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

EIA FOR THE PROPOSED LANGEZANDT QUAYS DEVELOPMENT IN STRUISBAAI HARBOUR: CRR
3.1.112
3.1.113
3.1.114
Justine Sweet (97)
Justine Sweet (97)
Justine Sweet (97)
The EAP is a well known and well regarded
firm and we do not wish to place its integrity
in question. However, given the
requirement that EAPs must at all times
remain objective and independent in their
duties as a practitioner, we are constrained
to point out the following: Throughout the
public participation process, questions of
the EAP's independence and objectivity
have been raised. In this regard, we refer
to the minutes of the public participation
meetings;
The EAP has not specifically made any
recommendation on whether or not the
proposed development should proceed.
As an independent expert, the EAP's
responsibility is, in our view, to make a
recommendation on whether or not a
particular development is appropriate in the
circumstances. In our view, the EAP has
failed to do so.
It appears that, where contentious issues
arise, the EAP simply refers to the
proponent's argument or decision. In this
regard, we refer to paragraph 2.4.5. of the
draft EIR in which, with reference to the
request that the development proponent
consider a two storey alternative, it states
that "the proponent has argued that a two
storey building will not be financially
sustainable …" The EAP has apparently
not committed itself to a conclusion either
way. This, in our view, and more
particularly given the integrity of the EAP, is
problematic
It is often the case that I&APs make
allegations about the Environmental
Assessment Practitioners. More specifically, if
I&APs do not agree with the Environmental
Assessment Practitioner findings. Aurecon
maintains that these allegations are
unreasonable and unjustified. Please refer to
Section 1.8 of the FEIR.
Disagree. The Environmental Assessment
Practitioner has provided its opinion in Section
7.5 of the DEIR and the FEIR in terms of
Section 32 (2) m in GNR 385 (the NEMA EIA
Regulations). Conclusions were provided in
Section 6 of the DEIR and FEIR.
With reference to Annexures P & R of the
FEIR it is clear that a 2 storey alternative is
not financially feasible or reasonable in the
circumstances. The EAP obtained a
motivation of market and economic viability
which has been independently reviewed. As
such we accept the argument that the
proponent does not wish to apply for this
option and requires only a decision on the
option it has shown to be reasonable and
feasible. - The EAP thus assessed
alternatives that are considered financially
feasible and as such the decision making
authority would need to apply their minds to
consider if the proposed development is
acceptable within the context of the receiving
environment.
Process
Process
Process
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