P O Box 256, UMDLOTI BEACH, 4350
February 15, 2007
We need your urgent clarification of the actual land use framework. Nathan Iyer stated that of the Sibaya Precinct area of 850ha, some 41 % would be retained as natural forest. We queried whether or not the Hawaan Forest, which lies outside of the study area, was incorporated in determining the division of land uses. If this is correct then it will grossly distort the percentage used in the report for ‘built environment’ of 21 % and other designated areas.
We regard this as a very serious issue as it brings into question the validity of other information provided in this report.
Page 88 of the Draft Scoping Report Aug 2006 Ref 44 stated, “the exact densities of the development will be based on the outcomes of the specialist studies”.
From what we understand so far, the built environment densities may be unacceptably high.
David McFarlane made a very strong case in his Sibaya TIA revised Aug. 2006 para.6.2 as to why the M4 should not be widened. These included impact on environmentally sensitive Hawaan Forest, scenic route for tourism and knock on effects. We had already passed this on to Institute of Natural Resources with the request that the Sibaya TIA be incorporated into the La Mercy Airport TIA.
We were shocked therefore to hear him tell us that the M4 needs to be widened from 2 lanes to 4 or more lanes. Given the constraints posed above is this a realistic suggestion?
It is important that TIA for La Mercy Airport be included in this Report to get a true picture of traffic densities.
McFarlane also made reference to the fact that the existing M4 reached 80 percent capacity during peak hours. There is already a strong case to reduce traffic flows by restricting heavy vehicles from using the M4. Assuming that the M4 cannot be widened it is clear that alternative routes will be necessary to cater for the envisaged increase in traffic.
Urban design charts include provision of a niche resort and spa in the Mhlanga Forest area. We request details of this proposal.
Brendan Magill indicated that sewerage would be linked to the Phoenix system. Can you confirm that the proposal of using the Umdloti system has been abandoned? With regard to storm water management we have requested Umdloti Coastal Conservancy to respond on our joint behalf.
It is well known that there is an escalation of crime during construction and building phases of new developments. The Sibaya Precinct development will be no exception given the large workforce required.
Safety measures, including a fenced buffer between Nodes 1 and 5 and the forest area on Umdloti's Western boundary needs to be implemented before construction
commences. Thereafter, there needs to be adequate security management planning for the entire area.
These have not so far been addressed. We have made the point on several occasions that the parking capacity of Umdloti is limited and there is a need to redesign the entrance to Umdloti. Page 88 of the Draft Scoping Report Ref 45 states that, “DMA’s understanding is that parking areas are to be provided within the Sibaya Precinct with shuttles to the beaches.” Page 89 of the Scoping Report Ref 52 promised an investigation/specialist study to address the concern that there is no connection between Umdloti and the new town center. Page 100 Ref 96 suggests the eThekwini Municipality would need to be involved.
In the 8 Feb Report Back two references were made that back-of-beach parking was planned in Nodes 1 & 5 but no indications as to how beachgoers would access the beach other than via a pedestrian link via Fourth Avenue and another from the Sports Precinct area via Margaret Bacon Avenue. Neither of these avenues has pavements and would have to be upgraded.
Noise pollution from aircraft landing and taking off from the proposed new La Mercy Airport needs to be taken into account in this Study. Noise implications for the proposed La Mercy Airport specialist study are currently being redone by INR and should be factored in to the Sibaya Study when available.
GAEA Projects : Fax 031 201 0700
7 pages inclusive / email firstname.lastname@example.org
Attention Ms D Donkin / Mr G Butler 10th September 2006
Thank you for the above draft scoping report received 18th August 2006, additional amended (traffic) document received 28th August 2006 and the opportunity to comment before final submission to DAEA. Please note the following comments are additional to those submitted to you over the past year, which are still relevant, some of which are confirmed in your report.
Of particular concern is that the above EIA application for the Sibaya Precinct development was registered with DAEA on the on the 9th November 2004 for a development bulk of 2500 residential units, 6 resort/hotels with potential commercial retail. During this scoping process however, this development has now 'ballooned' to nearly three times its original bulk which has increased to 6000 residential units, 8 hotels/resorts + 186,000 sq m commercial bulk (commercial and offices). This is confirmed in the recently received (traffic) letter above which refers to a mistake made by the traffic engineers.
Of further concern is that the above letter was received after publication of the 18th August 2006 Draft Environmental Scoping Report which appears to contain outdated information upon which all bulk services including water / electricity supply / sewerage disposal / stormwater requirements etc have been based.
The proposals and conclusions in the Draft Environmental Scoping Report therefore appear to be based on out of date information and the proposed development will need to be re-evaluated. Please confirm that the full EIA will provide detailed comment on this.
The development is to be applauded for removing proposed development from the Umhlanga / Umdloti Coastal Forest and surrounding area, for which we are certain Durban will be gratefull for in years to come. Please however see concerns below regarding hotel etc.
Concern however is that the remaining development proposal outside the forest appears to have evolved from a tourist friendly environmental concept into city sprawl which competes with Umhlanga's new Gateway buildings. 5 cityscape block nodes made up of 6 storey towering masses incorporating 6 no 15 storey 'iconic' towers will collectively dominate and dwarf the surrounding area.
This development is disappointing to all who have contributed time and energy participating in this process over the past two years in the hope that the final outcome would reflect the genuine and sincere comments of what was hoped would result in a quality international and 'must see' destination and attraction for locals, visitors and tourists alike. Tragically this development has ended up as another dominating concrete commercial jungle development with little or no relief or space for a natural African wildlife experience and environment for even remotely adopting the principles of 'One Planet Living'.
Figure 9 SIBAYA PRECINCT HEIGHTS with projected 'cityscape'
We are concerned that the whole development is not restricted to 'the hilltops' as recently presented. On the contrary it appears every available space that is not wetland, watercourse drainage channel or steep and unbuildable has been covered with development right down to the edge of the M4. This creates a visibly dominating continuous building mass with no identifying space relief. The end to end development of the 5 'cityscape' nodes has unfortunately given a continuous ribbon like walled cityscape appearance effectively blocking out, rather than integrate with, any of the natural environment that is left. The Public have registered overwhelming support for a strong and visible natural indigenous African environmental foreground (not relegated to the background behind a building facade) tourist route and vista that should influence and subdue building scale not be dominated by building bulk.
The 'Charrette' meeting between 8 individuals appears to have been 'developer' led and outside the public participation process resulting in the overbuilt / overdensified 'cityscape' precinct currently proposed. This is based on following concerns observed in the report's Charrette presentation:
It is difficult to reconcile the presented mediterranian 'top of the hill' village scale with this developments resultant building mass which in eThekwini's words is 'out-of-scale' .
The whole presentation appears to be 'city' structure orientated with discussion around 'built form' challenging / harmonising with 'built form'. It should not be the point of departure for an environmental project of this nature to start with a building/architectural debate. It should rather be about accepting the logistics of an indigenous african rehabilitated sugar cane environment and topography (a major project on its own) as the dominant form which dictates what building, if any, should be built and at what scale as dictated by Hawaan Forest, Peace Cottage Forest, Conservation Trust Forest, Forest 31, Mlanga Forest and Umdloti Border Forest. These areas are recognised as being eternally irreplaceable and invaluable.
The developments 'cityscape' architectural mass appears not to value the natural environment enough to be subdued by it and does not appear to be welcomed except by cosmetic 'urban greening'.
Melrose Arch and Point Waterfront 6 / 8 storey building masses may be acceptable within their designated City densification zones but they would be totally out of place in this coastal forest zone.
The developments proposed building masses of 6 to 15 storey high concrete structures 'dressed up' in an 'african contemporary' (actually modern international) designation and the idea 'Trojan Horsed' into the Sibaya Precinct does not mean these bulk structures are either automatically environmentally sensitive or acceptable.
The existing function and african aesthetic of the Sibaya Casino is the first 'roll-out' for tourism and indigenous building context for the area. A bold and successful local and internationally welcomed and clearly KZN home grown 'african' architectural initiative with its mass appropriately scaled, curved and moulded comfortably within the landscape. Its indigenous design softly breaking the skyline which clearly the currently proposed 'modern' adjunct development does not wish to acknowledge. We therefore totally support this 'tail wagging the dog'. (architectural response to eThekwini p 94)
Special consideration should be given to the fact that the proposed Sibaya development is within a remote 'greenfield' site bearing no relationship to any 'nodal' development and is outside eThekwini's Urban edge and bulk servicing support zone. This means that additional road, water and waterborne servicing requirements etc are currently viewed as unsustainable if extended outside the urban edge (Umhlanga). This development therefore contradicts eThekwini's consolidation of services, densification and 'urban sprawl' policies.
This 'cityscape' development within this remote area would create a 'sub node' and undue attention and pressure for further development and urban sprawl in the area and almost certain 'death' of the remaining rare pristine dune and coastal forest and eco-tourism in the area.
We agree with DAEA / ETHEKWINI / WESSA / DWAF/ that the current densities appear too large and that large buildings on hilltops and (elsewhere) will negatively affect viewsheds.
The National Forest Act No 84 of 1998 provides the mandate for the Department of Water Affairs and Forestry to protect our natural forests as it is a fact that the majority of the coastal forest ecosystems in the province of KwaZulu-Natal have already been destroyed or transformed. We are therefore disapointed that there are still development elements such as a boutique hotel and gondola etc being proposed within what remains of this highly sensitive coastal forest ecosystem in KwaZulu-Natal which should be protected. All development should be excluded from this very sensitive zone.
The principle issue of human activity proposed within the forest and beach using boardwalks, foofy slides and gondolas etc which entail supporting infrastructure development and maintenance is not supported. The natural environment experience for both locals and tourism is welcomed.
Current input is required from national, local environmental and planning agencies, including eThekwini, concerning the protection of this exceptionally rare remaining stretch of indigenous coastal forest within eThekwini municipality which, with the Hawaan Forest and other forests in the area, form a main part of Durban's national / international inheritance and eco tourism attraction zone.
We believe this small stretch of coastal forest and coastline, between Umdloti and Umhlanga should be kept as a natural national heritage for the people of South Africa. This stretch of beach is unsuitable for swimming purposes. If allowed, concern would be that life-savers and supporting facilities would need to be provided leading before too long to the coastal forest being replaced with life-saving huts, access roads and buildings. We also re-iterate our objection to any further shark nets being installed, not only here, but anywhere along the coastline. Please note also that this stretch of beach has been accepted for consideration by MCM as part of a greater Marine Protected Area.
There are good beaches for public use at Umhlanga and Umdloti and there should be no public access to this section of the beach through the forest, as there is adequate public access to the south from Umhlanga and from the north at Umdloti. There should be improved back of beach parking made available at these two access points.
We are opposed to a dune boardwalk across this section of the beach as we do not believe it is appropriate or needed and also oppose construction of a groyne / jetty being established as this will have negative impacts on littoral drift and sediment transfer along the coast and may impact the river mouth.
As confirmed in the report, stormwater mitigation measures for the recently completed Sibaya Casino have failed to protect the wetland areas and drainage channels possibly seriously affecting the Ohlanga river. Attention is also drawn to the report by VKE (engineers) confirming the 'vulnerability and susceptibility' of stormwater disposal and physical impact on the future of the Umdloti coastal forest buffer strip and properties below from proposed development above.
There is therefore a major concern with 'GOBA' (Pvt) Ltd (consulting engineers) design for sewage disposal of Nodes 1 and 5 through the Umdloti Forest and into the Umdloti system (see also EIA confirmations above) as shown on Figure 1 (appendix 27). This drawing shows sewer lines cutting through and alongside the Umdloti Forest including the positioning of a sewer pump station within the valley of a primary watercourse catchment into Umdloti ?!! . Besides destroying the indigenous forest and vegetation which is protecting catchments and dunes in the area, the proposed location of this sewer infrastructure would seriously destabilise the primary dune in the area, also risking existing development below as highlighted in VKE's report.
We also have difficulty understanding GOBA engineers design for sewage from Node 4 being pumped eastwards across the M4 motorway !! and up the elevated hill to Node 5 and through the Umdloti Forest into the Umdloti system (discharge point 3). Neither can we understand some sewage from Node 1 being taken through another part of Umdloti Forest to the Umdloti system (discharge point 2) when it can all be pumped alongside the M4 into the Casino outfall. This outfall is already planned to take the Sibaya Precinct into the Phoenix works and which in the report DWAF confirm can take the additional capacity.
This would avoid the cost to eThekwini and the ratepayers to upgrade the Umdloti Sewage Works to 3M/l (unless the Developer is paying which is not confirmed in the report) and avoid placing more pressure on the existing Umdloti system which is already stressed as the main sewer is laid within the littorial beach zone where it has already been undermined and fractured by the sea in a number of places.
Please note that the EIA / ROD for Umdloti South pump station is for 44 umdloti residents only. It is confirmed that the only access to the Umdloti sewer system for development outside the Umdloti boundary would be by cutting through the Umdloti Boundary Forest. Any such consideration would be entertaining certain 'dune destabilising' risk (see stormwater concerns above) requiring an EIA. Any upgrade to sewer infrastructure and Sewer Works to facilitate additional flows also requires an EIA.
There are reports that the indigenous forest is already being cut for surveying / planning pipe infrastructure in this area. This is making a mockery of the EIA process. Please could we ask that all cutting of the forest for surveying and / or other reasons is immediately stopped and that the EIA process is allowed to take its course and verify what planning will or will not take place in the area.
The protected indigenous dune forest running north / south along the Umdloti's west boundary from the Mdloti Estuary down to Mhlanga Forest should be incorporated within the newly promulgated Hawaan Trust to allow the free flow of animals / birds and flora diversity without any hindrance of security fences etc. This would also incorporate and enliven the existing tourist trails which are relatively isolated.
We believe that the Developer should demarcate an area for a Biodiversity Park as a “must see” international aspect to the development. This proposed Biodiversity Park could tie up well with a rehabilitated buffer area along the Ohlanga River.
We are concerned about the certain conflict between residential use and noise pollution on the Sibaya Precinct (and also Waterloo, Cornubia and Umhlanga) if both the airport and the Sibaya developments go ahead. South Africa is a signatory to ICAO and its agreement of international health and noise pollution levels for human habitation and eThekwini have a legal responsibility and duty of care to uphold the health and safety of the local people.
We note that you are aware of a number of archaeological sites mainly along the hill tops which conflict with the proposed development, two of which are Stone Age sites. We trust that these will be suitably safeguarded and could be used very successfully for tourism purposes in the future.
Please note that the appeal regarding the ROD for Hawaan Forest Estate was upheld in April, 2005 and that this development is proceeding on an invalid ROD!
Please note we have not seen any EIA/5102 Peace Cottage scoping report which you confirm was submitted to DAEA on 7 September, 2005 for adjudication. Please could you forward us further detail.
This ROD is being opposed due to the D144 access road being in the flood-plain and periodically flooded. This appeal has been supported by DWAF
The M4 is an important visitor / tourism and vista route northwards for Durban City. The current development is proposed right on the edge of the M4 which would not only dominate this tourist route with wall-to-wall buildings but provide a 'canyon' type 'cityscape' corridor that would threaten the existing roadside mature indigenous vegetation strip and Albizia (flat crown) trees which currently provide a canopy and sense of place over the M4 tourist route.
The M4 route is also not capapable of facilitating an extention of future bulk service requirements in the area and is a 'dead end' for large development.
To show the strength and depth of feeling that this development has evoked with population groups from eThekwini to Ballito it is felt that a different 'approach' should be put forward with this submission to try and capture the essence what has been said above.
It is stressed that we do not agree with the developments designated 5 nodes or the 'out-of-scale' intensity of 6 storey planning of the individual building masses. We reiterate no building should be higher than 3 storeys and should be off the skyline or designed so as not to dominate the skyline. It is reconfirmed that 15 storey 'iconic' cityscape building mass is totally out of context in this environment.
Please see Map B below for a loose graphic suggestion using M4 visitor / tourist ecological corridor to relocate dominating 'cityscape' development from virtually on top of the M4 to the western side of the N2. This would 'relax' and 'quieten' the the M4 tourist route and would 'mirror' commercial form and function and a development corridor involving both sides of the N2. This would form a 'tee' junction with development on the MR96 entrance road between Verulam and Umdloti. This would consolidate and simplify the bulk servicing requirements along the N2 and a spring board for any future development along this route.
Anything to 'un-city' and relax the M4 visitors / commuter / tourist route would be most welcome.
Fig 13 Map A Map B: Proposal showing ecological
Ecological corridors & rehabilitation areas corridors and rehabilitation areas used to
demarcate and reposition development
from the M4 to the N2
It should be noted that supporting reports including the SOCIO -ECONOMIC IMPACTS and ELECTRICAL BULK AND RETICULATION NETWORK PLANNING show the necessity to incorporate development on the west side of the N2.
The general removal of building bulk and mass from the area would allow more area to be rehabilitated back to indigenous vegetation and a platform to consider the formal adoption of an international 'Kirstenbosch' type botanical gardens 'must see' tourist product and a far more 'softer' and acceptable integrated natural 'africa' base use and context for the Sibaya Casino. This could include 'game reserve' type camps for housing and tourism and a generally more 'safari park' use and product in the area to keep people and tourism in Durban.
We hope you will find these comments helpful in looking at a more broader based 'holistic' use and inherent coastal hinterland value for the area. This includes high value visual areas of lower land and magnificent estuaries, which may not have 'sea views' but with indigenous forest and animals will, because of its location and size, be highly attractive to both the international tourist and investor in Durban City's future.
A Mather, K Breetzke, C Kerr, D Roberts, T Breetzke, D Dold, A+P Carnegie, H+G Cairns, S Moonsammy, G Benjamin, M Sutcliffe