The Gauteng Department of Agriculture and Rural Development rejected the Final Basic Assessment that was submitted and requested additional information.
The reasons for the rejection of the Basic Assessment report as well as the consultants response can be downloaded here:Cover Letter
The Basic Assessment has been amended and is available for review and comment until the 02nd of February 2015.Basic Assessment
GEKCO’s comments on the amended BAR can be downloaded here:
The Draft Basic Assessment report has been released for the construction of Polo Fields on the Inanda Fields Property. This was an agreement reached when Inanda Club sold the property to Century Properties.
Comments are due 28 August. Please register as an Interested Party and send any comments or objections to the consultants at the details below:
GEKCO submitted the following comments:
- Specialist reports required:
The report dismisses the presence of red data or endangered species on the basis that the photos taken do not indicate their presence. No on site investigations have been conducted. These species have been confirmed in the area and are recognised in a number of ecologist reports done for adjacent properties and those within a 2km radius.
The presence of the African Bullfrog is well known in the area and this area was chosen as a research site for the University of Pretoria with a bullfrog conservation programme proposed within 2km from this site. Extract below from the Draft EIA for the Diepsloot East development GAUT 002/07-08/N0420 Yonanda Martin, Newtown Landscape Architects
“6.2 Giant Bullfrog Habitat Assessment
The proposed Giant Bullfrog habitat, on the southern corner of the property, was currently part of a doctoral study undertaken by Caroline Yetman from the University of Pretoria. It is for this reason that we’ve appointed both Caroline Yetman and Vincent Carruthers to make suggestions regarding the protection and conservation of the Giant Bullfrogs and to compile an Environmental Management Plan (EMP) for this specific site. Please refer to Appendix E for the comments from Caroline Yetman and the EMP from Vincent Carruthers.
The Giant Bullfrogs is “Near-Threatened” in South Africa, and the Giant Bullfrog population present on the site represents one of the two potentially viable populations of the species between Pretoria and Johannesburg. According to Caroline’s studies the Giant Bullfrog population has revealed that the adults in the population are concentrated around three seasonal pans situated to the south of the site. The three seasonal pans include the artificial dam and wetland area on the proposed site and the wetland on the neighbouring property (Portions 97 & 100 of the Farm Diepsloot 388 JR) to the southeast of the artificial
dam. In order to protect all the adult bullfrogs it will be necessary to demarcate a 1km buffer zone around these breeding ponds. This is however not achievable as the properties to the northwest, west, southwest, south, southeast and the east are already developed or are demarcated for future development. This leaves the area to the north and northeast of the breeding pans which is the proposed site for the Diepsloot East Residential Development. The only other movement for the Giant Bullfrogs is to the southeast through the adjacent wetland corridor towards the river.”
The report identified an important corridor to the river / riparian zone for bullfrog movement. The river / riparian zone is shown in the top left of this photo. No obstructions are identified between this corridor and the study site, indicating that the bullfrogs currently have free movement to and through the study site.
African Grass Owls:
The presence of breeding African Grass owls is confirmed in the conservancy and has been reported to GDARD. Dr. Theron also handled this application (Blue Hills X74) [Annexure A] and has full details of their presence. Residents have also reported seeing African Grass Owls on the study site.
Professor Andrew McKechnie, ornithologist, viewed the wetland area that runs through the Riversands property and the study site in September 2013 and recommended that:
a) a specialist survey assessing the presence of African Grass Owls and the suitability of natural habitats for this species at Riversands Estate be conducted as part of the Environmental Impact Assessment (EIA) process, and
b) local ornithologists with expertise on African Grass Owls, namely Geoff Lockwood and Dr Craig Whittington-Jones (GDARD), be consulted as part of the EIA process.” [Annexure B].
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We therefore request that a amphibian study and avifauna study be conducted to investigate the presence of these endangered and threatened species.
African Hedgehogs are also regularly seen in the area and an ecologist should visit the site to investigate their presence.
The site constitutes Egoli-Granite grassland which is an endangered vegetation type. This should also be investigated on site by a specialist.
2. The BAR is misleading in terms of what is being applied for and the environmental value of the site.
a. The BID document ask for permission for bridge construction, clubhouse, sewage infrastructure and two polo fields. The BAR now requests permission for only one polo field, however still contains previous requests and reference to Industrial and Warehousing on the property. Extract below from the BAR:
“Section 3. IMPACTS THAT MAY RESULT FROM THE DECOMISSIONING AND CLOSURE PHASE :The proposed development of industrial and warehousing facilities will probably operate in one form or another for a very long time – it is thus not realistic to evaluate the decommissioning phase at this stage. It is not foreseen that the proposed development would reach a decommissioning and closure phase due to the type of development. Section 3 is therefore not applicable to the proposed development.”
b. The installation of services to the area is used as a motivation for the development, however the consultant states the option being sought does not include services. The site is outside the Urban Development Boundary where services are not supported by the City of Johannesburg SDF. Motivation for development stated in the proposed alternative Environmental Impact statement of the BAR: “The proposed development could also positively impact on the safety and security of the area, the expansion of services capacity (water and sanitation), as well as the upgrade of existing infrastructure. It is therefore suggested that the proposal be approved.”
c. The report states that 50% of the site is bare soil, however photographs and satellite imagery clearly show the erosion occurring on only a small portion of the 67 h.a. site. Rehabilitation of this disturbance should be considered in the document.
d. The No-go option is dismissed implying that the site will further degrade if a polo field is not built. The site is currently used by a number of recreational birders, mountain bikers and horse riders from the area and Inanda Country Base and is located in the Greater Kyalami Conservancy (GEKCO). Consultation with and cooperation with these parties could result in rehabilitation and better management of the site and preservation of the Egoli Granite Grassland, Red data and threatened species (African Hedgehog, African Bullfrog, African Grass Owl) while allowing for sustainable equestrian and recreational use.
3. The consultant’s summary does not mention many concerns raised by I&APs.
The summary given in the BAR does not mention environmental concerns at all. These were raised previously by GEKCO and other interested parties.
The only concerns summarised in the BAR:
Concerned about Security in the area and that there are already a large number of vagrants in the area.
Concerns about the development of the property versus the polo field only.
Provision of services
Provision of an access road
- The site is considered an important area in terms of the C-plan and forms part of an important wetland / riverine system feeding the Diepsloot and Jukskei rivers.
- Wetlands on site should be rehabilitated. Soil erosion is recognised on a portion of the wetland, however photos downstream show the wetland in good condition. This wetland forms part of an important system running from Blue Hills through to the Diepsloot and Jukskei Rivers. Has consideration been given to locating the polo field outside the 100m buffer? The polo field is 1,8h.a. and the site is 67 h.a. GDARD requirements state that a 100m buffer applies outside the Urban Development boundary. It is unclear why the consultant is requesting the buffer be reduced to 32m.