I Live at 1 Lower Trill Road, Observatory, Cape Town and Have Lived in This House, Which I Co-Own with My Husband, for Nearly 20 Years

From: Kath Hall To: Amy Hill Cc: [email protected]; Leslie London Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 19:32:06

Dear Amy Hill

My name is Katharine Hall

ĚĚƌĞƐƐ: I live at 1 Lower Trill Road, Observatory, Cape Town and have lived in this house, which I co-own with my husband, for nearly 20 years. Before that I lived at 2 Cambridge Road Observatory for three years. ŵĂŝů: [email protected] WƌĞĨĞƌƌĞĚŵĞƚŚŽĚŽĨĐŽŵŵƵŶŝĐĂƚŝŽŶ͗ email dŚŝƐĞŵĂŝůŝƐǁŝƚŚƌĞŐĂƌĚƚŽƚŚĞĨŽůůŽǁŝŶŐ͗ Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3 dŚŝƐŽďũĞĐƚŝŽŶŝƐŝŶƌĞůĂƚŝŽŶƚŽ: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

ĞĐůĂƌĂƚŝŽŶŽĨĂŶǇĚŝƌĞĐƚƉĞƌƐŽŶĂů͕ďƵƐŝŶĞƐƐ͕ĨŝŶĂŶĐŝĂůŽƌŽƚŚĞƌŝŶƚĞƌĞƐƚŝŶƚŚĞĂƉƉůŝĐĂƚŝŽŶ: As a de facto direct neighbour living at 1 Lower Trill Road I am immediately affected by this development. This includes being immediately affected in relation to: Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. Flooding. Pollution during the course the development and additional pollution due to increased traffic. Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. Light pollution due to increased amount of dwellings and development. Additional stress on the sewerage infrastructure. I have been informed through the Observatory network that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially and illegally annexed and privatised by John Comittis of CtFC). High Heritage value of the site in terms of the history of the Khoi. High Heritage value in terms of the first parcel of free-settled farms. Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. Flora and fauna and the destruction of the breeding areas of endangered species. Destruction of a vital wetland and green lung which helps to keep our cities cooler. dŚĞŽďũĞĐƚŝŽŶƚŚĂƚ/ĂŵůŽĚŐŝŶŐŝƐŝŶƌĞůĂƚŝŽŶƚŽ͗ The Basic Assessment Report, which is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans.

The Khoi heritage is one that I support and uphold, same for the environmental heritage of the rivers, flood plain, endangered species of plant and wildlife that is ours to protect. In this regard, no comment is irrelevant.

Once this area is destroyed it can never be undone.

TRUP is also a land parcel where the entire City is considered stakeholders.

The Kyoto Protocol sets internationally binding emission reduction targets which was adopted in December 1997 and acceded to by South Africa in July 2002. The Protocol recognises that developed countries are principally responsible for greenhouse gas emissions as a consequence of decades of industrial activity. South Africa needs to adopt further ambitious actions by 2050. Developing a wetland is the worst thing that you can do.

Further issues that wish to raise include:

2. FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.

There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park.

3. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc.

I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57).

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or airport hangar.

4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spatial development plan does not allow for this development.

While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose.

The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place.

6. FLOODING Have you forgotten the flooding of 5 August 2004? Do you remember that Barloworld sued the River Club for 2 million rands after 15 of its vehicles were damaged in the flooding. There have been many more recent examples.

Who can I sue when my house is flooded? Or when I cannot get access to my house because there is only one entry into lower Observatory via Ossian Road? When Ossian Road is flooded, how will we get into Lower Observatory? Who is liable for damage in this case? The developers? The City? Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved.” The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.

We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain.

We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now?

7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post- Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site.

Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals.

Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations –Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here?

8. EUROPEAN HERITAGE The first free burger settlements in South Africa are immediately adjacent to this development on both sides of the Liesbeek. Coornhoop, Westoe, Raapenberg, Bellvliet, Molenvliet, and the heritage nature of the largely Victorian and Edwardian houses that surrounds these farms reflects the wide diversity of history that results in our country. Coornhoop was the site of key negotiations at the end of Apartheid and this area. Coornhoop makes an important contribution to the local character and identity and was proclaimed a national monument in 1966. Finally, the Observatory itself is a key historic landmark.

9. COST According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. I agree with this.

The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1) (b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

It is not too late.

Please note my strong objections to this development and desire to protect this area.

Regards

Katharine Hall 1 Lower Trill Road Observatory Senior Researcher: Children’s Institute, University of Cape Town.

Disclaimer - University of Cape Town This email is subject to UCT policies and email disclaimer published on our website at http://www.uct.ac.za/main/email-disclaimer or obtainable from +27 21 650 9111. If this email is not related to the business of UCT, it is sent by the sender in an individual capacity. Please report security incidents or abuse via https://csirt.uct.ac.za/page/report-an-incident.php. From: Marc Privett To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 19:32:11

Dear Ms. Hill,

My name is Marc Privett

Address: I live at 43 Duke Street, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for 8 years. Email: [email protected] My preferred method of communication is: email

This email is with regard to the following: Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 43 Duke Street I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. Traffic between Station Road and the N2 has already become problematic, and this development will further exasperate the issue. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the Victorian houses in the area, especially those in lower Observatory which will be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans.

TRUP is also a land parcel where the entire City is considered stakeholders.

Cape Town already has a bad reputation for being in the pockets of the developers. Bo-Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding.

Please note my strong objections to this development and my desire to protect this area, it's heritage and wildlife.

Regards

Marc Privett 43 Duke Street Observatory From: Donna Wills To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 19:57:44

Dear Amy Hill

My name is Donna Wills Address: I live at 8a Willow Road, Observatory, Cape Town and have lived here in Observatory, for 8 years. Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 8a Willow Road, I am immediately affected by this development, this includes being immediately affected in relation to: Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. Flooding. Pollution during the course the development and additional pollution due to increased traffic. Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. Light pollution due to increased amount of dwellings and development. Additional stress on the sewerage infrastructure. Flora and fauna and the destruction of the breeding areas of endangered species. Destruction of a vital wetland and green lung which helps to keep our cities cooler. The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans. Once this area is destroyed it can never be undone. Further issues that wish to raise include:

1. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed. (see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. From a visual design perspective, the height and density of the buildings are a complete eye-sore. 2. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place.

3.FLORA & FAUNA Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 make no mention of this plant! The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park. 4. COST According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development.

Please note my strong objections to this development and desire to protect this area. Regards Donna Wills 8a Willow Road Observatory

Donna Wills 8a CREATIVE +27 72 386 9298

From: Lorraine Ward To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:01:02

Dear Sir/Madam

ƌĨŶƵŵďĞƌƐ: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

With reference to the following: a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

I am absolutely horrified to learn about the intention to develop a beautiful piece of land for pure profit. Surely the impact studies would have shown what a vital area this is for plants, birds and all river creatures.

Who is benefitting politically and financially from this self centred development. Who decided that a few should benefit to the obvious disadvantage to the biodiversity of the area and the surrounding suburbs that would be impacted be increased traffic.

Was this always the intention of the purchaser of these erven, to develop, and why was this condoned.

I look forward to your response by way of email

Your faithfully

Lorraine Ward 19 Northway Pinelands 7405 0825513644

From: Margot Lynn To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 23:30:18

To whom it may concern:

Herewith my objections to the proposed development of the River Club area in Observatory, Cape Town, at the following erf numbers: Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175

The applicable reference numbers are: DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

My name is Margot Lynn, and I am a property owner in Alfred St, Observatory, in the area between the Liesbeeck River and the railway line (Erf 26628 - Sectional Title scheme). I can be contacted via email at the email address above ([email protected]) or via sms /phone call or Whatsapp message on 071 514 7926.

I have several objections to the proposed River Club development.

In no particular order:

I object to what will be the absolute destruction of what is currently a rare urban green lung, natural wetland and heritage area. The proposed densification of this area in terms of the heights and numbers of buildings proposed for the site is absurd. It is also lamentable (and objectionable) that none of the proposed development would actually serve one of the most pressing needs in Cape Town - that of inclusionary or social housing.

I object to what will become insurmountable traffic congestion. The congestion in and out of Observatory (especially subsequent to the developments on Main Road) is already becoming problematic, and as a resident who works elsewhere, I am already finding it extremely difficult to get in and out of Observatory in the mornings, and from mid-afternoon onwards. I fear becoming trapped by the influx of traffic.

I am very concerned as to what will happen to the water table if extreme development takes place on this wetland and natural flood plain. Flooding of the existing River Club is a known problem in the rainy season and clearly developers would have to try and deal with that. How do they propose to do that without severely impacting the water table and causing possible flooding elsewhere - eg Lower Observatory?

And having seen visuals of the proposed developments I would argue that a 5 year old with Lego blocks could have been more creative in architectural style than this. Which suggests that the developers have approached this solely with revenue in mind - fill the most space possible with monolithic blocks.

Yours sincerely Margot Lynn

Disclaimer This e-mail transmission contains confidential information, which is the property of the sender. The information in this e-mail or attachments thereto is intended for the attention and use only of the addressee. Should you have received this email in error, please delete and destroy it and any attachments thereto immediately.

Under no circumstances will the Cape Peninsula University of Technology or the sender of this email be liable to any party for any direct, indirect, special or other consequential damages for any use of this e- mail. For the detailed e-mail disclaimer please refer to , CPUT Disclaimer or call +27 (0)21 460 3911. From: Reagan du plessis To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:08:41

Dear Ms. Hill,

My name is Reagan du Plessis

Address: I live at 72 Arnold Street, Observatory, Cape Town for a year and have lived here in Observatory, for 2 years. Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 72 Arnold Street I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. Traffic between Station Road and the N2 has already become problematic, and this development will further exasperate the issue. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the Victorian houses in the area, especially those in lower Observatory which will be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-applicationbar.It I believe that the scale of the River Club development means that the entire populace of Cape Town is entitled to comment. I believe that all entities from Ward 57, around the two rivers, Pinelands, Oude Molen, Observatory, environmental agencies, civics, churches, schools, business parks from around the City are entitled to object.

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans.

TRUP is also a land parcel where the entire City is considered stakeholders.

Cape Town already has a bad reputation for being in the pockets of the developers. Bo- Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding.

Please note my strong objections to this development and my desire to protect this area, it's heritage and wildlife.

Regards

Reagan du Plessis 72 On Arnold street Observatory

Sent from my iPhone From: Lindsay Kennedy To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:10:41

Dear Amy, My name is Lindsay Kennedy and I prefer to be contacted by: email kenross@mweb.co.za Erf 151832, Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175), DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club, Cape Town I am appalled at this crass and insensitive application by the developers. The development will impact on so many spheres but particularly the sensitive ecological area – one of the few left in the city. The ghastly visual impact is one concern, but more so the degradation of the existing wetland and the wildlife which is slowly increasing in the area. The developers spin a ‘good story’ but are obviously profit driven. When all is said and done can they look objectively at their proposal and say ’we are going to leave this area in a better place’? If they are truthful unto themselves I sincerely doubt it. Shame on them! Sincerely Lindsay Kennedy 082 4933312 24 Pillans Road Rosebank [email protected]

9LUXVIUHHZZZDYDVWFRP From: Kirsten Burgess To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:12:57

Dear Amy Hill

My name is Kirsten Burgess Address: I live at 39 Duke Street, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for nearly 2 years. Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 39 Duke Street I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course of the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. According to Paddy Chapple, our ward councillor, the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

I believe that the scale of the River Club development means that the entire populace of Cape Town is entitled to comment. I believe that all entities from Ward 57, around the two rivers, Pinelands, Oude Molen, Observatory, environmental agencies, civics, churches, schools, business parks from around the City are entitled to object. This proposal impacts thousands of people and intangible heritage that belongs to all South Africans. The Khoi heritage is one that I support and uphold, same for the environmental heritage of the rivers, flood plain, endangered species of plant and wildlife that is ours to protect. In this regard, no comment is irrelevant. Once this area is destroyed it can never be undone. TRUP is also a land parcel where the entire City is considered stakeholders. The Kyoto Protocol sets internationally binding emission reduction targets which was adopted in December 1997 and acceded to by South Africa in July 2002. The Protocol recognises that developed countries are principally responsible for greenhouse gas emissions as a consequence of decades of industrial activity. South Africa needs to adopt further ambitious actions by 2050. Developing a wetland is the worst thing that you can do.

Further issues that I wish to raise include:

1.FLORA Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 make no mention of this plant! 2. FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park. 3. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. 4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spatial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place.

5. POLICY I don't believe that playing the affordable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. 6. FLOODING We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. 7. COST According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. I agree with this. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1) (b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent. Cape Town already has a bad reputation for being “in the pockets” of the developers. Bo-Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding.

Please note my strong objections to this development and desire to protect this area.

Kind Regards, Kirsten Burgess 39 Duke Street Observatory Professional Architect From: Görkem Gölbasi To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:16:05 Attachments: LETTER OF OBJECTION CONCERNING River Club Redevelopment PreApplication BAR.pdf

Dear Ms. Hill,

Please find attached document as my objection letter for River Club Redevelopment Project.

Kind Regards, Gorkem Golbasi From: june bam-hutchison To: Amy Hill Cc: [email protected]; Tauriq Jenkins Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:17:51

Dear Sir/Madam,

RE: Erf 151832, City of Cape Town, and adjacent properties (Erfs 26426, 108936, 26427, 15326 Rem, 26169, 26170, 26171,26172, 26173, 26174, 26175)

Reference Numbers: DEA&DP Ref No: 16/3/3/6/7/2/A7/173104/16

HWC Case No: 15112504WD1217E DWS Ref. No. 16/2/7/G22/A/11 and WU9026 River Club

I hereby object to the proposed River Club Development on the basis of the profound meaning the above grounds have for Khoe heritage and spirituality as born out by the community consultation tribunals. The area is of great historical significance for restorative justice, a much documented history in the archive and through oral tradition. The rights of indigenous people are recognised globally and the Liesbeeck river area in question and its protection is integral to such ritual archive rights to the people of the Cape and the larger South Africa (as a place which symbolises also a 'turning point in South Africa's larger history. This is a non-negotiable sacred right linked to restorative justice.

My preferred form of communication is per this email.

Sincerely

Dr June Bam-Hutchison Centre for African Studies University of Cape Town Visiting Professor, Stanford University Turning Points in History series co-convenor (winner of UNESCO Peace Education Award for South Africa, 2008)

From: Roger Burgess To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:26:24

Dear Amy Hill

My name is Roger Burgess Address: I live at 39 Duke Street, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for nearly 2 years. Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website athttps://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

Further issues that I wish to raise include:

Please note my strong objections to this development and desire to protect this area.

Kind Regards, Roger Burgess 39 Duke Street Observatory From: Lisa Morrison (Strachan) To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:29:38

Dear Amy, My name is Lisa Strachan and I prefer to be contacted by: Email [email protected]

Re: Erf 151832, Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Err 26172, Erf 26173, Erf 26174 and Erf 26175), DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club, Cape Town

1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area.

2. My objection is based on the flood risk and hydrology. I strongly object to increasing the flood risk and reducing the ability of the river to adapt to climate change by adding several meters of concrete into the very soil sponge of a floodplain that currently absorbs the increasingly risky weather events. This shifts the greater risk and uncertainty on ratepayers, residents and commuters in the whole catchment area of the Black and Liesbeek Rivers and tributaries. The proposed river ‘rehabilitation’ does not offset the loss of flood absorption capacity and sets a dangerous precedent for future development in floodplains, giving others the right to do the same, and further reducing our ability to adapt to extreme weather. If the city must densify, it should be outside the floodplain where it could get the same benefits without the uncertain amount of risk and reduction in our ability to adapt to climate change.

3. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial. Furthermore, this should be widely publicised and questionable practices such as this should not be allowed to flourish with elected government officials party to decisions that are clearly NOT IN THE PUBLIC INTEREST

4.My objection is based on the flora and fauna (pages 18 to 83). The proposed plan to concrete over an area of ecological importance is not sustainable. The flora of the Cape Floristic Region are of international biodiversity heritage significance, hosting more than 6000 plants that are found nowhere else in the world. The site soil currently has the potential to host three vulnerable and endangered vegetation types. Reducing the soils’ potential to recover in the future by adding concrete to it and making it more alkaline is not acceptable since the target preservation of all the three vegetation types, Western Leopard Toad and Morea aristata have not yet been met. As the confluence of two rivers and the ultimate meeting point of several river tributaries, the rivers here are important for the movement of several avian, aquatic and mammal species throughout Cape Town. Such dense development is not compatible with the long term survival of these ecological functions.

Sincerely

Lisa Strachan

9 Roseberry Rd, Mowbray [email protected] --

Lisa Morrison (Strachan) Mobile: +27 76 112 2189

From: penelope rose To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:34:50

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Kind regards Dr P{ Rose From: Lorraine Tanner To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:35:25

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Lorraine Tanner [email protected] 0721030661 From: Marijke Barnard To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:38:11

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Kind regards Marijke Barnard From: Rebecca Sher To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:39:02 Attachments: riverclub.pdf

Dear Ms Hill

Please find attached my objection to the proposed development at the River Club site.

Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

In relation to the following case and reference numbers: HWC Case No.: 15112504WD1217E DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

Yours truly,

Rebecca Sher Disclaimer - University of Cape Town This email is subject to UCT policies and email disclaimer published on our website at http://www.uct.ac.za/main/email-disclaimer or obtainable from +27 21 650 9111. If this email is not related to the business of UCT, it is sent by the sender in an individual capacity. Please report security incidents or abuse via https://csirt.uct.ac.za/page/report-an-incident.php. From: frankie murrey To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:44:45

Dear Amy

I would like to lodge an objection to the proposed development.

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)UDQNLH From: Adam Marshall To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:46:40

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

Dear Amy,

I am writing to register my concerns about the planned redevelopment of the River Club site. My name is Adam Marshall and I’m a new resident here in Observatory, in fact I’m new to Cape Town (arrived from the UK January of this year).

I am slowly getting to know the area and its environs so understand the need for accommodation to be available but am concerned about the risk associated with a development in such a fragile and important river flood plain. I feel as if I’m on a very steep learning curve as I try and understand the sense in allowing this to go ahead. I hope that you are sensitive to the needs of all the residents – both home owners and tenants (like myself and my wife), people who work in and travel through the area.

I would appreciate it if you can keep me informed about the progress of the application by email. I will endeavour to familiarise myself with the history of both the application and the area.

Yours,

Adam

From: David van der Want To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:47:02

To whom it may concern,

With regard to proposed development of Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) and with reference to the following reference numbers:

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club and as a resident and property owner in Observatory I would like to lodge my objection to the proposed development.

I object on the following grounds:

1. The area is a water way and the proposed development ignores important issues related to flooding and is an inappropriate use of riverfront land

2. There is no adequate provision of social amenities to support a development of this scale

3. Several areas of the development are zoned as public open access and the development will deprive the public of access to this land.

David van der Want 30 Cambridge Road Observatory Cape Town 0837032398 From: Candice Henley To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 20:52:22

Dear Amy,

Kindly record my objection to the proposed redevelopment of: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175).

I refer to the following reference numbers in respect of my objection:

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

I have viewed the project visuals from SRK Consulting and, as a resident and homeowner in Observatory, I object to the site redevelopment citing the following reasons: 1. Negative impact on the natural ecosystem currently occupied at the aforementioned sites. 2. Negative impact on the heritage in the immediate surrounding area. 3. Probable increase in traffic / people volume as a result of the redevelopment. 4. Probable devaluation of property in the area as a result of the redevelopment.

Kind Regards Candice Henley

Resident, 5 Howe Street, Observatory 084 707 0268 [email protected] From: Gareth Bowers To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:04:02 Attachments: 119091621035600789.png 119091621035600989.png 119091621035601389.png 119091621035601589.png

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Dear Amy Hill

My name is Rofhiwa Nthangeni

Address: I live at 6 Lynton Road , Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for a year as I am a student at UCT Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 6 Lynton Road I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler. The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-applicationbar.It

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans.

Once this area is destroyed it can never be undone.

TRUP is also a land parcel where the entire City is considered stakeholders.

Further issues that wish to raise include:

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers.

4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development.

5. POLICY I don't believe that playing the affortable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application.

Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain. We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now?

7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site.

8. EUROPEAN HERITAGE The first free burger settlements in South Africa are right on the other side of the Liesbeeck. (this includes Valkenberg Farm on the affected side) This is where I live and will be affected by the flooding. Coornhoop, Westoe, Raapenberg, Bellvliet, Molenvliet, and the heritage nature of the largely Victorian and Edwardian houses that surrounds these farms reflects the wide diversity of history that results in our country. Coornhoop was the site of key negotiations at the end of Apartheid and this area. Coornhoop makes an important contribution to the local character and identity and was proclaimed a national monument in 1966. Finally, the Observatory itself is a key historic landmark.

The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

Cape Town already has a bad reputation for being in the pockets of the developers. Bo- Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding.

It is not too late.

Please note my strong objections to this development and desire to protect this area.

Regards

Rofhiwa Nthangeni 6 Lynton Road Observatory From: janine stephen To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:25:05 Attachments: SPM-for-cities.pdf Objection to River Club Development.docx Importance: High

Dear SRK,

Please find my objection to the proposed development attached.

Please acknowledge receipt, as I understand objections must reach you before midnight tonight.

Regards,

Janine

-- Janine Stephen Journalist / Editor / Researcher +27 21 422 0818 (w) +27 73 519 7036 (m) [email protected] Twitter: @janine_stephen From: Mark Chong To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 23:29:03

Dear Amy Hill

DǇŶĂŵĞŝƐDŝĐŬŝĞŝƌŬĞƚƚ

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ŵĂŝů͗ŵĞΛŵŝĐŬŝĞďŝƌŬĞƚƚ͘ĐŽŵ

My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b) HWC Case No.:15112504WD1217Ec) DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Increased Traffic in an already congested city and a suburb with tiny roads.

Flooding.

Pollution during the course the development and additional pollution due to increased traffic. Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. Light pollution due to increased amount of dwellings and development. Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. The deprivation of exercise as a user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) High Heritage value of the site in terms of the history of the Khoi High Heritage value in terms of the first parcel of free-settled farms. Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. Flora and fauna and the destruction of the breeding areas of endangered species. Destruction of a vital wetland and green lung which helps to keep our cities cooler.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

I believe that the scale of the River Club development means that the entire populace of Cape Town is entitled to comment. I believe that all entities are entitled to object. This proposal impacts thousands of people and intangible heritage that belongs to all South Africans.

Once this area is destroyed it can never be undone.

TRUP is also a land parcel where the entire City is considered stakeholders.

Further issues that wish to raise include:

1. FLORA

Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 make no mention of this plant!

2. FAUNA

The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.

3. DESIGN ISSUES:

The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc.

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers.

4. LAND-USE ISSUE

The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development.

5. POLICY

I don't believe that playing the affortable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application.

6. FLOODING

Have you forgotten the flooding of 5 August 2004? Do you remember that Barloworld sued the River Club for 2 million rands after 15 of its vehicles were damaged in the flooding. There have been many more recent example.

7. KHOI HERITAGE

The Khoi heritage has already suffered the indignity of being ignored and forgotten in post Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site.

8. EUROPEAN HERITAGE

The first free burger settlements in South Africa are right on the other side of the Liesbeeck. (this includes Valkenberg Farm on the affected side) This is where I live and will be affected by the flooding. Coornhoop, Westoe, Raapenberg, Bellvliet, Molenvliet, and the heritage nature of the largely Victorian and Edwardian houses that surrounds these farms reflects the wide diversity of history that results in our country. Coornhoop was the site of key negotiations at the end of Apartheid and this area. Coornhoop makes an important contribution to the local character and identity and was proclaimed a national monument in 1966. Finally, the Observatory itself is a key historic landmark.

9. COST

According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development.

The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. I agree with this.

It is not too late.

Please note my strong objections to this development and desire to protect this area.

Regards

Mickie Birkett From: Mark Chong To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 23:25:49

Dear Amy Hill

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ŵĂŝů͗ŵĂƌŬĐŚŽŶŐƐĂΛŐŵĂŝů͘ĐŽŵ

My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b) HWC Case No.:15112504WD1217Ec) DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Increased Traffic in an already congested city and a suburb with tiny roads.

Flooding.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

Once this area is destroyed it can never be undone.

TRUP is also a land parcel where the entire City is considered stakeholders.

Further issues that wish to raise include:

1. FLORA

2. FAUNA

3. DESIGN ISSUES:

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers.

4. LAND-USE ISSUE

The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development.

5. POLICY

6. FLOODING

7. KHOI HERITAGE

8. EUROPEAN HERITAGE

9. COST

It is not too late.

Please note my strong objections to this development and desire to protect this area.

Regards,

Mark Chong From: Miranda du Toit To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:26:03 Attachments: Miranda du Toit Objection River Club Development updated.pdf

Hi Amy,

Please see attached my application for objection to the development you are proposing at the River Club.

I am not only a resident of Obs but my home directly overlooks the beautiful greens of the River Club and the Liesbeek River. The joy of the my first leopard toad in my garden (with the save return to the river) as well as my first sight of a pelican flying in for landing at the river. The sight of the birds sitting in their 100's on the green fields after the rain pecking up the worms on the flood plains.

I hope that our outcry will be heard as it seems today you can do anything as long as you have enough money!

I am available at the mobile number in my signature and objection letter or you can contact me on 021 447 1950.

Kind regards,

Miranda du Toit [email protected] Mobile: 084 823 8004 From: Fairoze Daniels To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:36:39

Dear $P\+LOO

I Fairoze Daniels with contact 071 415 1975 (preferred communication email) would like to refer to:

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As a Ons community member i would also like to strongly oppose the above plants for development as it will directly affect the environment with the canal right which will affect the natural habitat that the canal offers so many animals ....

Kind Regards Fairoze From: Liz Barnett To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:44:10

Dear Amy,

I am Elizabeth Barnett, a South African citizen, resident in Pinelands. I prefer to be contacted by email at [email protected].

Re: Erf 151832, Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175), DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club, Cape Town

I object on the following grounds:

1. The emphasis of the development seems to be commercial where there should be a much higher affordable housing component.

2. The ecological importance of the flood plain, especially with the risk of climate change, has not been taken into account sufficiently.

3. The confluence of the 2 rivers is an important feature for the biodiversity of the area and the whole area should be treated much more sensitively to preserve endangered species.

4. The huge scale of the development will negatively affect the aesthetics of the national heritage site at the SAAO.

Sincerely

Mrs E Barnett

11 Aandblom, Pinelands, 7405

Phone 021 531 8605.

9LUXVIUHHZZZDYDVWFRP From: [email protected] To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:45:08 Attachments: letter of objection concerning River Club Redevelopment PreApplication BAR.pdf

3OHDVHILQGP\OHWWHURIREMHFWLRQDWWDFKHG From: kat cooney To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:51:47 Attachments: River Club Redevelopment final copy.docx

To whom it concerns. My name is Katya Cooney and I object to the development of the River Club. Please see document attached. From: Paolo Israel To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 21:59:43

Dear Amy Hill

My name is Paolo Israel

Address: I live at 38 Florence ave, Observatory, Cape Town and have lived in the Observatory area for over 10 years. Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Declaration of any direct personal, business, financial or other interest in the application: I am a neighbour living at 38 Florence ave. I am therefore immediately affected by this development, in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Risk of flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the developments along the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the Victorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club- redevelopment-pre-application-bar.It

The scale of the River Club development means that the entire populace of Cape Town should be entitled to comment. I believe that all entities from Ward 57, around the two rivers, Pinelands, Oude Molen, Observatory, environmental agencies, civics, churches, schools, business parks from around the City are entitled to object. I am however directly affected as I live within 500 meters (directly) and 700 meters by road of the development.

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans.

Once this area is destroyed it can never be undone.

Further issues that wish to raise include:

The density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57).

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers.

6. FLOODING

7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post-apartheid South Africa. This is such an important site: a burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site.

The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7- 8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

It is not too late.

Please note my strong objections to this development and desire to protect this area.

Regards

Paolo Israel 38 Florence ave Observatory From: Ceinwen Smith To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:02:15

Dear Amy Hill,

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0\REMHFWLRQVUHODWHWRWKHIROORZLQJ 1) Ecological Corridors and Buffer Zones: *UHHQVSDFHVSDUNVSODQWHGYHUJHVDQGULYHUEDQNVSURYLGHHVVHQWLDOSDWKZD\VRUFRUULGRUVIRU ZLOGOLIH ELUGVLQVHFWVDQGPDPPDOV WRPRYHDURXQGVDIHO\LQWKHXUEDQODQGVFDSH 7UDQVIRUPDWLRQRIWKHVHDUHDVE\WKHSURSRVHGGHYHORSPHQWZLOOFDXVHKDELWDWGHVWUXFWLRQDQG FRQWULEXWHWRWKHJURZLQJWKUHDWRIVSHFLHVH[WLQFWLRQ

2) Endangered species: 7KH:HVWHUQ/HRSDUG7RDGDQGMoraea aristateLQSDUWLFXODUDUHWZRWKUHDWHQHG VSHFLHVWKDWZLOOEHKHDYLO\LPSDFWHGE\WKHSURSRVHGGHYHORSPHQW7KHVHSRSXODWLRQVDUHLVRODWHG IURPVXUURXQGLQJDUHDVDQGWKXVORFDOLVHGVSHFLHVORVVLQWKHDUHDFRXOGFRQWULEXWHWRVSHFLHV H[WLQFWLRQ

3) Birds & pollination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

4) Critically endangered vegetation type: 7KHUHLVOHVVWKDQRI3HQLQVXOD6KDOH5HQRVWHUYHOGOHIWDQGPXFKRIWKHH[LVWLQJYHJHWDWLRQ RFFXUVLQLVRODWHGSDWFKHVDURXQG2EVHUYDWRU\DQGWKH&LW\%RZO7KHWUDQVIRUPDWLRQRIWKLVODQGDV SURSRVHGE\WKH$VVHVVPHQWZLOOFRQWULEXWHWRIXUWKHUORVVRIWKLVFULWLFDOO\HQGDQJHUHGYHJHWDWLRQ W\SH

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6) Impact I struggle to comprehend that the development can be seen as having "ecological, visual and cultural impacts (that) are generally acceptable". Who has defined these so-called "acceptable" levels of impact? How can a cultural heritage site, a sacred site of our early ancestors, be so disgraced by multi-story office blocks, concrete and tar? The visual impact of these buildings on the surrounding area will be significant, particularly for the neighbouring Astronomical Observatory. The ecological impact of increased run-off from additional roads, parking areas and buildings will reduce water infiltration through the soil and into the groundwater, adding to an already water-stressed system. how multiple office and apartment blocks, additional roads and parking lots, not to mention the impact on the area during development.

7) Rehabilitation Once the soil structure of an area has been disturbed through ploughing, excavation or even topsoil removal, the area will never be able to be fully restored, and yet the Assessment claims that the development will have "significant" ecological benefits through ecological restoration...I would like to see research showing that "significant ecological benefits" have ever been fully achieved following a development or any act of land transformation for that matter!

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)RUQDWXUHLVRXUILUVWKRPHWKHIRXQGDWLRQRIWKHFRPPXQLW\WKHGZHOOLQJSODFHRIWKH VSLULWVZKRZDWFKRYHUXVDQGORQJWREHUHFRQQHFWHGZLWKXV0DOLGRPD3DWULFH6RPH From: Rosalyn Rowe To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:11:33 to: Amy Hill, [email protected] cc: [email protected] EMAIL subject: River Club Redevelopment Pre-Application BAR

Dear Amy,

My name is (ROSALYN ROWE] and I prefer to be contacted by: [ EMAIL ]

Because of the size of the buildings the wonderful view from the canal will be completely spoilt. We will not be able to walk along the rivers as usual. Because the property is mostly commercial use it will not be attractive at night and lonely.

2. My objection is based on the policy coherence - there is no social housing included in this development.

3. My objection is based on the flood risk and hydrology.

More flooding can be expected as the concrete being added into the floodplain will prevent the increased amount of water from being absorbed into the soil sponge. It will thus reduce the ability of the river to adapt to climate change. No attention has been given to offsetting the flood absorption capacity in the so-called rehabilitation of the river. The risk will thus become the responsibility of the residents, ratepayers and commuters. If permission is given to develop on one floodplain, then for certain it will again be given on another floodplain, even further reducing the ability of the land to absorb the floodwater.

4. My objection is based on the heritage (pages 123 to 270) of the site of national and potentially international importance.

This site is of particular value to the cultural practices and history of the Khoi. The social benefits of housing and jobs can be taken to a site which is not of such irreplaceable heritage value.

5. My objection is based on the feasibility and cost. Social, Environmental and socio-economic considerations have not been taken into account as feasibility in this report refers only to costs to be borne by the developers as to which version is preferred. The evaluator is employed by the major investor in this project so this evaluation cannot be considered impartial.

6. My objection is based on the flora and fauna (pages 18 to 83). The soil, flora and fauna of the site is tied up inextricably with the heritage value of the site. Adding so much concrete will change the nature of the soil's potential to recover which poses a serious risk to flora, fauna and vegetation. This type of development should be made on a site less sensitive and more suitable for the project. These two rivers are important for the movement of several avian, aquatic and mammal species throughout Cape Town. Such dense development is not compatible with the long term survival of these ecological functions.

Sincerely

Rosalyn Rowe 084 800 2152

16 Raleigh Road, Little Mowbray

Email: [email protected]

From: Chloe Derbyshire To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:22:21

Dear Amy

My name is Chloe Derbyshire and I prefer to be contacted by email.

My objection is based on the flora and fauna (pages 18 to 83). The historical and cultural heritage of the site is intimately tied to the soil, flora and fauna as part of colonial historical conflict narrative, and the spiritual landscape and practices of the Khoi. The flora of the Cape Floristic Region are of international biodiversity heritage significance, hosting more than 6000 plants that are found nowhere else in the world. The site soil of TRUP currently has the potential to host three vulnerable and endangered vegetation types. Reducing the soils’ potential to recover in the future by adding concrete to it and making it more alkaline is not acceptable since the target preservation of all the three vegetation types, Western Leopard Toad and Morea aristata have not yet been met. Risking to lose this conservation potential is not worth taking since there are other less sensitive sites more suitable to such dense development. As the confluence of two rivers and the ultimate meeting point of several river tributaries, the rivers here are important for the movement of several avian, aquatic and mammal species throughout Cape Town. Such dense development is not compatible with the long term survival of these ecological functions.

Furthermore, my objection is also based on the heritage (pages 123 to 270) of the site of national and potentially international importance, and of particular value to the cultural practices and history of the Khoi. Commercial buildings of the proposed size and nature are not compatible with these practices and memory. There are presidents of Princess Vlei and Maiden’s Cover where the city has outweighed the broad general public benefits of the cultural and heritage value of a place over profits of development for a few. The social benefits of housing and jobs could be achieved elsewhere, and should be, at sites without such irreplaceable heritage value.

I urge you to reconsider the implementation of this development because of the severe social, cultural, and environmental repercussions.

Sincerely Chloe Derbyshire 064 753 0253 [email protected] From: Edward Frank Tilanus To: Amy Hill Cc: [email protected] Subject: RIVER CLUB REDEVELOPMENT PRE-APPLICATION BAR. Date: Saturday, 14 September 2019 09:21:48

The above refers;

ERF NO's. 151832 City of Cape Town and adjacent properties (Erf 26426, Erf 108936, Erf 26427, Erf 15326, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173 and Erf 26175).

Ref No.

DEA&DP Ref. No. 16/3/3/6/7/2/A7/17/3104/16. HWC Case No. 15112504. DWS Ref. No, 16/2/7/G22/A/11 and WU 9026 River Club.

Edward Tilanus Cell. No. 0731743025 Sunrise Mansions 206 Main Road Muizenberg 7945 [email protected]

TO WHOM IT MAY CONCERN.

I have been involved with the development of the Two Rivers Urban Park from its earliest conception.

Firstly through various non governmental organisations which joined forces under the banner of the Confluence Alliance which lobbied the City of Cape Town to consider the protection of the open spaces of the Black and Liesbeek Rivers, Valkenberg West and East, The Astronomical Observatory, Alexandra Care and Rehabilitation Center, Maitland Garden Village and the Raapenberg Bird Sanctuary, South African Railways and Harbours Sport and Recreation Club (now the River Club) and the reclaimed wetland adjacent to it. Malta Sports Fields and Hartlyvale area.

From as early as 1985 the concept of a large urban park has been envisaged by the local community and of the City Planners.

I have been a member of the Two Rivers Urban Park committee for many years.

The Park is a valuable resource as green lung in a densely populated suburban context, as a flood plain and as a bird conservation and movement route.

The area has numerous other historical and archaeologically important features.

The area has undergone exhaustive Public Participation processes since these earliest days resulting in all the documents and declarations which are before those now considering this River Club development proposal.

It is an important recreational resource for residents in the surrounding suburbs to the West, East, South and North of the Park. STILL, Developers feel the need to exploit the area for self gain and profit!

I therefore object to this development proposal on the following grounds;

1. It ignores the wishes of the broader community as described above and ignores the resolutions arrived at in the numerous documents published on the area to date.

2. The City of Cape Town itself through its Planners and Catchment Management committees has highlighted the importance of the area for flood attenuation purposes. To build in a flood plain should NOT be permitted. Development here will simply result in flood waters being dispersed to other low lying areas such as Maitland and Paarden Island. This development is proposed in an area well known for its severe flooding!

3. This development is proposed to take place in an area important for avian breeding and terrestrial nesting and will result in total habitat destruction of this important function adjacent to an important Raapenberg Bird Reserve and wetland remnant.

4. This development is proposed on land which has a certain zoning which does not permit such a proposal. It should therefore be rejected.

5. The legality or lack thereof of the transfer of the South African Railways and Harbours Recreation Club into private hands warrants official and high level investigation.

This is public land once owned by the State and State Operated Enterprise (TRANSNET and the Rail Commuter Corporation). This proposed development might thus be on land not legally owned by the developers.

6. The Park is to focus on non mechanized transportation within its boundaries and the impact of this development on traffic congestion will run counter to this stated policy objective.

7. With Global Warming becoming more accepted it can be expected that severe storm events are more likely. Situating high density public facilities in a former wetland (Varschvlei) is reckless and will endanger public safety.

8. This development is unnecessary. There are numerous other such developments elsewhere. It's purely for profit and not in the public interest. Whereas this unique POS is a dwindling resource and should be protected at all costs.

I request that I or my representative be allowed in person to address the Council when it considers this development proposal.

Edward F. Tilanus. From: Paula Dugmore To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 23:23:21 Attachments: River Club Objection_ Dugmore.pdf

To whom it may concern,

Please find my letter of objection attached.

Kind regards Paula Dugmore From: Emily Gammon To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application Bar Date: Monday, 16 September 2019 22:57:19 Attachments: Comments on River Club Development Pre-Application BAR (Emily Gammon).docx

Dear Amy

With regards to the River Club Development, please find my comments attached.

All the best,

Emily Gammon (please contact via email if need be) From: Jean Sleigh To: Amy Hill Cc: [email protected]; Carol Clark PRRA Subject: River Club Redevelopment Pre-application BAR Date: Monday, 16 September 2019 22:23:42

Dear Ms Hill

This objection refers to the following ERF and reference numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) .

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club.

I object to the proposed development, on the following grounds: 1. I live in Pinelands and drive past the River Club regularly. At present the area is a pleasant and refreshing green wetland within an urban area. I regard the intended high-density development as unnecessary and visual pollution. 2. I object to the infringement on the habitat of birds, fish, frogs etc. e.g. the Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. Apparently there are also plant species unique to this piece of land. Nature is vital and must be allowed to thrive unhindered. 3. The area is one of very few green 'lungs' of the City. In view of the threatening global warming and climate change, Cape Town needs more green areas and fewer built-up areas. Cape Town is becoming over-crowded and over-populated and it needs its green open spaces. 4. For the same reason, I oppose the rezoning of this land. It must remain public open space and in fact, be recognized as natural heritage for all to enjoy and not any single culture, company or entity to claim as their own and be allowed to exploit it.

Yours sincerely DŝƐƐ:ĞĂŶ^ůĞŝŐŚ ϬϮϭϱϯϭϱϰϭϯ WůĞĂƐĞƐĞŶĚD/>ŶŽƚŝĨŝĐĂƚŝŽŶƐ͘ [email protected] From: Britt MacLaughlin To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR: Objection Date: Monday, 16 September 2019 12:45:14

I wish to object to the Riverclub Development:

ERF Numbers:

Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

Reference Numbers:

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

Personal Details:

Name: DB MacLaughlin Address: 39 Wesley Street, Observatory 7925 email: [email protected] (preferred method of notification) No direct personal, business, financial or other interest in the application. From: Jerome 2 To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR: Objection & Comments Date: Monday, 16 September 2019 22:27:12

Ref: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

Attn: Amy Hill at SRK

Dear Ms Hill,

As a resident of Lower Observatory whose home is nearby and thus being an affected party, I herewith lodge an objection to the proposed development options put forward for the River Club site by Liesbeek Leisure Properties Trust (LLPT) — based on reasons set out below. First of all, however, I’d like to echo a concern expressed by a number of other stakeholders, namely that there appears to be a flaw in the consultation process: issues previously raised have not been systematically addressed. When interested and affected parties raise specific issues, is it not within the remit of your firm to provide substantive responses to these?

1. The price paid for the River Club property by LLPT appears to be approximately commensurate with the land’s current zoning and usage rights — attributable to nature of the site. Others have already voiced their unease about the sale of public land with such common good characteristics, and the circumstances surrounding such sale. I will limit my comments here to the issue of re-zoning and development rights. Given the extent of opposition already expressed by affected parties, it is incumbent on the developer to demonstrate how in the longer term, the proposed development’s broader societal benefits substantially outweigh and compensate for the numerous negative impacts and risks identified by stakeholders in their submissions. After all, granting of such permission effectively represents public assistance to a private entity. If no clear and compelling case can be made, current zoning and usage rights should remain in place. It is noteworthy that several affected parties have not opposed development SHUVH, but argue for a more acceptable form of development. LLPT maintains that only two commercially viable options exist, both requiring that 150,000 m2 of floor area be built; a less intense development alternative is cast aside because an initial annual return of 7.56% is not deemed sufficient. Hence, the only other option being analysed in the pre-application documents is the so-called ‘No-Go’ or status quo scenario. The case put forward for not maintaining the status quo is neither compelling nor sufficient: ‘7KH5LYHU&OXE ZRXOGFRQWLQXHWRSUHVHQWDSK\VLFDOEDUULHUIRU107V\VWHPVDQGZRXOGFRQWLQXH WREHDUHODWLYHO\VWHULOHSULYDWHDPHQLW\DWDNH\ORFDWLRQZLWKLQ7583DQGPD\ SRVHDSK\VLFDOLPSHGLPHQWWRWKHLPSOHPHQWDWLRQRI7583DVFXUUHQWO\HQYLVDJHG’. The importance of NMT systems being blocked is not assessed; leaving aside the subjective ‘UHODWLYHO\VWHULOH¶term, the fact remains that the bulk of land would remain a private amenity in the same sense as it applies to current use arrangements; and it isn’t demonstrated that the ‘LPSOHPHQWDWLRQRI7583’ is a major consideration in the proposal. If LLTP does not deem it viable in the current market context to develop the property in a manner vaguely acceptable to a majority of other affected parties, perhaps it would make better sense for it to wait until market conditions improve. In the meantime, it can simply enjoy the benefits of what it has actually paid for. 2. To prevent flooding of the site (which lies in a flood plain), the hydrological study 'established that the most achievable mitigation measure’ would be 'to raise the ground surface at The River Club to an elevation slightly above the 100-year flood elevation’, but rather contentiously avers that 'this measure would have limited detrimental effects on neighbouring properties’. The credibility of this study has been questioned by more than one affected party, and a request made that it be subjected to an independent review. It is certainly difficult to believe that such a massive decrease in the flood plain’s water holding capacity would leave the flood lines basically unchanged as shown in the study. The fact that previously (in the 1950s when environmental safeguards were limited) there was significant ill- considered infilling of the site does not constitute a valid argument for even more radical infilling. On the contrary, the flood plain’s role as a buffer in major rain storms having already been somewhat compromised, development options that help regenerate this buffering capacity should be explored as a priority. This will be increasingly important going forward given increasing likelihood of extreme weather events and rising sea levels (there being an estuary not far downstream) due climate change. Many of the original houses on the Observatory side are Victorian, generally built with sun-dried clay bricks that do not fare well when submerged. The property market analysis report update by Rode & Associates of Nov 2017 acknowledges the hydrology issue, observing that 'WKHXQNQRZQDWWKLVVWDJHLVWKH FRVWRIPDQDJLQJIORRGZDWHUVDQGZKRLVJRLQJWRSD\IRUWKLV’. No provision appears to have been made to avoid liability for flood damages to ultimately fall on the City, or on affected homeowners (who may find their home insurance premiums rising, or in the worst case scenario, be unable to obtain flood insurance at all). It is somewhat surprising that the answer provided to the question ',VWKHGHYHORSPHQWWKH EHVWSUDFWLFDEOHHQYLURQPHQWDORSWLRQIRUWKLVODQGVLWH"[top of page 95 of the Basic Assessment Report] is “YES”. 3. As underlined by many other stakeholders, it is simply disingenuous to argue that two potential (but so far unconfirmed) future developments (the SKA office building & Berkley Road extension) would considerably change the character of the site, and that therefore the proposed development is not such a big issue. A statement such as ‘We take these two future developments to be inescapable facts’, without substantiating evidence, has no place in a document such as this. Personnel from SAAO have convincingly dispelled the notion that the SKA office block as presented in the pre-application document is a IDLWDFFRPSOLand no progress has been made on the Berkley Road extension since it was first proclaimed in 1968 (indicating that it has not been a priority for the City in over 40 years). What is clear, however, is that the Berkley Road extension is indispensable to the proposed development.... 4. The civil engineering report states that on the southern portion of the site 'Where the bedrock is at relatively shallow depth, it may be feasible to excavate down to the bedrock and install one basement level below the existing ground level’. How would significant height variations in this bedrock layer be addressed? It is of major importance to the surrounding ecosystem and properties that no blasting takes place. The blasting of bedrock when the N2 underpass was constructed caused damage to many houses in the area. Please note that my preferred method of notification is by email to the above address ([email protected]). I would appreciate receiving confirmation of receipt from you.

Kind regards, Jerome van Rooij 75 Strubens Road From: G. Leyman To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR/Objection Date: Sunday, 15 September 2019 22:01:10

Dear Amy Hill, My name is 'ĂƌĞƚŚ>ĞǇŵĂŶ/;ϱϬϬϲϬϯϱϭϮϮϬϴϲͿ Address: I live at 3 Fairfield road, Observatory, Cape Town and I have lived here for 19 years. Email: [email protected] My preferred method of communication is email Cell: 0725582823 14th September 2019

1. I wish to register my objection to the proposed redevelopment of(UI &LW\RI&DSH7RZQDQGDGMDFHQWSURSHUWLHV (UI(5)(UI(UI 5HP(UI(UI(UI(UI(UI(UIDQG(UI 2. The many unique characteristics of the site are of an irreplaceable nature, although the course of the river has been diverted at an earlier stage.

3. The redevelopment and the developers cannot ignore nor adequately compensate the citizens of Cape Town and South Africa by the removal or interference with the existing; a/ A sensitive wetland on the floodplain of rivers which drain large areas of Table mountain East facing fascade and great portions of the Cape Flats and in this regard alone it is not a decision to be made by and between Observatory, The river Club and the City of Cape Town as it concerns all those affected in the catchment area. b/ The site is a Heritage for the many displaced indigenous peoples referred broadly as Khoi-San who annually visited to graze their cattle, and conduct ceremonies under the mountain; It is then an issue also of all the descendants of the Khoi-San. c/ The site should be used by the State as an example of “Expropriation without compensation” where the possible proceeds from sensitive consultative planning could be redistributed to the most affected and vulnerable of Cape Town, namely the disposed homeless Khoi-San now wandering our streets.

Further, I draw your attention to the following reference codes for your convenience to action:

D '($ '35HI1R$ E +:&&DVH1R:'( F ':65HI1R*$DQG:85LYHU&OXE I do not have any business interests which could influence my personal feeling with regards to the proposed development that I am objecting against. I also cite the below information supplied by public bodies as reasons for my objection: ^/'E The size/scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO (South African Astronomical Observatory) have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which has National Heritage Site status. The height and density of the buildings are grotesque. They are laid out without environmental concern or urban integration development imagination (taking into account the environmental/urban design that architects have access to globally) and rather resemble an army barracks or Lego towers. >Eh^/^^h The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current local spatial development plan does not allow for this development. While deviations may be applied for, there must be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City must permit the developers to lease or purchase portions of land owned by the City. 11 (eleven) portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. WK>/zK,ZE The contribution to affordable housing is only 4% of the development, in total. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. ,zZK>K'zE&>KK/E' Flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for runoff of the floor waters. Where will this water go now? ,Z/d'/^^h^ The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledged to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. They have done so because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations – Maiden’s Cove, Princessvlei are examples. Why should theCcity not take that position here? K^dE&^/>/dzK&WZKWK^s>KWDEd The reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they must build so densely. If they accepted a small, but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent. &>KZE&hE

There are also Cape Clawless Otters (Otter holt with young pups) that have been sighted on the Liesbeek River, on the River Club bank side of the river confluence where the development is proposed. These are an endangered species and a gift to our river as their presence here indicates the status of the river’s water quality.

An Obs resident also raised the problem of a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction (on the SANBI website at http://pza.sanbi.org/moraea-aristata). https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar

I trust you understand the seriousness of this objection.

Kind Regards,

Gareth Leyman

From: bifftess To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application Date: Monday, 16 September 2019 19:58:23

Dear Amy, My name is Tessa Kennedy and I would like to be contacted by email (see below). Erf 151832, Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175), DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club, Cape Town I would like to object most strenuously to the above redevelopment for a number of reasons: the particularly unattractive concrete-block type buildings which are completely out of kilter with the aesthetic of nearby areas; the density of said buildings; the potential danger to the flora and fauna of the two rivers and surrounding land; the increased risk of flooding in an area which floods regularly each year. Yours sincerely, Tessa Kennedy 073 2185974 24 Pillans Road, Rosebank 7700 [email protected]

From: Dorothy Holder To: Amy Hill Cc: [email protected] Subject: RIVER CLUB REDEVELOPMENT PRE-APPLICATION Date: Monday, 16 September 2019 07:57:34 Attachments: River Club objection 2019.pdf

Dear Ms Hill,

Please see the attached letter re: the River Club Redevelopment Pre-Application.

Thank you,

Yours sincerely,

Dorothy Holder 083 572 3259

Observatory resident and home owner. From: Lindsay Clowes To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application Date: Sunday, 15 September 2019 11:43:15

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I am a resident of Observatory, and lived in the suburb decades ago while a student. The area has always been a ‘mixed’ community in term of residents, and has a big place in the social and political history of the city. I am a firm believer in the importance of inclusionary housing to address the spatial legacy of apartheid. However, in the light of the limited open and green spaces around the city, and the potential implications for this unique space I do not believe that the development contributes significantly to the problem, and that its loss to development will significantly impact on the character of the area. As a result I object to the proposed development and would like to be kept innformed of the process.

Sincere regards

Vaun Cornell

Alfred Street, Obsrvatory [email protected] From: Simon Scott To: Amy Hill; [email protected] Subject: River club redevelopment preapplocation BAR Date: Monday, 16 September 2019 11:50:58

Dear Amy, Kindly record my objection to the proposed redevelopment of: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175). I refer to the following reference numbers in respect of my objection: DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club I have viewed the project visuals from SRK Consulting and, as a resident and homeowner in Observatory, I object to the site redevelopment citing the following reasons: 1. Negative impact on the natural ecosystem currently occupied at the aforementioned sites. 2. Negative impact on the heritage in the immediate surrounding area. 3. Probable increase in traffic / people volume as a result of the redevelopment. 4. Probable devaluation of property in the area as a result of the redevelopment. Regards, Simon Scott Resident, 5 Howe Street, Observatory 082 961 0152 [email protected] (preferred contact)

Sent from my iPhone From: Christopher Auret To: Amy Hill; [email protected] Cc: [email protected] Subject: River Club Redevelopment Re-Application - BAR Date: Sunday, 15 September 2019 13:58:41

To whom it may concern,

Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club

Name: Chris Auret Contact details : 083 377 1605 Preferred method of communication: email – [email protected] Declaration of any direct personal, business, financial or other interest in the application: As a de facto direct neighbour, living in 28 Cambridge Road, I am immediately affected by this development, this includes being immediately affected in relation to: Destruction of a Heritage Site Removal of an important “green lung” in the city Permanent destruction of the important and unique ethos of Observatory Increased Traffic Flooding Pollution during the course the development and additional pollution due to increased traffic. Noise pollution due to the increase amount of traffic and the significant increase in businesses transacting in the area The deprivation of my exercise as a daily user of the Two River Urban Park The inevitable detrimental effect on the resident Birdlife.

Further issues that I raise as objections include the following, based in large part on the document: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It.

While the below text includes text drafted by the OCA, I have added amendments and additions.

1. Design Issues: The scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57).

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are grotesque. They are laid out without imagination and resemble an army barracks or lego towers.

2. Land Use issue. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current local spatial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose.

3. Policy coherence The contribution to affordable housing is ONLY 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application.

4. Hydrology and flooding Flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now?

5. Heritage Issues The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town.

The site is of INTENSE CULTURAL AND HISTORIC SIGNIFICANCE FOR THE KHOI NATION. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals.

Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. They have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is GROSSLY INAPPROPRIATE to permit this development to go ahead, which will PERMANENTLY DESTROY THIS HERITAGE SITE. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations –Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here?

Heritage issue two relates to the fact that the European buildings on the other side of the Liesbeek Parkway that will be affected by the flooding are amoungst the first free burger settlement farms of South Africa, this includes Coornhoop Westoe, Raapenberg, Bellvliet, Molenvliet, and the heritage nature of the largely Victorian village that surrounds these farms. Coornhoop was the site of important negotiations during the ending of Apartheid and this history is vital to the varied and diverse nature of our democratic, multicultural country.

6. Cost and Feasibility The reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development.

The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

7.Flora and Fauna. The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. ”An Obs resident also raised the problem of a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory.

Otters have recently returned to the area and there are porcupines, water mongooses and a wide variety of birds including pelicans and flamingos that reside in the area.

Despite its location within a protected area, it is on the verge of extinction(on the SANBI website at http://pza.sanbi.org/moraea-aristata). As far as we can tell, the specialist reports (Appendix G2 in two parts) make no mention of this plant.

Yours Sincerely, Christopher Auret 28 Cambridge Road, Lower Observatory (021 447 2824) From: Bonnie & Chris Auret To: Amy Hill; [email protected] Cc: [email protected] Subject: River Club Redevelopment Re-Application BAR Date: Sunday, 15 September 2019 13:48:32

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