KEEVERSFONTEIN to WARDEN (De Beer’S Pass Section) EIA Ref No: 12/12/20/1992
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ENVIRONMENTAL IMPACT ASSESSMENT (EIA) FOR THE PROPOSED NATIONAL ROAD 3 : KEEVERSFONTEIN TO WARDEN (De Beer’s Pass Section) EIA Ref No: 12/12/20/1992 WRITTEN COMMENTS ON DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (EIR) Submitted by: PAUL STEYN BOERDERY (PTY) LTD (Registration number 1999/023304/07) (hereinafter referred to as “PSB”) Contact address and particulars: The farm Vaalbank, Warden, district Harrismith P.O. Box 286, Warden, 9880 Tel. 082 770 1977 (G Steyn) or 082 413 4526 (Office) Kindly direct all communication to [email protected] and CC to [email protected] ENVIRONMENTAL IMPACT ASSESSMENT (EIA) FOR THE PROPOSED NATIONAL ROAD 3 : KEEVERSFONTEIN TO WARDEN (De Beer’s Pass Section) EIA Ref No: 12/12/20/1992 WRITTEN COMMENTS ON DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (EIR) Submitted by: PAUL STEYN BOERDERY (PTY) LTD (Registration number 1999/023304/07) (hereinafter referred to as “PSB”) Contact address and particulars: The farm Vaalbank, Warden, district Harrismith P.O. Box 286, Warden, 9880 Tel. 082 770 1977 (G Steyn) or 082 413 4526 (Office) Kindly direct all communication to [email protected] and CC to [email protected] 1. INTEREST OF PARTY MAKING THIS SUBMISSION PSB is farming on a number of farms East of Warden and the new planned De Beer’s Pass Section road (hereinafter referred to as “the Road”) will cross over PSB’s farming land in the most sensitive area possible, namely through PSB’s irrigation operations, which form the economical nucleus of the total farming enterprise. The farms are inter alia Leeupoort, Leeukop, Brakwal and Vaalbank, district Harrismith. PSB produces some 70 000 (Seventy Thousand) tons of 2 food per annum in the form of potatoes, maize and meat, which equates to 192 000 kilogram per day, which in turn represent 480 000 (Four Hundred and Eighty Thousand) meals per day, estimated at approximately 400 grams per meal. This means that 160 000 (One Hundred and Sixty Thousand) people are being provided with three meals per day, each and every day, year in and year out, from this farming enterprise. This can also be expressed as 1,752,000,000 (1.75 Billion) meals per annum, produced by PSB. This farming enterprise is a very serious contributor to food security in South Africa. (Refer to Par 8 of the attached Wiese report regarding food security and agriculture as a national priority.) 2. RELEVANT INFORMATION AND ATTACHMENTS The reader is referred to the attached submission/report prepared by Dr Hein J Wiese (an economist) which provides all details of the land areas involved, the scale of PSB’s operations and the potential negative socio- economic and ecological impact that the new Road will have, if built. The reader is further referred to the attached List of Proposals (Annexure 2) that is suggested by PSB in order to mitigate the serious negative impact that the new Road will have. It has to be stressed that PSB is totally opposed to the building of the new Road and trust that this submission, together with comments from numerous other stakeholders, will convince SANRAL not to proceed with the construction of the new Road, but should that eventually prove to be inevitable, PSB requests that the attached Proposals are considered to mitigate the negative impacts. 3 3. SUMMARY OF IMPORTANT POINTS For the convenience of the reader, some of the more important points, that are canvassed fully in the detailed attachments hereto, are summarised here. 3.1 This farming unit (PSB) produces enough food to keep a city with a population of 160 000 (One Hundred and Sixty Thousand) people nourished year in and year out. 3.2 In addition to the food, animal skins and wool are produced for clothing of thousands of people. 3.3 PSB employs a workforce of approximately 500 employees. 3.4 The new Road cuts through the heart of the farming operations as it dissects the most productive parts, namely the irrigation lands. 3.5 Although it may seem as if a relatively limited number of hectares (±60 Ha) are directly affected by the new Road, there is a much larger knock on effect. The irrigation lands are the catalyst that unlocks the potential of many of the other farming divisions. As one example only, the irrigation lands give stability to the total dry land potato production, which would not be attempted by PSB if there was not the security of the irrigation section. Potatoes are very moisture sensitive and if PSB does not have the certainty that a substantial part of the potato crop is secured by irrigation, the risk will become too big to rely upon dry land production only. The cost of moving the current irrigation lands is vast and topographical factors also play a role. PSB will probably find it far too costly to relocate the irrigation lands and the new Road could have the effect that a large part of the irrigation production is lost. 4 There is a tipping point effect in the sense that, with the extremely narrow profit margins in agriculture, the economics of PSB’s enterprise are delicately balanced. To take a substantial number of irrigation lands out of commission, will disturb such balance and could full well press it beyond tipping point with a consequential domino effect. This multiplication factor is clearly illustrated by a letter issued by PSB’s auditors (Marais & Crowther) on 14 February 2014 (See Annexure D) which explains how PSB’s core business changed since commencing with irrigation. The irrigation lands brought about that “Turnover has increased more than tenfold …”. Even without the multiplication effect, the direct loss in food production is in itself shocking: Approximately 56 Ha of irrigation lands will be lost. On each hectare 23,000 kg food is produced every year (57,550 meals!), meaning that on 56 Ha the total loss of food is 3,222,800 meals per annum. That is enough food for 3,000 people on a permanent basis. Thus, the Road on PSB’s farms alone, will at the very least, take food permanently off the tables of 3,000 fellow South Africans, unless far reaching mitigating actions are taken. With the knock on effect, as described above, the loss of food is obviously much more. 3.6 If the construction of the Road goes ahead without mitigating intervention, it will have a devastating effect on food security, employment, socio-economical aspects, the local Warden economy and PSB’s ability to sow good deeds into the Warden community, as it is currently doing. 3.7 Quite severe pollution risks are expected, e.g. spillage of chemicals into the nearby irrigation dams; dust and fuel emissions settling on the products, wool and grazing; noise etc. 5 3.8 The ideal would still be that the new Road is not constructed, but should that prove to be inevitable, the PSB operations can still be salvaged to a certain extent, provided that crucial mitigating steps are taken. Such mitigating action will be beyond PSB’s personal financial ability and PSB needs to engage SANRAL on this aspect to discuss and to agree on what steps can be taken and how it will be financed. The different mitigating steps and interventions are canvassed in the Proposals Document (Annexure 2). 4. WHY HAS PSB PROCEEDED TO ESTABLISH THE IRRIGATION LANDS? The question may arise why PSB went ahead to establish these irrigation lands on the route of the planned road after proclamation thereof. The following should be borne in mind: PSB started with planning of the irrigation operation more than 20 years ago, but PSB could only really get going therewith when the water rights were finalised. This was round about 2007/8. PSB was never 100% certain exactly where the new Road would be constructed. There were many indications that the new Road will not be built and from many quarters, including political office bearers and the ruling Party, the message was constantly conveyed that the other alternatives were so appealing and the cost and negative impacts of the new Road were so vast that the new Road will never be built. As an example, an MEC stated categorically in a public meeting that if he was to pass away the next day, the De Beer’s Pass road could perhaps be built, but if he does not pass away, the new Road will never be built. It was also stated categorically that a situation will not be allowed where an initiative of Free State Province, in the form of the logistical hub at Harrismith, is diluted by another project of a parastatal. PSB fully realises that SANRAL always maintained the opposite view, but one should also place oneself in the shoes of a vibrant and dynamic farmer who has obtained water rights, has access to productive land and who wishes to unlock the huge potential thereof. Most importantly, 6 during the past seven years, PSB has produced more than 12,000,000,000 (12 Billion) meals and these irrigation lands played a major role therein. It was thus absolutely the correct decision to proceed and it was in the best interest of the local economy and of our country. PSB wishes to expand its horizons further, but feels justifiably threatened by the new Road. The economies of scale principle applied in expanding the farming activities and the impact of the forward and backward linkages to the local economies of Warden and the Eastern Free State enforced market demand for PSB produce. In supporting the National Development Plan’s objectives of job creation and food security, PSB business plan for the near future include further investment in establishing an abattoir in Warden and the cultivation of apples with substantial job opportunities.