CRR IV FEIR ~ 26042010 [FINAL].pdf - Environmental Projects

EIA FOR THE PROPOSED LANGEZANDT QUAYS DEVELOPMENT IN STRUISBAAI HARBOUR: CRR
3.1.7
3.1.8
Justine Sweet (97)
Brian Knobel (142)
We submit that as presently proposed this
application should be dismissed. In
summary, it is the view of our clients that
DEADP has insufficient reliable information
before him or her to enable an informed
decision. The development proponent has
failed to demonstrate the feasibility of the
proposed development which it must do in
order for the application to succeed. In
addition, the proposed development is
misaligned with the SDF, which is a guiding
document that must be complied with
unless there is a good motivation for
departing from it. Sustainability of the
proposed development has not been
illustrated and the socio-economic impacts
of the proposed development have not been
properly assessed (particularly given the
public rights attaching to the property).
Finally, our clients also have concerns
about the adequacy of the EIA and the
public participation process which are set
out in this document.
In the last meeting at Struisbaai North
Library, I proposed that the developer erect
poles of 16m on the outer extremities of the
development so that everyone can see the
real size of the development and thus avoid
the smoke and mirrors effect that is being
portrayed at present.
We respectfully disagree with this submission.
The process triggered by the activity was a
Basic Assessment. On the advice of the EAP
after initial public consultation the application
was elevated voluntarily to an EIA and was
accepted by the competent authority
(DEA&DP). Numerous specialist inputs,
extensive public participation (as evidenced
by the voluminous comments) and detailed
assessment has been undertaken. There is
sufficient information upon which the
competent authority can base an informed
decision. The choice of the authority however
regarding whether to authorize this application
based on the clear and fully described
planning issues should not be pre-empted.
The 2006 CAM SDF made reference to a
height limitation of two storeys, however the
2009 CAM SDF makes no reference to height
limitations per se. Height is subject to the
applicable zoning scheme regulations and
development is promoted within the urban
edge.
Please refer to Annexure P & R of the FEIR
regarding feasibility. Please refer to Section
1.4 of the FEIR regarding the SDF
implications. Please refer to Table 6.2 and
Annexures P, R & U of the FEIR regarding
sustainability. Please refer to Sections 5.2.3,
5.2.4, 5.2.5 & 5.2.6 as well as Annexure H:
Social and Economic specialist study, of the
FEIR regarding the socio-economic study.
Please refer to Chapter 3 of the FEIR
regarding the public participation process.
Suggestion noted.. This suggestion has been
communicated to the proponent for
consideration.
Process
Process
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