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

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EIA FOR THE PROPOSED LANGEZANDT QUAYS DEVELOPMENT IN STRUISBAAI HARBOUR: CRR 3.1.131 3.1.132 3.1.133 Justine Sweet (97) Justine Sweet (97) Justine Sweet (97) At the outset it is important to note the emphasis which NEMA places on the required investigation of the potential consequences or impacts of alternatives to a proposed activity on the environment within an application for environmental authorisation [Section 24(4)(b)(i)]. The EIA Regulations require both a basic assessment report and a scoping report to identify feasible and reasonable alternatives to the proposed activity [Reg. 23(1)(g) & 29(1)(b) in GNR 385]. Given, amongst other things, the present economic crisis as well as the large bond on the property, there is some concern that there may not be sufficient financial resources to see the proposed development to completion. In this regard, and in the unlikely event that this development is approved, we submit that the development proponent ought to provide some comfort (by way of, for example, a bank guarantee) to the Department and interested and affected parties we submit that there is scope for this in the dEIA Regs.] Our clients do not deny that the site is presently in a state of disrepair. In this regard, we confirm that our clients would not be opposed to a development which is in line with relevant town-planning restrictions and which adequately accommodates public concerns and rights. NEMA only requires a Basic Assessment Report for the proposed development. However the Environmental Assessment Practitioner applied for an upgrade to full EIA process. Please refer to Section 2.4 of the FEIR and Section 3.1.52 of this Comment and Response Report regarding alternatives. Applicants response: All development funding is put in place pre-sales of an acceptable level is achieved. The developers‟ track record at Langezandt Fishermens Village, a billion rand development, provides proof of the ability to deliver. There is no obligation to provide comfort to I&APs. Your point is noted. Please refer to Section 3.1.52 of this Comment and Response Report. Process Process Process I:\ENV\PROJECTS\401807~Struisbaai\Public Participation\Comments & Response\EIR\CRR IV FEIR ~ 26042010 [FINAL].doc 160 of 193
EIA FOR THE PROPOSED LANGEZANDT QUAYS DEVELOPMENT IN STRUISBAAI HARBOUR: CRR 3.1.134 Justine Sweet (97) We submit that there is insufficient information [e.g. p. 81 of dEIR] in the draft EIR to determine the impact, feasibility and sustainability of the proposed development. For example, the costs of the apparently extensive infrastructure improvements required by the proposed development have merely been calculated on the basis of a 20% cost of development. In our view, this is wholly inadequate. In addition, the Cape Agulhas Local Municipality and the Directorate of Marine and Coastal Management ("MCM") has not been properly consulted regarding traffic and parking [p. 31 of dEIR.] Please refer to Annexure P and Annexure R of the FEIR. The various authorities have been engaged on several occasions throughout the past 3 years. The Cape Agulhas Local Municipality was consulted on the traffic alternatives at a meeting that took place on the 31 July 2009. Telephonic correspondence with Marine and Coastal Management ("MCM"), Desmond Marinus took place on the 30 July 2009 to discuss the traffic options in principle and the proponent was informed that MCM would consider traffic solutions proposed as a product of the EIA process. Process I:\ENV\PROJECTS\401807~Struisbaai\Public Participation\Comments & Response\EIR\CRR IV FEIR ~ 26042010 [FINAL].doc 161 of 193
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CRR IV FEIR ~ 26042010 [FINAL].pdf - Environmental Projects

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