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					                       WILDERNESS & LAKES
          P O Box 7, Rondevlei 6541   PH: 072 906 2620    EMAIL:

January 2004

Department of Environmental Affairs and Tourism
Private Bag X9154
Cape Town

To all concerned


The Wilderness and Lakes Environmental Action Forum (WALEAF) would like to take this opportunity
to strongly object to the above-mentioned proposal as it stands. The main reasons for objecting will be
highlighted in this letter, however a full list of issues and concerns are contained in the attached document.
The reason for circulating this letter and document is to ensure that all relevant authorities and key
stakeholders are exposed to a range of perspectives and to strongly encourage everyone to give this
proposal its due consideration.

Our understanding of the current status of this proposal is that an Application for an Amendment to the
Structure Plan is due to be submitted to the provincial planning authorities along with a Strategic
Environmental Assessment (SEA). Our Forum will fully participate in the Social Impact Assessment that
forms part of the SEA as well as any other public participation processes.

Our Forum wishes to state that we aim to support development that is sustainable, appropriate and
responsible. Furthermore, we strongly encourage development to be well planned, competently managed
and sensitive to the environment and all its inhabitants (including future generations). On the whole we
feel that this proposal is inappropriate for this area and not sustainable in a number of respects (these
issues are covered in detail in the accompanying document).

The main reasons for our objection are summarized below:
   1) This type of development would set a major precedent for further urbanization along the northern
      shores of the Lakes system. The current zoning is agricultural and a departure from this would
      ultimately lead to the decline of the rural character of the area and would add to the destruction of
      the natural beauty of the area (which is what presently draws tourists to this region). The George
      Spatial Development Framework (Draft Document, February 2003), states that “there should be
      no creation of urban nodes with residential and social components within existing rural areas”
      (B.5.6). It is inappropriate to develop a new urban area within this currently rural context.

    2) The water utilization of these types of Golf Estates is alarmingly high (upwards of 3 million litres
       per day – quoted in Golf Estates and Resorts 2001/2002). Sedgefield already battles with water
       supply over the peak holiday times. This sort of development certainly does not seem sustainable
       into the future.

    3) Swartvlei is one of a series of lakes in the area, two of which (Rondevlei and Langvlei) have been
       declared Ramsar sites. This makes the whole system one of national and international importance.
       Swartvlei is also an important estuary and runs the risk of damage due to runoff from the
        development (ie fertilizers/pesticides/herbicides are used in large doses for the maintenance of
        golf courses and polo fields). Furthermore, one of the principles of the National Environmental
        Management Act (No 107 of 1998) states that: “sensitive, vulnerable, highly dynamic or stressed
        ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require attention in
        management and planning procedures, especially where they are subject to significant human
        resource usage and development pressure” (Chapter 1, r). We feel that this principle applies to
        this context.

    4) The roads en route to the proposed site would be seriously affected during the construction phase
       of the project. A massive increase in the volume of heavy, as well as light, vehicles utilizing the
       Hoekwil/Karatara road over, at least, a 3 year period of construction can be expected. This is
       problematic for numerous reasons, among which are: the social impact on communities living
       alongside this road; the impact on the road itself; the fact that it passes through a National Park;
       and the potential impact on the residential areas situated along the dunes on either side of the road
       coming off the N2. These points are covered in more detail in the attached document. The
       alternative road leading to the proposed site (Die Vleie road) passes two Ramsar sites (Langvlei
       and Rondevlei). An increase in traffic along these roads will have cumulative impacts on these
       sensitive sites.

    5) It is important that the Garden Route preserve its scenic views as they play a vital role in
       attracting visitors to the area. The view from the N2 over Swartvlei is one of the last relatively
       unspoilt vistas. Such a development would have a huge visual impact from this busy tourist route.
       It would also impact heavily on the area’s rural “sense of place”.

The Forum will become involved with and support the Strategic Assessment that is underway, but it
would like to state that it is our view that there is a need for a much broader study to be conducted, one
which is carried out by independent consultants with input from a broad range of stakeholders, and which
is not connected to a specific development proposal, as in this particular case. Such a study should aim to
determine the ecological and social carrying-capacity of the Garden Route. This could then be used to
clarify issues such as how many golf estates are desirable and sustainable within the bio-regional context.

Further information regarding our issues and concerns with the proposal are contained in the attached
document. This was informed by our own research and observations as well as speaking to many
interested and affected parties, specialists and authorities.

Our Forum would like to cooperate fully with the developer and consulting team in exploring alternatives
that are both viable and sustainable. We all must seriously contemplate the implications and realities of a
proposal of this magnitude coming to fruition. Let us ponder on this issue sensibly, sustainably and

Thank you for your time.

Yours sincerely
Members of the Wilderness and Lakes Environmental Action Forum

                                    Issues to be Considered
                Compiled by Wilderness and Lakes Environmental Action Forum
                                              November 2003

The following document contains a list of issues, concerns and questions that have arisen over the past
months during our consultation with various interested and affected parties, specialists and authorities.
The main concerns are highlighted in the covering letter, while this report deals with all the associated
issues and questions in no particular order of priority but it is felt that each of these concerns and questions
are important and needs to be directly addressed.

Planning Perspectives
Assessment Issues from a Local Perspective
   -      It is apparent to our forum that if an urban development of this magnitude is given the go-
          ahead, it would set a major planning precedent for land-use on the northern slopes of the
          Lakes’ system, opening a whole new corridor of developments and urbanization in a currently
          rural area.
   -      One of the major planning questions should be whether the establishment of a town, in a rural
          area not designed to accommodate it, is feasible or appropriate. Isn’t it preferable to locate
          such developments closer to existing urban areas?
   -      The land was purchased at below actual value, as the value was based on agriculture, not
          township, values. The rezoning of agricultural land to residential could have serious
          implications in terms of setting a precedent for agricultural land to be valued as potential
          township land.
   -      Already many up-market golfing estates exist or are in advanced planning stages along the
          Garden Route (22+). How many golf estates can this sensitive stretch of coast realistically
          support? Have studies been done indicating the long-term sustainability and viability of these
          sorts of developments at these densities?
   -      The introduction of this type of up-market urban development will affect the rates and taxes
          of surrounding areas. We would like to ascertain the municipality’s stance on this.
   -      What is the process of rezoning this land from agricultural to resort, residential and other
          land-uses? Who makes the decisions? What are the guiding principles?

Assessment from Perspective of Existing Legal Frameworks
   -      The Draft Spatial Development Framework (SDF) for George states that there should be no
          creation of urban nodes with residential and social components, within existing rural areas
          (B.5.6). This area is earmarked as rural and agricultural.
   -      The property is listed in the Sensitive Coastal Zone Area Extension. What implications does
          this have on rezoning to resort/residential?
   -      Due to the fact that the SDF is still in draft format and the Structure Plans date back to 1982,
          developments of this size and nature should only be assessed once this draft document has
          been approved and finalized by the authorities and all other relevant stakeholders.
   -      It is felt that a Strategic Environmental Assessment is needed that covers the whole of the
          Garden Route, from Mosselbay to Plettenberg Bay. This would best be carried out by
          independent consultants, with input from a broad range of stakeholders, and should not be
          connected to a specific development proposal, as in this particular case. Such a study could
          aim to determine the ecological and social carrying-capacity of the Garden Route. This could
          then be used to clarify issues such as how many golfing estates are desirable and sustainable
          within the bio-regional context.
   -      It is hoped that the principles of sustainable development will be a major guiding force
          throughout the process of assessing this proposal, as well as the “triple bottom line” principle
            which asserts that there should be sustainability on all levels: economic; social and

Alternatives for the site.
    -      The existing Structure Plan zoning for this area is agricultural with an additional zoning of
           nature area over 30% of the site. We suggest the continuation of these dual zonings as a
           protection against the development of this Lakes District “green backdrop”. The rural and
           wilderness appearance of large green pastoral expanses lends the Garden Route its aesthetic
           appeal. Any deviation from this zoning would lead to a continuation of more “leap frog”
           urban nodal development from Wilderness to Knysna, damaging the very fabric of this
           sensitive nature area. Even permission for small scale rezoning to resort for low impact
           hotels, lodges or bushcamps could provide an open door for further development demand.
           The forum feels that existing zoning should remain in place as this would have the least
           detrimental ripple effect on the surrounding rural area.
    -      The purchase price of 7,5 million was well below even agricultural market value, and
           considering its aesthetic appeal, would be valued considerably higher. The current owner
           surely has many other options for profit from this land that could be investigated by his team
           of specialists.

Biophysical Environment
  -         The availability and sustainability of water has been a major issue and concern raised by most
            residents, municipalities and water experts.
    -       What studies are being done to address the sustainability of water supply, to the proposed site
            as well as to the surrounding area and region as a whole?
    -       What will the water requirements be for the huge number of residential homes, timeshare
            units, retirement village, hotel and various other components that shall constitute a final
    -       What are the requirements for irrigating 2 golf courses, polo fields, driving ranges, gardens
            etc (which shall make up the required “critical mass” for the development to be financially
    -       Where will this water come from? Runoff, or will new supply reservoirs need to be built or
            extra abstraction schemes required?
    -       How would water requirements be met during times of drought?
    -       How adequate and reliable will the water supply be into the future?
    -       Sedgefield already battles with water supply over the peak holiday periods.
    -       What impact will the development have on the local rivers, lakes and water systems? What
            are their present levels and how does drought affect them?
    -       All aspects of the water supply and usage for this proposal need clarification.

   -      If water for dams/water storage reservoirs is to be collected from the mountain catchments on
          the property, how will this influence the river systems, Swartvlei and wetlands alongside it?
   -      What will the cumulative impacts be on the ecology of the area as a whole?
   -      There are major concerns regarding the possibility of pollution and run-off into Swartvlei (ie
          fertilizer on golf courses; sewage contamination etc).
   -      What are the possible changes in flow of sediment and siltation rates?
   -      How will this affect the nutrient/chemical balances of Swartvlei?
   -      We would be interested in knowing exactly how the golf-courses and polo fields would be
          maintained and managed. What products would be applied, how often and by what means?
   -      How would run-off and seepage into Swartvlei be controlled.
   -      Would there be any rain water collection from buildings and roads into dams/reservoirs in
          order to augment the water supply for the development?

   -        What are the cumulative impacts of increased utilization of Swartvlei estuary and surrounds?
   -        What are the possible impacts on the ecological functioning of the various natural
            communities due to destruction of habitat, decrease in the size of the natural community;
            changes in availability of food; changes in quality and flow of ground water and
    -       What animal routes and corridors exist? How would these be affected?
    -       How much fynbos will be disturbed/lost/regenerated?
    -       What is the impact of such large tracts of lawns on the biodiversity/ecology of the area?
            (especially taking into account that there are so many golf courses already, and more
            proposed, along the Garden Route).
    -       Disturbances to bird populations (resident and migratory birds): What impact would an
            aerodrome/airstrip have (not to mention mass housing)? If flight paths pass over the Lakes
            this would invariably unsettle bird populations?
    -       How would the development affect the pair of nesting fish eagles situated on a granite outcrop
            on the western edge of the site?
    -       What influence would this development have on spawning fish that use the sensitive
            northwestern shores of the estuary as a nursery?
    -       If a marina with incoming ferries and boating activities is envisioned, this would lead to an
            increased demand on Swartvlei. How would this be controlled and managed? How does this
            fit in with the Wilderness National Parks’ vision for Swartvlei?
    -       We would like to see a map identifying conservation worthy habitats, fauna and flora on the
            site, as well as an alien vegetation control plan.

   -      How stable is the site in terms of the slope, nature of the substrata, compressive strength of
          soils: can it cope with this size development?
   -      How would the topography be changed in order to accommodate the various aspects of the
          development, but particularly the golf courses and polo-fields.
   -      How would the lawns (golf course, polo fields, homes, etc) be maintained and fertilized?
          What impact would this have on the soils as well as the sensitive lakes system?
   -      Would topsoil need to be imported onto the site? If so, how much would be required and
          where would it be sourced?
   -      What is the potential of the soil for agricultural purposes? (Consider successful dairy farming
          on eastern border; successful flower farming on western border.)
   -      We would like to see a site specific map indicating all the proposed changes to the natural and
          disturbed landscape.

Waste management and disposal
  -      Solid waste: where will this be disposed of and can the site/area cope with this extra burden of
         solid waste?
  -      Liquid waste: where and how will this be managed?
  -      What are the possible impacts on the microbiological quality of Swartvlei, and impacts on
  -      The sewerage works is currently sited in close proximity to two tributary rivers, the Diep
         (feeding the Wolwe River and Swartvlei) and the Klein Wolwe (feeding the Hoogekraal and
         Swartvlei). These systems would potentially be at risk of bio-contamination, especially
         considering the frequent “hundred year” floods we have experienced in the last decade.
  -      What sustainable waste management practices would be utilized?

Aesthetic/Visual impact
   -       The development would be very visible from the N2 (driving across the Swartvlei bridge and
           from the view-point located just beyond the Swartvlei beach turnoff) and from the Outeniqua
           Choe-Tjoe railway bridge. An urban development of this scale would have a major visual
           impact on these natural scenic vistas, especially during the construction phase.

    -       We would like to see a detailed report, with impressions of the proposed development (during
            construction and post construction) from a range of vantage points.
    -       It is vitally important for the Garden Route to maintain and preserve its beautiful views and
            vistas, as this is what drives our tourism industry. Developments that ruin our scenic
            landscapes and negatively impact public memory will have a devastating effect on eco-
            tourism potential.

Energy issues
   -       A development of this size would require major energy inputs (electricity for all the
           homes/hotel/maintenance of lawns and gardens etc). What is the long-term sustainability
           rating of such a large development. Can it be justified in terms of the principles of sustainable
   -       Would power lines need to be substantially upgraded?
   -       How would the development aim to conserve and reduce its energy consumption?

Road Networks
   -     The roads en route to the proposed site would be seriously affected during the construction
         phase of the project. There would be a massive increase in the volume of heavy as well as
         light vehicles utilizing the Hoekwil/Karatara road over, at least, a 3 year period of
   -     A conservative estimate of the number of heavy vehicles that will be used during the
         construction phase of the infrastructure of the development is approximately 60 000 trips
         (there and back) along the above-mentioned road. This was calculated on the assumption that
         an average living unit uses about 15 truck load of materials in its construction. This was then
         multiplied by 2000 units (a conservative average worked out from the current wish-list which
         includes 1200 residential homes; 120 unit retirement village; 300 timeshare units; plus all the
         materials for a hotel, sporting facilities and all other infrastructure that is envisaged). Added
         to the figure of 60 000 journeys for infrastructural development, is a further 20 000 trips for
         the materials needed for the gardens/greens/fields, etc (ie topsoil). This, when worked out
         over a 3 year period over five 8 hour working days of the week, comes to an alarming 9 heavy
         vehicles every hour or one truck every 6/7 minutes.
   -     This estimate does not include the increase of the light vehicles that would be servicing the
         project by dropping off various building materials. As one can extrapolate from the above
         estimate, a huge increase in light vehicular traffic could be expected on this road.
   -     The impact of this sort of increased utilization of the Hoekwil road will be immense and
         varied. Some of the potential impacts include: the social and physical impact on the
         communities that live alongside this road (ie impact on social networks, safety and mobility of
         farming communities and Touwsranten community who constantly utilize this road); the
         impact on the road itself; the fact that it passes through a National Park (and over the
         Serpentine river); and the potential impact on the residential areas situated along the dunes on
         either side of the road coming off the N2 (ie how stable is the dune system that Kingfisher
         Close and Wilderness East Roads are situated on; what are the potential cumulative impacts).
   -     Some farmers have raised a concern about getting livestock across the road to grazing camps
         as well as the possibility of an increase in stock theft.
   -     The alternative (and shorter) roads leading to the proposed site (Die Vleie road and the Pine
         Lake Marina road) each pass two Ramsar sites (Langvlei and Rondevlei). An increase in
         traffic along these roads will have cumulative impacts on these sensitive sites. What are the
         potential impacts and how are these Lakes protected in terms of the Ramsar Convention?
   -     Possible impacts of an increase in volume of trucks and cars on this sand road that have been
         raised by local residents: more dust is stirred, which lands on roofs and consequently pollutes
         rainwater tanks; in particular, diesel and other vehicle emissions being carried by dust and
         settling on rooftops would contaminate water tanks, with the consequence that drinking water
         would become toxic. For most people living on this road, rainwater is the only source of
   -     Risks to people who walk/cycle/play on these roads are increased (especially children).

    -       Other concerns raised by I&AP’s associated with an increase in traffic are noise pollution and
            the impact on wildlife (notably baboons, monkeys and buck) that traverse this road.
    -       What are the chances in future of these roads getting tarred due to increased utilization? What
            are the pros and cons of this? (ie decline of rural character; pedestrians and wildlife more at
            risk due to increased traffic and speed of traffic; pollution impacts on Lakes caused during the
            process of tarring as well as oil spills washing into the Lakes instead of being filtered through
            a sand road, etc).
    -       The increased traffic on these roads will have a direct impact on the values of properties along
            these routes as well as on the sense of place and views from these affected properties. All of
            these impacts must be thoroughly investigated in a traffic study.
    -       A comprehensive study on the social, physical, economic and ecological impacts of this
            proposal on the road network is urgently needed and remains crucial to understanding the full
            implications of this proposal.

Socio-economic environment
Social impact assessment
   -       It is vital that a comprehensive social impact assessment (SIA) is carried out that will truly
           bring to light the issues and concerns relating to the very large number of people and diversity
           of communities that could be affected, both negatively and positively, by this development.
   -       We look forward to seeing a Plan of Study for the SIA so that we can positively contribute
           and feed into this process.
   -       It is hoped that the SIA will provide opportunities for community education and capacity
           building, and that regular feedback and monitoring will be given throughout the SEA process
           (as well as during the EIA process if called for, and ultimately throughout the life cycle of the
   -       Local communities should be informed of both the potential positive and negative impacts of
           the proposal, during the planning and construction phase, as well as in the operational phase.

   -     How would this development affect the growth rate of the local population?
   -     Can this area cope with a sizable increase in population?
   -     How would an influx of “outsiders” (workers and residents) influence and affect the areas
         sense of place?
   -     What will the impact of an increase in seasonal visitors to the area be (particularly along the
         public sand roads alongside 2 Ramsar sites which offer a short-cut access to the development
         from the N2)?
   -     How will the longtime residents accept newcomers into the area?
   -     What are the benefits of having a larger, more diverse population in the area?
   -     The development will invariably attract migrant labourers into the area. How and where will
         these people be accommodated and effectively absorbed into the area?
   -     What are the concerns of local people regarding a swelling of population? (ie possibility of an
         increase in crime, resentments between long-time residents and newcomers; competitive
         employment issues, escalating costs of rates and services; access to services etc).
   -     Haven’t many of the locals chosen to live in a rural setting to avoid the security issues facing
         urban dwellers?
   -     An increase in the local population would result in the need for new or upgraded community
         resources (ie schools, child day care facilities, sporting and cultural facilities and so forth).
         What is envisaged on this front?
   -     What segment of society is the development aimed at (ie foreigners, tourists, retired people or
         economically active)? These sorts of questions would help to determine how this
         development would impact on the social fabric of the area.
   -     In our opinion, the net result of proposing an up-market security-village style development
         with labour housing in separate “locations” is tantamount to proposing a new style of
         “separate development”.

Employment issues
  -      During construction phase, although an initial figure of 4000 jobs is proposed by developers,
         how many locals will benefit (look to other similar developments in the area)?
  -      Is there enough skilled labour in the area for the construction phase? If not, where will the
         rest most likely to come from?
  -      Where will these construction workers be housed and what are the long-term employment
         opportunities for these people once the construction phase is over?
  -      After construction completion (operational phase) although a figure of 1000 permanent jobs is
         proposed by developers, how many currently unemployed locals will benefit (look to other
         similar developments in the area)?
  -      How will local people stand to benefit from the development beyond the employment
         opportunities it creates? Will they have access to the sporting facilities?
  -      What social upliftment projects would be considered? Would a percentage of the profits be
         spent on these sorts of projects on an on-going basis?
  -      Many unemployed locals do not have the necessary skills for the construction or operational
         phases. Will there be an opportunity for these people (especially the young people) to be
         trained so that they can gain employment through the development.
  -      Will local contractors be used or does the developer have his own team?
  -      We would hope to see some sort of policy put in place that assures local people and
         businesses would benefit from the development. This will also set a sound, socially
         responsible precedent for future developments in the area.

Impact on the rural character of the area
   -       The Wolwerivier valley and surrounding areas are very rural at present, with mostly small to
           medium scale farming activities taking place. This type of development would fundamentally
           alter the character of the area by creating a new node of urban development.
   -       As discussed earlier, the impact on the roads network would be substantial. This would have
           its associated social impacts. A growing community concern is evident regarding the safety
           for pedestrians, children, cyclists (and cattle) who utilize this road daily. Impacts would also
           occur on the social networks of people that live alongside these roads.
   -       What building style is envisaged? How would this blend with the local environment? Will
           the development be “security style” or will the public have free access to it?
   -       An aerodrome and airstrip would severely affect the regions rural character and “sense of
           place” through impacts such as noise pollution, obscuring the evening sky and the disruption
           to wildlife and bird populations.

Economic issues
   -      How will this development stand to benefit the economic environment of the local area and
          the Garden Route as a whole?
   -      The development may push up property prices and rates in the area. Who does this stand to
          benefit? (ie foreigners and others who can afford to pay higher prices, property owners, estate
          agents etc) Who loses? (locals who can’t afford to buy land in the area they have lived in for
   -      This urban node may also devalue rural property along the roads leading to the development
          due to increased traffic, influx of job-seekers without adequate accommodation and other less
          desirable development along these routes.
   -      How would the local community benefit from this development? Would local contractors;
          labour; craftspeople and so forth be utilized? What has been the outcome in this regard with
          other developments of this nature?
   -      What is the economic viability of yet another 2 golf course developments in the area?
   -      How would existing tourism infrastructures, namely B&B’s; guesthouses and hotels be
          affected by the development? Would they be robbed of the scenic backdrop they have come
          to rely on?
   -      Over-development of the Garden Route will reduce the charm and lure of the area to tourists,
          which may negatively impact the eco-tourism prospects of this region.

  -     The Swartvlei estuary supports may local subsistence fisherman. Should resulting damage to
        the estuary result, this resource could be negatively affected or completely lost.
  -     How do the proposed benefits of local economic development (through promises such as
        increased tourism and employment) weigh up against other potentially damaging social and
        environmental impacts of the project. Who decides what is more important?

        WALEAF strongly feel that a resounding NO should be given to this development at an early
        stage as it is blatantly inappropriate for this rural area. Furthermore, I&AP’s should not have
        to defend such areas from inappropriate proposals, as each has a limited time to comment and
        voice opinion on developments. If these types of proposals are given serious consideration it
        will only be a matter of time before I&AP apathy gives way to such developments. This
        development would constitute a not so “thin end of the wedge”. Authorities need to take a
        stand as happens in countries such as the UK and Switzerland where no amount of money or
        argument allows Authorities to sacrifice the National heritage for future generations.


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