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EIA Draft

EIA Draft documents
  • The EIA Draft was completed in Feb 2012, and made available in March 2012
  • The EIA practitioner was Gwen Theron
  • The EIA was paid for by CalgroM3
  • The PDF's are scans of the printed documents - hence they are somewhat large in size. We've received the originals, some are still large
  • The PDF's are searchable - either when downloaded or using the search box on the site

Comments on EIA Draft documents

General Comments
  • The EIA was paid for by CalgroM3 - hence the conclusions are in favour of CalgroM3
  • The earliest references to the development is August 2009 in Vol1-08-Heritage-Impact-Assessment.pdf
    • Residents were only informed in April 2011
    • Why were residents not informed sooner of the proposed development?
Traffic Impact Study
  • The Traffic Impact Study is dated 12 Jan 2012
    • Some analysis was done in November 2011. December and January are quiet periods.
  • The Trip Generation Calculations, as listed in ANNEXURE D, the basis of the report are incorrect
    • The Rate/Unit should be between 1 and 1.1 for "Residential 1", this will conservatively increase the calculations by 21% for the eastern and 40% for the western development - See P. Peska and C. Venter 2010 - "A Relook at Residential Trip Generation Variables"
    • The "mixed use reduction factors", fail to observe that in the plan there are no internal routes between the eastern and western developments and that major major facilities like schools and shopping complexes are located at the northern edge. This will have the opposite effect and increased trip generation.
    • The "mixed use" reduction is incorrectly applied, as there is no meaningful work opportunities 
  • The Study failed to consider Linhill FC, which generates significant traffic between 17:15pm-20:00pm during the football season which is February - September
  • The Study recommends that "The development should contribute 30% and the local authority the remaining 70%" to construction cost of the intersections.
    • In our opinion, the developer should contribute 70%, as the road improvements are only required because of the development.
  • The Study failed to consider existing busy arterial routes which fall within a 1.8km radius of Moffat Park
    • Prairie (M11) / Verona (South Rand/M38) (1.3km west of Moffat Park)
    • Comaro (M11) / Victoria / Boundary / N12 Ramps (1.2km-1.3km west of Moffat Park)
    • Marjorie (M19) / Heidelberg (M31) (1.8km north of Moffat Park)
  • The Study failed to notice a major development 2.8m away at Oakdene/Richmond Parks
  • The figures used to calculate the trips are from 2007.  Transport profiles in have changed significantly since then.
  • No consideration has been taken of the number of cars that will be using South Rand Road as a route to avoid the tolled highway.
  • The specialist keeps referring to the South Rand Road / Plinlimmon / East Road interchange as a single interchange.  This is incorrect.
  • No consideration been given to the fact that the amount of traffic on East Road is going to be unmanageable at peak hour in the mornings.  Linmeyer Gardens is going to work, St Martins is arriving for school and the residents of the development are leaving for work.  Serious consideration should be given to closing or moving at least two of the access points on East Road.
  • No consideration seems to have been given to how the residents without cars will access amenities?
  • The Study document makes a comparison with “Brickfield” and “Legae”, but these are inner city developments with very different amenities closely available.  This will be a suburban development.
  • On page 21, there are 4 recommended changes to the intersection of the R59 and South Rand road, but on page 37, there is only one - please clarify.
  • There are taxi pullover points shown using East Street directly outside the primary school.  This does not make sense from a safety, hygiene or noise level.
  • It is almost a certainty that an informal taxi rank will spring up to service this community.  No mention of this risk or any mitigation actions have been made in the Traffic Impact Study.
  • Mariteng seems to lack local knowledge of traffic patterns in the Southern Suburbs and which roads are currently congested.
  • Based on the above, the traffic study cannot be relied upon. We would recommend that this study be re-done with the above factors take into consideration.  Failure to do so will result in significant congestion and costs at a later stage.
WSM Leshika Geotechnical investigation
  • The report is "overlay printed" with many sections missing, eg. 7.2, 7.6, 7.8 are all missing
  • The missing sections and printing make the report unreadable and unusable
  • We have not scanned this report
  • We request that a proper copy be supplied - we have received a proper copy
Geo hydrological Report (information derived from the summary as WSM Report is broken)
  • South Africa is an arid country, with water being a scarce resource.
  • The fact that the Moffat Park lies in the headwater region with no up gradient contaminant source is important in an arid country trying to make best use of its water resources.
  • This development will render this water source unusable.
  • P26 of the Geo hydrological report recommends that further investigation be conducted into the impacts of the development on the catchment area.

Refuse removal
  • There is no assessment as to Pikitup's capacity to deal with the increased amount of waste or will there be overflowing skips of rubbish?
Educational Facilities
  • There are two schools earmarked on the site, to accommodate 750 primary school pupils and 1600 high school pupils.
  • In Dr Gwen’s responses to I&A questions, she states that "These sites will be made available to the Dept. of Education".
  • There is no correspondence / request with the department of public works / department of education to build these schools.
  • There is no plan or commitment to building any schools or even a time period for such construction - this is the same as PennyVille where educational facilities have not yet been started.
  • Sunday Times 25th March 2012 states that the state will be spending R657 million LESS on new schools in the future, so the chances of a school being built are minimal.
  • This also assumes that only half the households will have a child.  It is far more likely that there will be more than 10,000 children needing schooling (2 per house hold)
  • Where will the 2350/10,000 children go to school?
  • Existing schools are already at capacity and as these are low cost dwellings, the parents will not be paying private fees.

Fire Station
  • The Study does not consider the fire department requirements
  • The fire department does not currently have capacity to cope with the existing area under its mandate. 
  • It has already closed the fire station in Linmeyer. 
  • Will it be able to absorb responsibility for all the additional dwellings? 
  • Also keeping in mind that the fire department is also responsible for paramedic response.


  • The Study does not adequately address safety.
  • There are currently too few police officers and/or response vehicles for the area.
  • How is it proposed that this development will be accommodated?
  • The present policing service is a satellite station which is not coping with the present demand.
Health facilities
  • The Study does not perform an analysis of the health facilities in the area.
  • The current hospital and clinic do not cope with the existing demand on their services.
  • How they cope with an influx of another 10,000 people needing primary health care.
City Power
  • It is going to cost City Power R40 million to upgrade the electricity infrastructure. 
  • Do they have capacity and budget? 
  • The proposed timeline is to commence the upgrades in March 2013 and complete them in Dec 2014? 
  • This timeline was proposed by the consultants, but has not been agreed to by City Power. 
Water and sewage
There is repeated mention of a storm water management system which must be built.  Will this be accommodated in the plans?
The pumpstation is going to have to be upgraded to accommodate this development.  Have Joburg Water got capacity to do this?
The geo hydrological report states that the development must be evaluated in terms of the overall impact on the Upper Vaal catchment area, and not just on this development site alone.  There is no evidence that this has been done.

Conservation issues

Dr Theron states that the Red Data List (“RDL”) plant Khadia Beswickii, which was once thought to be extinct, will be relocated and implies, without guarantees, that research funding will be made available in order to facilitate this.  According to the GDACE Threatened species policy, this plant must be conserved in situ with a 200 m buffer zone.  This is clearly stated in David Hoare’s document. The EIA states that the buffer zone will be reduced to 50m. (pg 36)
There are 9 other species which are very likely to exist on the site, which are red or orange listed.  The survey was done in September 2009 and it was stated that “The feasibility study was done before the rain season.  Thus the list of dominant floral species is by no means an indication of the vegetation diversity present on the site.  Other species, and more important, RDL species could be present on the site.”
No mention is made of any investigation into any migratory species that may use the site at only particular times of year.
The Joburg Metropolitan Open Space System identifies this site as a “priority area” which must not be developed. (2007)
The wetland area near East Street is protected by environmental law but the plans show it under buildings.
The vegetation type is Soweto Highveld Grassland which is listed as endangered. 
The conservation target for this vegetation type is to conserve 24%.  Currently only 0.2% is conserved. 
The following fauna are listed as potentially using the site:
South African Hedgehog      Protected     High probability
White tailed mouse         Endangered      High probability
Lesser Kestrel             Vulnerable      Very High probability
Heidelberg Copper butterfly      RED LISTED      Very High probability
Marsh Sylph butterfly          REDLISTED      High probability
On page 79 there is repeated mention of “may be required to work in/near wetland”. 
What rehabilitation plans are in place?

Additionally, Dr Theron ignored aspects of the environmental reports to suit the development.
For example: Reducing a buffer zone from 200m to 50m (see p21 of report)
Recommending relocating RED plant species to suite the development, but not realising, that the very people who would benefit from the current location, would be deprived by its relocation.

Impact on values of surrounding properties
  • I&A raised the question of devaluation of surrounding properties.
  • No scientific analysis was done, and answers are based on misinformation.
  • The answer from Dr Gwen was that a “buffer of single family units on the edges”.
  • This contradicts the development plan which has many 3&4 level units on the edges (Blue).
Heritage Impact Assessment

"The geological site is viewed to have a high significance on a regional level and should be avoided at all costs.
The two sites used by adherents of the Apostolic faith are viewed to have a high significance on a local level.
The developer should communicate with the people using these sites prior to the development taking place
The two informal dump sites are viewed to have a medium significance on a regional level and test excavations should be done on them by a suitably qualified
  • The EIA ignores the recommendations of the assessment - the sites identified are overlayed by the development will be destroyed by the development.
  • When will the excavation be done
The EIA promotes the fact that the development will create jobs and reduce crime related to unemployment.
Real life shows that the jobs will go away again once the development is complete, creating a higher level of unemployment.
Anecdotal evidence also shows that crime levels generally tend to increase while building operations are in progress.
The EIA does not propose mitigating advice on dealing with the increased crime.

Blue sky thinking
How are you planning to prevent the approximately 10 000 residents from destroying the public open space? 
There is a high probability of the space being used to dump household refuse, or potentially grow crops. 
Simple foot traffic will cause a significant amount of damage. 

It is stated on page 96 that “walkways through open spaces will be enforced”.  How? “the development will blend in/compliment(sic) the surrounding environment completely”, but on the same page (pg 40) you state that the development will have a high visual impact.

There are already a number of vacant dwellings in the surrounding areas, is there sufficient demand for this development, or will it rapidly generate into a slum?
CoJ currently does not have the capacity to maintain / improve Moffat View Flats, South Hill Flats, Welfare Park Flats, but it is proposing to more build 4 Level flats.

The EIA seems to think that the development will be deposited in place and will have no ripple effect into the surrounding community. 
Once CalgroM3 and Standard Bank have made their money and left, who will be maintaining the premises and the public open space?

The Leshika geological survey states that there will be “shallow severe excavation difficulty”.
This means that it will require blasting and jackhammers to create solid foundations.
How will this impact on the surrounding suburbs and schools?
Will the developer pay the repair costs for any houses potentially damaged by the blasting?

Why are the numbers different?
When reading theE IA document, not everyone seems to be working from the same data. 
Dr Theron states 4200 dwelling units, the traffic summary states 5161 dwelling units, the civil engineer states 5189 dwelling units at the top of the page and 5161 at the bottom of the page. 
The civil engineer states that the figures are for this development, but puts a heading of Fleurhof?

Documentary flaws
There is an e-mail about a development in Irene included in the public participation pack.
There is reference to an airport on page 76 and page 98 "the potential to provide additional airport facilities"
There is reference to a retirement village on page 94.
Is this document just a cut and paste mash-up?
It appears that proper focus has not been given to this document and as a result it should be discredited and another EIA done by another practitioner.
Dr Theron’s declaration that she has no vested interest in the development is not included in the pack.

It is stated on page 59 that the lower income properties will be located away from the existing schools, but the map shows that the highest density of 4 storey GAP units directly overlook Hill High school and the crèche.

A  number of times in the document it is mentioned that things will be done "as far as possible".
For example, "indigenous vegetation will be reintroduced to the newly created urban open spaces as far as possible."
Who determines what is possible? The environmental specialist or the budget?

There is no time line in the document, only repeated references to "lengthy” (sic) so even if the neighbours are in favour of the development, they have no idea how long they will be living with the discomfort of construction.

The document does not present itself as an unbiased document.
Word usage and phrase selection seem to lean in favour of the developer. 
Instead of presenting alternatives 1 through 5,  the author gives an opinion, by calling them ‘no-go’  and ‘preferred alternative’.
This shows significant bias in favour of the development.
Also, the document states that there will be no job creation if the option of Res 1 is pursued.
This is blatant nonsense.  There may be slightly fewer construction jobs but ongoing employment for domestic workers, gardeners, security personnel and maintenance personnel would probably be higher.

Some of the motivations for the development are "Improved tax base for the local community" due to the employment of the construction workers.
This is just an assumption.  The use of local labour, goods and services is not a guarantee, merely a sales pitch.
Every supplier would have to go through the tender process and local suppliers will probably not be given preference.

Public Participation
The public participation process seems to be fatally flawed, with the majority of stakeholders unaware of the development, or misinformed about the scope of it?

The public participation process was very poorly done, as evidence by only 24 people attending LEAP’s 5th April 2011 meeting.
As of 28 March, we have received and lodged 800 official objections with CoJ.

While Dr Theron will have you believe that LEAP did all they could to be consultative in this decision, the simple truth is they failed and fell far short of what would be expected in a matter of this magnitude.
This was demonstrated by the outrage and surprise that virtually all rate payers expressed.
We were all shocked by the extent and implications of the Moffat Park Development.
There are an estimated +5,000 homes within 1km radius of Moffat Park.

Of the I&A submissions, 95% were against the development.
I would project these numbers to reflect that 95% of residents surrounding Moffat Park are against the development.

The consequences of LEAP’s superficial Participation Process has very serious implications for residents. 
Residents were not informed, and when some did discover what was planned, were left with very little or no time to object.


I&A respondents were misled into believing that their comments would influence the process. 
Clearly, their submissions had no influence, with most of Dr Theron’s one line responses being of a condescending nature and just fobbing off the questions
P50. “The area had been neglected and the City Council simply does not have the money to maintain derelict open pieces of land
It’s meant to be an open natural piece of land.
It’s derelict because the CoJ does not do what rate payers pay it to do.
Maintain Large open areas are simply too costly for the city to maintain it in the manner that is required by residents
Moffat Park is a “Passive Park” and COJ/CityParks does not do anything currently, they spend zero, so how can it be too costly?
Large areas of Moffat Park will be retained as open space and active and passive recreational areas will be developed.  Also the development will reach an agreement with CoJ to develop and maintain the park.”
These 2 quotes contradict each other, if the CoJ can’t maintain a the current passive park, how can will it maintain the new active and passive parks?
CoJ can’t maintain most parks the South.  Drive around South Hills, Moffat View, etc and you will see that no parks are maintained.
In Linmeyer, the residents have resorted to maintaining the park at their expense.

P62. Response: Lots of “Noted”, but where is the answer? “Noted” is not an answer.

Civil Engineering Services Outline Scheme Report
  • R141m Cut & Paste estimate - see Page 13

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