Afdaksrivier Trust Housing Development

Botfriends comments on the Afdaksrivier Trust housing development for farm 21/575. The process for getting approval for the development is an ongoing process with many twists and turns, especially for this development.

Botfriends’ major concern with this development, right on our doorstep, is, in fact wholly within our area and directly linked to the Bot River estuary. The development stretches from Stormalong Road in Fisherhaven up to the R43, across the R43 at the entrance to Fisherhaven and along the R43 all the way to the new RDP houses in Hawston, and from the R43 to the base of the mountains.

The largest environmental effects are on the areas surrounding the development. The area between Fisherhaven and Hawston (sewage and change in waterflows), Fisherhaven (sewage) and the estuary itself (potential pollution, sewage and storm water flows), are affected. The pollution potential and storm water flow especially as regards the sand mine, which has already altered the hydrology, is being shelved for a future EIA (Environmental Impact Assessment) and left out of the existing proposal.

A proposed sewer line from a holding works adjacent to Fisherhaven will run along Protea Road to link with the Hawston sewer works. Another sewer line will run on the Fisherhaven-farm portion 6/575 boundary to the Hawston sewer works. This development will almost double the size needed of the Hawston sewer works to handle the new volumes.

The necessary sewer-holding works near the corner of Stormalong and Riverside Roads and through Fisherhaven, ignores the future expansion of Fisherhaven piped sewage. The additional storm water flows from new roofs and sealed surfaces (roads etc), will run into the Afdaks section of the estuary fairly directly and across the proposed green corridor from the estuary to the mountains. This corridor includes wetlands and high biodiversity areas. The initial development area had to be changed to accommodate these wetlands and high biodiversity areas. Unfortunately, they have not considered this area as regards the effects on them from the proposed development. The potential for sewage leaks and additional concentrated storm water flows, will cause potential silting and pollution directly into the estuary.

The other sewer line (Fisherhaven-farm portion 6/575 boundary) will have earthworks that run through a wetland area with potential permanent damage to the wetland and across a proposed green corridor linking the estuary to the mountains, which would include the wetlands. The expansion of the sewage works extension which is necessary for the development is proposed but the necessary EIA is left out of the proposal. The proposed extension of the sewage works would intrude into a wetland area; and the existing sewage works have already polluted the Skilpadsvlei area.

The storm water flows from the mountains across the development, with the addition of extra stormwater from new roofs and sealed surfaces (roads etc), will be drained into the altered hydrology of the sand mine area. The water from the sand mine area has already altered the seepage areas below the R43. This will be vastly increased by the development, and the concentration of additional water flows has not been accommodated in the wetland corridor. The sand mine area, which is critical to the green corridor and wetlands (both within the development and below the R43) has not been accommodated in the existing proposal. It has, in fact, been shelved for a future EIA, which will in fact have a huge impact on the existing EIA for the development. This alone should make the existing EIA invalid and not able to be accepted. In fact, the corridor through part of the development above the sand mine has not been accommodated either.

Comments on the first draft of the Afdaksrivier Trust housing development proposal were submitted to the authorities by M N Austin in his private capacity. Many of these comments agreed with comments from Cape Nature (see downloads below, 2017 & 2018) and the DEA&DP. Some amendments were made and then a new environmental agency was appointed. M N Austin and Botfriends were registered as interested persons and organisations. The process then seemed to grind to a halt.

An altered draft version was released by Cornerstone Environmental Consultants for comments in 2019 (see download below). Cape Nature Conservation Intelligence commented on this development and forwarded these comments to Botfriends, together with a copy of the new version, with a request to review them. Botfriends commented on this new proposal and forwarded comments to Cape Nature. Botfriends also wrote a summary of comments, distributed to members of Botfriends.

It appears that Botfriends is no longer registered as an interested party in this development and that public participation in the process is now closed, and, therefore, Botfriends interests can now be ignored. This puts us in the position of having to take legal recourse to be heard, or rely on the good will of Cape Nature to take our interests forward. Legal recourse costs money, which Botfriends as a volunteer organisation does not have.

If the existing proposal is approved, Cornerstone or Afdaksrivier Trust can then use that approval, at a later date, to get approval for the sewage and storm water flows, as one cannot at that stage reverse the development.

Botfriends is now involved in trying to deal with the issue of the original problems which have effectively been shelved for the future. The shelving of the problems has the effect of not dealing with the original problems but of changing the problem to a new problem, to be dealt with in the future. In the opinion of Botfriends the existing EIA is not complete and can not be accepted without modification.

Michael Austin (Comments on the Afdaksrivier Trust housing development)

Chairperson Botfriends January 2020

Download the referenced documents below