Overstrand Conservation Forum
OCF Ecowatch DEAT le terre Bantamsklip 2009-04-14-0
2009-10-25
NMA Effective Social Strategists
ATTENTION: Theo Hansford
PO Box 32097
Braamfontein
2017
Fax: 086 601 0381
e-mail theoh@nma.org.za
Dear Sir
COMMENT: DEVELOPMENT OF ALTERNATEIVE TRANSMISSION LINE
CORRIDOR ROUTES – INPUT TO MULTI-STAKEHOLDER WORKSHOP
OVERBERG / AGULHAS PLAIN AREA
(DEAT EIA Ref.NoS 12/12/20/1223 & 12/12/20/1224)
The Overstrand Conservation Foundation (OCF) wishes to make the following comments regarding the attempt to find an acceptable and feasible transmission line corridor associated with the proposed Bantamsklip Nuclear Power Station. The comments relate to the following observations:
- The expectation that NGOs will propose alternative transmission line routes is unrealistic.
- Western Cape Provincial Spatial Development Framework
- Specialist Study on Impact on Local Economics
The expectation that NGOs will propose alternative transmission line routes is unrealistic
The OCF contends that it is unrealistic to expect NGOs to propose
alternative transmission line routes. It is beyond the financial capacity of
any of the NGOs participating in the Multi-stakeholder workshop to
prepare competent submissions on route alternatives. The inability of
NGOs to finance adequate field studies or even the corroboration of the
veracity of specialist study reports is a major problem. This seriously
limits the ability of NGOs to engage meaningfully with parties employed by
the developer to develop arguments for the approval of the proposed
development.
The OCF will participate in the Multi-stakeholder Workshop. We protest,
however, that the process is biased in favour of the developer.
Western Cape Provincial Spatial Development Framework
The Western Cape Provincial Spatial Development Framework (WCPSDF) was signed into law by the Western Cape MEC responsible for environmental affairs and development planning. The WCPSDF has been established as a Structure Plan in terms of Article 4(6) of the Land Use Planning Ordinance 1985 (Ordinance 15/1985).
Objective 5 (Conserve and Strengthen the Sense of Place of Important Natural, Cultural and Productive Landscapes, Artefacts and Buildings) of the statutorised WCPSDF requires under section 2.3.14 (Transmission Lines, Pipelines, Telecommunications Masts and Wind Farms) that Pipelines, transmission lines and telecommunications masts should be aligned along existing and proposed transport corridors rather than along point to point cross-country routes (Policy HR26). This objective also requires that specific visual resource management plans must be prepared and used to prevent unsympathetic or foreign built systems from detracting from the scenic value of designated scenic routes.
None of the proposed transmission line routes follows an existing or proposed transport corridor and all alternative corridor routes proposed on the map distributed to participants of the multi-stakeholder workshop will seriously detract from scenic routes that are important to the development of the tourist industry in the Overberg.
The OCF finds all proposed routes unacceptable in terms of visual impact to scenic routes in the Overberg. No suitable existing or planned transport corridors in the vicinity of the Bantamsklip site exists along which a further alternative transmission line route can be proposed. The OCF therefore strongly argues that no feasible transmission line route exists that can service the proposed Bantamsklip nuclear power station site.
Specialist Study on Impact on Local Economics
The OCF has recently become aware of a study that has been done for the Kogelberg region of the Overstrand coastline that throws new light on the impact of development upon the local economy (Ref. Ecology, Value and Management of the Kogelberg Coast by JK Turpie, BM Clark, K Hutchings, KK Orr & J de Wet). This study employs resource economics as a means to determining the effect upon local economics of various environmental management and development scenarios. The findings of this report suggest that development that detracts from the impression of the area as a pristine wilderness area will have serious adverse consequences for the Tourist-based Overbetrg economy as a whole and will have very serious consequences for property values in the vicinity of the proposed nuclear power station and along the proposed transmission line corridor routes.
It is critically important that a similar specialist study must be performed for the Bantamsklip coastline and for the scenic area across which the proposed alternative transmission line corridors pass. The OCF asks that a suitably qualified and experienced resource economist (for example, the Anchor Environmental team) must be employed to do a specialist study.
The OCF contends that there is no acceptable terrestrial transmission line corridor that can be used to service the proposed Bantamsklip nuclear power plant site.
Yours faithfully
Rob Fryer
Manager
Cc: OCF members.
