts relating to the
proposed development and how these can be
mitigated. Unlike strategic, wider level
assessments such as Environmental
Management Frameworks, State of the
Environment Reports or Strategic Environmental
Assessments EIAs do not quantify trends of
wetland loss in a spatial context wider than the
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potentially affected area. Studies assessing /
quantifying regional wetland loss in an area such
as the Mbombela LM would need to be
undertaken as part of one of these wider-level
studies,.
However the EIA process obliges us to examine
cumulative impacts, and as such the EIR-phase
wetland study will need to examine how the
proposed project may cause / exacerbate
cumulative impacts, such as area-wide /
catchment-wide wetland loss.
I would like to confirm that alternative routes are
being considered; the original routing is an old
provincial servitude and alternative routings have
been identified in areas of environmental
sensitivity (both biophysical and social), and the
wetland study will include a comparative
assessment of these routes to propose a
recommended routing from a wetlands
perspective. The consideration of a preferred
routing will also take into account any measures
to avoid significant impacts on wetlands.
The route will go through a wetland area, the current sense
of place would be disturbed
Leandri Joubert,
Comment &
Registration Form,
Emailed,
The potential impact of the road on wetlands
has been scoped in the wetland study, and a
number of potential impacts have been
identified. These impacts will be further
assessed in the EIR-phase wetland study.
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My concern is that the project encroaches on a wetland and
affects traffic routing
Charles Robin Hugh
Clanahan, Comment
& Registration Form,
Emailed
This factor is recognised, however the current
EIA is being undertaken in terms of updated
legislation that requires the impact of a
proposed development on environmental
features such as wetlands to be fully considered.
As such the impacts on wetlands will be fully
assessed in the EIA. The EIA process is bound to
identify suitable mitigation measures for all
impacts identified; in the context of wetlands,
this includes routing, design changes, and even
the consideration of alignment alternatives.
I‟m concerned about degradation of wetlands, road
crossings / overpass designs.
Robin Clanahan,
Comment &
Registration Form,
Emailed, White River
Ratepayers
Association
The way in which a road crosses a wetland is
very important in terms of the nature and
intensity of the impact on the wetland. This
relates to the relative spatial area of the
wetland that is impacted upon / transformed by
the road; when crossed perpendicular to a
typically linear wetland / drainage feature, the
area transformed is much smaller than if the
road runs through the wetland area obliquely or
along the feature. In the context of the White
River wetland, this issue has been noted as a
very important potential issue that will need to
be further investigated in the EIR-phase of the
study to determine the nature of the impact of
the proposed road on the wetland along the
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entire stretch of the road as it traverses the
wetland.
SOCIAL ISSUES
Needs of the low income population of Mbombela which lies
east of the Hazyview/ KMIA axis
Expand development between the Kruger National Park
boundary, with its parallel rail line and the Hazyview/ KMIA
axis”
The issues of HIV/AIDS have little relevance in this report
“The key strengths of the Ehlanzeni DM and Mbombela LM
have to be enhanced, to cater for the very large population
of unemployed, with a high proportion of illiteracy. These
have little to no bearing on the route selection.”
We also consider the area between the Msholozi
(Dingwell/Phumlani) informal settlement and the R40 to be
suitable for industrial development the alternative Phumlani
3 route would largely eliminate this feasible development”
Robin Clanahan, CRH
for White River
Ratepayers
Association,
comments Emailed
This project is meant to promote positive growth
and development, as in the vein of most
infrastructure projects. This project looks at the
development of a new route linking White River
to Nelspruit and thus the N4. R538 as alternative
route has been addressed in the “Needs and
Desirability” section of the Draft Final Scoping
Report.
Profiling the vulnerabilities of a community
(Mbombela) or local municipality should include
all aspects of social and economic relevance.
HIV/AIDs are of both social and economic
relevance. This is after all a Scoping report –
which is meant to set the scene for the impact
assessment to come.
Profiling the vulnerabilities of a community or in
this case the LM should include all aspects of
social and economic relevance. Unemployment
and illiteracy is of both social and economic
relevance. This is after all a Scoping report –
which is meant to set the scene for the impact
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The alternative Phumlani 1 route through the upper section
of the farm Heidelberg passes through valuable agricultural
land Rendering them unviable for agricultural process”
Should the P166 be tolled, there would be a number of
large vehicles passing through White River central area.
The drivers of which are pocketing the toll fees
assessment to come. The SIA will have to
investigate how Phumalani 3 could impact on
potential industrial development in the area
between the informal settlement and the P9/2
road.
The Phumlani Alternatives 1 and 3 have been
discarded as they are not regarded
environmentally feasible, and will not be
considered further.
Tolling of P166 is a funding issue which will only
be considered once implementation is due. This
does not have any effect on the route as
proposed.
These property owners will be affected by this road in the
following ways:
a) Noise pollution from the road
b) Unsightly flyover road visible right next to their houses
and from afar
c)Property values will be hugely reduced as a result of this
road, especially those closest to the current route.
Kate Barnett,
Chairman of the
Environmental
Committee of Uplands
College, Comments E-
mailed
In the context of noise-related impacts one of the
most sensitive receptors are the noise-sensitive
residential areas, and these areas will be the
main focus of the noise impact assessment study
in the EIAR phase. The noise levels from the
projected traffic volume will then be compared
with the prevailing ambient noise level to
determine the intrusion level at the different
noise sensitive areas and mitigation measures
will be suggested.
A number of I&APs have raised visual-related
issues. This comment refers specifically to the
potential impact of the proposed road on the
„sense of place‟ in the area. In order to address
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these concerns, a visual impact assessment
study will be undertaken in the EIAR phase of
the project.
The socio-economic study has identified the
potential negative effect of the road through the
White River area on property value. This will be
further assessed in the EIAR-phase social study
The Cromdale Intersection, from a planning and
development perspective, is situated to close to already
highly densified rural residential areas, other economic land
uses and agricultural activities. The locality of the Cromdale
Intersection should be reconsidered for the following
reasons:
It will form an unacceptable physical barrier at the southern
edge of the current semi-urban area and future residential
areas as provided for in the approved Mbombela Spatial
Development Framework, 2011 (SDF). Future urban
development according to acceptable town-planning
proposals will be drastically impacted upon and ignored if
consideration is not given to alternatives for the Cromdale
Intersection.
Areas proposed in the SDF for future development,
especially residential development will be physically
separated and divided in terms of access, services
provision, urban integration and implementation of planning
principles and policies if the Cromdale Intersection remains.
Further alternatives for the Cromdale Intersection and the
Hennie van Rensburg,
Nuplan, Comments
Emailed
The P166 route as presently defined has formed
an integral part of the Mbombela SDF for many
years. The Mbombela roads master plan has
been defined to incorporate P166 and define
access for the Cromdale area via class 2 and 3
roads.
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section of road P 166-2 north thereof is there for justified.
There is a governance disaster in the making at Msholozi
squatter camp where Mbombela is accommodating an
unstructured land grab which could:
i. Either impact negatively on the routing of the road.
ii. Or cause unnecessary social upheaval if handled heavy
handed.
Theunis Steyn,
Registration form,
Emailed
Matters relating to impacts that involve the
informal settlement will be investigated during
the social impact assessment.
A number of I&APs have raised the issue that
parts of the Msholozi-Phumlani settlement were
allegedly “illegally” settled. Nonetheless a
housing development & community now exists
within certain parts of the servitude and wider
area (in which alternatives to the existing
servitude in the Msholozi area are being
considered) and as such the potential social
impact of the proposed road on this community
needs to be considered by this EIA and
compared with the impacts of the alternative
alignments.
GENERAL ISSUES
Concerned about the effect on water sources (borehole).
Concerned about safety and security, noise pollution, wild
life in the area.
Concerned about the route and numbers of affected
properties. Most traffic on R40 is commuters working in
Nelspruit. Is this project economically viable/necessary
Linda Liversage,
Comment &
Registration Form,
Faxed
An EIA is being undertaken for the proposed
project to determine whether the development of
a road would be environmentally sustainable.
The EIA and associated specialist studies will
look into these issues raised.
Uplands are an Independent Co-Educational school in close
vicinity to the proposed P166 Road. We would like to be
Katia van der Merwe,
Uplands Collage,
The school have been registered as one of
interested and affected parties and they will be
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kept posted on any development as it might affect our
educational environment
Emailed included in all communication regarding the
proposed project
From early December 2012, at first notice, I have requested
improved maps for the proposed development. These were
only supplied AFTER the public participation meeting. Prior
to the meeting, it was unclear as to where the roads were
intended to go. It is most unfortunate that this error may
have meant some parties were not aware and thus have not
attended the first round of public meetings.
In the public participation meetings (repeated and I did not
attend the first), there was incorrect processes shown in
that it was indicated that the public would not have an
opportunity to review and comment on the final scoping
report.
Andrew Rossack,
comments E-mailed
This error in the presentation is acknowledged
and was corrected for subsequent presentations
Report back by I & AP's from some of the public meetings
has been the impression gained from the EAP is that the
proposed P166 is a fait accompli.
Andrew Rossack,
comments E-mailed
The claim that the proposed road is a fait
accompli is incorrect. An EIA is being undertaken
for the proposed project to determine whether
the development of a road would be
environmentally sustainable.
The route determination process now under consideration
has not presented exact details as part of the public
participation process but only presented approximate
alignments as per Plan No N 2317 – Locality Map prepared
by Endecon Ubuntu Engineering Consultants.
Hennie van Rensburg,
Nuplan, Comments
Emailed
Full details of the public participation undertaken
will be made available in the Draft Final Scoping
Report made available for public review.
In our email correspondence of 23 and 26 November 2012,
we requested to be registered I & AP's to which you replied
that we would be kept informed. It has now come to our
attention that numerous public meetings were held in the
Barry Carlse, Sand
River Irrigation Board,
Comments e-mailed
RHDHV acknowledge the negative impact this
miscommunication had on your organisation and
project. We truly believe that your role in the
project is critical hence your organisation was
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week of the 11th March.
Can you please explain why we received no notification of
these meetings? We believe irrigation boards are important
stakeholders, representing the interests of various parties.
What measures do you intend to undertake to address this
serious flaw in your public participation process? It is also
unclear as to where you wish correspondence to be
addressed to your Cape Town office or Johannesburg
office?
identified as one of the critical stakeholders when
the project commenced.
Your organisation is registered in the project
database and you will receive project
correspondence. We acknowledge the
seriousness of the matter and its consequences
for the environmental study being undertaken
and sincerely apologised for the inconvenience.
All project correspondence should be sent to our
Johannesburg Office
I appreciate having roads constructed but request that the
local public be employed.
Safety of the public is my concern, so I think Phumlani 2
Alternative will be right.
Thabo Dube,
Comment Form
Minutes of Phumlani
Public Meeting,
The employment of people will be carried out
during the construction phase of this project and
SANRAL will follow the existing labour legislation
and regulations or guidelines.
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the pubic. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative is recommended December Ndziane,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the pubic. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
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111 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative is recommended Jeoffrey Mthethwa,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the pubic. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative but also to be shifted
away from the community.
Lucky Lukhele,
Comment Form: P
Minutes of Phumlani
Public Meeting
The environmental team will assess this
alternative including the recommendation and
will recommend where the best line should run
based on the environmental assessment. In the
context of this comment it is important to note
that due to environmental issues Phumlani
Alternatives 1 and 3 have been discarded and
will not be considered in the EIAR phase.
Selection of Phumlani 2 Alternative. This will create jobs for
the community.
Caris Ndhlovu,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative. This will empower the
local community.
Oupa Mokoena,
Comment Form:
Minutes of Phumlani
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
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Public Meeting 13
March 2013
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative. This will empower the
local community.
Linah Biya Mathebula,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative. This will empower the
local community.
Lucia Mathebula,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative is recommended
Margaret Mudaka,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
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Selection of Phumlani 2 Alternative.
Consider the human nature.
Louis Sidubela,
Comment Form:
Minutes of Phumlani
Public Meeting:
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
Selection of Phumlani 2 Alternative.
This will create jobs for the community.
Sonto Nkosi,
Comment Form:
Minutes of Phumlani
Public Meeting
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
We need this road in the area. Comment form from
the Minutes of
Phumlani Public
Meeting
The need and desirability of the proposed project
has been indicated in the report and assessment
of all alternatives will be undertaken whereby the
final decision will be the responsibility of the
DEA.
Selection of Phumlani 2 Alternative.
Robert Lekhuleni,
Comment Form
Phumlani Public
Meeting:
The environmental team will assess all the
alternatives and will recommend those that are
feasible based on the environmental assessment
and comments from the public. In the context of
this comment it is important to note that due to
environmental issues Phumlani Alternatives 1
and 3 have been discarded and will not be
considered in the EIAR phase.
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This will create jobs for the community.
We need more safety to the area.
Bigboy Khumalo
Comment Form:
Phumlani Public
Meeting
Job creation and road safety will be addressed
during detail design. Impact of Phumlani
township on road safety is one of the reasons for
consideration of alternative alignments.
With regard to yesterday's meeting at Phumlani Village, we
as members of the community and ANCYL BTT we were
not happy about the unconstitutionality of the meeting, the
meeting was non political but it was chaired by a political
appointee of the community, in our capacity as ANCYL BTT
we found that to be improper and unconstitutional in so
many levels, we want the RHDHV to come back and host a
proper meeting chaired by them, Not DA, not ANC.
As the ANCYL BTT we are going to do everything in our
power to ensure that OUR community's interests are put
before anyone else‟s, as it was evident in yesterday's
meeting that you(RHDHV) have already chose people to
work with and excluded others. We want to talk as ANCYL
BTT with you, to correct your mistake moving forward.
Ngumazino Khoza,
ANCYLBTT
coordinator)
Comments Emailed
The involvement of local ward councillors is a
standard public participation procedure in
environmental impact studies conducted across
South Africa and it is also a legal requirement of
the Environmental Impact Assessment (EIA)
Regulations (2010), R54(b)iv. As an elected
official representing the community, RHDHV
requested the councillor to open and close the
public meeting.
We understand through your e-mail
correspondence that you are uncomfortable with
the fact that the ward councillor was involved in
the facilitation of the public meeting for the
Scoping phase and this is noted as part of our
public participation records for the project. Your
concern will also be conveyed to our Client, the
local council and the environmental authorities.
Your issue in this regard was not raised during
the public meeting itself and we see no merit in
holding an additional meeting at this stage.
There will be a further meeting during the next
consultation phase of the EIA and we will seek to
find a way to accommodate your concerns in
running this next meeting in Phumulani.
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