GARDEN ROUTE
NATIONAL PARK
STAKEHOLDER PARTICIPATION
REPORT
AUGUST 2010 PARK MANAGEMENT PLAN GARDEN ROUTE NATIONAL PARK
MANAGEMENT PLAN
STAKEHOLDER PARTICIPATION REPORT
for submission to the
MINISTER OF WATER AND ENVIRONMENT AFFAIRS
AUGUST 2010
ii TABLE OF CONTENTS
1. INTRODUCTION ...... 1
2. THE STAKEHOLDER PARTICIPATION PROCESS...... 1 2.1 Objectives ...... 1 2.2 Approach ...... 1
3. THE STAKEHOLDER PARTICIPATION STRATEGY FOR GARDEN ROUTE NATIONAL PARK...... 2
4. STAKEHOLDER EVENTS AND ACTIVITIES...... 3 4.1 Stakeholder consultation: Government and Non-government ...... 3 4.2 Registration as an Interested and Affected Party...... 4 4.3 Desired State and Hierarchy of Objectives Workshop ...... 5 4.4 Focus Group Meetings...... 6 4.5. Public Meeting to Comment on the Draft Management Plans...... 6 4.6 Public Meetings...... 7 4.7 Dissemination of Documentation and Feedback to Stakeholders...... 7
ISSUES AND RESPONSES...... 8
ANNEXURE 1: ISSUES AND RESPONSES: PUBLIC and FOCUS GROUP MEETINGS...... 9
ANNEXURE 2: ISSUES AND RESPONSE TO SUBMISSION BY R. Batson ...... 31
ANNEXURE 3: ISSUES AND RESPONSE TO SUBMISSION BY T. N. Cockroft...... 37
ANNEXURE 4: ISSUES AND RESPONSES TO SUBMISSION BY S. SWAIN, Plettenberg Bay Community ......
Environmental Forum...... 49
ANNEXURE 5: ISSUES AND RESPONSES TO SUBMISSION BY A. WALTERS ...... 55
ANNEXURE 6: ISSUES AND RESPONSES: MEETING WITH BITOU MUNICIPALITY...... 61
ANNEXURE 7: ISSUES AND RESPONSES: MEETING WITH KNYSNA MUNICIPALITY...... 62
ANNEXURE 8: ISSUSES AND RESPONSES: MEETING WITH GEORGE MUNICIPALITY...... 63
ANNEXURE 9: COMMENTS: NATURES VALLEY RATEPAYERS ASSOCIATION...... 65 G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
iii STAKEHOLDER PARTICIPATION
1. INTRODUCTION
The Garden Route National Park was proclaimed during May 2010 and in terms of the National Environmental Management: Protected Areas Act it is a legal requirement for national parks to submit a Management Plan to the Minister of the Department of Environment for approval.
2. THE STAKEHOLDER PARTICIPATION PROCESS
2.1 Objectives
The objectives of the stakeholder participation process are to: ●● Create a channel for the accurate and timely dissemination of information to interested and affected stakeholders; ●● Create the opportunity for communication between SANParks and the public; ●● Promote opportunities for the building of understanding between different parties; ●● Provide the opportunity for stakeholders to give meaningful input into the decision-making processes that drive the development of the Park Management Plan.
2.2 Approach
The approach to the Stakeholder Participation Process is based on the principles embodied in the following legal framework: ●● The Constitution of the Republic of South Africa Act No. 108 of 1996; ●● National Environmental Management Act No. 107 of 1998 (NEMA); and ●● The National Environmental Management: Protected Areas Act No.57 of 2003 as amended by the National Environmental Management: Protected Areas Act No.31 of 2004.
In addition to the above legal framework, the stakeholder process was developed with the Guiding Principles for SANParks Stakeholder Participation in mind. SANParks thus undertakes to: ●● Seek to notify stakeholders of participation processes through appropriate mechanisms. ●● Ensure that the process provides the opportunity for input from all stakeholders within reasonable timeframes, emphasising the sharing of information, joint- learning and capacity building. ●● Promote participation by stakeholders through timeous and full disclosure of all
1 relevant and appropriate information. 3. THE STAKEHOLDER ●● Provide feedback on the outcome of the process to PARTICIPATION STRATEGY FOR stakeholders and demonstrate how their inputs have been considered in the decision making process. GARDEN ROUTE NATIONAL PARK ●● Ensure that methodologies accommodate the The Stakeholder Participation Strategy for the context of the issue at hand and the availability of development of the Park Management Plan for the resources (people, time, money) and do not conflict Garden Route National Park is detailed in Figure 1. The with these guiding principles. various stakeholder events and activities carried out ●● Give particular attention to ensuring participation during the process are summarised in the tables below. by marginalised communities, communities with specific concerns, or communities that have contractual rights in the National Park.
STAKEHOLDER PARTICIPATION STRATEGY GARDEN ROUTE NATIONAL PARK
CALL FOR STAKEHOLDERS National media Local media TO REGISTER Existing stakeholder database
Media INVITATION TO PARTICIPATE E-mail IN THE Posters Fax PARK MANAGEMENT PLAN Personal invitation MEETINGS Telephone
STEP 1: STAKEHOLDER STEP 2: STAKEHOLDER Comments + WORKSHOP MEETING Inputs - Review Draft - Define the Desired State
DRAFT PLAN
COMMENTS INTEGRATED
CONSULTATION WITH SPECIAL INTEREST FOCUS GROUPS REPORT BACK TO STAKEHOLDERS
APPROVAL BY EXCO
FINAL PARK MANAGEMENT PLAN G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P SUBMIT TO MINISTER FOR APPROVAL
Figure1. The Stakeholder Participation Process for the development of the Park Management Plan for the Garden Route Natioanl Park
2 4. STAKEHOLDER EVENTS AND ACTIVITIES
Table 4.1 Stakeholder consultation: Government and Non-government
This table reflects the various organisations that were identified to participate in the Park Management Plan Process. The government departments are at national, provincial and local level. The intention is to show that, in terms of the spirit of co-operative governance SANParks has approached these parties.
Local Government Knysna Municipality; George Municipality; Bitou Municipality; Eden District Municipality; Koukamma Municipality; Cacadu District Municipality.
Provincial Government Department of Environmental and Development Planning.
National Government Department of Agriculture Forestry and Fisheries; Department of Water and Environmental Affairs.
Visitors to Parks Notices of all meetings were placed at public reception areas throughout the Garden Route National Park.
Neighbours and landowners. A comprehensive database exists for all neighbours of the Garden Route National Park. An electronic invitation was sent to all the neighbours and landowners associated with the Garden Route National Park.
Community Organisations The Garden Route Initiative’s database was used to contact Community Organisations.
Local Business and Business The Garden Route Initiative’s database was used to contact Local Associations. Businesses.
Media Knysna Plett Herald; George Herald; Kouga Express; The Edge Newspaper; Action Ads.
SANParks Staff Copies of the draft Management Plan was sent to all offices within the Garden Route National Park to disseminate to staff.
Conservation Organisations CapeNature; Eastern Cape Parks Board.
NGO’s The Garden Route Initiative’s database was used to contact NGO’s. Some of the NGO’s include WESSA; Eden to Addo; WWF.
Tourist Associations George Tourist Association; Knysna Tourist Association; Eastern Cape Tourist Association.
Tour operators The Garden Route Initiative’s database was used to contact Local Businesses
3 Table 4.2 Registration as an Interested and Affected Party
Stakeholders had the following opportunities to register as interested and affected parties.
Mechanism to Register Description Date
1. Media Advertisements The database off the previous Public workshops for the 2006 Wilderness and Tsitsikamma National Parks were used.
Advertisements for registration was placed in the following April 2010 newspapers and publications: • Knysna Plett Herald • George Herald • Kouga Express • The Edge • Action Ads
2. National Registration Via the Garden Route National Park website April 2010
3. Local Registration At all offices in the Garden Route National Park. Registration April 2010 Forms were available at reception and were distributed by staff.
Posters and advertisements were also placed at the following Public libraries (with registration forms): • George Public library • Pacaltsdorp Public library • Thembalethu Public library • Wilderness Section of the GRNP (reception) • Touwsranten Public Library • Sedgefield Public Library • Smutsville Public Library • GRNP Regional Offices, Queen Street • Knysna Public Library • Khayalethu Public Library • Hornlee Public Library • Plettenberg Bay Public Library • Kranshoek Public Library • Kwanokuthula Public Library • New Horizons Public Library • Municipal office in Storms River Village • Municipal office in Kareedouw • Municipal office in Kurland Village • Coldstream Community Centre
• Nomphumelelo Community Centre T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P • Uniondale Public Library
4. Registration at meetings Stakeholders were able to register at all workshops and 17-18 May 2010 meetings
4 Table 4.3 Desired State and Hierarchy of Objectives Workshop
The Desired State and Hierarchy of Objectives Workshop took place on the 23rd and 24th March 2006 and involved a wide range of stakeholders and SANParks specialists in the development of the desired State which entails drawing up a vision for the Park supported by higher level objectives which form the framework for the management plan.
Activities Description
Invitations Personal invitations were send to selected interested and affected parties on The existing Park Database of Stakeholders was the 2nd of March 2006. used to identify interested and affected parties.
Desired State and Hierarchy of Objectives Workshop The workshop took place on 23 and 24 March 2006 at the Wilderness Protea Hotel.
Attendance: Participants represented the following interested and affected parties: A total of forty one (41) participants attended the • Municipalities meetings. • NGO’s • MTO • Eastern Cape Parks Board • Tourism Associations • Agriculture • Nelson Mandela Metropolitan University • Marine and Coastal Management • SANParks Management • SANParks Scientific Services • SANParks Park Planning and Development • CapeNature
5 Table 4.4 Focus Group Meetings
These are meeting called with constituencies that are essential in the Park Management Plan process. In the Garden Route National Park context the various municipalities and the established Park Forums of the three sections were identified as Focus Groups.
Group Date
Eden District Municipality 10 June 2010
George Municipality 02 June 2010
Wilderness Park Forum 17 May 2010
Knysna Municipality 26 July 2010
Knysna Park Forum 18 May 2010
Bitou Municipality 02 June 2010
Tsitsikamma Park Forum 20 May 2010
Koukamma Municipality 09 June 2010
Table 4.5. Public Meeting to Comment on the Draft Management Plans
The public meetings were held to elicit comments and input into the Draft Management Plan.
These meetings were widely advertised in the media, by email and telephone and by poster in a number of communities. All registered Stakeholders were invited to the meetings.
Method Description Date
Media Advertisements Adverts were placed in the following newspapers: May 2010 for Public Meeting • Knysna Plett Herald • George Herald • Kouga Express • The Edge Newspaper
Emails, Faxes, Park database, compiled from existing Park database and May 2010 Telephone newly registered participants
Posters displayed Posters advertising the meeting displayed in: May 2010 in the following All the public libraries listed in table 4.2. communities
Display of Draft The Draft Management Plans were displayed in all the offices May 2010 Management Plans of the Garden Route National Park as well as all the public libraries listed in table 4.2, prior to the public meetings. The G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P draft plan was also available on the Garden Route National Park website.
6 4.6 Public Meetings
Public meetings were held as follows:
Number of Stakeholders Venue Date that attended
Wilderness, TOUWSRANTEN 17 May 2010 17
Knysna, RIVERSIDE HOTEL 18 May 2010 9
Tsitsikamma, BOSKOR 20 May 2010 21
Table 4.7 Dissemination of Documentation and Feedback to Stakeholders
Date
Dissemination of finalised Park • The Plans will be available Once the Plan is approved. Management Plan on the SANParks Website once approved by the Minister • They will be made available to registered stakeholders by post or email where possible • They will be placed in municipal offices in local communities • Copies will be available from the Park on request
7 ISSUES AND RESPONSES
The following SANParks personnel replied to issues raised by the public:
●● Dr. Nomvuselelo (Mvusy) Songelwa: General Manager, Garden Route National Park ●● Len du Plessis: Manager Planning and Implementation, Garden Route National Park ●● Andre Riley: Area Manager, Knysna Section of the GRNP ●● Jill Gordon: Area Manager, Wilderness Section of the GRNP ●● Wana Bacela: Area Manager, Tsitsikamma Section of the GRNP ●● Elzette Bester: Manager People and Conservation, GRNP ●● Zanemvula Gozongo: Communications Manager, GRNP ●● Clementine Mbatani: Marketing Manager, GRNP. ●● Derec Giles: Manager Finance and Administration, GRNP. ●● Dr. Wessel Vermeulen: Scientist, SANParks Conservation Services ●● Dr. Ian Russel: Scientist, SANParks Conservation Services ●● Dr. Rod Randall: Scientist, SANParks Conservation Services ●● Graham Durrheim: Scientist, SANParks Conservation Services ●● Johan Baard: Scientist, SANParks Conservation Services ●● Russel Smart: Park Planning and Development G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
8 ANNEXURE 1
ISSUES AND RESPONSES: PUBLIC and FOCUS GROUP MEETINGS
GRNP PUBLIC PARTICIPATION PROCESS: RECORD OF MEETINGS, 17th-20th MAY 2010
WILDERNESS FOCUS GROUP – LOERIES NEST 17th MAY 2010
Issue raised Response (R) Organisation Questions and Responses by by
Dave Jones Q: Is this a closed meeting, may he report on the meeting in the local paper and what is the forum that is here today
Len du Plessis R: There are three management units within the new GRNP. In each unit there are three groups that have been identified, local municipalities, Park Fora and open public meeting. Not a closed meeting and he may report on it in the paper, open and transparent process.
Richard Batson Park Forum Q: The problem is that the executive committee of PFM got the invitation, not the Executive rest of the forum and some people felt that they were not invited as they did not get Committee invitations.
Len du Plessis R: Representatives of the entire park forum were invited according to the SANParks Jill Gordon list and in terms of who they have called and followed up with after sending out invitations.
Ray Barrell Wilderness Q: People may be at the meeting this evening. Lakes Water Forum
Jill Gordon R: The matter will be investigated to make sure who got invitations and that the list is correct.
Peter Harinic Khoi Khoi Q: No chance to bring comments from my community because we did not get the Forum necessary information in order to prepare properly for the meeting. Outeniqua
Jill Gordon R: The invitations were sent to all the members of the forum and notices were put up in libraries, in the paper and at public places and we took steps to let everyone know about it in good time. There is still time for the group to review the plan and respond and the plan is at the library for consideration. No decisions will be made today (that will disadvantageous to his community).
9 Issue raised Response (R) Organisation Questions and Responses by by
Lwayipi Sam Forestry Indaba Q: We are the public and are happy to hear this a public meeting. This will be a long process and we need to get on with it. DWAF process also took place and was a problem as it didn’t work. We must get it done for the community. We are the forestry workers. We want to know what the financial sustainability outlook is for forest worker community. We want to be part of the decision making process and want to know what is going on with finances. Decision making must be participative.
David R: Thank you and we must make sure that SANParks deal with what is their Grossman mandate and that they can’t answer for other departments such as former DWAF.
Richard Batson Q: A framework was posted on the internet in 2008, for developing and implementing management plans for South African national parks. It is very different from the process that has been outlined today, especially with respect to PP process. The framework is quoted with the essence being that everyone is able to contribute meaningfully
R: Wishes to finish the description of the process and will come back to these issues.
Quaanitah Park Forum Q: Serves on park forum as deputy chair and serves on wilderness forum. Have Simons Deputy Chair to guard against creating false expectations. Biodiversity lends itself to community participation and communities have very clear understanding of what they want it to look like and how everything should build to the bigger picture, communities interested in bigger picture. Were previously told the plan was waiting for a signature and now we are looking at draft plan.
David R: Would like to continue with the explanation of the process to date. We are Grossman dealing with the GRNP and not the former individual parks. Is a new and unique product with a mix of various issues and is an amalgamation of the former Wilderness and Tsitsikamma national parks, Lakes and Forestry areas.. Those parks have already walked a public participation process before this of which there are records. At these meetings the establishment of the GRNP was always mentioned, while the other planning processes were underway. Comments from the Minister and the public that had previously been raised were taken into account in a number of ways in this process and the shortcomings of previous plans were addressed.
Benny Outeniqua Khoi Q: This is a new thing, an amalgamated park. If this is a new park and a new Carncaoss Region Forum plan, has it been put together in such a way that it takes the community and their comments from previous plans into account? Does the plan take note of heritage issues and are SANParks aware of his group. We are the owners of the Outeniqua land, the west Cape and the east Cape. I am the representative of the leader. In putting this all together, have you taken us into account? We are the traditional owners of this land and we have people that live on our heritage land. Sounds like you did not realise who we are. We are a rights group not a political group.
Jill Gordon R: The fact that you are here today and that you are on the PFM means that you are taken account of. But should you wish to add anything that has previously not been said, now is your chance to tell us what you are about and what you want in the plan.
Ray Barrell Q: In the last year the Integrated Coastal Management Act has come into effect with the aim that coastal waters and estuaries be properly managed in an integrated
fashion. There are three big estuaries in this area, what is the status of the T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P estuarine management plans with respect to this overall management plan,
10 Issue raised Response (R) Organisation Questions and Responses by by
Mvusy R: The act gives direction to this matter and reinforces corporate governance. The Songelwa municipality is tasked with this outside of the state protected areas. SANParks has recommended that they be represented on the provincial and local management committees and at a strategic level in order to manage collaboratively.
Richard Batson Q: Question of clarification on budget in presentation and budget in plan
Pat Maqubela R: Gives explanation on costing based on activity based costing.
Richard Batson Q: Method of producing the plan does not meet with the framework on the internet
Mvusy R: Should view the stakeholder participation as having started with the drafting of Songelwa the first Tsitsikamma and Wilderness National Park Plans in 2006, during which vision, objectives were agreed on, and process recognised future GRNP.
Richard Batson Q: The assumption with that is that there was satisfaction with the original plans which is not true. Comments were put forward that were hidden and were not answered. Got a letter from head office that comments were not taken into account. The mission etc, were never workshopped as required by the framework. Public did not have an input into the formulation of mission etc. Feels that comments were ignored and that the public was not properly involved.
Mvusy R: Comments may have appeared hidden to you but there was a process in place. Songelwa We got an approval from the minister which noted that certain issues needed to be reviewed, which was agreed to be part of this process. Since 2005, the GRI planning processes have included workshopping the mission and vision of the GRNP with the various stakeholders.
Richard Batson Q: Not happy, not one was workshopped, there is a difference between a meeting and a workshop.
Jill Gordon R: Big public meetings were held in 2006 and these discussed the various issues that needed to be pulled in. Meetings were recorded and held along the coast. His comments are included in the issues and comments trail from previous meetings.
Richard Batson Q: An example is the process description in the Preamble to this draft Management Plan, which says that various meetings have taken place – this is untrue.
David R: Apologies, I was pre-empting this meeting and wrote that into the draft in the Grossman knowledge that the meetings would take place.
Denton Meyer Forestry Indaba Q: Unclear – the 16 villages that are still going to be taken over by the new Park. How are people going to be handled, is not clear to them and they are the people that live in the forestry areas. How will they be affected
11 Issue raised Response (R) Organisation Questions and Responses by by
Mvusy R: All the affected parties have been consulted by DWAF exec and SANParks Songelwa about the residual housing issue – dealt with solely by DWAF, and SANParks just facilitates that programme. Should have had a report back from their reps who sit in that programme.
Q: They have a history there and graves that they need to be able to access.
Mvusy R: Guidelines been developed for accessing graves by SANParks Songelwa
Ben Oelf Grond Els Q: Land claims and Khoi background – refers to a document and the fact that Kraaibos areas established in 1912. Land claim in Kraaibos was agreed to that they would sit around a table to discuss the area. At the moment he lives in Vaalie where they have a claim. Hurts them terribly that their children always hear that they have and are being chased off their land. No opportunities for them on their own land and they have to go to Joburg. Now again people are being chased off their land due to the park. The minister is on the way and he will talk to them and he needs to show how people are hungry and don’t have work and are still being chased away. He agrees with Richard that workshops were not held to discuss matters with people. The youth are respected in the country but lower people are not listened to and we need to do something good. He wants SANParks to come and visit and ask about how things are going and discuss options and solutions.
R: Thanks for the comments which have been noted. We trust that SANParks will visit the area and that the right departments will also pay the issue attention.
Quaanitah Q: would like to point out that each park has a different context that needs to Simons be taken into account. Land reform is a big issue in this area and the act is now under review. Thank you for inviting us and the issues that come out are critically important. We can all read the same acts and understand them differently, when we see the development programmes that you have, because captured under certain headings but needs to be interpreted by interested and affected parties and unpacked by them. Is there not money available due to international status of the park? Expanding human capital is vital and that is what she wants to hear and also want to know that they are going to access funds for this. Security of tenure threatened in some instances and overlapping issues need to be taken seriously and sorted out.
Mvusy R: are being addressed in many ways and this a problem across the board. Songelwa Activity based budgeting a step towards doing this. Socioeconomic development programme highlights deliverables on how they are going to facilitate development and SMME opportunities. Make sure tender processes in line. Working for Water and EPWP also part of this. An officer has been appointed to drive this programme. SANParks also has to adhere to land reform programme and will be followed properly. Have to abide by the law and cannot deal with these issues on its own.
Ray Barrell Q: Interested in terms of management in looking at structures. This park is going to be one of the most difficult to run efficiently because of its peculiar and conflicting features and interest groups. Different local and district municipalities, heritage organisations, people who have been flooded, land claims, etc. Apart from this the forum should meet regularly to make things easier – in the plan there should be some structures planned for engaging with these issues so that we do not end up having to deal with a crisis situations.
David R: Constructive engagement of each and every person in finding solutions is critical. T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Grossman Thanks for that suggestion.
12 Issue raised Response (R) Organisation Questions and Responses by by
Lwayipi Sam Q: The land was taken from people and this is a very sensitive issue. We don’t get recognised and it’s my grandfather’s land. Now SANParks must feel the pain of something that was not their fault in the first place, but we are asking to be recognised and it upsets us that decisions are made without us and without taking our opinions into account. We would like SANParks to listen to how we think things can be done. Black people want their land back. We want to use the resources wisely and share them between all of us together for greater good. But there needs to be a proper land reform process in place. Get it right before nationalisation takes place.
David R: SANParks is your friend as you said because it has to be friend of the people Grossman and work to the advantage of all and to people’s benefit. We all need to work together as friends so that we can assist SANParks in getting this right. Everyone should bring their talents to the table and make constructive contributions to the process. There are many problems that need solutions, we can be guided by the laws of the land and then we have to do the necessary work to make things better.
Ray Barrell Q: Date for comment is 14 days from when? Needs to be published in the paper. Public processes and outcomes must be consensual.
Len du Plessis R: It is 14 days from the advertised meeting date.
Dave Jones Q: Question on park forums – he was involved in representing constituencies – establishment of Wilderness Park Forum was mentioned as a legal requirement. He understood that they established a park forum and that a meeting was going to be held. Meeting never took place. Communications possibly halted because of current process but they have been left in the dark about its way forward.
Mvusy R: Correct, as part of reviewing the GRNP we looked at the previous park forums Songelwa which were not always inclusive and need to be. The stakeholder plan on the table says that we need to establish a GRNP Forum, taking into account who needs to be involved, and as well as this a strategic forum is needed. We recognise the importance of different stakeholders and forums and realise it is critical, especially in the context of the GRNP.
Ben Oelf Q: People are hungry, what must we do? We want to make sure our voice is heard.
Mvusy R: We need to find solutions between us. Songelwa
Lwayipi Sam Q: Will there be minutes of the meeting?
David R: A record of these discussions will be sent to everyone. Grossman
13 Issue raised Response (R) Organisation Questions and Responses by by
Dave Jones Q: It is a big park and we would like to know what everyone else at other forums thinks.
David R: All the minutes will be included. The issues and response report from all Grossman meetings will be sent to everyone that attended the meeting. Please send corrections if anything is not correctly recorded.
PUBLIC MEETING FOR WILDERNESS AREA - TOUWSRANTEN 17th MAY 2010
Issue raised Organisation Response by Questions and Responses by
Terry Cockroft Wilderness Q: When were the stakeholder meetings one and two held? Lakes Water Forum
Len du Plessis R: The stakeholder participation report needs to be submitted with the management plan. Refer to 4.4 of the contents of this report – it indicates that the two workshops were held in 2006 as part of the GRI planning process and there are minutes of these workshops as well as an issues and responses report. These were held in the Protea Hotel in Wilderness and at Portland Manner.
Richard Batson Park Forum Exec Q: At this afternoon’s meeting it was agreed that the stakeholder meetings one and Committee two were not held?
Len du Plessis R: That is not correct, the meetings were held as indicated.
Richard Batson Q: OK, the meeting were held but they were not workshops that debated a vision and they were not workshops aiming to achieve consensus.
SANParks R: Yes they were stakeholder workshops and minutes of the meetings are available to indicate this.
Nick Sweet Sedgefield Q: Has stakeholder meeting two taken place? ratepayers
Len du Plessis R: Yes, as above
John Mc Gregor Sedgefield Q: If it was workshopped, can we have the minutes? Flood Action Committee
Len du Plessis R: Yes, they will be emailed to you together with the record of tonight’s meeting.
Alex Walters Montage Village Q: What value will these comments have and how will they affect the final Sedgefield document?
Len du Plessis R: The stakeholder report has to be part of the management plan that is submitted Phillipa Holden to the minister for approval. Issues and responses are included with the plan. Further to this, each comment will be looked at and where possible addressed in the plan. SANParks will indicate how all these issues have been addressed in the
plan, or not as the case may be, depending on the comment. T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
Louise Hart SR & VA Q: What is the date for submission of comments?
Pat Maqubela R: This will be dealt with in closing and way forward
14 Issue raised Organisation Response by Questions and Responses by
Louise Hart Q: The problem is that the plan talks about the Disaster Management Act but there is not really anything set out in the plan that deals with what must be done. There is a section about fire but nothing about how to manage the flooding. It is her constitutional right not to be flooded. She has been dealing with these issues for the last 10 years with Eden Municipality and Kynsna Municipality but coordination seems to be lacking and therefore it is a disaster, SANParks does not seem to be a part of these forums and meetings.
Len du Plessis R: Refers to the relevant Programme in the Draft Management Plan and explains how they work. There is a statement of intent to do exactly what she is asking for. It is in the disaster management programme, the plan needs to be built up. Sedgefield will be consulted as per the plan.
Richard Batson Q: We are talking about the security of the people in the surrounding towns so wording of the policy statement of the disaster management programme needs to be corrected to reflect the needs to people living there, not just visiting and working in the park.
Mvusy Q: She refers to the actions part of the table and indicates that we will be engaging Songelwa with all the relevant agencies and we need to be able to respond properly.
Terry Cockroft Q: Why were venues for these meeting not in places where flood damage has taken place? Why was nothing organised for Sedgefield or Plettenberg Bay area?
Mvusy R: Management units of the National Park are categorised into three areas. Songelwa An area is identified as being central and that is going to accommodate all the communities living in the area, and that is where the meeting is to take place.
John Mc Gregor Q: There is no disaster prevention programme and in the last 10 years there have been 2 major floods.
R: There is a statement of Intent in the Management Plan as mentioned earlier.
Richard Batson Q: No communications back from SANParks on the flood issue – why?You are being held responsible for any future damage. Various municipal managers have written you a letter asking that the mouth be kept open so that peope are not flooded out – these have been disregarded and not responded to.
Jill Gordon R: She was personally out there and has been involved in dealing with this issue. The councillor would tell you this if she was here today. Doris Brown has been engaged with on this issue. We need to voice our concerns truthfully. We might not have responded in the way that was expected but we need to acknowledge that SANParks has been involved in the matter.
15 Issue raised Organisation Response by Questions and Responses by
Tom Fowls Sedgefield Q: We would like to inform the panel that since the last flood we have a paper trail Flood Action of all the correspondence going to SANParks and all the various other department. Committee No one has come back from SANParks with a response, it is true. In this time they we have dealt with Knysna Municipality and the Eden Disaster Management Committee and we have put together an early warning system - people from SANParks have been invited to attend and be a part of this. SANParks came once and not again which is great pity and in two years we have not moved along the path together. Has been extremely difficult and there has been no meaningful interaction with.
Jill Gordon R: Several meetings have been held with the flood committee, and there have been meetings with the flood action committee and ratepayers and with the mayor of Knysna, etc etc and there are records of all the meetings.
Q: Ok, you were at those meetings but we have not got together with all the right people – SANParks Sedgefield residents.
Russel Smart R: We need to comment on the management plan and if we could channel your thought s into what could go into the management plan that would be very useful.
Richard Batson Q: Hydrological survey, p87 of the plan – says formulate a TOR and then it indicates that the TOR have already been done. Jill promised that these TOR would be done together with interested parties and local technical experts.
Len du Plessis R: It is an indicator for monitoring – the TOR are still be drafted and the indicator in the table is ‘TOR drafted’ – explains table again.
Richard Batson Q: Thanks, what are our chances of getting any money?
Mvusy R: It is a concern and the issue has been raised with the minister and we hoped that we were going to get it from the disaster management fund. Before that happened there was another disaster and the money went to another issue. We are highlighting this issue as a priority and we are continuously lobbying the municipalities for this money.
Richard Batson Q: We can help to formulate the TOR and we already have a model that can be used. Would like to work with SANParks to tweak the model
Ian Russel R: We have been working on it too. There are three separate components including one for catchment management, then hydrological modelling of the estuary that incorporates sediment movement, lastly we need to understand marine processes and how these affect the estuary. Need to tie these three separate models up into one. We are moving along the road to working out what is needed in order to model the system effectively and we welcome your inputs on TOR and would be happy to discuss them and would welcome that stakeholders are involved.
Richard Batson Q: We want to redo the analysis and see what the effect might be. The effect of sediment movement is that the mouth becomes bigger. We can estimate without having the money about which way things might move. Can we help to raise the money?
Mvusy R: Ian and the hydrological group will be able to discuss this whole issue with you, Songimvelo the model and fundraising.
Terry Cockroft Q: Appendix G – statement is made that certain actions will be taken if there is a forecast of more than 100mm and 200 mm of rain. Where do these warnings G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P come from?
16 Issue raised Organisation Response by Questions and Responses by
Ian Russel R: If a rise in water is measured - 50mm rain leads to 20mm rise in water level. Trying to be pre-emptive. Use what info we have on rainfall and respond and try to make smarter decisions earlier. Different ways of improving the way the park can make better decisions earlier. If it rains 500mm in one day we are all going to go under, e.g. in 1996 – not much that can be done in the event of extreme rainfall.
Alex Walters Q: P24 of the Appendix G refers to premature breaching of the estuaries – question is around how it is written – how can we be sure of what action will be taken. If this is the action that needs to be taken it is too late already. In December we had 500mm in two days and the volume of water that came down in the two days, which is much more than the estuary can ever hold. What happens if that rain falls and the estuary is closed? No time to open the mouth and there is no comfort that flooding will be prevented. If it rains it is going to be too late. Are the personnel mandated to proceed – is the process smooth enough? No clear statement about preventing flooding in SANParks documents.
Ian Russel R: Corrections to the text will be made.
John Archer Sedgefield Q: Why do we have to wait for the rain to fall before taking action. During the last Flood Action flood the estuary was already quite full. Why wait for the disaster to happen before Committee doing something about it? Just open the mouth – don’t say there is nothing that can be done. Do it long before the problem starts.
Ian Russel R: In the past when it was approaching 2 metres with heavy rains it was breached prematurely on decision by the park manager. Swartvlei system – N2 and railway acts like a big dam. When it rained in the past Swartvlei filled up slowly and there was a 24h delay period which gave enough response time to breach. Now when big rains fall then we are overwhelmed once that water breaks. Worried that hydrological characteristics of the estuary have changed and the hydrological model needs to take this into account. Should the response time be modified and there are a host of things that can be done. Unusual events tend to be more unmanageable.
Louise Hart Q: What measures have you got in place tonight should the heavens open?
Jill Gordon R: There is a bulldozer there and action can be taken immediately.
Alex Walters Q: The 2m level came from reports in 1979 and 1983 which states that there are 1600 residents in Sedgefield. There were 1900 in 2000 and now there are 600 – 700 people alone that are affected by the flooding. Outdated data is being relied on and the situation has changed.
Ian Russel R: As below (answer ro Messrs Walters and Sweet)
Nick Sweet Q: What systems are in place for monitoring runoff?
17 Issue raised Organisation Response by Questions and Responses by
Ian Russel R: Together with other organisations we need to work on this. We have a real time link to catchment based monitoring rainfall stations and we get the information 10 minutes later. This is one of the steps that has been initiated but we still have a way to go to developing a proper monitoring system. We are working together with the Meteorological Society, the relevant Dept and there is ongoing monitoring.
Terry Cockroft Q: We have done a lot of hydrological modelling of the catchment and have established that the maximum that can come down is 2500cumecs. Agreed that the bridge and the road are a disaster and have made the problem worse. Reports are all out of date. Why are they not updated – hydrological and biological?
Ian Russel R: Scientific Services have produced state of knowledge reports summarising historical reports and are updated twice a year with the most recent scientific and grey literature and research and these are available on the internet.
Louise Hart Q: We would like a follow up meeting in Sedgefield to discuss these issues around the table together.
Ian Russel R:Yes, agreed.
John Archer Q: We have a common goal despite having two sides. Rather than adversarial let’s talk around the same table in a friendly fashion.
Mvusy R: Yes, please Songimvelo
KYNSNA FOCUS GROUP MEETING – SANParks REGIONAL OFFICE KNYSNA, 18th MAY 2010
Issue raised by Organisation Response by Questions and Responses
Debbie Stanley ECO ED I: What is the difference between this meeting and the one this evening?
Len du Plessis R: This is a focus group meeting. This evening is a public meeting, the Agendas are the same.
Adam De Vos SANParks Q: There has been five years of planning but we are still not sure of where communities in the forestry villages stand. There were talks that the people need to move out of where they are living and the elderly people especially are anxious about this. We need to be sure of what is going on as we hear nothing from SANParks and DWAF about this issue.
Mvusy R: We have communicated with the forest village people as SANParks. This issue Songelwa came before you were transferred from DWAF to SANParks. Discussions were facilitated and SANParks wants to make sure this promise is fulfilled. DWAF is meant to be securing land from the municipality but it seems DWAF is not being successful and land has not been secured. I promise that we will continue to ask them to come to you and update you on what progress has been made. It is a concern to us too – it has implications for everyone including us with respect to housing and people going on pension with the potential result of a lack of housing for staff. It is evident that there are funding problems on the DWAF side.
Jeneil Arendse Harkerville - Q: Lots has been said about the planning process of SANParks, but how do Member PFM the smaller communities get involved in the planning of SANParks and in the development opportunities. There is no development in sight for the community G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P and for the youth. Other places have things on the go but not in Harkerville.
18 Issue raised by Organisation Response by Questions and Responses
Mvusy R: Agreed, there are lots of talks about planning but we can only act once this Songelwa is finalised. Smaller communities need to be involved and this is a valid issue. We have people who are responsible for socio-economic development and we are trying to make it a point that projects across the GRI are implemented and have benefits for people. Refers to relevant section of the management plan. Proper procedures also need to be followed so that is transparent and equitable. Need suitable procedures for small businesses too and this is now going to be implemented. The youth are involved in educational programmes and this is over and above the business programmes. Have to also take into account the scale of the problem and the size of the communities. We can only do a certain amount but there are other players that need to get involved too. Also business has to be in line with conservation objectives.
Noel Melville HOJ Rastafari Q: We have been part of the PFM since 2001 but we don’t know where it stands now. Was a platform to talk about the Rooiwortel and now the demand is huge but the plant is scarce. The problem is how much for own use and how much for sale. Amounts have not been determined and people have continued to use it. Now people are being caught and being fined. People have to keep using it. Need feedback from the plant project. Want to move forwards not backwards. No invitations to Diepwalle – want to grow in our own area. We know lots about places where it grows that even the scientists don’t know about but want to do it properly. How about accessing resources on private land. Need to talk about this issue.
Mvusy R: The future of the PFM – the concern has been that when planning started there Songelwa were different groups with different focus issues. We are trying to work out what Elzette Bester the best way forward is – the law indicates that one big forum must be formed but we are not sure this is the best due to there being so many different people with different interests – better to have different focus groups looking at different issues. Area forums must look at specific issues so will be sorted out and the right system will be put in place now that we have the support for it. The people are going to be determining the role of the park forums. With respect to the Rooiwortel – going to leave this to my staff to deal with the issue – I understand that the stalling of the project is the fault of the municipality who have not got the land for us. Have started at Diepwalle nursery and seeds are growing nicely. The idea of going there is fine and a trip can be organised. The challenge is the time until when the plants will be big enough for harvesting. There is going to be a gap. We are engaged with healers in the area and SANParks will share their harvesting M&E with landowners in order to facilitate its use on private land.
Pat Maqubela Q: Please talk about the planning process.
19 Issue raised by Organisation Response by Questions and Responses
Mvusy R: Since 2005 we have been going through a series of planning processes but Songelwa are now ready for implementation. We understand that people are frustrated Len du Plessis and that its been ongoing for a long time with promises of implementation, but we really are ready to start with this. Plan will be signed off by the minister then the plan kicks in and the timeframe indicated is something by which we can be held responsible. The targets are realistic and we have to deliver on them. All stakeholders will be able to refer to this one common document
Pat Maqubela Q: Please elaborate on the estuary management planning processes which were embarked upon by the C.A.P.E. Estuaries Programme a few years ago?
Andre Riley R: A few years ago the C.A.P.E. Estuaries Programme appointed a consultant, CES, to compile a Estuary Management Plan for the Knysna estuary. At the time of the proclamation of the GRNP we decided to combine aspects of this draft Estuarine management plan into the GRNP estuarine management programme, and other places of the management plan. The public participation process for this process will from here on be combined with any public participation process relating to the GRNP Management Plan on the whole. This current PPP puts closure to any of the previous meetings held in this regard. Like all programmes, the estuary planning process for management of the estuary is continuing. Wherever possible, we will in future endeavour to align the estuaries programme with the Integrated Coastal Management Act, National Estuarine Protocols.
Debbie Stanley Q: What is the anticipated process for people from the community to put forward their proposed projects and how are we going to get more people involved?
Mvusy R: We have been promised that the executive of SANParks is going to approve Songelwa the process in the next executive meeting and we hope that before the end of the year this will happen and can be implemented. While waiting for the process at national level to happen we developed tools for this so that devolution can happen, we have tools in place for project assessment. Templates are available for project applications as is a process sequence of events to indicate how assessment will happen – and the tool that will be used for making decisions - draft documents are available and can be shared with everyone. Once approved some adjustments might need to be made. Getting people in – suggestions welcome but the main way for promoting that opportunity is through the park forums. A new fresh approach is needed. Need to get ideas from the forums.
Spars Wildeman Diepwalle Tea Q: In the five year planning we need to make sure that there are options for the Garden young people who don’t have any work – there is nothing for them to do.
Mvusy R: Saying this with humbleness – SANParks People & Conservation need to look Songelwa at this – but it is a challenge to deal with communities who are not associated with the park. There are people who stay in the park because their parents work for the organisation. There is only one P&C officer for each unit. We need to strike a balance in what we can do within and without. Conflict of interests if people who are resident get prioritised – already associated with SANParks so we need to be careful of that. Park employees are employed to work with external stakeholders.
Adam de Vos Q: The school children need assistance, we have a library but we don’t have a lot of other stuff such as computers and other resources. Children do not have access to resources in the place that they live and not always possible to get a bus into town to access resources that they need to get their school work done.
Mvusy R: The human capital development programme might be able to cover this. Each T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Songelwa area needs a staff computer - if staff children are going to use it then we need to work out how. We need to look under that programme to deal with it.
20 Issue raised by Organisation Response by Questions and Responses
Ammerentia Diepvalle Forest Q: The area school children go to school with a public bus – leave at 6.30am and October Indaba come home at 5pm – they are small and this is not great. Can Diepwalle small children drive with the SANParks combi? Then they don’t have to go so early and come back so late.
Mvusy R: The purpose of this meeting is to discuss the management plan. These Songelwa questions do not need to be addressed here. But I can say that there is no money to acquire a bus. Management has tried to help staff and this is a benefit for staff only.
KYNSNA PUBLIC MEETING – RIVERSIDE HOTEL KNYSNA 18th MAY 2010
Issue raised by Organisation Response by Questions and Responses
Dave Jones Mountain Club Q: The registration process – registered when the Wilderness draft plan was and sailing formulated, and then when the Garden Route NP was announced the same constituency responded again because of being affected. Is there a conflict in being registered twice? Perhaps other people are not sure of what their status is in this respect. He would have expected to have received direct information about this meeting as a registered person.
Mvusy Songelwa R: No conflict. At the time WNP was in isolation and we are now building up a database for the whole of the GRNP. There are some groups only interested in certain sections, others on strategic issues across the whole. You would be updated on all of these issues. People are welcome at all public meetings.
Sue Swain Plettenberg Q: The perception might be that the IAPs expect personal invitations by email. Bay Community Environment Forum
Len du Plessis R: For the record. There were adverts placed. In the stakeholder registration form there was a place to say if you would attend. 430 email invitations were sent to all people on the database with receipts.
Amanda de Vos Protea Wilds Q: For people that border with the park with private property – 80ha fynbos but Eco-Village with alien vegetation – is there funding available for alien clearing ?
21 Issue raised by Organisation Response by Questions and Responses
Mvusy Songelwa R: In the last three years we have had a chance to reflect on this and we need to Len du Plessis make sure that what we do is in line with what land owners are doing. We only have funds for the park itself. We have mapped the whole park area for the first time. We need to manage at a landscape level. Park needs 44 million and only got 14 million, so can’t help outside the park. We can offer technical advice and would like to promote that when you want to do control we will do the same on our adjacent land at the same time. Will give contact details.
Amanda de Vos Q: Is SANParks able to offer financial assistance for the burning of fynbos on adjacent land ?
Len du Plessis R: We can assist with technical advice on burning for biodiversity, timing and age of veld. Fire Protection Association has been set up and systems are being established for use by landowners, including fire suppression and burning – these costs are subsidised though a joining fee needs to be paid. Sandhoek a management unit within Southern Cape FPA.
Sue Swain Q: Is there any possibility of getting payment for ecosystem services – carbon sequestration – is this not an opportunity for financial fundraising?
Mvusy Songelwa R: We need to explore a variety of ways to source funds and there are various opportunities that we could pursue with some of the other stakeholders. These kinds of ideas are being implemented elsewhere and we need to wake up and catch on to what is being done in other places – need political lobbying at a local and an international level.
Sue Swain Q: Reference is made in the bioregional programme – please elaborate on mechanisms for promoting conservation on private land.
Mvusy Songelwa R: We are overwhelmed with the number of private land owners in the Garden Route. We have to prioritise due to our lack of funding and have had to work out how to strategically engage private land owners. We will be guided by the national policy and look at what we can and can’t do so that we know how to engage with landowners. There is a range of mechanisms within our mandate, guided by policy. At this stage its at a more strategic level eg EIA and land use decisions, but we will be looking at different options as our mandate develops and is clarified. In the next five years we will be taking certain actions. Different parcels have come in from different sources.
Fay Jones Q: Sailing and license fees – everyone expects to pay, that is not a problem, but the original public meetings asked what was fair to pay but since then fees have gone up with no further consultation. No thought seems to have gone into categorising sailing boats. They have offered to help and it seems SANParks needs this help in terms of categorising them all so that fees are fair and dependent on boat size. George Lake YC. The comment is that the decision was made top down without consultation with people who understand the issue and they were told that this has been done for you – not with you.
Andre Riley R: Kynsna has different categories – there is an attempt to align all fees in the GR area. Was a problem with Swartvlei but there will be an outcome shortly. Problem will be taken up with Island Lake / Wilderness. Question registered and we will ask that Wilderness area get back to you.
Amanda de Vos Q: Tourism – has income from an accommodation portal been considered – a commission could then be charged for this service? G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
22 Issue raised by Organisation Response by Questions and Responses
Mvusy Songelwa R: Have taken an approach to complement what already exists. The local tourism authority is already doing something similar and we don’t want to interfere with that and play the same role. We are also just one of the stakeholders. We are not wanting to build more accommodation, just fix up dilapidated structures, not expanding and not wanting to compete. Will be focusing more on adventure activities and using current accommodation.
Dave Jones Q: The Mountain Club has 120 years experience with a long history of service to conservation – offers voluntary assistance of various kinds and this is available to GRNP. Search and rescue, trails work, guidelines, etc. We know the area very well, especially dangerous areas.
Mvusy Songelwa R: Thank you, we are very appreciative of this offer.
Len du Plessis R: One of our actions is a safety and security plan and we want to engage IAPs in this respect to develop protocols. We will make use of your offer.
Andre Riley R: We have been working together and there is a history of this. We have a close relationship and the club have assisted us on rescues in many instances.
Pat Maqubela Q: Please elaborate on the estuary management planning processes which were embarked upon by the C.A.P.E. Estuaries Programme a few years ago, and explain how it fits in with the current process?
Andre Riley R: Approximately two and a half years ago a process was embarked upon to compile an estuarine management plan for the Knysna estuary. This was done as part of the C.A.P.E. Estuaries Programme. During this process one public participation meeting was held by the Consultants, Coastal Environmental Services, and C.A.P.E. Estuaries Programme. With the proclamation of the GRNP, SANParks decided not to have two separate plans for the management of the Knysna Estuary. Aspects of the draft plan produced by the C.A.P.E. Estuaries Programme were incorporated into the GRNP estuarine management programme. The overall management plan for the GRNP and the public participation process will now fall in with that for the whole park. There will be no additional public participation meetings for the original C.A.P.E. Estuaries draft management plan for the Knysna estuary. Over the next five years, where possible, we will strive align our estuaries management with the Estuarine Management Protocols as contained in the Integrated Coastal Management Act.
23 TSISTSIKAMMA FOCUS GROUP MEETING – BOSKOR RECREATION CENTRE 20th MAY 2010
Issue raised Organisation Response by Questions and Responses by
Annelie Wyatt Storms River Q: Please elaborate on the tourism plans you have. Adventures
Mvusy R: The World Bank funds that were received as part of the GRI were used to further Songelwa develop tourism planning. Our strategy is not to develop new products that will compete with neighbouring enterprises. Our tourism framework identifies adventure activities rather than new products. We will look to develop gateways in certain areas. We have advertised the position of business development manager – someone who will drive the development of these plans. A point is made of working with the local tourism authorities and on building local and regional partnerships.
Len du Plessis R: Focus on providing activities in the park rather than more accommodation – there is ample in the area. The plan thus far identifies activity zones – activity products still to be developed.
Ena Brand Natures Valley Q: Might not be a species specific park but there seems to be a research gap. eW Ratepayers have unique afro-montane forest that needs protecting. Association
Wessel R: Not certain what is meant. We manage entire habitats that include those species. Vermeulen We make sure the whole ecosystem is maintained. We do also have a ‘species of special’ concern programme that focuses on particular species that may need individual attention, both in the fynbos and forest components.
Andre Riley R: Research in forest components – Natures Valley community has been very exposed to SANParks work in the area. Spatial extent of the park has now changed and new areas have come in where years and years of research have been undertaken that people are perhaps not aware of.
Annelie Wyatt Q: Archaeological and palaeontological sites – where are these covered?
Elzette Bester R: These fall under the Heritage Management programme and we want to sensitise our own managers as well as the public about these sites of value. There is a database for all cultural heritage sites, more than 200 and each of these are monitored regularly. They have management plans that also indicate their national or international importance. The plans are there to protect them and suggest what action needs to be taken. The sites are both very old and more recent historical sites. We also consider the intangible heritage e.g. stories and legends. Intellectual property rights are also protected.
R: Is there going to be new accommodation in the Tsitsikamma area for the lower market – is the old staff housing going to be developed in this regard ? Are peak season rates over Christmas being offered at reduced prices? Is this meeting minuted and are the minutes available?
Mvusy R: Planning still to be done for the accommodation that might be developed. 40% Songelwa discount if booked now but this would not be offered during peak season, only from 1st May to middle June. Yes, meeting minuted and these will be sent to you.
Daniel Cloete Natures Valley Q: The mileage restrictions seem to inhibit the work that people can do, they are Trust left sitting in the office when they should be out doing their jobs. It is impacting on delivery and fishing monitoring is especially impacted. He feels that the prioritisation has not necessarily been done properly.
Mvusy R: Economic crisis means prioritisation of tasks. Not a simple decision and there are T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Songelwa repercussions. Hopeful that things will improve.
Karel Pieterse fern Q: Is SANParks looking at opening other areas for harvesting of forest ferns?
24 Issue raised Organisation Response by Questions and Responses by
Len du Plessis R: We have considered looking at other areas and products. Extractive use programme and zoning programme deal with this issue. Special management classes have been determined, including fern harvesting areas where there would not be any conflict of interest. Sustainable harvesting systems still need to be developed and then these opportunities need to be put out on tender. We are almost at stage three where we can put them out on tender. These areas have been identified throughout the GRNP and we need to facilitate an open and transparent access process and system.
Wessel R: Don’t want to overutilise the resource and it entails a lot of work to understand Vermeulen what can be sustainably harvested so therefore we have come up with interim harvesting guidelines, which we will then adapt and refine over time, with data collection by partners who are involved with the harvesting.
Annelie Wyatt Q: Are SANParks planning a backpackers at any time?
Mvusy A; We are still going to look at the details of possible tourism development and Songelwa different initiatives that need to be explored for growing revenue. Nothing at this time that we can say is going happen, it needs to be worked out.
Daniel Cloete Q: Any plans for Natures Valley campsite?
Mvusy R: This is an unprofitable camp that is seasonally busy and we are considering how to Songelwa make it a cost effective camp.
TSITSIKAMMA PUBLIC MEETING - BOSKOR RECREATION CENTRE 20th May 2010
Issue raised Organisation Response by Questions and Responses by
Mary- Ann Q: Where was the call for stakeholders advertised for this meeting? A lot of people Mngomezulu are unemployed and can’t afford to buy newspapers and there must be another way to advertise to the small settlements – including personal notification and information directly to the communities. People don’t understand the impact it can and will have on them as a community so how does the plan then reflect their needs? Speaking directly to the community has value for everyone.
Len du Plessis R: The Koega Express, Knysna Herald, George Herald, The Edge, The Burger, as well as 21 placards in public places such as libraries together with a hard copy of the plan, as well as that the the whole database of stakeholders was emailed a notification.
25 Issue raised Organisation Response by Questions and Responses by
Mvusy R: We said we could consider it, but the act dictates the process we have to follow. Songelwa It is unrealistic to think that we can have community meetings where we present the plan to each and every smaller community. Would also be patronising for us to think that people do not understand what the park is and what the implications are for them. We had a busload of people here previously and we discussed a number of issues with them at that time. When we were going to proclaim the park we went around giving information to people throughout the Garden Route and whilst this was not called for in terms of the legislation we did it in order to let people know about the park that was coming. This is not the only meeting that we have had. For each area there has been two meetings and the municipal meetings are still to come. We know that people also have representatives at some of these meetings. We have to engage the people at a strategic level for this process and then at another level in order to hear the unheard voices. SANParks is using NEMPA as the act that guides it in this respect. The park management plan does not talk in detail about operational issues, it talks about strategic issues so we need the right forum to discuss the right issues.
Mary- Ann Q: Clarification – out of the total budget there is only R36,000 available for the socio- Mngomezulu economic programme, is that right? We cant exclude people from conservation, then it becomes preservation. This is what we see here. We don’t see a benefit for people and therefore there is not support for conservation. This is a parastatal and therefore should be developing the people. This is a forest area and the local people must benefit.
Mvusy R: We have to contribute to community development, that is part of our mandate. Songelwa We have to account across the board from employees to SMMEs to public works programmes. 75% of the operations are BEE credited. Statistics on jobs can be provided too. We are not responsible for the design of public works programmes, we are implementing agents and that is what we are responsible for. Need to address issues at the right platform. We are here to highlight the things that we are going to do in the next five years in order to align with government policy in various respects.
Len du Plessis R: This is an activity based budget. This programme has three strategic objectives. The costs indicated show the costs to SANParks, not what will flow out of them.
JR Joseph Tskitsikamma Q: Can we get this document in electronic form? I want to comment on the slide that Village Trust you showed on the park that you want to be and the one that you don’t want to be. The minister should have realised that this is not the right time to declare the national park. There is much to be done to get a national park going. Has the park already been proclaimed ? How do you find synergy between the different acts and NEMPA, specifically BEE. There seems to be conflict between them.
Len du Plessis R: The plan is available on the internet. The table was a comparison – we were saying that the GRNP is a unique model, not the same as many of the other parks as it has a unique number of characteristics. We were not saying that one is the park we want to be and the other is the park we don’t want to be. The planning for this park started 75 years ago which has finally been realised and these are the final closing stages of that. The park was proclaimed on the 6th March 2009. The management plan lists the various acts that have an implication for this park and its management. We have to account to Parliament on all of it but with NEMPA as the over arching act. The constitution allows for cooperative governance and at municipality level the conservation priorities have to be reflected in the IDPs.
Robert Branch Restaurant Q: You mentioned engaging with the IDP – you have a duty to step forward and do T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P something about the river pollution and this is one way of showing people that you are utilising your resources and your position to protect biodiversity and the people. What process do you play with feeding back into the IDP?
26 Issue raised Organisation Response by Questions and Responses by
Len du Plessis R: This is strategic management plan with strategic objectives. We also have to stick to our mandate but then play a role as an IAP where something that happens outside of a park might affect biodiversity within a park and its there that we can play a role. We are actively engaging with all the municipalities with respect to mainstreaming biodiversity concerns into the IDPs. We can only ensure that the municipalities reflect biodiversity issues in the IDPs and then assist technically with that planning. We are not a watch dog body. We can interact on issues related to environmental compliance but we don’t police it.
Cornelius Haupt neighbour Q: As a local community member I want to acknowledge the tight rope that SANParks is walking and park management has impressed me immensely People that live on my farm see the benefits and we would all like to thank you for the work that you are doing.
Andre Steenbok Q: How are the different communities in the MTO forestry villages going to be affected? Concern that even if it is just land that is being transferred, what about the jobs associated with that land ?
Mvusy R: Official residences of MTO are being asked about and we do not have official Songelwa bearing or information on this. MTO managed land with people that we are receiving is on the western side in the western Cape. The forestry villages in the west are being transferred to us. SANParks has official residences for staff and policies for those areas as well as for people that come over, the same policies apply. If staff are going to be transferred there are negotiation processes and agreements that are needed. In this area it is only land that is going to be transferred. MTO villages here will be kept by MTO to maintain forestry areas.
Sam van der Agriculturel Q: Cooperation with municipalities is difficult for local residents and there is a need Merwe for more grazing land – as a major land owner MTO and SANParks are being looked at as the rest of the land is so limited and it is difficult to find land at the right scale. Should the Department of Land affairs approach you, would you be happy to negotiate on this issue ?
Mvusy R: Anything that has to do with land transfer is managed by the Department of Land Songelwa Affairs and it is not a SANParks mandate, we cannot do that. Land reform processes Len du Plessis follow a clear procedure and the rights of people including to grazing are part of that. The proposed zonation plans do not accommodate grazing as a land use. Some land is returning to conservation status. Land transactions happen at a national level and they cannot be negotiated at this level – they are Cabinet decisions.
27 Issue raised Organisation Response by Questions and Responses by
B Geisman Tsitsikamma Q: Two weeks ago there was a meeting where the deputy minister was supposed Anglers Forum to come and talk about marine harvesting issues but there was a no-show. Many people that rely on fishing to eat to live but the seas are closed to us and there are big fines if we do fish. The seas are only open in rich white places. We can’t fish but they can because they live on the edge of the sea and it’s theirs. There are also big trawlers that take all the fish out of this water and we are not allowed. Our people are suffering. People in Plett are catching tons of fish. It also seems that SANParks monitor in an unfair way and are selective in their law enforcement. Akkerlaan was built in the 30s and we are wanting to live in those houses again, get our houses back. Another issue, the widow of a man that moved to live closer to the work and lived in that house for 20 years, got one months notice to vacate the house, this is unacceptable.
Mvusy R: Fishing – together with the angling forum we were part of the task team as Songelwa SANParks to discuss opening the fishing area. The minister went through the consultation process and your representative was invited to the Cape. A decision was made and we have to implement it, we cannot change it. On the housing issue – when people are transferred to SANParks their package is negotiated – they can stay inside the park in staff housing or they can get a housing allowance. The negotiations included an explanation of the housing policy and that was accepted at that time. Policy is set by SANParks Head Office
Mary- Ann Q: The law also says that you cannot throw people out after a number of years if they Mngomezulu do not have another house to go to.
ATTENDANCE REGISTER
NAME: SURNAME: DEPARTMENT: POSITION: ADDRESS: CONTACT NUMBER:
Quaanitah Simons Park Forum Deputy Chair 27 Pluimbos street, 0762048352 Kleinkrans [email protected]
Richard Batson Park Forum Executive 68 CharlesSt., Sedgefield 0836594875 Commitee [email protected] 044 3432426, 0866193433
JJ Meyer Forest Indaba Representative Inderuigtvleiprim.wcape. 0732514047 school.za
V.S. Meyer Forest Indaba Representative Inderuigtvleiprim.wcape. 0782090412 school.za
Dave Jones Sailing and Mountain Representative PO Box 594, Sedgefield, 0724366078, 044 3431407 Club 6573 [email protected]
Lwayipi Sam Forestry Indaba Representative 18 Longstreet, Karatara, 6580 0762072283
Ben Oelf Grond Els, Kraaibos Chairperson PO Box 5, Karatara, 6580 0835200646
Benny Carnnres K401, Religion Forum Chairperson 12 Rieielane, Pacaltsdorp 9839969417
P Harinic Koi Forum, Outeniqua Chairperson 22 Balis street, Pacaltsdorp 044 – 878 0531
Ray Barreck Wilderness Lakes Member Sedgefield 0734672780
Water Forum T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
Terry Cockroft Wilderness Lakes Exco Member Sedgefield 044 343 2277 Water Forum [email protected]
28 NAME: SURNAME: DEPARTMENT: POSITION: ADDRESS: CONTACT NUMBER:
Harald Escherich Wilderness Forest Member Hoogekraal 0844390196 Estate 044 8501188
Louise Hart Sedgefield Chairperson Sedgefield 0721116119 Ratepayers [email protected] Association 044 343 1384
Tom Fowls SFAC Member Sedgefield 0824664088, [email protected]
Willem Rhode Touwsranten Secretary Bester St. 14, Towsranten, 0781693363 Kontrakteur Hoekwill, 6538 Associates
Benet Mcimbi Towsranten Contractor 55 Mountain View street, 0848965849 Contractor Touwsranten Assocaition
Sidwell Vis Community Member T96 0788334237
Vukile Basi Franusco Community Member Pastorie, PO Box 54 0765933400
Felicia October Diepwalle Tea Deputy PO Box X08, Diepwalle 0784091263 Garden Secretary
S. Wilderman Diepwalle Tea Deputy PO Box X08, Diepwalle 0836178001 Garden Secretary
A. October Forest Indaba PO Box X08, Diepwalle 0723567100
Debbie Stanley Eco Ed – Owner The Couch #se, Garden of 0786112817 Environmental Eden, Harkerville Education
Noel Maxi Mellville HOJ Rastafarians Chairperson 24 N2 Main street, Knysna 0786112817
George Benga HOJ Community Vice 24 N2 Main street, Knysna Chairperson
Alex Walters Montage Village, Owner 80 Montage village, [email protected] Sedgefield representative Sedgefield
John McGregor Sedgefield Flood Chairperson PO Box 693, Sdgefield [email protected] Action Committee 044 343 1084
Richard Batson Friends of Sedgefield Member PO Box 505, Sedgefield [email protected] 044 343 2426
Joneil Arendse Harkerville Member PFM 25 Harmony Park, Harkerville 0725221130
Dave Jones Mountain Club and PO Box 594, Sedgefield [email protected] Sailing
29 NAME: SURNAME: DEPARTMENT: POSITION: ADDRESS: CONTACT NUMBER:
Fay Jones
Jessica Hayes Pezula Knysna Environmental PO Box 1240, Knysna [email protected] Manager 0839570321 044 384 1195, 044 3841016
Sue Swain Pletternberg Environmental PO Box 1170, Knysna, 6570 0847736084 bay Community Advisor [email protected] Environmental Forum 044 388 4681
Andre Stuurman Forestry Indaba Tsitsikamma 0735851859
Booi Leyong Forestry Indaba Tsitsikamma 0839849948
Percy Cunnigham Private, Thornham Tsitsikamma, Thornham 0734532334 Commuity Community
Mary- Ann Coldstream 0828874818 Mngomezulu [email protected]
Sam Van der Agriculture PO Box 26, Joubertind 042 2731342 Merwe [email protected]
Amanda De Vos Protea Wilds. Eco Owner/ PO Box 1386, K nysna 0824936811, 044 532 7665 Village, Heideplaas Manager [email protected]
Carlo Peterse Forest Ferns Manager PO Box 15, Stormsriver 0828718923 [email protected]
A. Wyatt Stormsrive MD PO Box 116, Stormsriver 042 2811836 Adventures 042 2811666
R. Sikiwe Stormsriver Advert A.D. PO Box 116, Stormriver 042 2811b 836, 042 2811 666
Gloria Mandzebe Storms River ilitha Principal PO Box 153, Stormsriver 0783547585 Creche
Cindy Lee Cloete Natures Valley Trust EC Officer 338 Caroon drive. Natures 0714966900 Valley [email protected] 044 531 6820, 044 531 6820
Daniel Cloete Natures Valley Trust Programme 338 Caroon drive, Natures 0833565563 Director Vallley
Ina Brand Natures Valley Committee PO Box 222, The Crags 044 531 6699 Ratepayers Member Assocation
Irene Barnado Covie CPA PO Box 283, Crags, 6602 044 531 6600
R Branch Restuarant G.M> 22 Formosa street, [email protected] 0711404895
S. September Bloukrans Bungy Operator 25 Boskor houses 0789576672
JR Joseph Tsitsikamma Forest Manager 12 Sanddrift 042 2811450 Village Trust [email protected]
MF Marnewecke Blackwater Tubing Managing Storms River [email protected] Member
P Van Forest Hall Manager Forest Hall [email protected] Rensburg G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Karly Behuising Box 96, Storm River 0737832291 Gysman
Cornelius Haupt Farm 256, Knysna 0711129011
30 ANNEXURE 2
ISSUES AND RESPONSE TO SUBMISSION BY R. BATSON
The response by R. Batson is a 29 page long series catchment and system itself, but there is no indication of statements, with essentially four major themes a) that the system has in the immediate past functioned as Legislation applicable to park management, b) the a permanently open estuary. competency of SANParks, c) the natural estuarine mouth state d) attributes of permanently and temporarily open Batson makes the statement: estuaries. No questions are posed. Nevertheless, it is Swartvlei Estuary is suffering from: over-harvesting of believed that several of the statements that are made sand prawns … (pp2). by Batson can be challenged. However, it is not the intention here to provide a detailed comment on every SANParks reply - Batson does not state what information comment and statement made by Batson, but to rather he has used to draw this type of conclusion which is just comment on a few issues which characterise the written as if it is fact. Data from surveys of sand prawn document content (Legislative issues are not discussed Callianassa kraussii in Swartvlei estuary actually show as these should be referred to SANParks legal the opposite to be true, with prawn densities being department for comment): similar in areas where there is regular collection and isolated areas where collecting is unlikely. Several statements are made about the past and current status of Swartvlei Estuary which are written Batson makes the statement (pp3) - as if they are fact, and yet no information/reference is “There appears to be nobody in SANParks with the provided to support these claims, and current published necessary geomorphological, hydrological and ecological understanding of estuarine functioning and survey knowledge to manage ecosystems” results indicate the opposite to be true. As examples: SANParks reply –. The research and planning sections Batson makes the statement: of SANParks conservation services are tasked to provide Swartvlei Estuary is suffering from: degradation of its advice on ecosystem management within national natural habitat ever since the railway bridge was built parks. By rough calculation, amongst the scientists across the estuary, splitting it into two parts, greatly and management personnel in this section there are reducing the natural exchange of fresh water and tidal 19 who’s highest qualification is a PhD, 3 with a BVSc, water between the estuary and Swartvlei Lake and and 10 with an MSc. There is even a smattering of cum changing the estuary from a permanently open estuary laude’s. Moreover, this does not even begin to discuss (POE) to a temporary open/closed estuary (TOCE) the qualifications and experience of park management (pp2). personnel who “manage ecosystems”. It is amazing that Batson has the insight into the abilities of this entire SANParks reply - There is no sound basis for making group of people to decree that all are incompetent at this type of claim. All available records and information environmental management. Furthermore, included indicate Swartvlei is naturally a temporary open/ in this lot there are persons with experience in closed estuarine lake system. The length of time that geomorphology and who have published on hydrology. the estuary is, on average, open each year is though However SANParks personnel, unlike most engineers, to have reduced due to anthropogenic changes to the do not masquerade as being experts in these fields,
31 but instead if we require expert geomorphological or the folly of releasing preliminary data from an incomplete hydrological advice we choose to obtaining it from the survey. Program deliverables will be published by the real experts such as Prof. K. Roundtree for riverine program participants upon completion of the program, geomorphology, Prof. D. Hughes for freshwater and hence will in due course be available in the public hydrology, and Mr. P. Huizinga and Ms. L van Niekerk for arena. estuarine hydrology. Batson statement (pp4) - Batson in reference to the document titled Russell “I have personally spoken to researchers from Rhodes IA, Randall RM, Hanekom N, Kraaij T, Gordon J & University who were engaged in a fish count in Swartvlei Grootendorst PM. 2008. Monitoring of environmental Estuary. They expressed a very strong disappointment indicators in Wilderness National Park. SANParks with SANParks’ monitoring of the biodiversity of Swartvlei Internal Report. 31pp, which is cited in the Draft GRNP Estuary.” Management Plan, states (pp4): SANParks reply - This statement was referred to “According to this document SANParks’ present and the researchers from Rhodes University involved in planned monitoring of the biodiversity (i.e. health) of the Swartvlei fish surveys during 2009 and 2010 for Swartvlei Estuary is limited to: verification. They denied the accuracy of this statement in the strongest terms as indicated in the extract from a a) checking the weather at Rondevlei on a daily basis, reply from Dr. O. Weyl (Rhodes Univ.) to Dr. I. Russell b) measuring some of the physical properties of the (SANParks) given below: water in the lower reaches of the Wolwe, Karatara & Hoëkraal Rivers four times per year, “SANParks has been monitoring the Wilderness lakes c) assessing the extent of some submerged aquatic system and the Swartvlei estuary for some time. In 2009 plants once per year and the Department of Ichthyology and Fisheries Science d) measuring some sand profiles in the lower estuary, (DIFS) was invited to participate in these SAN-Parks led generally once per year.” surveys. This resulted in the participation of the DIFS Honours class in your 2009 and 2010 surveys. During SANParks reply - The only conclusion that can be drawn these surveys the students gain valuable experience from this statement is that Batson either (a) did not read in field sampling methods. I led the 2009 DIFS trip and this document, or (b) read the document but did not participated in the 2010 trip with Dr Warren Potts who understand it. Reference is made to pages 8 to 24 of is now the Honours course coordinator. At all field sites this 31 page document where ten monitoring programs a SAN-Parks official, either yourself or Kyle Smith were in the Wilderness Lake Systems, over and above the present. Direct questions by members of the public are four mentioned above, are described and include: handled on an ad hoc basis but were generally referred to the SAN-Parks official on duty. At no stage did I nor 1. Estuary water quality Dr Potts express “a very strong disappointment with 2. Emergent aquatic plants SANParks’ monitoring of the biodiversity of Swartvlei 3. Knysna seahorse populations Estuary.” To the contrary, we are extremely grateful for 4. Waterbird abundance and distribution the opportunities that your monitoring projects provide 5. Occurrence of alien and extralimital biota and appreciate the professional and competent manner 6. Recruitment opportunities for marine biota in which they are coordinated. Neither DIFS nor SAIAB 7. Waterbody aesthetics are involved in non collaborative (with SAN-Parks) 8. Occurrence of physical hazards and obstructions research at the moment so I am not sure to which “fish 9. Sandbar height count” Mr Batson may have been referring.” 10. Estuarine bait organisms Batson statement (pp4) – Batson statement (pp4) - “I shall send copies of both SANParks’ “Monitoring of “I have witnessed staff from SANParks GRNP carrying Environmental Indicators in Wilderness National Park” out fish counts in Swartvlei Estuary. Ian Russell (Aquatic and the Garden Route National Park Wilderness Coastal Ecologist: Scientific Services) undertook to make the Section “State of Knowledge” to the South African results of this fish count and prior fish counts available to National Biodiversity Institute and ask for their opinion stakeholders. This has not been done.” on whether SANParks at the Garden Route National Park can be trusted to monitor and report upon the G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P SANParks reply - The fish surveys mentioned were biodiversity of Swartvlei Estuary at the necessary level.” component of a three year program being undertaken as a collaborative program between SANParks and Rhodes SANParks reply - The fact that supplementary reports University. The survey program is, at the time of writing for the management plan are being submitted to SANBI not yet complete. It is trusted that Batson can understand for ‘evaluation’ is welcomed. We trust that SANBI will
32 be asked to compare these to equivalent documents not a single instance could be located where this direct and programs for other estuarine systems in South claim was made. It remains a mystery where Batson Africa, and particularly the estuary plans and program extracted this phrase for which SANParks is now being documents that Batson’s preferred estuary managers, criticised. SANParks has always been very clear about namely Eden District Municipality, have prepared for the the origins of the 2m amsl breaching policy for Swartvlei. estuaries which they currently manage. We would be For example, four quotations from the management plan happy to recommend the appropriate persons in SANBI are: who might be able to willing to undertake such and assessment for Batson, and trust that the outcome of Management Plan (pp34) It has been recommended such an assessment will be conveyed accurately. that for hydrological, ecological and social reasons Swartvlei Estuary mouth be artificially breached at Batson statement (pp13) in reference to the proposed 2.0 m amsl (CSIR 1978, Howard-Williams & Allanson remodelling of hydraulic processes in the Wilderness 1979, Whitfield et al. 1983). Lakes systems – “Certain members of Scientific Services, based at Appendix F (pp8) It has been recommended that for Rondevlei have no wish to see any new modelling hydrological, ecological and social reasons Swartvlei undertaken, since they realize that the modelling will Estuary mouth be artificially breached at 2.0 m amsl demonstrate conclusively that the management of (CSIR 1978, Howard-Williams & Allanson 1979, Swartvlei estuary under SANParks has led to excessive Whitfield et al. 1983). sedimentation, major degradation of the biodiversity and totally unnecessary flooding in Sedgefield.” Appendix G (pp21) The height at which estuaries are artificially breached are in essence a compromise to SANParks reply - Given that Scientific Services reduce the threat of flooding of residential and other personnel from the Rondevlei Office (i) initially properties that have been developed on the estuarine motivated for the hydrological reassessment of the floodplains, whilst retaining sufficient head of water Wilderness systems, (ii) included it as an objective in on breaching to perpetuate hydrological processes the management plan for Park Manager to investigate influencing the erosion of marine sediments in the funding, and (iii) took the lead in 2009 in drawing up the estuary mouth and maintain patterns and processes terms of reference for assessment of program costs, it dependant on varying estuarine water levels. would have been very informative if Batson had stated, firstly, exactly which persons at the SANParks Rondevlei Appendix G (pp 21) In the case if Swartvlei Estuary office did not want the program to proceed, and it was recommended by Howard-Williams & secondly, exactly what information he used to draw this Allanson (1979) and Whitfield et al. (1983) based on conclusion. Or is this simply yet another unsubstantiated, hydrological modeling undertaken by CSIR (1978) libellous, statement made to try and discredit SANParks and ecological considerations that artificial breaching personnel? should occur at 2.0 m amsl.
Batson states on at least three occasions (pp11 & 12 What also should be added here, and is a fact invariably ) that SANParks erroneously claims that Swartvlei and conveniently overlooked by critics of the 2m breaching height and subsequent sediment scour are breaching rule for Swartvlei is that this approach was based on scientific studies included in the Knysna-Wilderness-Plettenberg Bay Guideplan in 1983 - three years prior to SANParks in In a scan of the Draft Management Plan and appendices assuming management functions of his waterbody.
33 (Dept. Constitutional Development & Planning The DWAF scope of work called for a “Rapid level” 1983) This is a legal and binding document. Other investigation and therefore no field research or complex management recommendations have also been made modeling was included in the terms of reference. The such as those reported in Fijen & Kapp (1995b) where specialist team did however undertake some limited based on a some modelling exercises and various fieldwork and water level modeling. The final report information gathering exercises, including public surveys was completed in November 2009 whereas the Draft of the desirability and feasibility of moving towards a Management Plan was written in September-October more natural (higher) breaching strategy. Fijen & Kapp 2009. The last version of the State of Knowledge report (1995b) state “In order to achieve a balance between was completed in March 2009 – 8 months prior to the maximum water levels and prevention of flooding, it is issuing of the draft Reserve Determination report for proposed that the estuary mouth be opened at water- Swartvlei Estuary. At the time of writing the Swartvlei levels in Swartvlei Lake of not less than 2.0m above Reserve determination has not yet been sighed off by MSL.” Furthermore, it was recommended that “In order the Minister and hence is not yet policy. It is difficult to to not disrupt the tourist industry upon which much of include documentation into the GRNP plan that did not the economy of the region depend, it is recommended yet exist at the time of writing, and SANParks is not in that the estuary mouth is opened during the Christmas the habit of citing draft and incomplete documents. holidays at water levels of 1.8m above MSL” Batson has attempted to calculate the tidal prism for the Batson makes the statement pp (11) Swartvlei system as (2 x 106 m2 x 0.5 m + 8.8 x 106 “SANParks have ignored the set of professional norms m2 x 0.2 m) m3 = 2.76 x 106 m3, to demonstrate that it and values when they claimed that the level at which falls within the range given by Whitfield (1998) for typical they determined that the mouth of the Swartvlei Estuary Permanently Open Estuaries (pp18). should be opened was based upon scientific study knowing that no study covering the relationship between SANParks reply – The accuracy of the data Batson the level at which the mouth is opened and the degree of has used to define spring tidal range in the estuary scouring of the mouth had ever been carried out.” (0.5m) and lake (0.2m) differ significantly from that available in the literature, and the accuracy thereof is SANParks reply – The issues relating to false quotations strongly questioned. The spring tidal range in Swartvlei by Batson about scientific documents is discussed in estuary has been measured by, and is provided in CSIR the comment above. It remains unclear whether or not (1975). The fact that tidal range declines significantly Batson is claiming here that there is no relationship up the estuary is given both graphically in Fig 12 of this between breaching height and degree of sediment scour. document and described in the text. The drop-off in If not and he agrees that there is such a cause and effect the tidal range up the estuary is also described in both then his reasons for the objection remain vague other Whitfield et al. (1983) and Fijen & Kapp (1995a). Fijen & than to be argumentative. If he is claiming that there is Kapp (1995a) estimate tidal range at the estuary mouth unlikely to be such relationships then he is referred to to be 1.0m (based on measurements at Wilderness recent reviews and studies such as Schumann (1993), Estuary). It is stated in both Whitfield et al. (1983) and Hay et al. (2005) and Beck & Basson (2007) where Fijen & Kapp (1995a) that only 0.5 km upstream of these relationships are discussed and modelled. the mouth that the tidal range is reduced by one third or even more during storm river flow conditions. The Batson states (pp14): actual spring tide range measured by CSIR (1975) 1 “Integrated coastal management policies and plans are km up from the mouth of the approx 6 km long estuary being prepared at National, Provincial and Municipal was in the order of 0.5m. At the upper and far broader levels based on information gathered and assessed end of the estuary the tidal range is reduced by 90% by researchers working mainly under contract to the (Whitfield et al. 1983) with and amplitude of about 0.2m Department of Environmental Affairs and the Department (Fijen & Kapp 1995a). CSIR (1975) also describe in of Water Affairs. Much of this research was initiated some detail how the tide surges up the estuary thus and is being used in the determination of the ecological the whole estuary is not rising of falling at the same reserves of our rivers and estuaries. It is notable time and you can actually simultaneously get flow in that none of this research has been considered by two opposite directions. All this serves to demonstrate SANParks, Garden Route National Park, when they that the estimation by Batson that the average tidal prepared the latest issue of the state of knowledge.” variation throughout the estuary of 0.5m is likely a gross overestimation. G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P SANParks reply - The ecological reserve of the rivers flowing into Swartvlei has not been investigated. The An even larger error is that Batson estimates the tidal ecological reserve of Swartvlei estuary was assessed range in Swartvlei Lake to be 0.2m. The actual spring in a program commissioned by the then Department tidal range in Swartvlei Lake is actually an order of of Water Affairs and Forestry, and completed in 2009. magnitude lower at 0.02m (Fijen & Kapp 1995a).
34 Separate modelling exercises by the CSIR (1978) and of the river mouths (Orange, Bloukrans, Lottering, Fijen & Kapp (1995a) have both demonstrated that Elandsbos, Storms, Elands, Groot (Oos), Mzimvubu, the removal of the railway bridge would increase tidal Mvoti, Tugela, Mfolozi, Houtbaai). Prof Bate was queried variations in Swartvlei Lake by only a few millimetres. about this and pointed out that in lake systems the In Swartvlei Lake water level varies by about 0.2 m distance from the mouth to the head is very long and as between spring and neap tide (Whitfield et al. 1983, a result there must be a much larger hydraulic resistance DWAE water level records) which differs substantially to flood and ebb flow than would be the case in shorter from the approx 0.02m (not taking into account the TOCE’s. Lakes systems, embayments and river mouths retention of water in the lake in the move from neap to are gemorphologically and hydrologically very different spring tide), which could potentially be used to determine from conventional estuaries (both POE and TOCE) that tidal prism, which is defined in Wikipedia as “the volume the described relationships between MAR and mouth of water in an estuary or inlet between mean high tide status do not necessarily hold for these systems. The and mean low tide, or the volume of water leaving an insertion of Swartvlei into the table provided by Prof Bate estuary at ebb tide”. is the MAR/mouth status for POE’s and TOCE’s in South Africa both inappropriate and misleading. Batson has obtained a table from Bate (2007) which describes relationships between size, tidal volume and Batson describes a publication by Harrison et al. (2000) MAR, and whether an estuary is typically a Permanently to try and claim that they describe Swartvlei Estuary as a Open System (POE) or a Temporarily Open/Closed permanently open system (pp23). System (TOCE), and chosen to insert Swartvlei system and claiming that the tidal volume for the entire system SANParks reply - Harrison et al. (2000) provide one of is 1.8m in an attempt to try and argue that Swartvlei is several methods of classifying estuaries. It is based on naturally a permanently open system (pp20) the observation that in South African estuaries there is a bi-modal distribution terms of the proportion of that they SANParks reply - Past measurements and modelling, as are open or closed (Perissinotto et al. 2004) with groups discussed in the box above, have demonstrated that the of estuaries that are either open for less than 33% of the tidal range in Swartvlei Lake is in the order of 0.02m with time or more than 66 % of the time. Only very few have the rail bridge in place, and only a few millimetres more if balanced open/closed regimes. Harrison et al. 2000 it were removed. Water level fluctuation in Swartvlei Lake suggested that they based their split based on estuaries over a full tidal cycle is in the order of 0.2m. Batson’s use that are open more than 70% of the time and those that of 1.8m as the tidal amplitude of the Swartvlei System is are open less than 30% of the time. They did not indicate desperately far from reality. how they dealt with the few estuaries that fell between these ranges. They indeed classified Swartvlei correctly Highly questionable data besides, perhaps the question as a Normally Open, Barred, River Dominated system, that Batson really should have been asking is why Prof with SANParks records indicating that between 1968 Bate did not originally include Swartvlei in his table? and 2010 it has been open 55.6% of the time with Fijen Indeed, if a bit more of a critical assessment had been & Kapp (1995b) estimating this under virgin conditions made of the table presented by Prof Bate it could it would have been open at least 65%. Swartvlei falls also have been asked why NONE of South Africa’s within that small group with a balanced open/closed estuarine lake systems were included (Bot/Kleinmond, regime. It is interesting to note, in Harrison et al. (2000)’s Klein, Swartvlei, Wilderness, Nhlabane, St Lucia, Kosi, list of Normally Open, Barred, River Dominated system Mgobezeleni) as well as NONE of the embayments (in which they included Swartvlei) they also include a (Knysna, Richards Bay, Durban, Mhlathuze) or ANY number of other temporarily open systems along the
35 Cape south coast such as the Klein Brak, Groot Brak and Goukamma. “Normally open” should thus not be confused with always meaning permanently open. It is References cited interesting to note how the description of Harrison et al. (2000) of Swartvlei being and estuary that is “Normally BECK, JS & BASSON GR. 2007. Klein River Estuary Open” has under the pen of Batson metamorphosed (South Africa): 2D numerical modeling of estuary into a “barred permanently open estuary” (see 2nd last breaching. Water SA 34(1): 33-38 paragraph pp 24). Accurate citation of literature would CSIR 1975. Hydrographic survey of the Sedgefield have been more useful and informative. lagoon. CSIR Report C/SEA 75/13. Coastal Engineering and Hydraulics Division, National Batson provides a series of quotations from Whitfield Research Institute for Oceanology, Council for & Bate (see pp pp25-29) which describe some of the Scientific and Industrial Research, Stellenbosch. attributes of both permanent and temporarily open CSIR 1978. Hidrouliese studie van die Swartvlei estuaries, with the objective being to “demonstrate some Estuarium. CSIR Report C/SEA 7805/1. Coastal of the ecological advantages of a Permanently Open Engineering and Hydraulics Division, National Estuary (POE) over a Temporary Open/Closed Estuary, Research Institute for Oceanology, Council for in terms of the biodiversity of the two states and some Scientific and Industrial Research, Stellenbosch. of the factors leading to such differences in biodiversity, DEPARTMENT OF CONSTITUTIONAL DEVELOPMENT such as nutrient levels and the velocity of water currents AND PLANNING. 1983 Knysna-Wilderness- set up when an estuary mouth is breached at a high Plettenberg Bay Guideplan.Government Printers, water level.” Pretoria. 99pp. FIJEN APM. & KAPP JF. 1995a Swartvlei Catchment, SANParks reply – Presumably the intention of this Diep, Klein Wolwe, Hoekraal, and Karata Rvers. component of Batson’s document is to convince Water Management Strategy. Volume 2: Water SANParks and others that because POE’s generally Resources. Department of Water Affairs and Forestry, have higher number of species than TOCE’s then Pretoria. 40pp it must be desirable to deliberately try and convert Swartvlei, a natural TOCE, into a POE by radically altering fundamental environmental processes such as the duration of open phases. The physico-chemical changes that would result from repeated breaching of a naturally TOCE, in the vain attempt to try and get it to function as a POE, would heavily impact on natural biota and radically alter normal estuarine functioning. As an example one just needs to look at literature on community structural changes in the naturally TOCE Mdloti Estuary after it was artificially breached 16 times over a 2 year period. It has long been recognised that TOCE’s fluctuate between and ecological state characterised by high diversity but low biomass (open phase) and another which is high biomass but low diversity (closed phase) (Perissinotto et al. 2010). It is the low diversity/competition that allows a few euryhaline species to dominate the ecosystem during the closed phase, thus resulting in optimal biomass conversion of the resources available. TOCE’s thus play a fundamental nursery function for these biota (Perissinotto et al. 2010). To propose to radically alter the fundamental functioning of a natural system in the quest to increase species count demonstrates a poor grasp of basic conservation principles, and management practices as applied by SANParks and other conservation agencies. In protected systems the objective is to maintain natural patterns and G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P processes, not to try and manipulate and alter systems, and create artificial environments because you think it will be impressive if one of the outcomes is a longer species list. That is the function of a zoo, not a national park.
36 ANNEXURE 3
ISSUES AND RESPONSE TO SUBMISSION BY T.N. COCKROFT
Comments & Queries to the GRNP Draft studies undertaken by Dept Water Affairs and published Management Plan in 1993. No comparable follow-up studies have been undertaken since that time, and would necessitate Prepared by T N Cockcroft Pr Eng, BSc Eng (Civil) assessment of landuse changes in the catchments, [email protected] particularly forestry and agriculture, which are the P O Box 753, Sedgefield 6573 biggest uses. One of the objectives of the Freshwater and Estuarine program is to investigate the feasibility of General: remodeling the hydrology of the Swartvlei system. This would incorporate more advanced modeling techniques Most of the Reports referenced in the Man. Plan for the than have been used in past assessments including Swartvlei system are old, (published more than 10, or improved understanding of linkages between freshwater, even 20 years ago) & it seems inevitable that the land estuarine and marine systems, and consideration of use in the catchment areas, for one thing, has changed sedimentary processes, and would be based on more dramatically. For example, the water Abstraction by current bathymetric assessments of the estuary systems Sedgefield from the Karatara River is likely to be much and topography of its immediate surrounds. A product of greater now, than when the investigations leading to such a modeling exercise would be a more up-to-date these reports were done. database on landuse, which could in turn be used to How is this taken into account in the Man. Plan, as I improve understanding of water interception and usage. do not see any mention of updating the key reference Licensing of water usage as required by Dept Water reports, as part of the Man. Plan? Affairs will, when fully implemented, also provide a more accurate assessment of abstraction. These data will be IAN RUSSEL incorporated and used as and when they are available. The plan makes use of the best available information. The early ecological studies undertaken predominantly Whitfield, AK. 2000. Available scientific information on by Rhodes University, CSIR and to a lesser extent individual South African estuarine systems. WRC CapeNature, form the foundation of much of the Report No. 577/3/00 217pp understanding of the lake systems. They are not invalid because they were undertaken 20 plus years ago. 2. Why is there no venue for Public Participation Swartvlei is considered to one of the best researched Meetings in the two largest areas, where there was estuaries in the country (Whitfield 2000) It is, however, significant flood damage to public property in the Nov recognized that there are still several areas where 2007 Floods, namely Sedgefield (Swartvlei Estuary) additional ecological research and monitoring work & Plettenberg Bay (Keurbooms Estuary)? I know the could be undertaken which would provide information Keurbooms estuary is not part of the GRNP, but the area beneficial to the management of the lake systems. surrounding it is. These are addresses as finances and expertise, both internal and external to SANParks, permit. The LEN du Plessis involvement with researchers from Rhodes University . The GRNP is divided into three management sections, continues and is in the processes of being expanded. namely Wilderness; Knysna; and Tsitsikamma. There The information on water usage stems from detailed were three venues chosen for the Public Participation
37 Process. The location of these venues was carefully AM, SS, PIM, GM., ISCU CA, AIP. What do these stand considered in terms of their accessibility (availability of for? public transport) and being central to a specific area. It is the opinion of SANParks that the three chosen venues LEN: This will be corrected were best suited considering the above criteria: - Wilderness Section: - Touwsranten Table of Contents: Numbering system listed is faulty. - Knysna Section: - Premier Hotel. Ashmead - Tsitsikamma Section: - Boskor LEN: This will be corrected
3. The SANParks have a document on their web site Table of Contents: Why no provision in the Table of called “Developing & Implementing Management Plans Contents for the Marine Man. Plan or the Elephant for SA National Parks.” This document specifies that Man. Plan? Both are referred to in the overall Man. Plan. Stakeholder participation is required in Developing the Objectives & Initiatives / Actions of a NP Man. Plan LEN: This will be corrected once these plans are (Stage 1) & there should be a participation in focus approved group meetings to align programmes in support of the objectives (Stage 2) & in writing the Draft Man Plan Overall Man Plan: Is this not supposed to have been based on the information generated in Stage 1 & 2. tabled within a year of the GRNP being Gazetted? i.e. by (Stage 3). The final stage is the Presentation of the Draft 5 Mar 2010, latest? ( See also point 3 above). Man. Plan for Stakeholder input & comments. (Stage 4). Why are Stakeholders only now even being made aware LEN: The National Environmental Protected Areas of the Man. Plan, when the process is already at Stage Act states that a Management Plan for a Protected 4? Area (National Park) should be submitted within one year of the Park being proclaimed or the land being LEN: The process described was indeed followed. The assigned to the Management Authority (SANParks). process started in 2006 with workshops to develop The area proclaimed as the Garden Route National a desired state for the GRNP as well as setting the Park was assigned in March 2010 from the Department hierarchy of objectives. Details of these workshops will of Agriculture Forest and Fisheries to SANParks. The be included in the Stakeholder Participation Report to be Management Plan should thus be submitted within one submitted with the Management Plan to be approved. year from March 2010.
Why is there no Index for the Appendices? The page Part One numbering of these Appendices sections is also faulty. Man. Plan, p 10: The boundaries as shown are not clear. I understood that the whole of the previous LEN: This will be corrected Wilderness NP was now included, but it is not clear that is so. Who will provide the independent assessment of the comments received during & arising from the Public LEN: The map indicated on Page 10 is in accordance Participation Process? to the requirement from the Department of Water and Environmental Affairs. In the Pre-amble it is mentioned LEN: All comments received and related responses that the former Wilderness National Park now form part to those comments will be collated in an Issue and of the Garden Route National Park. Response report. This report will form part of the submission of the plan for approval by the Minister of Man. Plan, p 12: There are several access points in the Department of Water and Environmental Affairs. The & near Sedgefield, which are not shown. Why not? Minister will then assess the comments. Similarly for Knysna. The scale of these plans is too small. Preamble: On page 3, there is reference to “Appointed Consultants”. Who are they, as no other reference is LEN: The access points identified and indicated are made to them in the Man Plan? clearly defined access points (i.e. boom or gate) which are manned (controlled access) or un-manned (open LEN: The consultants appointed through the Garden access). Route Initiative are David Grossman and Associates, G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Phillipa Holden and Rich Davies. Man Plan, p 16: Reference is made to an area of land between Rondevlei & Swartvlei, which was in the Preamble: The Abbreviations & Acronyms list is Wilderness NP but is not clearly shown as in the GRNP not complete. No reference is made to, at least, the Plan ( Fig 1a). Why not? following:
38 JOHAN BAARD: This map shows Location and Extent, extreme rainfall at George, South Africa. South African the scale is too small to show the kind of detail Mr Journal of Science 103: 499-501. Cockcroft wants. The purpose of the map is only to show Location and Extent and does not focus on other Man. Plan, page 34: The recommendations made detail. about the water level (2.0 m MSL) at which the mouth of the Swartvlei estuary should be artificially Man. Plan, p 18: Why is there no reference to Lake breached, was made in a report prepared by CSIR in Pleasant & the area around it, which is administered by 1978, & that Report, & subsequent ones in 1979, did Cape Nature? Reference is made to the Brenton Blue not take into account any sediment transport at all, Butterfly Special Reserve, also administered by Cape in the mathematical modelling that was done. How Nature. can these results be considered realistic?? These recommendations are more than 30 years old & should LEN: The Lake Pleasant and area around it that are have been updated long ago. In addition, this level does being managed by CapeNature forms part of the not tie in with the common practice followed by an earlier Goukamma Reserve that is mentioned on p.18. SANParks Manager in this area & what was agreed with the old Sedgefield Municipality. Man. Plan, page 23 & 24: In this section, no mention is made of Swartvlei, one of the most important estuaries IAN RUSSEL AND JILL GORDON in SA (Was identified as 6th most important in SA, in the The hydrological model used by the CSIR did not GR Environmental Management Framework document). incorporate sediment movement as such models did not exist at that time. Although these studies were LEN: This comment is not clear. On p.23 the vegetation undertaken 30+ years ago they still remain the best of freshwater and estuarine systems is briefly described available information. New modeling techniques do with specific reference to Swartvlei exists that can incorporate sediment movement. Hence one of the park objectives if the Aquatic program is Man. Plan, page 34: Reference is made to the fact that, investigate the possibility of having the hydraulics of the “Severe floods in the Swartvlei system are infrequent.” Wilderness lake systems, including Swartvlei reassessed Please define use of the word “Infrequent “, as there using a more modern modeling technique and revised have been 4 in the last 12 years. input data.
IAN RUSSEL: Severe floods are generally associated A TOR for a Hydrological study on both the Swartvlei with high rainfall events. A high rainfall event such as the and Touw systems is currently out for public comment. 230 mm (as measured in George) which fell in August Current practises are based on an adopted Estuary 1996 resulting in flooding in the region, has a predicted Management Plan which formed part of the 2006 return frequency of 1 in every 1222 years (Mélice & Management Plan Process. The current draft does Reason 2007) which in most peoples language is pretty however contain considerations for an “earlier breeching” infrequent. Based on this assessment the 263mm (as in the event of : measured at Rondevlei) that fell in November 2007 The breaching level for the Swartvlei Estuary remains at which also resulted in severe flooding is likely to have 2.0m amsl, and for the Touw estuary at between 2.1m a comparable return frequency and can probably quite and 2.4m amsl. However, premature breaching of either correctly be considered to be infrequent. estuary can be considered if one of the following three conditions apply: Mélice, J. & Reason, C.J.C. 2007. Return period of
39 1. The estuary water level is at 1.8m amsl or above, and thereafter 50mm or more rain, as measured at a Man. Plan, page 45: Why is no mention made of the recognised meteorological station within the estuary Disaster Management Act, when referring to Fire? catchments, falls within a period of 24 hours or less. Surely fire is a major weakness if the DM is not taken onto account? 2. The estuary water level is at 1.6m amsl or above, and thereafter 100mm or more rain, as measured at a LEN: The National Veld and Forest Fire Act deals with recognised meteorological station within the estuary veld fires as described on p.45 and not the Disaster catchments, falls within a period of 24 hours or less. Management Act. The National Veld and Forest Fire Act makes provision for the establishment of Fire Protection 3. The estuary water level is at 1.4m amsl or above, Associations. Eden District Municipality is a member of and thereafter 150mm or more rain, as measured at a the Southern Cape FPA. recognised meteorological station within the estuary catchments, falls within a period of 24 hours or less. Man. Plan, page 46: I believe DEAT no longer exists? It is called something else. Systems to obtain information on prevailing meteorological conditions as well as early warning LEN: DEAT will be replaced by DWEA (Department of forecasts from Disaster Management are in place to Water and Environmental Affairs). facilitate decision making. Man. Plan, page 48: Again, no mention in either 3.4.6 Man. Plan, page 38: The dates of many of the major or 3.4.7 of meeting the requirements of the Disaster reports relating to Swartvlei are all at least 30 years old Management Act. Why not? & should be updated. SANParks have a Tech Advisory Team based at Rondevlei. Why have they not done this? LEN: The Disaster Management Act (No. 57 of 2002) is This is particularly true about the references to Pollution listed as relevant legislation in 1.4 of the plan that deals aspects. with the legislative and policy frameworks.
IAN RUSSEL: Refer to comment on pp 1 regarding the Man. Plan, page 49 & 50: Reference is made in 3.4.10, age of references. The Scientific Services (Rondevlei) to “Inadequate law enforcement…”. It is understood that, have produced what are termed State of Knowledge in part, this is currently due to inadequate fuel supply reports which reference, and in some cases summarize for the Law Enforcement staff vehicles? Why is this not published scientific information relevant to different specifically mentioned? What is the status of other Law conservation areas, including the estuarine systems Enforcement officials vis-a-vis SANParks? within the Garden Route National Park. These are updated annually, and have been available for some JILL: Due to the current World Wide Economic years on the SANParks webpage. It is not stated Downturn, SANParks National has applied cost effective which ‘references to pollution aspects’ have not been measures across all parks. One of these measures considered so it cannot be commented on whether these include a cap on kilometers driven per vehicle per month. are indeed addressed in the State of Knowledge reports This does not however prevent SANParks to continue or indeed are relevant. to respond to Law Enforcement issues as and when deemed necessary Man. Plan, page 40: The CMA relating to this area is very unlikely to be constituted, even in the next 3 Man. Plan, page 50: If Marine & Coastal Management years. Surely, the GRNP Man Plan should take this into are responsible to regulate fishing in the estuaries, account? why are their Officials never seen here; only SANParks officials? LEN: From discussions with the Department of Water Affairs it is our understanding the Gouritz CMA are JILL Gordon: SANParks has signed a Memorandum currently in the process of being established. of Understanding (MOU) with Marine and Coastal Management and in the spirit of cooperative governance. Part Two: SANParks Official act in their capacity as fishery control Man. Plan, page 44: There are some spelling mistakes officers within the area managed by SANParks in the SWOT Table. G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Part Three: LEN: After consultation with various stakeholders Man. Plan, page 53: The map is not accurate in that it was decided to remove the SWOT table from the the Wolwe/Diep River & the Klein Wolwe River are not Management Plan as circumstances continuously shown. change
40 JOHAN BAARD: This map’s purpose is to show Use Estuary. Surely Swartvlei should be in a separate Zoning Zones. Major roads and rivers are shown for orientation Area? purposes only and many smaller roads and rivers are deliberately excluded not to distract from the purpose JILL: Swartvlei falls within the Wilderness Section of the and readability of the map. As such the rivers are also Garden Route National Park and is classified according not annotated. to a standard SANParks zonation plan, which takes sensitive ecosystems into consideration. Man. Plan, page 59: Mention is made of Maintenance of Infrastructure, but none has been done after the floods Man. Plan, page 83: Under 4.2.3, Aquatic programme, of 2006 & 2007. For example, on the Half-Collared no mention is made in the last section of para 1 of Kingfisher Trail, where the Great Kingfisher Trail Swartvlei at all. Why not? The other major estuaries are branched off, this part has not been repaired after the specifically noted. It is noted in the earlier section of that 2006 flood. The elevated boardwalk along side the Town para. River in Wilderness has not been restored after flood damage, & parts of the Terblanche Trail are no longer DAVID GROSSMAN: Added usable. Similarly, the Bosbok Trail has not been fixed. These are all in the Wilderness Area. Man. Plan, p 86: Why is the Groot River (West) not included in the Table re “Assessing the JILL potential of early warning systems for high level This is untrue. Since the 2006 flood, various sections occurrences….? of all the boardwalks mentioned had been restored and maintained against a maintenance plan. The first IAN RUSSEL part of the Giant Kingfisher Trail will not be re-opened Flooding of the Groot Estuary does not pose as due to severe erosion. The last section of the Giant significant a threat to adjacent residential properties Kingfisher Trail to the Waterfall has been upgraded with as occurs in the Touw and Swartvlei systems. Areas the assistance of the George Municipality (2008), who of Natures Valley that are likely to get inundated had to repair the water supply line to Wilderness and during floods are the carpark, portions of the estuary build a boardwalk 90% of the trail. This section is now front road and the syndicate lawns, which is more an connected with the Half Collard Kingfisher Trail, which inconvenience rather than a threat to property. The Groot has been upgraded with boardwalks & staircases (2009) River (West) was not at this stage considered as being after the completion of the Giant Kingfisher Trail. The necessary to be part of an early warning system due to Waterside Boardwalk was repaired by Working for the this low threat relative to the other two estuaries. Coast in conjunction with our own staff during 2009. The Bosbok Trail has been closed since 2006, due to under Man. Plan, page 87: The Table refers to the TOR utilization for the Hydrological Study for Swartvlei, as being completed. Why has no-one in Sedgefield (or the Knysna Man. Plan, page 66: In Fig 9 on page 66, why is Municipality for that matter) been consulted, & even Swartvlei shown as falling under the Wilderness seems to know anything about this? The Sedgefield Aquatic Zoning. It is not even in the same Local Ratepayers & Voters Assoc has been requesting this Authority area as Wilderness & as already mentioned, study for at least 3 years, & has asked on a number of the Swartvlei Estuary is considered to be one of the occasions to be kept in the picture, when the TOR are major Estuaries in SA. The Touw River Estuary at developed. There are a number of retired civil engineers, Wilderness is scarcely as important as the Swartvlei in this area, with considerable hydrological experience,
41 that may be able to add to the knowledge base for this plantation exit areas, reference is made to: “Once study. the delineation of the re-commissioned areas are finalised…..” the exit programme will be re-visited. DAVID GROSSMAN: Addressed at Public Meeting, co- When will this occur? operation agreed to. LEN: The delineation of the re-commissioned areas Man. Plan, page 89: Reference is made to ”cooperative is currently underway. It is a process driven by the governance with MCM and Cape Nature.” Please define Department of Agriculture Forest and Fisheries. what is meant by this statement? Man. Plan, p 100: Mention is made in the table under JILL: Either managing the area together as in the case the section on the Rehabilitation Programme, that with the MPAs, where our officials act as Fishery Control “Funding secured where possible” to manage Alien Officers; aligning our environmental/ biodiversity plans plants etc. From where will this be sought? The budget for a conservation outcome ith Cape Nature; Firebelt for 10 years for this section of the work, is already R44 agreements with MTO to name a few. million.
Man. Plan, page 90: Mention is made of the Marine LEN: The R44 million is an annual cost to do alien plant Management Plan being in the process of compilation. clearing. Various avenues of funding will be explored. When will this be ready for comment? This might be through other National Departments like DWEA or DAFF that administers Expanded Public Works LEN: Enviro-Fish Africa (Pty) Ltd. (EFA) has been Programmes (Working for Water) or local authorities/ contracted by WWF-SA and C.A.P.E. to develop an Municipalities Integrated Management Plan (IMP) for the Garden Route (Marine). The IMP covers the area from the Groot Man Plan, p 133: Reference is made in this section River (East) to the Kaaimans Estuary from the high on Stakeholder Engagement Programme to “To water mark to three kilometers offshore except where the establish a GRNP Forum.” When will this occur? Tsitsikamma National Park (TNP) Marine Protected Area Surely this should have happened already? (See page (MPA) boundary extends further offshore This clearly 3 of the SANParks doc, “Stakeholder Participation does not cover the entire Garden Route Marine area, …..” referred to above, in point 3 of these comments. but the IMP is structured in such a way so as to facilitate its integration with other management and planning ELZETTE: Previously, both the SANParks Park Forums initiatives, primarily the IMP for the Garden Route and the DWAF PFM Forums applied. During the first National Park (GRNP), Estuary Management Plans and year since the proclamation of the GRNP, proposals the envisaged Coastal Management Plan (CMP) for have been discussed to establish a new Forum System the Eden District Municipality. A final draft of the report for the GRNP. (A discussion document outlining the is available on http://www.envirofishafrica.co.za/page. proposed forum system is available.) This new Forum php?pid=9 System will be implemented once the Public Participation process for the new GRNP Plan has been concluded Man. Plan, page 92: Reference is made to SANParks undertaking beach cleanups. This has only been done Man. Plan, p143: No mention is made about the part in recent times after the 2007 flood, & after the 2006 that SANParks does, or perhaps should, play in regard flood, this was organised & done by the Municipality to Safety on the Water of the Public Users. Similarly, no & not SANParks. Trail maintenance on the trails in the mention is made about the Disaster Management Act Wilderness area has not been done in recent times, even & any part that that may play in regard to water borne though an admission charge is made for Users. Similarly, activities. e.g. sinking of a large passenger-carrying the boardwalk alongside eth lower Wilderness Estuary vessel. has still not been fixed. ANDRE RILEY JILL: The Boardwalk along Waterside Road has indeed Water safety: all safety matters relating to the use of only been fixed recently ( 2009), due to the fact that vessels on water areas are enforced by the Regulations Disaster Management Funds had not been allocated promulgated in terms of the South African Maritime from Province to fix all infrastructure damaged in both Safety Authority (SAMSA). This includes all Policies ( floods. Trail Maintenance is ongoing and trails are in e.g. SAMSA Small Vessel Policy) and Marine Notices G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P fact in a good condition. In the spirit of co-operative issued in terms of the SAMSA Small Vessel Policy: governance SANParks and municipalities execute a Implementation of the Merchant number of shared projects, including beach- clean-ups. Shipping (Small Vessel Safety) Regulations, 2002 (as amended). These Regulations are also applicable water Man. Plan, page 98: In the section on Rehab of areas managed by SANParks.
42 Disaster management is dealt with in the parks State of (1979) and has indeed proved to be true. Flooding of Area Integrity Management Program (SOAim). SOAim lands adjacent to Swartvlei Estuary can indeed occur includes a Safety and Security Plan. Reference is made when the estuary is open, and would in all probably be to this in the Safety and Security Programme of the exacerbated by a high sea level which occurs at spring Management Plan. tide. This was clearly demonstrated on 22 November 1996 when after 167mm of rain over a 5 day period and Man. Plan, p 146: This is blank. Should it be???? this was while the estuary mouth was open and had been open for 30 days – see attached photographs. DAVID GROSSMAN: No As on the 22 November 1996 the moon phase was 11 days after the new moon (ie. 3 days before springs) Man. Plan, p 149: The amount in the budget, of R74,707 the statement that “flooding of adjacent land can be for Infrastructure, is totally inadequate. Your comments? expected with a very high spring tide coinciding with a flood” is if anything an understatement. DAVID GROSSMAN: There is a separate budget for infrastructure per se, contained in the separate Business Plan for the GRNP; this is a budget for Actions articulated in the Management Plan Programme
Man. Plan, p157: Surely for any Man Plan like this, the budget should have provision for annual roll-over? Your comments?
DEREC GILES: There is no provision for rollover in the state budgeting system.
Man. Plan, Appendices: The comment has already been made that there should be a comprehensive index.
DAVID GROSSMAN: Added
Man. Plan Appendix F, p8: Again the comment is made about “Infrequent floods in the Swartvlei system.” This is wrong.
IAN RUSSEL: This is a repeat of an earlier statement. Already answered.
There is also a comment that “flooding of adjacent land can be expected with a very high spring tide coinciding with a flood.” This is not true.
IAN RUSSEL This is a quotation from Howard-Williams & Allanson
43 levels anywhere in the Estuary” cannot be commented on. Relevance to the management plan remains unclear.
Man. Plan Appendix F, p9: Reference is made in para 1, to the impact that the Railway Bridge has on the flow of water into & out from Swartvlei. It is claimed that the main restriction to outflow is the narrow estuary mouth. This is not true. Again, the mathematical modelling I have done shows that the flow profile of various size floods flowing through the mouth is always lower than elsewhere is in the estuary. This indicates that the narrowing at the mouth does not influence water Howard-Williams, C. & Allanson, B.R. 1979. The ecology levels or flow out of the estuary. However, the railway of Swartvlei: Research for planning and future bridge has been a major factor in limiting flow into & out management. Water Research Commission, Pretoria. of the estuary.Conclusions are therefore not correct in 26pp. regard to the low impact of the rail bridge on the flow regime into & out of Swartvlei. This is commented on The highest water level during the Nov 2007 flood, later in my comments. inferred from flood debris at the SANParks depth gauge, was at approx 2,65 m above MSL, & occurred at about IAN RUSSEL 02h00 on the Fri 23rd Nov 2007, according to a resident, The statement is a quotation made from studies on the who lives about 100m away from the level gauge. This is hydrology of the Swartvlei system. The railway bridge approx 700 m from the mouth of the Swartvlei River. and embankment has been recognised as altering The level of the High Tide at Mossel Bay predicted by flow into and out of the estuary. Published literature the SA Navy Hydrographer at about 02h18 on Fri 23 however has queried whether it is the main restriction or Nov was 1,95 m Tidal Datum. This is a level of 1,02 m not. Unfortunately once again, no information is given above MSL. on what mathematical model or what input data were, There is a difference of 0,93m between MSL & the Tide and no output data are presented so the accuracy of Datum, according to the SA Navy Hydrographer in Cape the claim that “the narrowing at the mouth does not Town. influence water levels or flow out of the estuary” cannot The highest Tide level predicted for Mossel Bay on Fri 23 be commented on. Relevance to the management plan Nov 2007 was 2.27 m Tide Datum, at 14h33 in Mossel remains unclear. Bay, which is 1,34 m above MSL. At this stage the water level at the SANParks gauge was at about 1,60m above Man. Plan Appendix F, p13: My earlier comments MSL. The mathematical modelling that I have recently about the older reports being dated, again applies to the done, shows that the highest tide level has NO EFFECT references made here. The findings must be updated. on water levels anywhere in the Estuary. Pics taken at the mouth at about 15h00 on the 23rd also indicate no IAN RUSSEL: Already answered above change in water level in the estuary because of the high tide. The Highest Spring Tide level predicted for Mossel Man. Plan Appendix G, p20: As no sediment modelling Bay was on Sat 24th at about 15h17, & was 2.29 m Tide was done by CSIR (1978) in their previous investigation, Datum. There was also no storm surge at that stage, this statement about improving scour by increasing which may have artificially increased the level of the the level at which artificial breaching occurs, may be Spring Tide. erroneous. There are recent papers of work in SA about artificial breaching, which should be taken into account. IAN RUSSEL The majority of the above paragraph is a series of data IAN RUSSEL rather than a question. Information on the actual rather Unfortunately no mention is made of exactly which than predicted tide height, and wave height (Mossel recent papers should be taken into account which Bay) are available from the Naval Hydrographer. Water presumably show the conclusions drawn by CSIR and level heights for Swartvlei Lake are obtainable from Dept others that sediment scour increases with breaching Water Affairs. These provide heights and times different height is erroneous. More recent publications of which from those given above. For example, the highest water I am aware do indeed demonstrate that ”breaching at a G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P level achieved during the flood far exceeded 2.63 m higher initial water level increases the flushing efficiency” amsl. Unfortunately no information is given on what and that “not only is the flushing channel wider and mathematical model or what input data was used, and beaches further upstream, but a greater volume no output data are presented so the accuracy of the of sediment is removed from the estuary as well as claim that “the highest tide level has no effect on water downstream of the berm” – as examples see:
44 “infrastructure inappropriately located on adjacent Beck, JS & Basson GR. 2007. Klein River Estuary floodplains.” I was not aware that SANParks are (South Africa): 2D numerical modelling of estuary qualified to comment on such matters. breaching. Water SA 34(1): 33-38 IAN RUSSEL: SANParks has a number of highly Hay D, Huizinga P & Mitchell S. 2005. Managing qualified natural and environmental scientists in its sedimentary processes in South African estuaries: A employ. guide. WRC Report No TT 241/05 25pp. Man. Plan Appendix G, p20: Reference is made to Schumann EH. 1993. Towards the management of “….new developments on floodplains continue to be marine sedimentation in South African estuaries with approved by local authorities.” I find it hard to believe special reference to the Eastern Cape. WRC Report that any LA’s in this area have approved any NEW No 1109/1/03 125pp developments on flood plains in the last 5 years. I think this statement only refers to historic actions by some Man. Plan Appendix G, p20: Clause 1.2 refers to LA’s. Regular artificial breaching occurring at a lower level of the water than at the recommended level. This is IAN RUSSEL incorrect, as it has not happened in the Swartvlei estuary The respondent seems to have arbitrarily chosen 5 years recently. to be the cut-off mark between recent and historic. Over the past 10 plus years several developments have been IAN RUSSEL: I am unable to see where this statement approved in areas that are known to be prone to regular of regularly breaching at lower than the recommended flooding. SANParks and others have objected but these level is supposed to have been made – see cut & pasted where either overruled or decisions overturned on appeal Clause 1.2 below - and hence am unable to answer this which enabled developments to proceed. These have question. included Montage Village, Island Village, and the Engen station complex. More recently there have been ongoing 1.2 Purpose development of lands adjacent to the Perdespruit as part Regularly artificial breaching the Touw, Swartvlei of the development sighnposted as Scarab Village. and Groot (West) estuaries when the water level is lower than when breaching could occur naturally is in Man. Plan Appendix G, p21: Reference is again made most instances undertaken, in the cases of Touw and to the influence on high tides coinciding with floods Swartvlei, to reduce the threat of flooding of residential & affecting flooding of property. With reference to and other properties that have been developed on the Swartvlei, this is refuted above. estuarine floodplains, and in the case of Groot (West) to prevent flooding of some facilities (access road, IAN RUSSEL: Already answered above parking area, septic tanks) in waterfront properties in Natures Valley, and camping sites in the SANParks Man. Plan Appendix G, p21: The 2m trigger level Nature’s Valley restcamp. Premature breaching and adopted by SANParks for Swartvlei, will already closure of estuaries may at times also be undertaken cause flooding on sections of the Island in Sedgefield. when considered essential for the restoration of natural Previously, and until about 2002, the Swartvlei mouth patterns and processes and reduction of the effects of was artificially breached at levels as low as 1,70m above pollution. MSL.
Man. Plan Appendix G, p20: Part 1.3 refers to IAN RUSSEL: As far as I am aware the only portion
45 of the Island that is flooded when the water level in the shallow channel for both the two local estuaries, of about estuary is 2 m amsl is the roadway over the Perdespruit 4 m bottom width, leading up to the mouth, even though which is itself at 2 m and possibly a small section of road a bulldozer has been used. Such a channel under the near the junction of Charles te Water and Pres Steyn Wilderness N2 bridge can be seen at the moment. streets. The road over the Perdespruit remains passable and the inconvenience to road users is negligible. At JILL GORDON: The Preparation channel is dug to Charles te Water no access to residential properties is maximise the possibility of the velocity of water entering inhibited. At SANParks started managing Swartvlei in the mouth to scour enough sediments out into the 1986 and since that time the estuary has been breached marine system, so as to not only open the mouth to on 22 occasions, 21 of which were due to rising water prevent flooding of development under the floodline, but levels. Throughout this period the policy has remained to ensure that the system is operating healthily (prevent to breach at 2m amsl to reduce the probability of further build up of sedimentation) flooding. At 11 of the 21 breachings the estuary has indeed been opened prior to the water level actually Man. Plan Appendix G, p23: This same section refers reaching 2m. This occurs when there is already a high to an Authorisation that has recently been received water level in the estuary (for example 1.7m upwards) from DEA for the method of breaching both the Touw and a significant amount of rain has already fallen that & Swartvlei mouths. This authorisation has been will in all probability in due course result in the estuary challenged in an Appeal. What is the current status of water level reaching 2m or above. Tidal influences were the Authorisation? also taken into consideration with wherever possible breaching taking place on a reducing tide which may LEN: The appeal is currently under revision by DWEA. have also contributed to the estuary on some occasions There is a directive issued by DWEA for emergency being breached prior to 2m amsl Whereas in the past works to be carried out until the appeal has been this was left to the judgement of the SANParks officials resolved overseeing the opening exactly how early the breaching should occur, one of the purposes of this management Man. Plan Appendix G, p24: Reference is made in plan has been to apply a more consistent approach, 1.4.4 to the need for Law Enforcement to be present not only in Swartvlei but across all estuaries that are when the mouth of an estuary is breached. Why has this breached, as described in the guidelines (cf. first bullet) not happened in the past? under 1.4.5 Premature Breach of Estuaries. Prior to 2002 the lowest breaching to minimise flooding occurred JILL GORDON: Law Enforcement has always been on 5 December 1991 at 1.73m amsl following the falling present, in a limited number of 51mm in less than a 24 hour period. Between 1986 and 2002 Swartvlei estuary was breached to reduce Man. Plan Appendix G, p24: Section 1.4.5 refers to flooding on 16 occasions of which 8 (50%) were below predictions of 100 mm or even 200 mm of rain in the 2m for the reasons described above. Since 2002 next 24 hrs, being a trigger to open the Swartvlei Mouth. Swartvlei Estuary has been breached on 5 occasions of The SA Weather Bureau only gives “More than 50 mm which 2 (40%) were below 2m amsl. Warnings”. Where will the 100 mm or 200 mm rainfall Forecasts Man. Plan Appendix G, p22: In 1.4.2, there is a come from? discussion about the skimming of the bar of the Swartvlei, & regular levels taken to determine the height Information received from Eden Disaster Management; of the bar. This has never happened in the case of which has access to more accurate information Swartvlei in recent times. (The last 7 years). Man. Plan Appendix G, p24: Reference is made in this IAN RUSSEL: Appendix G will be amended section (1.4.5) to receiving information from Disaster Management. Which one? Man. Plan Appendix G, p23: In 1.4.3, there is reference to Preparing a channel to breach the mouth in March & JILL GORDON: Eden District Disaster Management April and August to December. Why not now in May of June, when the mouth is closed? Man. Plan Appendix G, p25: Reference is made in 1.4.5 to SANParks determining whether a health risk is IAN RUSSEL: This possibility to be explored posed by any contamination of water in an estuary, & G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P where necessary, advised by an appropriately qualified Man. Plan Appendix G, p23: Section 1.4.4 refers to & competent authority. There is no fulltime SANParks the use of a bulldozer or similar to maximise the length presence in the Sedgefield area to determine this, in an & depth of a pre-breaching preparation channel. In the emergency, & who will judge if the relevant authority in recent past, SANParks have only ever cut a narrow the area is qualified & competent?
46 for the Hydrological Modelling of the Swartvlei JILL GORDON: Should contamination be assumed, system.” This was promised by SANParks after the Nov SANParks and / or DWEA should be informed 2007 flood. Why has this still not been done? It is immediately so that the relevant tests can be referred to elsewhere in the Man. Plan as well. administered before any decisions can take place. JILL GORDON: SANParks applied for Provincial Disaster Man. Plan Appendix G, p25: It is categorically Management Funds and reached the final round. stated that “There has been no time in a 24 month However at the time, another disaster hit the Western period where the estuary has remained open to Cape and funds were re-allocated. SANParks has one complete tidal cycle (28 days) or longer.” The formulated a draft terms of reference which has been Swartvlei estuary was always open from the 22 Nov circulated for input by interested and affected parties 2007 until about the middle of Mar 2010, considerably longer than 24 months. This statement is wrong. Man. Plan Appendix G, p26: Observations of the Swartvlei system have indicated that the increase in IAN RUSSEL: The respondent has misunderstood the salinity, due to the long period when the mouth was statement. It is a description of a condition under which open, may have affected the growth of certain aquatic SANParks could consider premature breaching, not a plants. Why is this not mentioned in 2.3? statement of what has happened in the past condition of what may happen, not a description of what has IAN: Submerged aquatic plants have indeed declined happened in the past. All bulleted points under 1.4.5, in Swartvlei from 2008 onwards. A statement describing including this one, must be read in conjunction with this is not included in 2.3 because it not believed to the first paragraph under the heading on premature be relevant to the description of circumstances and breaching of estuaries. e.g. localities in which aquatic plants may or may not be cut as discussed in the plan. 1.4.5 Premature breaching of estuaries Breaching of the sandbar at an estuary mouth to effect a linkage between Man. Plan Appendix G, p31: There is no checking of the estuarine and marine environment where the water the quantity of sand prawns taken out of the Swartvlei level in the estuary is, in the case of the Touw Estuary system, as set out in 5.1. Why not? below 2.1m amsl, and in the case of Swartvlei and Groot (West) estuaries is below 2.0m amsl, can be undertaken JILL: We are currently in discussions with MCM if one or more of the following conditions occur: regarding the issue of subsistence permits.
There has been no time in a 24 month period where Man. Plan Appendix G, p34: Why is there no visible the estuary has remained continually open for one law enforcement by SANParks in the Sedgefield area, complete tidal cycle (28 days) or longer, and where except at Xmas time? such an extended closed period is indicated by scientific investigation to have, or likely to have, a long-term JILL GORDON: Patrols are done within the Sedgefield detrimental effect on estuarine biota, or result in salinity area on a regular weekly basis, however with limited levels exceeding the range which would normally occur budget and kilometre caps, it is only during Christmas in the estuary. etc. times that staff can be based there on a daily basis.
Man. Plan Appendix G, p25: Reference is made to: Signed by T N Cockcroft Pr Eng, BSc Eng (Civil) on 16th “Investigations will be made into securing funding May 2010
47 G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
48 ANNEXURE 4
ISSUES AND RESPONSE TO SUBMISSION BY S SWAIN Plettenberg Bay Community Environmental Forum
COMMENTS RE GARDEN ROUTE NATIONAL PARK Ian MANAGEMENT PLAN The Plettenberg Bay Community Forum is thanked for providing some very helpful comments on the Draft Mention is made of the Joint Strategic Planning by the Management Plan for the Garden Route National Park. Conservation Agencies involved under the umbrella of the collaborative GRI. As it stands, this is largely defunct The respondents are indeed correct in recognizing that but the plan is to transform the GRI into a Biosphere the closed phases of naturally temporarily open/closed Reserve whereby strategic partnerships and cooperative estuarine systems (TOCES) are extremely important governance contribute to the conservation of core, for the natural functioning of these systems. They are buffer and transition areas. Would recommend that more referred to the article Perisinotto R, Stretch DD, Whitfield specific updated details are provided AK, Adams JB, Forbes AT & Demetriades NT. 2010. Ecosystem Functioning of Temporarily Open/Closed Len: The decision to form a Biosphere Reserve has estuaries in South Africa. In: Crane, JR & Solomon AE not yet been taken by the GRI steering committee at (eds) Estuaries: Types, Movement Patterns and Climatic the time of the formulation of the GRNP Management Impacts. Nova Publishers. 1-69. which succinctly Plan. The principle of Joint Strategic Planning by the describes what some of these are, for example, higher various Conservation Agencies will still apply regardless water levels enabling in floodplain wetland inundation; what form this collaboration takes. It is furthermore the increased sediment removal when breaching ultimately intention to only include more broader strategic initiatives occurs; altered nutrient dynamics; zooplankton, in the GRNP Management Plan and not specific details. meiofauna and mocrobentic changes; increased productivity; creating ideal fish nursery conditions etc. Mention is made in connection with Swartvlei, that it has In this article it is emphasized that available evidence been recommended for hydrological, ecological and strongly indicates that artificial breaching may have long social reasons that it should be breached – what are the term impacts upon sediment dynamics, biota and basic hydrological and ecological reasons? This would seem functioning of an estuary. to be contradicted by a paragraph that follows on Page 38 that mentions specifically that The section of the draft management plan being referred • “when the mouth is closed, wind mixing of the to is in Appendix F pp8 and states. surface waters of the lakes gradually breaks down the salinity layering. The longer the mouth is closed “It has been recommended that for hydrological, the more likely it is that stratification will break down ecological and social reasons Swartvlei Estuary mouth with resultant oxygenation of the lower waters of the be artificially breached at 2.0 m amsl (CSIR 1978, Swartvlei lake”. This would seem to indicate that Howard-Williams & Allanson 1979, Whitfield et al. 1983).” it is hydrologically and ecologically very important that the closed mouth phase be permitted its natural This is not meant to imply that from an ecological and duration, so more details should be provided to hydrological perspective it is desirable to artificially explain the hydrological and ecological reasons for breach the estuary, in fact the exact opposite. From a artificially breaching the mouth social perspective, the lower the breaching the better,
49 with perceived reduction in flooding of residential areas. • All facilities should not only be aesthetically From a hydrological and ecological perspective the appropriate but also designed to be self-reliant e.g. higher the breaching the better, with the ultimate being in terms of water and energy harvesting, storage, natural breaching. The 2m proposal was identified as the waste management, recycling best compromise to meet all these needs. Possibly the • Facilities could add value to the environment confusion will be eliminated if the statement is changed through to: • Creation of micro-habitats through natural reed bed filtration of black- and greywater that deal “It has been recommended that the best compromise with wastewater naturally; indigenous gardens; to meet conflicting hydrological, ecological and social planting of trees needs is that Swartvlei Estuary mouth be artificially • Natural pools, natural architecture, passive solar breached at 2.0 m amsl (CSIR 1978, Howard-Williams & design, running on solar energy, water harvesting Allanson 1979, Whitfield et al. 1983).” and storage, effective recycling, minimal lighting with sensors to reduce light pollution The only reasons where the estuaries would likely be • If laundries are used on site, energy- and water- artificially breached for ecological reasons are given efficient appliances must be used, with recycling in the estuary management plan under Appendix G: of water through biolytix systems 1.4.5 Premature breaching of estuaries, i.e. in order to minimize the effects of pollution events; restore Len: This level of detail will be considered when recruitment opportunities disrupted by say significant individual activities are allowed/initiated in the various freshwater deprivation and such like. zones. An operational Environmental Management Plan will be formulated for each activity and will address these It is mentioned that more than 111 drainage pipes lead issues stormwater directly into the Knysna Estuary - to what extent are these monitored, do they have grids to limit In terms of the maps indicating zones where activities litter from entering the system? are not permitted, it may be a positive measure to include a map that indicates exactly where the more Andre Riley: There is a monitoring protocol being intensive/obtrusive activities are permitted (Page 65) developed through the Knysna Catchment Management Forum Len: Will be considered
On Page 46, the acronym WHS is used but it is not listed The map on page 55 is particularly difficult to read in the Acronyms List Len: Will be referred to drafter for possible modification Len: The SWOT analysis table will no longer form part of the GRNP Management Plan. On the map on page 69, the Touw River is incorrectly labelled as the Touws With reference to the Zonation Plan and the “pack it in, pack it out” principles that are mentioned for the hiking Johan: On my 1: 50 000 map the name is written with a parts of the Primitive Zone, we would recommend ‘s’, ie Touws River and I follow that convention that this be extended to become “take it in, take it out” principles and applied In areas labeled as Catchment Protection Zones, will • within the Primitive Zone on 4x4 routes meaning no commenting on development applications take place? bins provided Seems to allow for it, since in the explanation it does • also for self-catering facilities in the Primitive Zone mention that “inappropriate activities such as dam • in the Quiet Zone where closed biolytix toilet construction, loss of riparian vegetation…should be systems would also be recommended opposed”. (Page 72)
Len: This level of detail will be considered when Len: Comments on development within this area will take individual activities are allowed/initiated in the various place. It forms part of The Bufferzone of the GRNP (as zones. An operational Environmental Management Plan described in the zoning section). will be formulated for each activity and will address these issues. With reference to the Bioregional Planning objective: G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P • Reference is made to “promoting conservation Within the Zonation Plan, we would recommend that outcomes on private land via a range of environmental conservation be incorporated into mechanisms” (Page 74), but these mechanisms are facilities. In terms of this, for the Low and High Intensity not described or listed in the tables. If mechanisms Zones, the following is recommended: are in place, it would be useful to list these
50 specifically indicating the “what” and “how” and Hoekwil communities (they have recently undergone • Further comments are made regarding the need to SASS 5 training and will be assisting the municipality “work towards a sustainable conservation outcome with water sampling) on priority properties” and that the “GR Bioregional Plan aims to expand the conservation estate of IAN the GRNP and to seek conservation outcomes on Water quality and quantity in rivers throughout South private properties within identified priority natural Africa is essentially managed by the Dept Water areas”. But the plan is lacking in details as to how Affairs via the Water Act. This will ultimately be largely this is going to be specifically achieved and if it is delegated to CMAs. Municipalities are managers of not achievable as yet, then stated time frames need effluent from urban areas, as in the example given of the to be checked, changed or maybe statements need Touwsrante and Hoekwill communities. Thus in order to be revised if mandate has not yet been sorted as to be effective co-operative governance arrangements the comments, as they stand, will raise expectations should be forged with these bodies. SANParks is (P73 to 75) more a recipient of water rather than a manager. Assistance from members if the public in environmental LEN: Once again these are strategic objectives. The monitoring could be extremely valuable where they are “mechanisms” for each individual case will differ. appropriately qualified and experienced and able to commit to the long-term, systematic, repetitive sampling Reference is also made to “endeavour(ing) to promote that much monitoring demands. Several attempts have conservation-friendly land use and practices around been made in the past to involve members of the public the park” and in the table, it mentions it to be the in environmental monitoring programs. All however responsibility of Area Managers and that Agreements have failed in the short to medium term because, and Contracts are the means. Again, perhaps this despite the initial involvement of some very enthusiastic should rather be worded as being “investigated” and members of public there has been an inability for them time frames may need to be adjusted to reflect when to commit long-term to these projects. This is entirely this could actually start happening so as not to raise understandable as they all have competing demands unrealistic expectations on their time. I therefore believe that these partnerships could be entered into where there is mutual benefit but it LEN: This objective will be met through ad hoc should not become an essential activity. engagement in terms of land use change applications within the identified areas. To assign specific time frames While it is understood that SANParks has received to this activity, will not be possible. Environmental Authorisation to artificially breach certain estuaries, does the permit extend to the other activities With reference to Aquatic Systems, (Page 85) a listed including the “cutting of emergent and submerged recommended activity to tackle the problem of pollution aquatic plants to reduce the trend towards single species of rivers would be to “Develop Partnerships with domination” and to “manipulate flooding”? (Page 86 or neighbouring communities in Priority Natural Areas thereabouts) to bring about co-operative governance and shared • Has research been conducted into the trend towards responsibility”. Training of community members in “single species domination” so as to determine appropriate sampling techniques could be the activity whether this is a result of anthropogenic activities where they assist the park in monitoring the health of the or not. If not, should this level of management/ river systems, particularly where the river runs through interference be undertaken or should the system not their community e.g Touw River and the Touwsranten be left to adapt and evolve as it naturally should?
51 left to function naturally? A holistic approach to this is Ian: Authorisation was given to SANParks to undertake needed. the following activities: JILL: This is certainly not a SANParks mandate. R386 Item 2: Construction or earth moving activities However educating communities in becoming flood wise in the sea or within 100 metres inland of the high- is surely a role of the municipality? water mark of the sea, in respect of- (f) buildings; or Reference is made to Floodwise and Firewise materials (g) infrastructure in the text but is not mentioned in the tables. This would R386 Item 3: The prevention of the free movement be a proactive means of engaging with and empowering of sand, including erosion and accretion, by means communities and it is recommended that workshops of planting vegetation, placing synthetic material on around these two topics should be considered and dunes and exposed sand surfaces within a distance planned for of 100 metres inland of the high-water mark of the sea. Len R386 Item 4: The dredging, excavation, infilling, The floodwise and firewise materials are only used removal or moving of soil, sand or rock exceeding as examples. There is a range of other topics to be 5 cubic metres from a river, tidal lagoon, tidal river, covered as well (i.e. Alien Plant Control). People and lake, in-stream dam, floodplain or wetland. Conservation function will develop and distribute R386 Item 5: The removal or damaging of interpretive material within adjoining local communities. indigenous vegetation of more than 10 square metres The level of detail of these activities will be reflected in within a distance of 100 metres inland of the high- the respective workplans/BSC’s of the P&C practitioners. water mark of the sea. R386 Item 6: The excavation , moving, removal With reference to the Sustainable Use of Natural depositing or compacting of soil, sand, rock or rubble Resources, if 9200ha of indigenous forest has been covering an area exceeding 10 square metres in the allocated to timber utilization this would appear to be a sea or within a distance of 100 metres inland of the high percentage (20%) of the indigenous forest (some 43 high-water mark of the sea. 000 ha) supposed to be under protection.
Research has indeed been conducted on the emergent Graham Durrheim: Harvesting does not take place in aquatic plants. Initial surveys are described in: ecologically sensitive areas within timber utilization areas Weisser PJ & Howard-Williams 1982. The vegetation (e.g. where too steep or too wet). The area actually of the Wilderness lakes system and the macrophyte harvested is thus approximately 6500ha. encroachment problem. Bontebok 2: 19-40. Mention is made of the research that has been Follow-up surveys are given in: Russell IA 2003. Long- conducted to determine “senility criteria” of individual term changes in the distribution of emergent aquatic trees, but has research been conducted into plants in a brackish South African estuarine-lake system. understanding the impacts on and interactions (chemical African Journal of Aquatic Science. 28(2): 103-122. messaging, for instance) with the forest ecosystem that which describes plant community changes that have an old tree nearing the end of its lifespan has and the occurred over a 22 year period, and discussed possible kind of responses and growth spurts that this kind of reasons for the changes. messaging initiates? By cutting an old tree down before it dies, this messaging is interrupted and could have all Studies of the effectiveness of manipulative flooding, sorts of longer term impacts on the system as a whole. along with management recommendations are given in: Russell IA & Kraaij T 2008. Effects of cutting Graham Durrheim: No research of this kind has been Phragmites australis along a flooding gradient, with carried out in the Garden Route forests. The low harvest implications for managing reed encroachment in a South intensity probably limits the longer term impacts. African estuarine lake system. Wetlands Ecology and Management. 16: 383-393. As the national Conservation Agency, one has to question why utilization of indigenous trees from While it is understood that the threat of flooding of protected forests is permitted under the rationale of properties inappropriately built below floodlines needs revenue generation – there are far more creative and to be mitigated and that the approach is to artificially non-consumptive ways of generating revenue than to breach the river mouths, has serious consideration and permit the “sustainable harvesting” of 100, 200 year old T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P investigation into alternative measures been undertaken trees (the assumption is that this is the age of some of such as flood barriers (water-filled flood barriers appear the trees being harvested or targeted for harvesting) – if to be particularly effective) which would serve to protect something cannot be replaced within a generation, which properties while permitting the estuarine systems to be obviously 100, 200, 400 year old trees cannot, then it
52 cannot claim to be sustainable harvesting. intensities, by both internal and external scientists (e.g. Geldenhuys & Van der Merwe 1988, 1994; Milton 1987; Graham: The timber harvesting system is based on the Milton & Moll 1987, 1988). We therefore believe that the natural mortality patterns and turnover rates. Trees current harvest prescriptions are scientifically sound and selected for harvesting are expected to die from natural that the harvest intensity of 50% is not “excessive”. We causes within 10 – 15 years, and are identified by means continue with monitoring, though, to assess long-term of visible signs of senility or severe damage. However, changes in population dynamics, especially considering not all dying trees are harvested. The harvest rates that viable fern populations largely establish in disturbed for all species are below the natural mortality rates, forest areas (e.g. by fire) and that the longevity of as determined through long-term monitoring. The populations are affected by forest succession in these average harvest rate within the timber utilization areas is disturbed areas (see, for example, Kok 1998 and approximately 2 trees per hectare once every 10 years Vermeulen 2009). (i.e. once in 10 years ±1.2% of living stems with stem diameter of 30cm or greater are harvested, or 0.12% Geldenhuys, C.J. & Van der Merwe, C.J. 1988. every year). Monitoring has been carried out in timber Population structure and growth of the fern Rumohra utilization areas for over 20 years so as to try to quantify adiantiformis in relation to frond harvesting in the any impacts of harvesting. Regeneration is plentiful for southern cape forests. South African Journal of most species. Botany 54(4): 351-362. Geldenhuys, C.J. & Van der Merwe, C.J. 1994. Site Considering that the carrying capacity of the forest is relations and performance of Rumohra adiantiformis determined by how much energy is available and that, in the southern Cape forests. Deliverable Report after plants use their energy for reproduction and growth, FOR DEA-759. Division of Forest Science and only 10% of their energy is available to the next food Technology, CSIR, Pretoria. chain level, the permitting of the cutting of 50% of ferns Kok, H.R. 1998. Studie na die volhoubare benutting van on a 15 month cycle would seem to be excessive and seweweeksvaring (Rumohra adiantiformis) uit die potentially damaging in the long term to the ecosystem inheemse woude van die Suid-Kaap en Tsitsikamma. as a whole (Page 117 or thereabouts). Mini thesis submitted for the degree Masters in Environmental Management, University of Orange WESSEL Free State, Bloemfontein. Only 50% of the “pickable fronds/leaves” on a plant is Milton, S.J. 1987. Growth of seven-weeks fern (Rumohra harvested (the plants are not harvested). As stated in adiantiformis) in the southern Cape forests: the management plan, a frond has to be more than 25 Implications for management. South African Forestry cm in length with no more than 10% damage for it to Journal 143: 1-4. be pickable. Together with the 15 month harvest cycle, Milton, S.J. & Moll, E.J. 1987. Utilisation potential the result is that much less than 50% of fronds on a of Rumohra adiantiformis in the southern Cape plant is actually harvested, while many plants in the forests. Forest Biome Project Report. Ecosystem population completely escape harvesting (e.g. if there is Programmes, Foundation for Research Development, only one pickible frond on a plant, then the plant is not CSIR, Pretoria. 50 pp. harvestable). Also, relatively small areas are exposed Milton, S.J. & Moll. E.J. 1988. Effects of harvesting to harvesting, scattered over a large forest area. The on frond production of Rumohra adiantiformis harvest prescriptions are based on extensive research (Pteridophyta : Aspidiaceae) in South Africa. Journal on the ecology, population dynamics and phenology of of Applied Ecology 24: 725-743. the species and population response to different harvest Vermeulen W.J. 2009. The sustainable harvesting of
53 non-timber forest products from natural forests in GRNP’s existence within the larger Garden Route the southern Cape, South Africa: Development of and that there should be greater cooperation and harvest systems and management prescriptions. collaboration with other tourism bodies, establishments PhD dissertation. Department of Conservation and attractions in order to make the region as a whole Ecology and Entomology, Stellenbosch University, even more attractive and to keep tourists in the region Stellenbosch. longer – this would be a far wiser way of ensuring derivation of benefits from the existence of the park than Reference to revenue generation through tourism, resource utilisation. The tourism plan, as described in resource use etc should also include cost-savings as a this Management Plan, would appear to have the park revenue stream – reducing energy, water consumption, operating too much in isolation increasing efficiency in operations (Page 120). This would require that audits be conducted to know exactly Len: The Tourism Development and Implementation what the consumption is which would then provide a plan is in progress and this comment has been noted for good idea as to what kind of savings could be made further deliberation
Len: Noted. This will take place on “precinct level”. In terms of the Environmental Interpretation and Education section, (Page 137) the programmes On Page 121, mention is made to “conduct long-term described deal with conservation education but should monitoring to assess the sustainability of resource use also be expanded to incorporate broader environmental and long-term impact on the resource” but this research education. To take it to that broader level, one of very definitely should be extended to determine the long- the most effective means would be to practice what term impact of resource use on the ecosystem within you preach – to be the epitome of environmentally which the resource exists. responsible operations –recycling happening on site, energy and water efficiency etc and to highlight all of WESSEL these It is correct that the impact the resource as well as the ecosystem as a whole is important. However, what is Len: Noted required with a specific use, would depend on aspects such as the growth form of the target species, ecology In terms of the Environmental Implementation and population dynamics of the species, the product Management Programme and the Infrastructure harvested (e.g. whole plant or plant parts such as Programme, things such as the proactive retrofitting of leaves, bark, etc.), harvest intensity, spatial distribution infrastructure with energy and water efficient measures, of harvest area, the ecological drivers in the ecosystem, and having environmental standards for any new etc. Considering the above, we believe that the infrastructure should be included monitoring programmes in terms of products currently harvested are adequate – although gaps are identified Len: Noted from time to time, and these are addressed through the adaptive management approach. In addition to In terms of the Human Capital Development Programme, monitoring that relates directly to resource use, there are environmental awareness and understanding should be also a range of other monitoring programmes in place incorporated to gain a better understanding of ecosystem functioning (e.g., succession in disturbed forest areas, forest Len: Noted gap dynamics, forest rehabilitation, post-fire fynbos monitoring, etc,) – this expands our knowledge base In terms of the Financial Management Programme, so to better understand potential impact of harvesting, reducing of costs, efficiency and green accounting or other management interventions, on forest or fynbos should be considered ecosystems. • Savings and efficiency should be promoted first and foremost – conduct audits to determine what With reference to the Sustainable Tourism section, (Page is being spent in the park on energy and water 124) no mention is made of things such as the need for consumption, calculate the true cost of water etc waste management, water and energy efficiency, use • In terms of revenue generation, it is recommended of renewable energy at Park facilities. These measures that Payment for Ecosystem Services be explored are key for facilities to operate according to Responsible as a major potential future income generation Tourism principles stream e.g for carbon sequestration by forests,
provision of clean water, pollination services etc T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Len: Noted. This will take place on “precinct level”. Len: Provision is made for exploring innovative means of With reference to the Marketing Programme, it is funding recommended that more emphasis be placed on the
54 ANNEXURE 5
ISSUES AND RESPONSE TO SUBMISSION BY A. WALTERS
COMMENT ON THE DRAFT MANAGEMENT PLAN thousands of annual visitors the assurance FOR THE GARDEN ROUTE NATIONAL PARK that SANPARKS as custodian and final authority of MARCH 2010 the Swartvlei, has an understanding of the DATE: 13 JUNE 2010 impact that flooding has on livelihood and property. COMMENT BY A J WALTERS – RESIDENT OWNER The justification for Managing Actions contained in IN MONTAGE RESIDENTIAL DEVELOPMENT, the Plan is furthermore based on incorrect SEDGEFIELD, COMPRISING OF 109 HOUSEHOLDS interpretations of recommendations made in the AFFECTED BY FLOODING IN NOVEMBER 2007. quoted references. The comments following focus only on the Swartvlei. The Draft Management Plan in its present form has shortcomings and is superficial on OVERVIEW pertinent issues. It does not address the interests of SANPARKS has tormented Sedgefield residents for the community and only gives many years by not putting a transparent estuary SANPARKS officials in charge of opening the mouth management plan on the table to give residents the the power to torment residents even assurance that SANPARKS will open the Estuary further. mouth in good time to prevent or at least reduce the risk of flooding. SANPARKS has earned a bad AN URGENT APPEAL IS MADE TO SANPARKS TO track record for ignoring the warnings and warning signs RECONSIDER ITS NORMS FOR OPENING in 2007 and persisting in applying the socalled OF THE MOUTH BASED ON THE UNDERMENTIONED 2m rule even though heavy rain had fallen and was still FACTS. falling. The 2m rule to manage flooding IT IS TRUSTED THAT THE COMMENTS AND which is applied out of context as shown below is APPEALS WILL BE TAKEN INTO perpetuated in the Draft Management Plan. CONSIDERATION BY THE OFFICIALS RESPONSIBLE There are about 11 000 permanent residents in FOR SIGNING OFF OF THE Sedgefield of which about 1000 are exposed to MANAGEMENT PLAN. flooding risk. The fear and trauma that the affected residents experience each time it rains in memory The following is a summary of the comments: of the devastating flood in 2007 cannot be measured. SANPARKS as custodian and final authority for 1. REASON FOR BREACHING THE ESTUARY breaching the estuary mouth owes residents a proper MOUTH plan of action. SANPARKS‟ reasoning that The Management Plan gives flood prevention as the people who choose to live on a flood plain must accept main/only reason for artificially breaching the consequences is unconstitutional and the mouth. unacceptable because flooding of the Swartvlei can be However, there are two distinctly different reasons why prevented or the severity reduced. the estuary mouth needs to be The Managing Actions for floods as contained in the breached and which are clearly described in the Management Plan and Annexure G guarantee a references CSIR 1978, Howard-Williams & repeat of the 2003 and 2007 flooding of homes by Allanson 1979, Whitfield et al. 1983. i.e. turning a potentially normal river flood into a - one for ecological reasons; and Manmade flooding disaster. - one to prevent flooding. It follows that the conditions for each are different. The Draft Management Plan lacks badly on the issue of flood management and control. It 2. HEIGHT AT WHICH ARTIFICIAL BREACHING MAY therefore falls very far short of its purpose as a BE UNDERTAKEN “single source reference”. It also fails in giving The Management Plan links the conditions for breaching residents of Sedgefield (stakeholders?) and the the mouth to a so-called 2m rule
55 purporting that it is based on the recommendations of on adjacent floodplains whilst at the CSIR 1978, Howard-Williams & same time maintaining sufficient head of water to Allanson 1979, Whitfield et al. 1983 maximise the scouring of sediments from the The recommendations of CSIR 1978, Howard-Williams & estuary mouth on breaching and maintain natural Allanson 1979, Whitfield et al. 1983 inundation flux in marginal wetlands, by are quoted out of context. The 2,m level was maintaining the system of artificially breaching estuaries recommended for normal circumstances and not in the Touw, Swartvlei and Groot (West) for situations when there is a possibility of flooding due systems”. to heavy rain while the mouth is Paragraph 1.3 on page 21 of Appendix G closed. (Implementation Plan) states: The height at which The „compromise‟ as mentioned in Appendix G for estuaries (note the generalisation) are artificially breaching the mouth at levels less than 2m breached are in essence a compromise to when certain conditions regarding rainfall levels are met, reduce the threat of flooding of residential and other is not workable. Can SA Weather properties that have been developed on the predict how much rain will fall, exactly when and where? estuarine floodplains, whilst retaining sufficient head of SANPARKS has a real-time rain water on breaching to perpetuate monitoring gauge but it is located far from the Swartvlei hydrological processes influencing the erosion of marine catchment area. sediments in the estuary mouth and maintain patterns and processes dependant on varying 3. LESSONS FROM PREVIOUS FLOODS estuarine water levels. It is very noticeable that no mention is made of the The above statements are out of context and create the previous river floods in 2003, 2004, 2006 impression that breaching can/must only and 2007. Why is no mention is made of these very be undertaken to prevent flooding and provided important events? that there will be sufficient flow velocity to scour the As far as the Management Plan is concerned these mouth – hence the strict adherence to the 2m rule events never occurred and the references notwithstanding that flooding may be to floods are generalized. imminent because of high volumes of flood water already flowing into an already full lake. 4. EARLY WARNING Notwithstanding the floods in 2003, 2004, 2006 and 1.2 Reasons according the references 2007 there is still no reliable early Paragraph 5.2.2 on page 22 of Howard-Williams & warning system. Rainfall statistics at the time of the Allanson (1979) states : “There is little doubt, previous floods clearly show that flooding however, that over the years the estuary has become could have been predicted and residents could have adapted to the regular opening of the been forewarned. Proper early warning estuary mouth by Man just as it has adapted to the systems would have shown that the mouth had to be presence of the rail bridge. …… By artificially opened earlier. opening the mouth at regular intervals Man has in fact In 2007, SANPARKS received ample warning of imparted a considerable degree of stability impending heavy rain. Its failure to act by to the system………“As the estuary has now become opening the mouth earlier because of the 2m rule (which adapted to the regular opening of the does not apply in flooding conditions mouth, this event must be considered part of the ecology – see Howard-Williams & Allanson 1979 and Whitfield et of the Swartvlei ecosystem and as such al. 1983) is a clear indication that has no detrimental influence on the plants and animals. SANPARKS has no empathy for the trauma, damage to It is in fact now an essential requirement property, possible loss of life, for maintaining the estuary in its present condition.” discomfort, bad publicity, to name only a few caused by Paragraph (f) on page 36 of Whitfield et aI. (1983) states flooding. that “Under normal circumstances this (artificial breaching) should only take place once the vlei 5. PROTECTION OF LIVELIHOOD AND PROPERTY has reached a level of +2m above mean The Management Plan stresses the need for safety and sea level. Under high risk conditions when the lake level security of visitors, but NO mention is is already high and when there are made of the permanent residents who have invested continuous heavy rains and a rising lake level, lifetime savings in property in the area. consideration can be given to opening the mouth Surely it is SANPARKS responsibility to ensure before the +2 m level is reached” protection and safety of ALL persons in the area of its custodianship. THE MOUTH THEREFOR NEEDS TO BE BREACHED IN TWO DISTINCTLY DIFFERENT COMMENT CIRCUMSTANCES, EACH WITH ITS OWN SET OF CONDITIONS: 1. REASON FOR BREACHING THE ESTUARY A. to prevent, or reduce, the risk of flooding in the MOUTH event of forecasts of heavy rainfall (such as in 2007) in which case the height of the T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P 1.1 Reasons stated in the Management Plan sandbar is irrelevant and breaching Paragraph 3.4.9 on page 83 states : “The main objective should be undertaken as a matter of urgency. of artificial breaching of estuaries is to B. as part of the ecology of the Swartvlei ecosystem reduce the probability of inundation of residential areas (Whitfield etaI. 1983), in which case the 2m amsl requirement would apply, (provided that
56 the overriding condition will be as in A above) Note further that both Howard-Williams & Allanson 1979 and Whitfield et al. 1983 base their 2. HEIGHT AT WHICH ARTIFICIAL BREACHING MAY “recommendation” for breaching at 2m amsl on CSIR BE UNDERTAKEN 1978 in the context of „normal‟ a. The Management Plan states that the mouth should conditions. only be breached when the water level in the estuary reaches 2m amsl as recommended in CSIR d. The mathematical model used for CSIR 1978 1978, Howard-Williams & Allanson evaluated different scenarios involving the 1979 and Whitfield et al. 1983. railway and road bridges with the mouth open. The mathematical model was also used to determine the b. The abovementioned 1978 CSIR report (Hydrological effect of the railway bridge in a flood Study of Swartvlei Estuary) was scenario with the mouth open commissioned to determine the influence of the railway NB – A flood condition with the lake already full or filling and national road bridges on the tidal rapidly due to heavy rainfall and with exchange between the ocean and the lake and to the mouth closed and the sand bar at 2m, was not identify possible negative effects of simulated with the mathematical model. artificially breaching the mouth and NOT to determine an ideal level for breaching the mouth e. Howard-Williams & Allanson 1979 states “As detailed under any circumstance. earlier, this should only be opened when the level reaches 2m amsl, and preferably in c. The conclusion of CSIR 1978 as regards the artificial period August to November, although breaching was obviously the water height will be of overriding i) “We are of the opinion that there will be no adverse importance in dictating the time. Artificial influenceattached to artificial opening, provided the 2m level is adhered to, will do no breaching of the mouth when the lake level rises to 2m” harm to the estuary….[and further down] (Ons is egter van die opinie This would allow time for equipment to be brought to the dat daar geen nadelige invloed verbonde sal wees aan mouth so that opening could start die kunsmatige oopmaak before serious flooding above the 2.0 m mark occurs. van die monding wanneer die vleiwaterstand to 2 m The period August to November referred to above was gestyg het) , and regarded the optimum period to ii) “Early opening should be avoided because the outflow “coincide with the spring season to allow maximum velocity may not be sufficient recruitment of fish into the estuary” and to scour the mouth large enough. Too early opening of the 2m amsl is to allow for scouring, i.e. NOTHING to do the mouth will lead to the with flooding. It then states that in mouth closing up sooner.” (”Daar moet egter gewaak the event of possible flooding the mouth should be word teen teen „n te vroeë opened sooner. oopmaak van die monding, in welke geval die laer It is very clear that the 2m rule is meant for “normal” uitvloeisnelhede nie is staat sal conditions when the lake level wees om die monding voldoende groot oop te skuur nie. increases due to “normal” rainfall so as to ensure „n Te vroeë oopmaak van die that the outflow velocity is great monding sal gevolglik daartoe lei dat die monding gouer enough to scour the mouth and NOT as a hard and sal toemaak”) fast rule to be maintained in all The CSIR conclusion was therefore not a circumstances, even in the face of imminent flooding recommendation as purported in the Management when the mouth is closed. Plan to be applied in all circumstances, but a comment The 1978 report gives the annual inflow into the clearly meant for normal conditions. It Swartvlei as 66X10 m³. The rainfall on the days stands to reason that flood water will do the scouring if that preceded the floods of 2003, 2004, 2006 & 2007 the mouth is opened before the 2m resulted in inflows that⁶ exceeded the mark. annual inflow.
57 Due to the narrow estuary mouth it takes a considerable a) “There are currently a number of initiatives from these time for a full estuary to drain. If flood agencies underway that need to be water enters an already full estuary while it is draining, incorporated into a strategic disaster response and and depending on the inflow velocity, the recovery plan for the park and surrounds. level might even rise and certainly flood following an These initiatives include an early warning system for intense downpour. (Much like pulling the floods;…..” Paragraph 4.6.2 page 144. plug on a full bathtub, opening the taps and then adding The Implementation Plan - Appendix G makes NO a bucket of water) It must therefore mention of any early warning system or stand to reason that heavy rain in the catchment process. area when the estuary is already full, will Howard-Williams & Allanson, 1979 state in paragraph result in flooding if the mouth is not opened well in 5.4.4 “The Department of Water Affairs advance or well before the 2m mark is has produced an equation which accurately relates reached. rainfall in the Swartvlei catchment to river When the lake is at minimum level and the mouth is flow based on monthly records. If this could be done closed it can accommodate an inflow of using daily flow rates and rainfall records a about 20 million cubic meters of water before flooding set of tables could be produced for the authority in becomes a risk. 200mm of rain in the charge of opening the mouth from which the catchment area is equal to nearly 60 million cubic meters rise in lake level over the next 24 hours could be of water. With the mouth open, flood predicted from rainfall information supplied by water will drain into the ocean and the lake will act as a the Forestry Department officers responsible for the buffer for surges in river run-off. If Man catchment rain gauges. This would allow controls the outlet, then the flood that occurs because time for equipment to be brought to the mouth so that the outlet is (kept) closed, will be a opening could start before serious flooding Manmade disaster and NOT a natural event. above the 2.0m mark occurs.” In paragraph 1.4.5 on page 24 of Appendix G conditions 3. LESSONS FROM PREVIOUS FLOODS for premature breaching of the estuary Paragraph 3.4.6 which deals with climate change states is described, namely: “Climate change is one of the biggest “Prevailing meteorological conditions or forecasts as emergent challenges…… a shift to more irregular rainfall provided by the Eden Disaster Management of possibly greater intensity …… Other (or South African Weather Services in the case of impacts include sea level rise and increased flooding.” Grootriver) will assist with the decision for While all the above factors were clearly typified by the premature breaching of the estuaries. If 50mm rain is heavy rainfall and floods that occurred in predicted and actually falls breach @ 1.8, 2003, 2004, 2006 and 2007, neither the Management 100mm predicted breach @ 1.6, 150mm predicted Plan nor Appendix G make any mention breach @ 1.4” thereof. Can SA Weather predict the exact mm of rain, the exact One would expect that lessons were learnt from the time and exact area where rainfall is previous heavy downpours and resultant expected? Note that the catchment area is small (only floods, especially the 2003 and 2007 floods when the 350km²) which is less than 20km X 20km. Swartvlei mouth was closed and residential In 2007 rainfall at two stations in the catchment area properties were flooded and that it would be incorporated about 15km apart differed by as much as or at least be mentioned in the 100mm on the same day. Management Plan. At the public meeting on 17 May 2010, it was learnt that SANPARKS has a facility for monitoring As far as the Management Plan is concerned, it would real time rainfall data. The relevant rain gauge is seem that the floods never occurred or however situated in the Knysna district about were non-events. 15km east of the eastern boundary of the Swartvlei catchment area!! 4. EARLY WARNING Is it not SANPARKS‟ responsibility to have a system Given the fact the area around the Swartvlei is prone to whereby for example holiday makers flooding, it is essential that an effective, camping at the caravan park next to the lake can be accurate and reliable early warning system should be in warned in the event of imminent flooding place. especially bearing in mind that these holiday makers It is surprising and extremely disheartening that an early would have no escape route in the event of warning system is not yet in place serious flooding?. especially after the 2007 flood when over 200mm of rain Every National Park has inherent risks and dangers that fell in the catchment area the day before are/must be managed by SANPARKS. the mouth was breached with a further 200 mm falling on The inherent risk for Sedgefield is flooding. This risk the day of breaching. (The flood applies equally to residents and visitors!! occurred about 15 hours after the mouth was breached) The Management Plan falls far short in this regard.
The Management Plan mentions: 5. PROTECTION OF LIVELIHOOD AND PROPERTY T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P a) “Assess the potential of early warning systems for Paragraph 4.6.2 on page 143 - Safety and Security high water level occurrences in the Touw Programme – Protection Plan – refers to the and Swartvlei systems” Table page 86 – Monitoring importance of visitor safety, SANPARKS‟ international activities. reputation as the custodian of choice for
58 protected area management, etc. A matter conspicuous SANPARKS has stood by and is still standing hard and by its absence is that NO mention of the fast by the 2m rule which is based on safety of residents who reside in the Park is made recommendations used out of context, i.e. anywhere in the Plan. CSIR 1978 only states that there is no problem In paragraph 3.4.9 on page 49 SANPARKS expresses breaching at 2m. the need for stakeholder support and buyin. Howard-Williams & Allanson 1979 state that regular Are the permanent residents not the stakeholders? Are breaching of the mouth has become an they not also entitled to the safety and essential requirement for the stability that it brings to the security proclaimed for visitors? Many of these residents system but also that breaching are retired and have invested lifetime earlier than 2m must be applied to prevent flooding. savings in property in the area. Whitfield et al. 1983 state that breaching before 2m There is no study that shows that flooding would occur should be considered in high risk while the mouth is open. The records do conditions. however show that flooding of homes only occurred None of the above state that the 2m level is the one and while the mouth was closed. Until such time only criteria for breaching the mouth and as a hydrological study is done to prove that there will be that it must be blindly applied in all circumstances. no difference to the probability and There is sufficient evidence to support the fact that the intensity of flooding with the mouth open or closed, 2m rule is quoted and applied completely out SANPARKS should take all the precautions it of context. can to ensure visitor and resident safety. A J Walters SANPARKS‟ responsibility to ensure the safety of email: [email protected] person and property has increased ten fold Tel: 044 343 2171 since Whitfield et al. 1983 when the permanent Cel: 083 529 4523 population of Sedgefield increased from 1061 to more than 11 000. The population now potentially affected by flooding is in the region of 1000. The changed circumstances must be taken into consideration for opening the mouth.
SUMMARY AND FINAL COMMENTS It is disheartening that SANPARKS ignores the plight of residents because it regards flooding as a natural event and that residents choose to live on the flood plan. The fact is that while the possibility of flooding is a reality it is also true that flooding in the case of Swartvlei Lake is controllable to a degree and can even be avoided or the severity thereof could be reduced if SANPARKS takes proactive action by opening the mouth in good time. Without venturing onto ecological aspects, no reference could be found in the Management Plan that refers to the essential requirement recommended by Howard-Williams & Allanson 1979 that the mouth should be breached regularly and not only to prevent flooding. The 1978 CSIR Hydrological Study which is the cornerstone for the 2m rule did not incorporate flood scenarios with the mouth closed and therefore cannot be used as justification for the 2m rule in the event of a possible flood when the mouth is closed.
59 SANPARKS RESPONSE TO A. WALTERS
Artificial breaching of the Swartvlei and Touw estuary mouths in order to minimise the risk of flooding.
The breaching level for the Swartvlei Estuary remains at 2.0m amsl, and for the Touw estuary at between 2.1m and 2.4m amsl. However, premature breaching of either estuary can be considered if one of the following three conditions apply:
1. The estuary water level is at 1.8m amsl or above, and thereafter 50mm or more rain, as measured at a recognised meteorological station within the estuary catchments, falls within a period of 24 hours or less.
2. The estuary water level is at 1.6m amsl or above, and thereafter 100mm or more rain, as measured at a recognised meteorological station within the estuary catchments, falls within a period of 24 hours or less.
3. The estuary water level is at 1.4m amsl or above, and thereafter 150mm or more rain, as measured at a recognised meteorological station within the estuary catchments, falls within a period of 24 hours or less.
Systems to obtain information on prevailing meteorological conditions as well as early warning forecasts from Disaster Management are in place to facilitate decision making.
The following actions are also to be undertaken by SANParks to manage the Estuary:
• In collaboration with Eden Disaster Management, early warning systems will be developed to forecast high rainfall events in the catchments of the Touw and Swartvlei systems.
• In the case of such forecasts, preparatory channels will be constructed to expedite future breaching activities.
• Mechanical equipment will also be kept on site (or close to) to assist in rapid reaction should the Swartvlei and Touw estuary mouths be artificially breached. Negotiations with Knysna Municipality are in place to provide equipment in Swartvlei.
Draft Terms of Reference have been drawn up by SANParks for an ambitious hydrodynamic study of the Swartvlei and Touw systems. These are currently out for comment by I&AP’s. The primary objective of such a study would be to provide guidelines to manage the hydrology of the estuaries based on achieving a balance between ecological considerations and reducing the risk of flooding. It is envisaged that such a study would incorporate use of more advanced modelling techniques than have been used in past assessments, and emphasise linkages between freshwater, estuarine and marine systems. The study would also necessitate reassessment of the bathymetry of the estuary systems and topography of their T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P immediate surrounds. It is envisaged that where feasible hydrological modelling should also consider estuarine sedimentary processes. Final study design will be influenced by feasibility assessments by hydrological and modelling experts as well as the availability of funding.
60 ANNEXURE 6
ISSUES AND RESPONSE: MEETING WITH BITOU MUNICIPALITY
Comments on Public Participation Process – Bitou Councillor Memory Booysen wants to know whether Municipality, Plettenberg Bay, 02 June 2010 SANParks works together with WWF
Present: Mr du Plessis responds that on some projects, we do Bitou Municipality: work together - The Mayor, Mr Mvimbi - PA to the Mayor, Mrs Mary-Anne Mngomezulu Councillor Elaine Paulse wanted to know when and - Councillor Lawrence Luiters where the public meetings were held. - Councillor Memory Booysen - Councillor Elaine Paulse Mr du Plessis showed the advert depicting where copies of the Park Management Plans could be accessed as SANParks: well as where the venues for the public meetings were. - Mr Len du Plessis - Mr Wana Bacela Mary-Anne raised the issue of the venue and the fact - Mr Richmond Gewers that it was inaccessible for the local poor community and that no transport were made available for the locals. The Comments/ Issues/ Suggestions language also seems to be problematic as locals could not engage meaningful. Mary-Anne also elaborated on Mayor: Raised the issue of affordability of locals to the the issue of PPP (concessions) and how it is dealt with Sections, especially Tsitsikamma Rest camp whilst regards to the BBBEE charter. She also mentioned that we say Sanparks Vision is to establish Parks for the no local monitoring systems is in place for the Tourism enjoyment of all South Africans- only a few can afford to Charter and is concerned with the exploitation of locals visit the Parks. He also raised the issue of profit making by the concessionaires. Sanparks to include locals in he vs accessibility to locals (PDI’s) awarding of concessions as the Park is not benefiting the locals around its borders. Mr du Plessis responded that the People and Conservation department do have programmes that Mayor: Why Plettenberg Bay was excluded as a venue cater for affordable access to locals, especially for school for the participation process and would like to have such and organised groups. a meeting in the “black/coloured” area.
Councillor Lawrence Luiters elaborate on the Robberg Mr du Plessis The public meetings for Knysna and example where the tariff increase has led to fewer Tsitsikamma were widely advertised in the Bitou area visitors to Robberg Bad experience with the restaurant and hard copies of the Plan were made available at whilst accompanied by dignitaries from the Province three locations within the Bitou district.
Mr Bacela responded that he is aware of the challenges and has already met with some of the concessionaires. He is newly appointed as the Area Manger for the Tsitsikamma Section and is working on the challenges.
61 ANNEXURE 7
ISSUES AND RESPONSE: MEETING WITH KNYSNA MUNICIPALITY
the fact that Knysna (greater Eden) is declared a disaster GRNP Management Plan: Meeting with Knysna area due to the prevailing drought. Municipality. 26/07/2010 A suggestion is made that Knysna Municipality Attendees: approaches the Eden District Municipality to enquire Municipality: (See attendance register) about the availability of funds for such a project. SANParks undertake to assist the Municipality with the SANParks: formulation of a business plan. - N.C. Songelwa - A. Riley R. Smith remarks that there is a small amount allocated - L. du Plessis to be spend on human capital (i.e. training).
Issues and Responses: N. Songelwa responds that the costing of the programmes is activity based. There is however an L. Warring enquired regarding the progress of the MTO initiative being launched by SANParks to introduce exit reversal process in the Southern Cape. conservation as a career by offering internships to local students. L. du Plessis responded that cabinet approved the re- planting of approximately 20 000ha of pine plantations. R. Smith mentions that a SITA workshop will be The original decision was to exit 40 000ha of areas arranged by the Municipality in the following months, and previously planted with pine and convert/rehabilitate SANParks will be invited to participate. these areas to natural vegetation (incorporated into the GRNP). The exit reversal endorsement by cabinet J. Douglas remarks that there is a definite need for the did not stipulate the spatial extent (what area of the 40 Municipality and SANParks to work together in terms of 000ha) should be re-planted. SANParks; MTO; and Integrated Fire Management (especially following the DAFF (Department of Agriculture; Forestry; Fisheries) recent wild veld fires within the municipal area). are in the process of delineating these areas. Once the final areas to be re-planted are agreed, the exit schedule L. du Plessis agrees and mentions that the Southern (timing) of the 20 000ha to be re-habilitated will be Cape Fire Protection Association is the appropriate agreed. platform for such collaboration.
N. Perring commented that the Municipality only receives EPWP (Expanded Public Works Programme) funding for training and not operational purposes.
N. Songelwa mentioned that there is scope for the T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P Municipality and SANParks to work together in terms of sourcing and implementing EPWP funding to do Alien Plant Control in the Mountain Catchment Areas (through Working for Water). This is especially relevant in view of
62 ANNEXURE 8
ISSUES AND RESPONSE: MEETING WITH GEORGE MUNICIPALITY
63 G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P
64 ANNEXURE 9
COMMENTS: NATURES VALLEY RATEPAYERS ASSOCIATION
extension of the surrounding National Park. The Manager Garden Route National Park As a result of the commitment by the community to P.O. Box 3542 protect and preserve this character of the village and Knysna the sensitive natural environment of which it forms part, 6570 Nature’s Valley is acknowledged as being an excellent example of the success that can be achieved by Dear Sir/Madam integrating, as it were, a residential area within a national park through collaboration between the community and Garden Route National Park: Management Plan SANParks.
Thank you for the opportunity to provide input concerning Nature’s Valley Ratepayers Association (NVRA) the Management Plan of the Garden Route National Park (GRNP). The community of Nature’s Valley and the NVRA as its long-standing representative, has always seen itself Our input should be seen in the context of the special as a staunch ally of the adjoining national park. For relationship that has existed between Nature’s Valley this reason the community strongly apposed actions and SANParks and its predecessors for many decades that would have had a great impact on the present De – specifically the De Vasselot section of the Tsitsikamma Vasselot section: National Park. • Successful lobbying against the construction of a To better understand and evaluate the importance of national scenic coastal road from Keurbooms to this relationship and the implications it may hold for the Bloukrans across the escarpment and over the front GRNP, the following relevant background is provided. coastal dunes of Nature’s Valley.
Nature’s Valley • Successful opposition to the proposed establishment of a holiday resort for South African This small coastal hamlet is situated at the bottom of Air Force employees in the area between Blue the Groot River Pass in an extremely sensitive and Rocks and Sinker Bay. beautiful natural environment as it is surrounded by the De Vasselot indigenous forests, Groot River estuary • Successful opposition to the development of 20 and Contractual National Park which fall under the residential erven on the island in the Groot River Tsitsikamma National Park. Estuary, resulting in expropriation of the land by the State and management thereof being handed over The township comprises only 407 erven of which 394 to the Park. are large wooded and mostly unfenced single residential properties and four are very large public open spaces. • Establishment of the Contractual National Park to This, and especially the fact that the back boundaries of protect the front coastal dune, lagoon frontage and all Forest Drive erven adjoin the indigenous forest, has Groot River flood plain. created the perception that the residential area is an
65 • Successful negotiations with Eskom to prevent which it can be renewed. highly intrusive power lines over the indigenous forest to the Toll Gate. It has played a vital role in affording the protection of highest conservation status to three extremely sensitive None of these achievements would have been possible areas in Nature’s Valley, namely the frontal coastal dune without tremendous support from the Park. This not (erf 444), a section of lagoon frontage (erf 434) and the only underlines the special relationship between the Groot River flood plain (erf 382). The protection of the community and the Park, but more importantly shows the front coastal dune from inappropriate development has positive outcomes this collaboration has had for the De been recognised in the Integrated Coastal Management Vasselot Section. Act of 2009 and held up as an ideal conservation measure with photographs to prove the point of the This co-operation has continued with valued support accompanying text. from SANParks for on-going NVRA opposition to development proposals for the open spaces of Nature’s The management contract of 1994 which is a tri- Valley contained in the Bitou Draft Land Audit, and partite agreement between the NVRA, SANParks and recently the proposed alienation of the Phyl Martin Park Bitou Municipality has empowered the community by and Fynbos Reserve by the municipality for development empowering Nature’s Valley with a further stake in the purposes. surrounding national park.
In view of the above we believe the community It is understood that this type of collaboration is one of of Nature’s Valley has proved its importance as a the wished-for outcomes envisaged for the GRNP. stakeholder in the Tsitsikamma National Park and wish to provide input which might be specific to this part of the We wish to suggest that the Nature’s Valley Contractual GRNP of which we have much experience. National Park, one of the oldest and hitherto most successful of its kind, should serve as a role model for 1. MANAGEMENT AT A REMOVE the establishment of other contractual national parks within the GRNP. To this end it should be excellently Our most pressing concern is that the establishment managed and run, and current isssues addressed e.g. of the GRNP encompassing a far greater area and too few personnel too thinly stretched; policing and law managed on much broader principles with consolidation enforcement improved; more regular meetings with of personnel and resources, would result in smaller the two partners to foster the SANParks / community but sensitive areas like the De Vasselot Section of the involvement and find solutions rather than fewer Tsitsikamma National Park being managed at a greater meetings with broader agendas. remove with fewer personnel that would lead to the erosion of the hands-on management which is essential This will be a challenge but one that the NVRA believes in an area like Nature’s Valley. can be met.
We believe that this has already been experienced in the SANParks will certainly endeavour to address the issue run-up to the establishment of the GRNP. For example, raised successful law enforcement and policing have become problematic with increased snaring and poaching Afromontane Forests activity in and around Nature’s Valley; greatly increased incidents of dogs running loose in Park areas; dumping While we understand that the GRNP will be managed of garden and household waste as well as building on broader based principles, we feel that a case can rubble in the Park and encroachment of buildings in be made for some species-specific research and SANParks land. conservation.
Our concern is that erosion will escalate once the GRNP We are extremely concerned about the deterioration of becomes fully operational, and request that these the great Outeniqua yellowwoods and other indigenous localised issues also be addressed in the Management trees in the seriously threatened Afromontane forest of Plan. We wish to draw your attention to the following which less than 1% remains. In the GRNP research on particular aspects: these forests are subsumed under Fynbos, Renosterveld and other types of habitat. G R N P M A N A G E M E N T P L A N ● S T A K E H O L D E R P A R T I C I P A T I O N R E P O R T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P The Nature’s Valley Contractual National Park In Nature’s Valley, for instance, the nearest law This Contractual National Park which is a joint initiative enforcement office is in Knysna which makes it almost of the NVRA and Tsitsikamma National Park, was impossible for local communities to protect this unique proclaimed in 1994 and will run for a 30 year period after heitage. This has resulted in the loss of too great a
66 number of protected and other indigenous trees. information they have gathered?
We are concerned that management at a greater remove SANParks is committed to ongoing stakeholder will have a very deleterious effect on these forests and engagement and various programmes make provision recommend that a special dispensation be instituted for this. for the Afromontane forests of the GRNP, in which local expertise can be harnassed with greater access to 2. PRIVATISATION scientific research. In principle the NVRA supports the concept of The species of special concern programme focuses on privatisation in the GRNP, but we feel very strongly that species requiring special attention. SANParks further the proposed privatisation of the Nature’s Valley Rest adopts an ecosystem approach to ensure optimal Camp in the De Vasselot Section of the Tsitsikamma functioning of the entire ecosystem National Park must be approached with the greatest circumspection for the following reasons: Role of Community Initiatives • The Rest Camp is situated in an extremely sensitive We are aware that it is a matter of principle to involve environment in the indigenous forest on the banks of local communities in the GRNP but feel that there is not the Groot River. enough focus on how this is to be achieved. • If the Rest Camp is to be run as a profitable private enterprise it could possibly lead to increased In the Nature’s Valley area there are a number of camping and other accomodation as well as a committees and NGO’s that have co-operated with and restaurant and other facilities. supported SANParks for many years. • A situation may arise where the demands of private enterprise would be in contravention of the • The Groot River Estuary Committee consisting sound nature conservation management principles of expert hydrologists, SANParks personnel, the followed by SANParks. NVRA, NVTrust, municipal officials and private • It is unclear whether managemnent at a greater citizenshave done sterling work in determining remove would be able to ensure that best citeria for the artificial breaching of the Groot River conervation practices would be followed at a mouth as well as monitoring the general health of privatised Rest Camp at all times. the estuary and water quality. • It is unclear how the valuable and successful joint environmental education programmes of the • The three member management committee of NVTrust and SANParks that have made use of the Contractual National Park has already been Swann’s Camp and other Park resources can be mentioned. accommodated if the Rest Camp is privatised. • The most important factor that must be taken into • The NVTrust has made a major contribution to account is the impossibility of expanding the existing research in the Salt River, Soetkraal area and the limited infrastructure of Nature’s Valley that serves Tsitsikamma Rivers Project. both the village and the Rest Camp, and is stretched beyond capacity during holiday seasons. What provision has been made in the GRNP ●● Nature’s Valley has no reticulated sewerage Management Plan for such bodies, how will they be system and depends on municipal tankers to accommodated and how will SANParks utilize the empty concervancy tanks. Overloaded and
67 overflowing systems, leaking and/or cracked aesthetic and conservation value by limiting traffic and tanks and unreliable servicing by tankers lead enforcing sound conservation practices. to pollution of the estuary that has forced SANParks to put up warning notices to this We recommend that this possibility receive some effect. consideration in the Management Plan. ●● Because of Nature’s Valley’s isolated location 30km from Plett, municipal waste management Comments noted is a grave problem that creates a serious health hazard at the Waste Transfer Station that Conclusion serves as a drop off between weekly collection days. The NVRA fully supports the great initiative taken with the establishment of the GRNP, and as staunch ●● Nature’s Valley is dependent on the Groot River SANParks ally will provide input and support wherever for potable water that has been pumped and possible. treated by means of a manual system since the flood of 2007 put the water purification plant out Yours sincerely of commission. The precarious state of affairs is set to continue for the foreseeable future. (Ms) Jeanne Biesenbach Chairman These comments have been noted.
3. ROAD SYSTEM
The road system in the GRNP is complicated and fraught with potential problems.
• The national, provincial and minor road network that runs through the GRNP fall under different authorities. • There is conflict when provincial maintenance crews cut back verges with total disregard for vegetation essential for stabilising embankments; destroy valuable or rare flora when clearing or cutting back road verges or when dry vegetation is left near the roadside creating serious fire hazards. • The erection of gates for entrance fees on a provincial road will be fraught with complications e.g. communities that are surrounded by a national park and are dependent on such access roads.
We recommend that a section be created in the Management Plan to address road and traffic issues.
Nature’s Valley supports the establishment of a scenic T O R I O N R E P T A I C P T R A D E R P K E H O L A T N ● S A L P T G E M N A N A M G R N P route from the R102 turn off to Nature’s Valley to the end of the Bloukrans Pass. Such a scenic road would be a national asset, provided it is an integral part of the GRNP and SANParks have the major say to ensure its
68