3A Howe Street, Unit 839 Obs Court, Observatory, Cape Town and Have Lived Here for 11 Months

From: Kevin Greenberg To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR - Kevin Greenberg Date: Monday, 16 September 2019 22:40:35

Dear Amy Hill

My name is Kevin Joel Greenberg

Address: 3A Howe Street, Unit 839 Obs Court, Observatory, Cape Town and have lived Here for 11 months.

Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at *3A Howe Street, Unit 839 Obs Court, Observatory, Cape Town, I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

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

Once this area is destroyed it can never be undone.

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

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

Further issues that wish to raise include:

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

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

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

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

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

Who can I sue when my house is flooded? Or when I cannot get access to my house because there is only one entry into lower Observatory via Ossian Road? When Ossian Road is flooded, how will we get into Lower Observatory? Who is liable for damage in this case? The developers? The City?

Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain.

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

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

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

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

It is not too late.

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

Kind regards,

Kevin Joel Greenberg 084 2468 742

3A Howe Street, Unit 839 Obs Court, Observatory, Cape Town

Production Manager and Music Director at HD Productions - www.HDMUSIC.co.za

Kind regards, Kevin Greenberg (C) +27 84 2468 742 | (E) [email protected]

To read our disclaimer go to http://db.tt/LU0GaEpK

Go GREEN. Reduce CARBON FOOTPRINT. Use RECYCLE BIN and please think twice before you PRINT From: Darryl Torr To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 12:34:37 Attachments: Signature.png

Dear Amy Hill

My name is Darryl Torr

Address: I live at 12 Crown Street, Observatory, Cape Town and we have recently bought this property and have lived here for 4 months. Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 14 Cambridge Road I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

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

It is not too late.

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

Regards

Regards,

Darryl Torr From: Candice Reddy To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 16:06:39

Good day

I would like to object once again, to the proposed development at the River Club site, relating to the ERF & Reference numbers below.

My objections are as follows: Heritage Issues There are moves to declare the TRUP area a UNESCO heritage site and, in 2013, the Dept of Arts and Culture (DCAS) earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by DCAS and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. The development will forever destroy this site, and also hugely alter views looking in to the site and views looking out across parts of Cape Town. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. Feasibility The proposed development is incredibly dense, and not in keeping with the surrounding areas. The developers have claimed that the scale of this project is due to the feasibility. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. This cannot be considered independent. Use of land Traffic will be a major issue with a development of this size. In addition, the developers and government should be accountable with regards to aiding the reduction of unemployment and poverty issues in the WC. The development should be down scaled drastically, and have a focus on housing for low-middle income members of the population. The low percentage of proposed housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no crèche, etc. Kind regards Candice Reddy [email protected] 072 316 1930 From: Alexandra Fraser To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR (Objection) Date: Monday, 16 September 2019 17:32:24 Attachments: image001.png Importance: High

Hello

Please add my voice, as an observatory resident, to the objections to the development at The Riverclub on Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

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

My name is Alexandra Fraser (7901180243083) and I live and own the property at 10 Ash Street, Observatory, Cape Town. I have no commercial, personal or financial interests in this project.

I have objected before, during the process but am concerned that despite this process, the project seems to be proceeding regardless. While in principal I am not against property development and inclusivity, I am vehemently against this development e for the following reasons: · Ecological destruction of the site and loss of habitats: This areas is ecologically sensitive and there are a number of bird, reptile, and animal species that depend on this habitat to survive, including the Cape Clawless Otter and it’s breeding ground (the quality of the river and the return of otters and birds to the site is primarily due to the efforts and clean-up of “Friends of the Liesbeek”). · Impact on the infrastructure of the surrounding area – traffic congestion (already a problem around Black River Park and now we know that Amazon Web Services is moving in); impacts on the water table and aging infrastructure – sewage (I was under the impression that bulk was a major issue for the city), water, etc. In addition, it is not clear how this development will integrate into public transport systems, if at all. · Density of the development – the proposed development is denser than Century City, includes a number of high rise buildings out of keeping with the local environment and no effort has been made to reduce the height of the proposed buildings and structures. The current square meterage and proposed usage indicate that thousands more people and cars will use this space and need access. The argument that it is not economically feasible to build fewer building or buildings that are less than 8 stories is unacceptable. · Ignoring the Heritage status of Observatory and the site – the development makes no effort to contribute or preserve the heritage status of the site or the suburb. In addition, this land traditionally belonged to the San people and if anything should be returned to them or alternatives for affordable housing provided to them. · Water levels & folding: This area is a flood plain and if you displace the water (by filling in that area with concrete) the water level of the surrounding are will increase. This is basic physics that a primary school child can understand. While it is proposed that most of the site will be raised above the flood level, basement parking will flood, roads and infrastructure will be damaged and the houses in the surrounding areas will be negatively affected. Most of the houses in Observatory are Victorian and have clay foundations, these will crumple with rising water levels, cracks will appear (which we already have seen with burst and leaking water pipes due to water damage) and the houses will be destroyed. This type of damage neither insurance companies or the City of Cape Town or the developers will pay for. So effectively this development will decrease the value of my asset to become worthless. · Absolutely NO evidence of shared value, inclusion, transformation or positive economic impact by developers – I work with clients at a number of developments built by the same property group (Biscuit Mill, Woodstock Exchange etc) and there is NO EVIDENCE of share value by this company. No affordable housing for local residents, no inclusion of local businesses in their developments as tenants, no community upliftment, no CSI projects and no long term job creation. In fact it is the opposite with residents who have lived in Woodstock and Salt River for decades no longer been able to afford their homes (due to rates increases) and have been forces to move further away from their jobs and economic inclusion due to gentrification. A few jobs for car guards are about the only “local” benefit of their past developments and this is UNACCEPTABLE. This developer will further exacerbate inequality in the city and should never have been sold the land in the first place. Recent press articles attempt to paint a different picture but where is the hard evidence of their economic impact in the past e.g. the V&A Waterfront has detailed economic impact assessment reports detailing their positive social, economic and environmental impact.

Despite contacting my ward councillor Paddy Chapple, writing objections and participating in this process, I feel that as residents and the people who will receive no benefits and will suffer, we are constantly being ignored and belittled around this development. This is not how to engage with the community and surely there are alternative ways to create real shared value, inclusion and new housing in the surrounding areas, without developing this ecologically sensitive piece of land or with profit as the primary motive?

Regards

Alexandra Fraser

email. [email protected] mobile. +27 79 881 3682 skype. alexandra.fraser twitter. @anfraser www.fraserconsulting.co.za

From: Kari Cousins To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR (Objection) Date: Monday, 16 September 2019 19:01:34 Importance: High

Please add my voice, as an Observatory resident, to the objections to the development at The Riverclub on Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16

HWC Case No.: 15112504WD1217E

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

My name is Kari Cousins (6608210190082) and I live at 16 Ash Street, Observatory, Cape Town. I have no commercial, personal or financial interests in this project.

· Ecological destruction of the site and loss of habitat: This area is ecologically sensitive and there are a number of bird, reptile, and animal species that depend on this habitat to survive, including the Cape Clawless Otter which has been breeding in the TRUP area. It should be noted that the quality of the river and the return of otters and birds to this catchment are is primarily due to the efforts of the “Friends of the Liesbeek”, who work tirelessly to maintain the ecological health of the River.

· Impact on the infrastructure of the surrounding area – Traffic congestion (already a problem around Black River Park probably increasing now we know that Amazon Web Services is moving in); impacts on the water table and aging infrastructure – sewage (I was under the impression that bulk was a major issue for the city), water, etc. In addition, it is not clear how this development will integrate into public transport systems, if at all.

· Density of the development – the proposed development is denser than Century City, includes a number of high rise buildings out of keeping with the local environment and no effort has been made to reduce the height of the proposed buildings and structures. The current square meterage and proposed usage indicate that thousands more people and cars will use this space and need access. The argument that it is not economically feasible to build fewer building or buildings that are less than 8 stories is unacceptable.

· Ignoring the Heritage status of Observatory and the site – the development makes no effort to contribute or preserve the heritage status of the site or the suburb. In addition, this land traditionally belonged to the San people and if anything should be returned to them or alternatives for affordable housing provided to them.

· Water levels & folding: This area is a flood plain and if you displace the water (by filling in that area with concrete) the water level of the surrounding are will increase. This is basic physics that a primary school child can understand. While it is proposed that most of the site will be raised above the flood level, basement parking will flood, roads and infrastructure will be damaged and the houses in the surrounding areas will be negatively affected. Most of the houses in Observatory are Victorian and have clay foundations, these will crumple with rising water levels, cracks will appear (which we already have seen with burst and leaking water pipes due to water damage) and the houses will be destroyed. This type of damage neither insurance companies or the City of Cape Town or the developers will pay for. So effectively this development will decrease the value of the houses of people in the immediate vicinity! Not to mention the impact of pollution from the run-off from cars in the "parking" basements proposed!

· Absolutely NO evidence of shared value, inclusion, transformation or positive economic impact by developers – There is NO EVIDENCE of shared value by this company. No affordable housing for local residents, no inclusion of local businesses in their developments as tenants, no community upliftment, no CSI projects and no long-term job creation. In fact it is the opposite with residents who have lived in Woodstock and Salt River for decades, who no longer able to afford to remain in their homes (due to rates increases) and have been forces to move further away from their jobs and any possible economic inclusion due to gentrification. A few jobs for car guards are about the only “local” benefit of their past developments and this is UNACCEPTABLE. This developer will further exacerbate inequality in the city and should never have been sold the land in the first place. Recent press articles attempt to paint a different picture but where is the hard evidence of their economic impact in the past? None has been forthcoming!

Despite contacting our ward councillor, writing objections and really participating in this process in good faith, I feel that we residents, that is the people who will receive no benefits from this development whatsoever but will suffer the negative impact in full measure, are constantly being ignored and our objections over-ridden with regards to this development.

This is not true "community-engagement " and I know there are alternative ways to create real shared value, inclusion and new housing in the surrounding areas, without developing this ecologically sensitive piece of land or with profit as the primary motive.

Regards

K H Cousins --

C +27 78 008 0464 | [email protected] From: Sarah Rice To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR (Objection) Date: Monday, 16 September 2019 06:28:45

Hi,

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

My name is Sarah Rice (7404240064086) and my family and I live at 26 Cambridge Road in Observatory.

My objections are for the following reasons. 1. Infrastructure pressure – Observatory is already under pressure. The traffic is terrible and adding thousands more people without any upgrading to transport and service infrastructure is going to be a disaster. 2. Increased threat of flooding – we are on a flood plain and our homes are already under damp pressure. Putting more weight onto the system will drive the damp up and our clay based houses will simply melt and neither insurance nor the city will cover the cost of upgrade. The financial gain of a one developer is being prioritized over the massive personal, financial and emotional loss of hundreds of households. 3. Environmental pressure – the Liesbeek is home to many birds, amphibians and animals and this development will displace them and mess with the ecosystem of the river. This will have an negative impact. In light of the drought we need to pay extra attention to our natural environment. This development and its developers do not appear to have considered much beyond their own personal gain. 4. No history of ‘shared value’ – the promise of shared value is laughable in the face of reality the developer’s previous developments. Where is the community involvement in Woodstock exchange? Where are the very local businesses in the Biscuit Mill? The community projects? The inclusion? A few hipsters selling R35 cups of coffee and a vegan rosti do not make a ‘community market’. Nothing in their history suggests that anything less than pure financial gain drives their decision making. 5. Physical Scale – The sheer monstrous size of the buildings. If these were three story building it might be okay but they are not – and they will dominate our skyline turning us into something more like a council estate in the UK than the character filled heritage suburb we actually are – and are supposedly protecting. (If we wanted to live in Century City we would have moved there.)

It feels like the voices of the community are being ignored. We have to continually fight to stop developers and other external interests from transforming this suburb into a high density, high traffic, high stress and low livability one. Progress is wonderful and profit equally so – but not when the people making the sacrifices will receive literally no benefit. All the upside is going to a very small number of people while we pay the price. There is an opportunity here for the City of Cape Town to really show up for its citizens. We are desperate to believe that this leadership can and will hear us.

Thank you. Please contact me via email in all future correspondence. Sarah

Sarah Rice 083 393 6030 [email protected]

From: Gideon van Lill To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 16:24:48

Dear Amy Hill

My name is Gideon van Lill

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 15 Cambridge Road I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially and illegally annexed and privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers. 4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development.

Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved.” The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.

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

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

It is not too late.

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

Regards

Gideon van Lill 15 Cambridge Road Observatory From: Ariana K. MacPherson To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR OBJECTION Date: Monday, 16 September 2019 20:52:25

To whom it may concern:

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

My name is Ariana MacPherson and I live and own property at 30 Dixton Road, Mowbray, Cape Town. I have no commercial, personal or financial interests in this project.

Some issues include: · Ecological destruction of the site and loss of habitats: This areas is ecologically sensitive and there are a number of bird, reptile, and animal species that depend on this habitat to survive, including the Cape Clawless Otter and it’s breeding ground (the quality of the river and the return of otters and birds to the site is primarily due to the efforts and clean-up of “Friends of the Liesbeek”).

· Impact on the infrastructure of the surrounding area – traffic congestion (already a problem around Black River Park and now we know that Amazon Web Services is moving in); impacts on the water table and aging infrastructure – sewage (I was under the impression that bulk was a major issue for the city), water, etc. In addition, it is not clear how this development will integrate into public transport systems, if at all.

· Absolutely NO evidence of shared value, inclusion, transformation or positive economic impact by developers – I work with clients at a number of developments built by the same property group (Biscuit Mill, Woodstock Exchange etc) and there is NO EVIDENCE of share value by this company. No affordable housing for local residents, no inclusion of local businesses in their developments as tenants, no community upliftment, no CSI projects and no long term job creation. In fact it is the opposite with residents who have lived in Woodstock and Salt River for decades no longer been able to afford their homes (due to rates increases) and have been forces to move further away from their jobs and economic inclusion due to gentrification. A few jobs for car guards are about the only “local” benefit of their past developments and this is UNACCEPTABLE. This developer will further exacerbate inequality in the city and should never have been sold the land in the first place. Recent press articles attempt to paint a different picture but where is the hard evidence of their economic impact in the past e.g. the V&A Waterfront has detailed economic impact assessment reports detailing their positive social, economic and environmental impact.

Many thanks, Ariana MacPherson +27 76 167 2484

www.arianakmacpherson.com From: Steven Macfarlane To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR OBJECTION Date: Sunday, 15 September 2019 21:47:41

To whom it may concern,

Please find below the objections I have to the above. RIVER CLUB REDEVELOPMENT Pre-Application BAR4. Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3 This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b) HWC Case No.:15112504WD1217Ec) DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Clu

Regards

Steven @ Bluestar Management cc 8 Willow Road, Observatory, 7925 Cell: 083 513 4525 Sent from my iPhone From: Kathleen Mawson To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:29:33

Dear Amy, My name is Kathleen Mawson and I prefer to be contacted by this email address Re: Erf 151832, Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175), DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club, Cape Town

1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57) and height of the development will completely change the local environment and will affect the experience and view from the national heritage site. I’m skeptical about the “accessibility” of the site as the development is largely commercial and so busy in the day and empty at night. 2. I find the social housing angle cynical because social housing needs to be included in all developments . 3. My objection is based on the fact that this development constitutes a flood risk in the area and sets an bad precedent for other environments in the future 4. My objection is based on the heritage (pages 123 to 270) of the site of national and potentially international importance, and of particular value to the cultural practices and history of the Khoi. The social benefits of housing and jobs could be achieved elsewhere, and should be, at sites without such irreplaceable heritage value. 5. My objection is based on the feasibility and cost. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial. 6. My objection is based on the flora and fauna (pages 18 to 83). The flora of the Cape Floristic Region are of international biodiversity heritage significance, hosting more than 6000 plants that are found nowhere else in the world. The site soil of TRUP currently has the potential to host three vulnerable and endangered vegetation types. Risking to lose this conservation potential is not worth taking since there are other less sensitive sites more suitable to such dense development. As the confluence of two rivers and the ultimate meeting point of several river tributaries, the rivers here are important for the movement of several avian, aquatic and mammal species throughout Cape Town. Such dense development is not compatible with the long term survival of these ecological functions.

7. Most importantly I am disgusted by the tacit acceptance of the cynical and insincere arguments made by this document. The real motivation for developing this site is for the financial benefit of the developers. It’s ludicrous to assert otherwise and I’d prefer less naivety in my municipality!

Sincerely Dr K Mawson Telephone 0732034236 Physical home address41 Dane Street, Obs

Regards

Sent from my iPhone From: Sandy Pienaar To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application Bar Date: Monday, 16 September 2019 15:23:01 Attachments: My Letter of Objection - River Club Development Sandy.pdf ATT00001.txt From: [email protected] To: Amy Hill Cc: [email protected]; [email protected] Subject: River Club Redevelopment Pre-application BAR Date: Sunday, 15 September 2019 17:20:52 Importance: High

Dear Amy Hill

My name is Emily Jane Stockden.

I live at 11 Perth road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for 14 months. I own my property. Email: [email protected] My preferred method of communication is: email

This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 11 Perth road I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler. The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It

This proposal impacts thousands of people and intangible heritage that belongs to all South Africans. The Khoi heritage is one that I support and uphold, same for the environmental heritage of the rivers, flood plain, endangered species of plant and wildlife that is ours to protect. In this regard, no comment is irrelevant. Once this area is destroyed it can never be undone. TRUP is also a land parcel where the entire City is considered stakeholders. The Kyoto Protocol sets internationally binding emission reduction targets which was adopted in December 1997 and acceded to by South Africa in July 2002. The Protocol recognises that developed countries are principally responsible for greenhouse gas emissions as a consequence of decades of industrial activity. South Africa needs to adopt further ambitious actions by 2050. Developing a wetland is the worst thing that you can do. I am so passionate about this that I contribute a monthly amount to a community group called 'Help Up' who pay homeless and unemployed people to help clean up the rivers.

Further issues that wish to raise include: 1.FLORA Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 make no mention of this plant! 2. FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park. 3. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers. 4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place.

5. POLICY I don't believe that playing the affortable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. 6. FLOODING Have you forgotten the flooding of 5 August 2004? Do you remember that Barloworld sued the River Club for 2 million rands after 15 of its vehicles were damaged in the flooding. There have been many more recent examples. Who can I sue when my house is flooded? Or when I cannot get access to my house because there is only one entry into lower Observatory via Ossian Road? When Ossian Road is flooded, how will we get into Lower Observatory? Who is liable for damage in this case? The developers? The City? Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain. We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now? 7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations –Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here? 8. EUROPEAN HERITAGE The first free burger settlements in South Africa are right on the other side of the Liesbeeck. (this includes Valkenberg Farm on the affected side) This is where I live and will be affected by the flooding. Coornhoop, Westoe, Raapenberg, Bellvliet, Molenvliet, and the heritage nature of the largely Victorian and Edwardian houses that surrounds these farms reflects the wide diversity of history that results in our country. Coornhoop was the site of key negotiations at the end of Apartheid and this area. Coornhoop makes an important contribution to the local character and identity and was proclaimed a national monument in 1966. Finally, the Observatory itself is a key historic landmark. 9. COST According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. I agree with this. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1) (b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

It is not too late. Please note my strong objections to this development and desire to protect this area. Regards Emily Stockden 11 Perth Road Observatory Owner: Shift Consulting

From: Céline Gravenor To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:38:22

Dear Amy, My name is Céline and I prefer to be contacted by: email.

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

1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area. The buildings will completely change the local environment and will affect the experience and view from the national heritage site at the Observatory and surroundings areas. It will detract from existing walkability along the rivers and the potential for improved access and walkability is not attractive as the development is largely commercial and so busy in the day and empty at night. 2. My objection is based on the policy coherence because social housing needs to be included in all developments so this benefit is not a benefit that adds to this application in particular. 3. My objection is based on the flood risk and hydrology. I object to increasing the flood risk and reducing the ability of the river to adapt to climate change by adding several meters of concrete into the very soil sponge of a floodplain that currently absorb the increasingly risky weather events. This shifts the greater risk and uncertainty on ratepayers, residents and commuters in the whole catchment area of the Black and Liesbeek Rivers and tributaries. The proposed river ‘rehabilitation’ does not offset the loss of flood absorption capacity and sets a dangerous precedent for future development in floodplains, giving others the right to do the same, and further reducing our ability to adapt to extreme weather. If the city must densify, it should be outside the floodplain where it could get the same benefits without the uncertain amount of risk and reduction in our ability to adapt to climate change. 4. My objection is based on the heritage (pages 123 to 270) of the site of national and potentially international importance, and of particular value to the cultural practices and history of the Khoi. Commercial buildings of the proposed size and nature are not compatible with these practices and memory. There are presidents of Princess Vlei and Maiden’s Cover where the city has outweighed the broad general public benefits of the cultural and heritage value of a place over profits of development for a few. The social benefits of housing and jobs could be achieved elsewhere, and should be, at sites without such irreplaceable heritage value. 5. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial. 6. My objection is based on the flora and fauna (pages 18 to 83). The historical and cultural heritage of the site is intimately tied to the soil, flora and fauna as part of colonial historical conflict narrative, and the spiritual landscape and practices of the Khoi. The flora of the Cape Floristic Region are of international biodiversity heritage significance, hosting more than 6000 plants that are found nowhere else in the world. The site soil of TRUP currently has the potential to host three vulnerable and endangered vegetation types. Reducing the soils’ potential to recover in the future by adding concrete to it and making it more alkaline is not acceptable since the target preservation of all the three vegetation types, Western Leopard Toad and Morea aristata have not yet been met. Risking to lose this conservation potential is not worth taking since there are other less sensitive sites more suitable to such dense development. As the confluence of two rivers and the ultimate meeting point of several river tributaries, the rivers here are important for the movement of several avian, aquatic and mammal species throughout Cape Town. Such dense development is not compatible with the long term survival of these ecological functions.

Sincerely Céline Gravenor 0726470027 17 Banksia Rd, Rosebank [email protected] From: Cheryl Muir To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-application BAR Date: Sunday, 15 September 2019 17:50:15 Attachments: My Letter of Objection River Club Development.pdf ATT00001.txt

Please see attached my letter of objection to the proposed development at Two Rivers Urban Park.

It is insane to propose a development of this nature in an area that can already not handle the existing development and the related traffic in the area. And that’s in addition to the rich natural environment that will be destroyed. Let’s not be climate change deniers and add to the problems we face in the world.

My contact details are in the attached should you require any clarification or have any questions.

Kind regards Cheryl Muir From: Mish B To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:43:50 Attachments: River Club Redevelopment Pre-Application BAR.docx

Dear Amy

I trust you are well, enjoying the onset of spring :)

With regards to the River Club redevelopment pre-application BAR, find my comments attached.

Best, Mischa Blecher 081 8529 351 From: [email protected] To: [email protected]; Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-application BAR Date: Monday, 16 September 2019 15:09:26 Importance: High

Dear Amy Hill

My name is Craig John Stockden.

I live at 11 Perth road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for 14 months. I live with my wife who owns the property. Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 11 Perth road I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

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

It is not too late.

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

Regards

Craig Stockden 11 Perth Road Observatory Owner: Pixeljet

From: Kershan Pancham To: Amy Hill Cc: [email protected]; Tauriq Jenkins; Kershan Pancham Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:50:31 Attachments: Objection to River Club Development BAR.docx

Dear Amy,

My name is Kershan Pancham and I prefer to be contacted by email address: [email protected]

This is an objection to the Basic Assessment Report, on the following multiple grounds.

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

The buildings will completely change the local environment and will affect the experience and view from the national heritage site at the Observatory and surroundings areas. It will detract from existing walkability along the rivers and the potential for improved access and walkability is not attractive as the development is largely commercial and so busy in the day and empty at night.

For us as students and workers of the University of Cape Town campuses and residential areas in the area - and so current and future residents and workers in the area, and immediately affected users of the space in question – the proposed design will detract from a quality of aesthetics that includes and pivots on Open Spaces – land, river and skies and skylines. The 50m proposed built development will stand as an aesthetically horrifying monolith that permanently alters the aesthetic, visual heritage landscape of future space users. The natural image of Table Mountain is a desirable item in the skyline, however the proposed development will scar the image and pristine open sky space because of its precise location.

I object based on the policy coherence because social housing needs to be included in all developments so this benefit is not a benefit that adds to this application in particular. Social housing for students has also not been factored in here, and following the recent national student crisis for housing, this needs to be centred. We do not need a consumer-oriented development on a prime and precious land site, we need student-oriented developments that are aligned and coherent with our social and educational needs.

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

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

The HIA severely underplays the importance of the sense of Open Space in the area. The Khoi within its endemic cosmological placemaking positions Open Space at its core. The author of the HIA demonstrates a convenient belittlement of Open Space. Radically high usage of concrete bulk (and pollution therefrom that contaminates groundwater), high rise buildings together with an intruding highway across the floodplain is a remote interpretation of Open Space from both a First Nations view point as well as how it is defined by contemporary standards and law.

The emphasis in the HIA on the Liesbeek river as “the primary physical and symbolic heritage resources” ethnocides the peopling of the embankments to the Khoi. The confluence of the Black and Liesbeek Rivers is of extraordinary, unique, naturally occurring significance just as the Table Mountain and surrounding sister-peaks themselves are – i.e. IT IS IRREPLACABLE AND CANNOT BE REBUILT OR EDITED. This has been a recurring fact brought to the attention of the author on numerous occasions, including at the Ministerial Tribunal but is audaciously being stamped out of the narrative. This report reduces the relevant intangible heritage as an invisible, unconfirmed ‘scientific’ myth. This is a site that holds the memory of the First Khoi wars resulting from Riebeeck’s hedge, hence the start of the eventual genocide of the Cape San.

The recommendations put forward to investigate burials are ignored. I would ask the author, if his family believed their ancestors were buried with reasons corroborated by two impact assessments which are mostly ignored in his submission.

Section 36 of the National Heritage Resources Act makes provision for the protection and conservation of burial grounds and graves that are protected in terms of the Act and that are not the responsibility of any other authority. This includes graves of victims of conflict, as well as graves that are deemed of cultural significance. The Act also makes illegal to destroy, damage, alter, exhume or remove from its original position or otherwise disturb any grave or burial ground older than 60 years and which is situated outside a formal cemetery, without a permit issued by SAHRA. Additionally, a permit will only be issued if the exhumation or removal is to be done by a qualified archaeologist or a person approved by SAHRA; with due respect for any human remains and the customs and beliefs of any person or community concerned; after arrangements have been made for the re-interment of any human remains.

4.4 Section 4(6) of the Cultural Institutions Act, 1998 (Act No 119 of 1998) specifies that a “declared institution may not, without prior approval of the Minister, sell or otherwise alienate any specimen, collection or other movable property”. Similar provisions are relevant to provincial museums in line with provincial museum ordinances. (NHC 2011).

Perhaps, the City of Cape Town and Province would like to see that road ravage its way across the floodplain, but the author does not work for the City, nor Province, but is an independent academic for hire, contracted for the River Club. How peculiar then is it to have this as a primary feature without the requisite mandated public participatory process. Who exactly is the author working for?

This HIA has proposed what it considers a memorial site for the Khoi history. This is contradicted by the fact that the river coursing round the site will be an artificially created one, to be created by developers. We reject fake rivers as a celebratory canvas of our history. This is a deep insult. It is the kind of thinking that is devoid of the understanding of the practice of Khoi ritual or any other first indigenous practice of remembrance. With high buildings next to the site, what a fantastic view it would be for people in their apartments and for those in cars passing by. This is creating more of a spectacle than a sacred space honouring the dead.

Our ancestors are not to be commodified into a tourist trap of commercialised observation. We vehemently objects to this. We once again consider this second edition by the author, similarly determined in our first submission, as a deliberate and arrogant act of ethnocide.

Surely, the Khoi must determine what constitutes adequate and meaningful memorial – and if they say it’s not helping them, believe them!

Therefore, a range of key issues have not been adequately considered in the HIA, or have not been adequately characterised in the HIA. It is therefore not a sufficient document to inform a careful heritage assessment under the National Environmental Management Act (NEMA) which must satisfy Section 38(8) of the National Heritage Resources Act.”

The main objectives of restitution, symbolic or repatriation, is to restore the humanity of those communities who have been affected. It is to bring back pride in and respect of their heritage and to allow for an identity as human beings with the right to be fully part of the South African and global community.

Existing ethical guidelines include:

● The Medical Research Council’s ethical guidelines;

● The International Council of Museums (ICOM) Code of Ethics;

● The Vermillion Accord on Human Remains was adopted in 1989 at the

World Archaeological Congress’ Inter-Congress in the USA; and

● The Tamaki Makau-rau Accord on the Display of Human Remains and

Sacred Objects.

I object on the grounds that this HIA is GROSSLY OUT OF DATE in terms of the academic methods, ethics and current knowledges that should be deployed in constructing HIAs. It deploys a heterosexist (androcentric), racist, colonial narrative of ‘science’ with regards to Intangible Heritage. In doing so, it effectively is writing itself as if this were the late 1900s. Recent trends in Heritage have CHANGED DRAMATICALLY in the post-Holocaust and post-Cold War eras. The shifts in ‘development with heritage’ have not been incorporated. Historical cases of inclusive development concerning the Nama in the Richtersveld National Parks, or the case of Xolobeni, show that the meaning of authentically participatory development has to be rigorously scrutinized and upheld, and only researchers who can remain relevent in the contemporary knowledges should be tasked with this precious and high-stakes work.

At a basic level - the pursuit of scientific knowledge should by no means be placed above moral concerns of indigenous groups.

It is shameful that this outdated report , and its potentially outdated academic author - is driving itself forward through sheer brute force and unwillingness to engage in academic, scientific and research discussion. I personally have engaged with the author who REFUSES to discuss the science of this report – that in itself, makes it the quality of a fancy blog, not a research exercise.

Oral history has been recognised as a heritage resource in the National Heritage Resources Act (NHRA, South Africa 1999) and the National Archives Act (1996, amended 2000).4 The Department of Arts and Culture has spearheaded a National Oral History Programme, in close collaboration with the National Archives. The National Archives also maintains a National Register of Oral Sources and a Directory of Oral History Projects.

The Riverclub precinct maybe ‘privately owned’ but the history it holds belongs to humanity. It also belongs to the First Peoples who once roamed the area for a millenia. The relevance and significance cannot be undone, not with concrete, landfill, hotels, nor with promises of a redirected river channel. It is a sacred space that holds the opportunity to heal our nation. This opportunity seems to be redirected towards a past we as a people have done much to move away from. The Khoi values open space, animal, and plant life, the cosmos, and restorative justice.

Further, the University of Cape Town community dominates this area. As students and workers, we are custodians of the history and future of the area. The ‘privately owned’ spaces belong to us.

Therefore, I object based on the academic integrity of this report. As an academic and researcher myself, across the Sciences and Social Sciences, I am saying this report does not pass Peer-Review, which is the cornerstone of academic opinion, verifiability and validity. One could question therefore, the academic competence that has been put into this HIA and BAR, for this specific case. My first-year students will be able to point out the gaping holes and shaky ground that this HIA is masquerading as 'academic'.

I object based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial.

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

Sincerely

Kershan Pancham

PhD Researcher, Centre for African Studies

University of Cape Town

Level 3, Harry Oppenheimer Institute Building

Telephone: 074 75 12345

Physical home address: 15 Shannon Mews, Lower York Road, 7700

Email: [email protected] From: Kevin Gordon To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-application BAR Date: Monday, 16 September 2019 20:08:50

Dear Ms. Hill,

My name is Kevin Gordon

Address: I live at 72 Arnold street Observatory, Cape Town for a year and have lived here in Observatory, for 3 years. Email: [email protected] My preferred method of communication is: email

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

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

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

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

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

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

Regards

Kevin Gordon 72 on Arnold Street Observatory From: Tanja W To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 22:59:51 Attachments: LETTER OF OBJECTION CONCERNING River Club Redevelopment PreApplication BAR.docx

Good evening.

Please find attached my objection to the River Club redevelopment proposal.

1. Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) 2. reference numbers 3.

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

Thank you

Tanya Woolf [email protected] (preferred method of notification) personal interest From: Roger Saner To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 23:06:42

To Mz Hill

I'd like to register my objection to the proposed Riverclub development in Observatory, Cape Town.

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

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

Name: Roger Saner Contact details: 0825598479 and [email protected] Preferred contact method: email

I have no direct business or financial interest in this application. However, I am a homeowner in Observatory (7 James Road) since 2012, and am invested in the best interests of Observatory.

I do not believe that the proposed development is in Observatory's best interests. This can be summarized as follows: reducing a green space, increased risk of flooding, lack of imagination in the Brutalist architectural designs with the result looking like blocks rather than something beautiful Capetonians can be proud of, inappropriate zoning, and unnecessary density based on desire for profit rather than what is best for Observatory. It will forever destroy the sense of place at the site.

More detailed objections follow.

1. Design Issues

The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed. (see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

The height and density of the buildings are grotesque. They are laid out without imagination and resemble an army barracks or lego towers. There is no excuse for this laziness: there are plenty of examples of beautiful architecture around the world. South Africa should not continue to be the victim of Brutalist architecture where unimaginative architects only think in blocks and straight lines. If the designs were something of beauty, I would reconsider my objection. The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc.

2. Land Use issue

The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. ndeveloped, well-located land exists outside of the park, where development could take place. he River Club owners have no entitlement to development rights. They bought the land with the existing zoning.

The current local spatial development plan does not allow for this development. While deviations ay be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided.

For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose.

3. Policy coherence

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

4. Hydrology and flooding

Flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant.

We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now?

5. Heritage Issues

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

The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river.

The confluence of the two rivers is the epicentre of intangible heritage and is likely to house hatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values.

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

Heritage WC have signalled their intent to investigate the heritage grading of the site based on reliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site.

The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits.

There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage.

There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations – Maiden’s Cove, Princessvlei are examples. Why should the city not take that position here?

6. Cost and Feasibility

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

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

Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough.

The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

Thank you for your attention.

Regards Roger From: Melt van Schoor To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 23:18:49

To whom it may concern,

Re: River Club Redevelopment Pre-Application BAR

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

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

My name is Melt van Schoor (email: [email protected], tel 0832619768), part-owner of and living at 3 Perth Road, Observatory. I have no personal, business, financial or other interest in the application.

I hereby object to the proposed development. The main grounds on which I am objecting are that

1) the proposed site is part of an important large green belt running through the city, and I am convinced that it is in the interests of the city to maintain a number of large green spaces for environmental and amenity value. Many such large green spaces are preserved in cities around the world that are generally considered to be attractive to live and work in. These large green spaces do make a fundamental positive difference to the character of these cities in terms of quality of living, health and tourism value. Cape Town has almost no such spaces, and it is vital to preserve the very few that do remain. The proposed development will permanently destroy the current value of the area as a green belt and more importantly the potential future value of the area if it or parts of it is to be sensitively developed as parkland, scenic route, or similar.

2) The development is too large for the proposed road infrastructure and will lead to unacceptable traffic congestion in and around the area, including the residential neighbourhood where we live. The roads are already congested for parts of the day and the proposed development is likely to multiply the negative effects of congestion, and make it hard to get in to or out of the existing residential and other areas surrounding the site. This constitutes a sizeable negative economic impact of the proposed development.

3) Even if the arguments in favour of commercial development on the site are to be accepted, the nature of the proposed development is too large, too high and too intensive, thus is not sensitive to the environment nor to the neighbouring areas. The amount and intensity of activity it generates will detract very significantly from the relatively peaceful, traditional residential character of surrounding areas. A more reasonably scaled and less intensive development for this area would have been less objectionable than the proposed one. Kind Regards

Melt van Schoor From: Alex Rodrigues To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 14:38:15

Hi Amy and the LDG Observatory

Please ignore my first mail based in the TRUP development objection and please use the second one I sent just now,

Thanks Alex From: Lloyd Barnes To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 16 August 2019 12:00:34

Hello Ms Hill.

My name is Lloyd Barnes and I would like to be registered as an I&AP for the above mentioned project in the capacity of a resident of Observatory. I have the following questions and concerns regarding the project;

1. Your PP notices refer to " Environmental Authorisation in terms of the NEMA EIA Regulations, 2014 for GN R983 (19); GN R984 (6) and (27); and GN R985 (15) and (18) activities.". Could you please provide information from DEADp as to why the latest regulations are not referred to? Eg GNR324 2. You have provided no evidence of a site notice at the entrance to Erf 151832. The regulations state that a site notice should be placed on the boundary of the site. There is no evidence of this. 3. My biggest issue would be the traffic (increased), will this development take place before or after the proposed extension of Berkley road? The TIA was done based on information from 2017. An updated TIA would be required due to the increased amounts of housing blocks in Observatory which access the N2 every day. In the past 2 years, 3 new blocks have been developed. This TIA is based on outdated info. As seend below; "4.3 Traffic Scenarios The following traffic scenario runs were made: Base Year (2017) land use development with present transport network; • Base Year (2017) land use development with the completion of Berkley Road; • Base Year (2017) land use with Precinct 1 River Club Development; • Base Year (2017) land use with full River Club Development; and • Future 2032 modified PD land use scenario with full River Club Development." 4. It is also evident through table 9 in the TIA that the model program is high inaccurate and decisions should not be guided by this. 5. Traffic growth was accounted for " The historic traffic growth for this area indicates a relatively low growth rate due to the existing congestion levels during peak periods. For purposes of this TIA a growth rate of 3% was assumed to consider impact of short term local growth." However 3% is EXTREMELY low and unacceptable. The increased amount of residents in Observatory. The growth rates of other southern suburbs should also be accounted for as they utilize the N2 too 6. Your socio economic study refers to population data from 2014. This is outdated. It is said that a person moves to the WC every 3 minutes, you cannot base a study on outdated population information, especially for an area that has experienced extreme growth over the past 4 years. 7. More evidence of outdated information was found in your TIA- trip generation rates: " Trip generation rates were obtained from the South African Committee of Transport Officials (COTO) Trip Data Manual, TMH 17, Volume 1 (2013)." That is over 5 years ago. This isn't only deceiving, but unprofessional. TIA's cannot be based on old or outdated info. 8. There is no evidence in your outdated TIA as to how you are proposing to alleviate traffic on the N2. The extension of Berkley road will only alleviate traffic from station road and Liesbeek road. 9. Your future modeling done in the TIA cannot be seen as trustworthy or accurate given the previous inaccuracy shown in table 9. 10. Under section 11.1.1- Existing Facilities, an assumption is made that people would use public transport in order to get to the proposed development. What evidence is shown that people will use public transport? The nature of the development is not one whereby people will be taking a golden arrow bus to work. This is a business park and not a mall or school. People use there own cars. Perhaps a case study should be done on Black river park. 11. Section 13 of the TIA concludes by saying " Status Quo of road network- The existing intersections within the study area reveals acceptable LOS, however the existing road network is reasonably congested during peak hours;" The study area should include the N2 as the proposed development is directly impacting the traffic on the N2. It is also naive to say that the the LOS is acceptable. This is based on outdated information and an inaccurate model.

Thanks. From: Julie Kenney To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Thursday, 12 September 2019 14:53:00

To whom it may concern,

I would like to oppose the River club redevelopment on Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

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

I am a resident in the area and am concerned with the following aspects- 1) The huge scale of the project and the massive size of the buildings. This is out of proportion to the heritage area. I don't think the land is being used effectively with only 20% used as housing either.

2) The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space.

3) The increased risk of flooding

4) The destruction and fauna and flora in the sensitive wetland area

King Regards Julie

Julie Tilanus email - [email protected] 072 370 8285 From: Charmaine Gower To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Thursday, 12 September 2019 15:00:02

Erf 151832, City of Cape Town, and adjacent properties (Erf 264266, Erf 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175

I am a resident of Observatory and wish to express my objection to Liesbeek Leisure Properties Trust (LLPT) proceeding with the mega-development on the River Club site. I believe such a development will have a very negative impact on Observatory, Liesbeek Parkway and surrounds and should not be allowed to progress. The traffic is already a nightmare and would definitely become much worse. The Liesbeek River's fauna (endangered Western Leopard Toad) and flora (the rare plant species currently on the verge of extinction, the Moraea aristate - SANBI website http://pza.sanbi.org/moraea- aristata) and would be compromised and probably destroyed completely. Tall buildings in this beautiful, quaint area are an unwelcome abomination. The site is of intense cultural and heritage significance for the Khoi and erecting huge buildings in this area is insulting and demeaning to their values.

Should you wish to correspond with me, you may use this email address.

Charmaine Gower T: +27214317296 | [email protected] |

African Law Firm of the Year (African Legal Awards, 2019)

This email is confidential and may also be legally privileged. If you are not the intended recipient, please notify the sender immediately and then delete it. Please do not copy, disclose its contents or use it for any purpose. Webber Wentzel will not be liable for any unauthorised use of, or reliance on, this email or any attachment. This email is subject to and incorporates our standard terms of engagement. Please contact the sender if you have not already received a copy thereof. From: Alan Davson To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Thursday, 12 September 2019 17:03:34

Dear Sirs,

I wish to voice my objections to the proposed development on the sites detailed below.

1.1 Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) 1.2 Refer to the following reference numbers a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

I have been a resident in Observatory for 35 years and am appalled at all the development currently passed and in progress to allow for increase in population, traffic and infrastructure. I regularly use the Two Rivers park and enjoy the open green spaces and river and wetland.

I feel it is a disgusting idea to develop such a beautiful open green space to cover with more tarmac and concrete. The River Club area should be retained as a green open space and become an extension to the 2 Rivers park. If development is a must ....then it should be low key, and low density without the impact of high rise buildings and shopping centres.

Please reject this horrible planning and retain open green lung space.

Alan Davson 0 Robins Road Observatory. 7925

021 447 2491 (H) 021 447 7118 (W) 083 264 1468 davson@mweb.co.za From: ferdinando fox To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Thursday, 12 September 2019 23:15:59

Attention Amy Hill

We reject the LLPT Development application,

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

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

As the owner of Ferdinandos pizzeria based in Observatory and a resident of Observatory I object the LLPT development.

Kimon Kiki Bisogno Watts app +27847710485 Calling +27646761626 Email [email protected]

http://www.ferdinandospizza.com/

A reminder that on Sunday’s & Monday’s we have our amazing pizza menu, no salads/pastas etc.

instagram Ferdinandospizza Facebook ferdinandospizzacapetown

♥Please support our community dinner initiative by following instagram Obspastakichen and making a donation on your bill in the evening towards feeding and caring for the homeless of Observatory! Or join us every Wednesday from 5:45pm- 7pm at the Obs Pasta kitchen to volunteer!

♥Pizza is about Love!and you will love our Pizza!♥

Ferdinando's Pizza South Africa, 205 Lower Main Rd, Observatory, Cape Town, 7925 084 771 0485 Google maps link

Kimon Kiki Bisogno Watts app +27847710485 Calling +27646761626

http://www.ferdinandospizza.com/ A reminder that on Sunday’s & Monday’s we have our amazing pizza menu, no salads/pastas etc. instagram Ferdinandospizza Facebook ferdinandospizzacapetown

♥Pizza is about Love!and you will love our Pizza!♥

Ferdinando's Pizza South Africa, 205 Lower Main Rd, Observatory, Cape Town, 7925 084 771 0485 Google maps link From: Alison Tame To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 10:44:08 Attachments: TRUP - 13 Sept 2019.pdf

Please see attached.

Regards Alison Tame From: Wendy Urquhart To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 22:45:24 Attachments: My Letter of Objection River Club Development.docx

ERF 151832, CITY OF CAPE TOWN, AND ADJACENT PROPERTIES (ERF 26426, ERF 108936, ERF 26427, ERF 15326 REM ERF 26169, ERF 26170, ERF 26171, ERF 26172, ERF 26173, ERF 26174 AND ERF 26175

REFER TO THE FOLLOWING REFERENCE NUMBERS:

a) DEA&DP Ref No: 16/3/3/6/7/2/A7/17/3104/16

b) HWC Case No: 15112504WD1217E

c) DWS Ref No: 16/2/7/G22/A/11 and WU9026 River Club

My full name is: Wanda Michelle Parker.

My contact details and preferred method of notification are: Cell No: 079 748 3844

I have no direct or indirect personal, business, financial or other interest in this Application.

Kind regards

WANDA MICHELLE PARKER Cell No: 079 748 3844 From: Wendy Urquhart To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 22:45:24 Attachments: My Letter of Objection River Club Development.docx

ERF 151832, CITY OF CAPE TOWN, AND ADJACENT PROPERTIES (ERF 26426, ERF 108936, ERF 26427, ERF 15326 REM ERF 26169, ERF 26170, ERF 26171, ERF 26172, ERF 26173, ERF 26174 AND ERF 26175

REFER TO THE FOLLOWING REFERENCE NUMBERS:

a) DEA&DP Ref No: 16/3/3/6/7/2/A7/17/3104/16

b) HWC Case No: 15112504WD1217E

c) DWS Ref No: 16/2/7/G22/A/11 and WU9026 River Club

My full name is: Wanda Michelle Parker.

My contact details and preferred method of notification are: Cell No: 079 748 3844

I have no direct or indirect personal, business, financial or other interest in this Application.

Kind regards

WANDA MICHELLE PARKER Cell No: 079 748 3844 From: Aoife Lennon-Ritchie To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 11:13:56

To Whom it may concern,

As an Observatory resident, I would like to lodge my objection to the proposed River Club development at:

Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) 4.3 With the following reference numbers: a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

The scale and density of the development are not appropriate to the existing zoning, nor to the surrounding environment. The proposed development would seriously impact the protection of open spaces, and the wildlife that reside within.

The current zoning is for Open Space with consent uses. Approving this development will deprive all Cape Town residents of a park space. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. I would like to lodge my objection to this.

Yours sincerely, Aoife Lennon-Ritchie 5 Lower Trill Road Observatory Cape Town 7925 South Africa Tel: 0613521405 Email (preferred method of communication): [email protected]

Virus-free. www.avast.com From: Olivia Andrews To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 11:15:00

To whom it may concern,

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

I am a property owner in Observatory and I am opposed to the proposed development at the River Club.

I am particularly concerned with the following aspects:

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

2. Only 20% of the development will be for housing. Cape Town is undergoing a housing crisis, particularly for social housing.

3) The increased risk of flooding, particularly in the context of climate change

4) The destruction and fauna and flora in the sensitive wetland area.

The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands.

There is a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction.. The specialist reports (Appendix G2 in two parts) make no mention of this plant.

5.) there are no environmental or sustainability aspects of the new development. With climate change Cape Town is going to be a water scarce city. All new developments need to have rain water catchment as well as grey water systems to reduce water use. This could be an opportunity to create a world-class eco-development with water saving, renewable energy and an emphasis on rehabilitation of the river system.

Kind Regards Olivia Andrews 083 74 100 74 preferred method of communication is email: [email protected] From: Chelsey Kayla To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 11:25:07 Attachments: My Letter of Objection River Club Development.docx

Good day Amy Hill,

Please find my letter of objection for the river club development attached. regards, Chelsey From: Justin Ashley To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 13:00:30

Dear Ms Hill This email serves to register my objection to the proposed development of the River Club (Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175; with the following reference numbers DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club). My interest in this application stems from my involvement in companies and a Trust that own several properties in Observatory, as well as my position as a long standing board member of the Observatory Improvement District (over 10 years on the board).

My objection to this development is based on several grounds. Firstly the DESIGN of the development is totally out of character with the surrounding area. The proposed use of the buildings is as primarily an office development which will mean the area is largely deserted at night, and the proposed density and height of the buildings will create an unpleasant contrast with the architectural charm of Observatory and the existing developments in Observatory which are largely sensitive to the environment in which they were built. Apart from this, the SAAO, a prominent landmark both architectural international relevance due to its involvement in SALT, will be adversely affected by having such a high development on its doorstep.

The development will also contravene the current LAND USE ZONING of the land. Many if not all of the erven fall into the Two Rivers Urban Park. This park should continue to be developed into an urban park for the use of ALL CAPETONIANS, similar to the way in which the Green Point park has been transformed into an open green and democratic space for the enjoyment of all who live in this city. The TRUP is also very accessible to those who live in less affluent areas, being close to various train, bus and taxi routes. This area could be a showcase asset for Cape Town’s commitment to making this City a wonderful place to live in for all its inhabitants. This development will destroy that possibility and serve only to enrich a few. The current owners bought the land knowing it was not zoned for development. Their application to rezone should not be approved - it will require alienation of public land to serve narrow private interests and it is time the City stopped acceding to the demands of rich developers and considered the needs of the people as a whole.

The land falls into a well known FLOOD PLAIN - event taking climate change out of the equation, which will likely lead to more frequent extreme weather events, this land regularly floods in winter, and the proposal of the developers to simply lay a slab of concrete that will evaluate the development above the expected flood zone is laughable. It may protect their buildings but the floodwaters displaced by their buildings will have to go somewhere, and will in all likelihood lead to damaging flooding in other area of Observatory.

Finally, and of searing importance, is that this land is of massive HISTORICAL IMPORTANCE. For the Khoi, who first lived here and fought the first battles against colonialism here. This land should be regarded as sacred to the First Nations, and any land use rezoning should be done in consultation with them. To my knowledge, their current representatives have roundly condemned this development as inappropriate and furthering the cultural genocide the First Nations people have suffered in this country over the last 350 years. The City should take the precedent of Princess Vlei here - instead of a shopping mall, the site has been preserved as an important cultural and environmental destination in Cape Town. The same should apply here.

Regards Justin Ashley Phone: 0826080088 Email: [email protected] From: YellowCake238 To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 13:22:27

To whom it may concern

With regards to (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) and reference to the following:

DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16

HWC Case No.: 15112504WD1217E

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

Kind Regards

Dean Mc Farlane From: Sian Louw To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 14:37:21 Attachments: image001.png image002.png

My full name is: _SIAN LOUW______Address:______PO BOX 5843 TYGERVALLEY CENTRE 7536______Please contact me via email: [email protected]______My phone number is:_____082 482 90 90 ______DATE:______13 SEPTEMBER 2019______ATT: Whomsoever Bears the Responsibility of Office of The City of Cape Town with Regards to the following Referred to below as Myself, a Civic Member of the Community The City of Cape Town. LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre-Application BAR This letter of objection is in respective of the following erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) I refer too to the following reference codes for your convenience to action: a. DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b. HWC Case No.: 15112504WD1217E c. DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club I , unequivocally and without influence, other than my own sovereign conscience, disregard and reject the above-mentioned planned development on the following grounds; I do not have any business interests which could influence my personal feeling with regards to the proposed development that I am objecting against. My reasons for this objection are stated below: DESIGN The size/scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO (South African Astronomical Observatory) have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which hasNational Heritage Site status. The height and density of the buildings are grotesque. They are laid out without environmental concern or urban integration development imagination (taking into account the environmental/urban design that architects have access to globally) and rather resemble an army barracks or Lego towers. LAND USE ISSUE The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current local spatial development plan does not allow for this development. While deviations may be applied for, there must be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City must permit the developers to lease or purchase portions of land owned by the City. 11 (eleven) portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. POLICY COHERENCE The contribution to affordable housing is only 4% of the development, in total. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. HYDROLOGY AND FLOODING Flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for runoff of the floor waters. Where will this water go now? HERITAGE ISSUES The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledged to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. They have done so because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations – Maiden’s Cove, Princessvlei are examples. Why should theCcity not take that position here? COST AND FEASABILITY OF PROPOSED DEVELOPMENT The reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they must build so densely. If they accepted a small, but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent. FLORA AND FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.”

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

An Obs resident also raised the problem of a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction (on the SANBI website at http://pza.sanbi.org/moraea-aristata). As far as we can tell, the specialist reports (Appendix G2 in two parts) make no mention of this plant.

If you are a flora and fauna enthusiast/expert, look up the reports on BAR website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar (see Appendix G2 in two parts) and see if you can muster specific arguments.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

I submit my objection here in full and without prejudice and request that the responsible bodies, whose mandate it is to ensure a sustainable environment for all as the elected Governance of this Region of Cape Town, Western Cape, ensure to take this objection as my true opinion upon the above.

Thank you,

I sign by my email, sent to you via this objection from, which is attached to this document. Should you have any further requirement of my identity you are required to contact me to request further proof of my identy as a citizen. This includes your requirement of my signature to this document prior to Monday 16 September 2019.

Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

______

From: Gideon Engelbrecht To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 13:52:30

Dear Amy,

My name is Gideon Engelbrecht and I prefer to be contacted by email.

My objection is based on the scale and density of the development that will have huge impact on our local area.

Judging by the presentation it will be an unattractive mass of buildings that’s largely commercial and will destroy our natural flora and fauna.

The flora of the area is unique and found nowhere else in the world and aggressive development like this will put species like the Western Cape Leopard Toad yet again at risk.

Such dense development is not compatible with the long term survival of these ecological functions.

We need to protect our natural heritage for all to enjoy especially our children, we don’t need more buildings from money hungry developers.

Kind Regards Gideon Engelbrecht

Landline: (021) 689 1515 | cell: 072 424 3302 | www.jaywalkdesign.co.za From: Richard Andrew To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 14:56:40

To whom it may concern,

I would hereby like to oppose the River club redevelopment on Erf 151832, City of Cape Town(including adjacent erven Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

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

I am a property owner in lower Observatory and I am opposed to the proposed development at the River Club. My property is near Liesbeek parkway and I would be significantly impacted by the proposed development.

I am particularly concerned with the following aspects:

1) The huge scale of the project and the massive size of the buildings. This is out of proportion to the heritage area. The scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development.

2). Only 20% of the development will be for housing. Cape Town is undergoing a housing crisis, particularly for social housing. 3) The increased risk of flooding, particularly in the context of climate change. My property, nearby the development would be at much more significant risk in this regard.

4) The destruction and fauna and flora in the sensitive wetland area. The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. There is a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction.. The specialist reports (Appendix G2 in two parts) make no mention of this plant.

Richard Andrew 071 870 4073 email (preferred) : [email protected] From: Anna James To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 17:19:58 Attachments: Letter of Objection River Club Development_Anna James.docx

Dear Amy Hill,

Please find attached my letter of concern about the River Club Development Basic assessment report and my statement of objection to the development.

Kindly consider my queries and let me know how they are being dealt with.

Yours sincerely,

Anna James -- Environmental Learning Research Centre (ELRC) Educator and researcher PHD candidate 0825054263 From: [email protected] To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Friday, 13 September 2019 23:57:02

I write to object to the proposed development at the River Club in Observatory, with Erf number 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175).

I refer to the following reference numbers a. DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b. HWC Case No.: 15112504WD1217E c. DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club My objections are as follows:

* The area in question is a flood plain and the developers are proposing to cover a significant portion of the property with buildings, which will greatly decrease its ability to absorb water, making flooding more likely. (Even without that the Liesbeeck overflowed onto Liesbeek Parkway some 15 or so years ago.)

* The proposed buildings will be multi-storey and completely out of keeping with the surrounding 'urban park'.

* The proposals imply that there will be "affordable housing" included, however the details show approximately 4% of the buildings will be (at best) of this type.

* There is plenty of nearby area where such housing would be possible and useful. Other objectors such as Marc Turok have included details relevant to this.

* The City Council agreed that this area would remain a conservation area. This notion seems to have been abandoned - perhaps in response to blandishments from the would- be developers. This is totally unacceptable.

My name is Frances Greene (aka Biddy Greene). You can contact me on my email: [email protected] I am a resident of Observatory (and have been for over 30 years) and have no business or any other financial interest in this application.

...... From: Bradley Rink To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 12:25:06

Dear Amy,

My name is Bradley Rink, and I am a resident of Mowbray who lives within steps of the Liesbeek River, and adjacent to the proposed River Club development. I prefer to be contacted at the email above, and I do not have any personal, business or financial interest in the application to develop as referenced below:

1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area. The proposed walkability benefits are possible and better with other the no development and lower density development scenarios.

2. My objection is based on the policy coherence because social housing needs to be included in all developments so this benefit is not a benefit that adds to this application in particular.

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

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

5. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erven of public land were sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The evaluator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial.

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

Finally, I wish to underscore the fact that the proposed development is situated on a sacred Khoi site and within a designated floodplain. Such development is simply not acceptable, and sets a bad and dangerous precedent for future developments.

Thank you for taking my objection into consideration.

Sincerely,

Bradley Rink

Bradley Rink, PhD email: [email protected] mobile: +27827138223 research: http://orcid.org/0000-0002-2903-9561 From: Joni Foster To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 13:15:47

To Whom it may concern

With regard to the above and the copies Cite and Erf numbers, I hereby send my objection regarding the proposed redevelopment of The River Club. (Cite the Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

As a resident and home owner in the area, I am concerned of the impact of this proposed development. The enviromental, social, security, logistic, lack of parking and more are causing much concern in this neighbourhood already. As a business owner in Lower Main where we are all experiencing major traffic, security, parking and other issues, that are causing so many problems in this area. The Lower mani road is already not able to handle the extra traffic in the area due to all the development. Daily there are issues with the large vehicles trying to navigate their way to the Local Grain supplies as well as al the other large delivery vehicles. This proposed development is only going to cause more problems for all in every aspect laid out above. I strongly object and would like my letter of objection noted.

My objection refers to the below reface numbers.

a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16

b) HWC Case No.:15112504WD1217E

c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

Yours faithfully

S E Foster [email protected] 0828296225 Home owner. 20 Campbell Street , Observatory 7925 business owner. The Garden of Odd, 331 Lower Main Road, Observatory 7925

CONFIDENTIALITY NOTICE: The contents of this email message and any attachments are intended solely for the addressee(s) and may contain confidential and/or privileged information and may be legally protected from disclosure. If you are not the intended recipient of this message or their agent, or if this message has been addressed to you in error, please immediately alert the sender by reply email and then delete this message and any attachments. If you are not the intended recipient, you are hereby notified that any use, dissemination, copying, or storage of this message or its attachments is strictly prohibited.

From: Claire Everatt To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 13:19:21

Dear Amy

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

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

Please note my objection to the above BAR on the following grounds:

Design Issues

I believe that the scale, density and overall design of the development is not appropriate to the surrounding environment. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people living and working in close proximity to the site will be enormous given the size of the proposed blocks and that they are laid out without imagination creating a concrete wall vista. There are few social amenities included and the area will create a ghost town after hours. There is a limited residential component and those units that will be available do nothing to address the current dire housing shortage in the social housing arena.

Land Use Issues

The current zoning is for Open Space with consent uses and the site is a key component of the Two Rivers Urban Park. The River Club owners have no entitlement to development rights - they bought the land with the existing zoning and the current local spatial development plan does not allow for this development. While deviations may be applied for, there has to be appropriate motivation to justify such deviation. No such motivation has been provided.

Hydrology and Flooding Issues

The estimated increased level of future floods is 15 cm, this is discounted as insignificant, whereas for those who will be affected, it will be highly significant and far more frequent. The estimate of 15cm also looks to be significantly understated and is a best case scenario only. Continued Climate Change will bring increasing likelihood of extreme weather events which will worsen the situation further. The additional submission by PRASA to develop on their land, If approved, will prevent the PRASA land continuing to act as a receiving site for run off of the flood waters. Where will these flood waters dissipate to?

In conclusion I believe this is an ill conceived scheme which is hideously over bulked in response to the cost of building on a wetland and flood plain in order to achieve an “acceptable” return. This is an important green lung of the City and should remain and be preserved.

Please acknowledge receipt of this correspondence by return email.

Your sincerely Claire Everatt

Claire Everatt Head of Valuations Switchboard: +27 21 410 1160 Direct Line: +27 21 410 1181 | Mobile: +27 83 459 9950 Email: [email protected] | Web: www.eris.co.za

CONFIDENTIALITY & DISCLAIMER NOTICE: This message contains confidential or proprietary information for exclusive use by the addressed entities. If you are not an intended recipient, then any usage or dissemination of this message is prohibited and you should destroy this message and notify the sender immediately. Opinions, conclusions and other information in this message that do not relate to the official business of Eris Property Group (Pty) Ltd and all lawful users of this information technology platform/system, shall be understood as neither given nor endorsed by it.

From: Sarah Driver-Jowitt To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 13:37:12

Dear Amy Hill

My name is Sarah Driver-Jowitt

Address: I live at 18 Cambridge Road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, both here and in Duke Street, for 7 years. My grandmother was born and grew up in the area at the turn of the century. Email: [email protected] My preferred method of communication is: email

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

· Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others.

· Flooding.

· Pollution during the course the development and additional pollution due to increased traffic.

· Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area.

· Light pollution due to increased amount of dwellings and development.

· Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road.

· The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially and illegally annexed and privatised by John Comittis of CtFC)

· High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms.

· Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion.

· The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area.

· Flora and fauna and the destruction of the breeding areas of endangered species.

· Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

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

Cape Town already has a bad reputation for being in the pockets of the developers. Bo-Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding. I am a teacher at a government school in Cape Town. How can I teach about saving the earth and trying to bring our global temperatures down when this is happening on my doorstep? It is not too late.

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

Regards

Sarah Driver-Jowitt 18 Cambridge Road Observatory Head of Strategy & Development: Shonaquip Social Enterprise From: bridget impey To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 14:46:54

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

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

Dear Amy

I object to the above development on the following grounds:

In terms of zoning the current zoning is for Open Space with consent uses and the site is a key component of the Two Rivers Urban Park. The River Club owners have no entitlement to development rights - they bought the land with the existing zoning and the current local spatial development plan does not allow for this development. While deviations may be applied for, there has to be appropriate motivation to justify such deviation. No such motivation has been provided.

Huge buildings at 50m negatively impact the SAAO heritage site and offer no solution to social housing issues and limited accommodation to the higher end. Given the current natural purpose of the land as a flood plain, the rate of global warming and the great expense of developing wetland culminating in an over bulked development that will be an eyesore and a sparsely populated ghost town after hours. Plain ugly massive concrete walls that will do nothing to enhance the area.

This is an important site for birds nesting and a green lung in a fast developing city and has little of benefit to offer local residents.

Kind regards Bridget Impey From: Chavonne Snyman To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 16:22:33 Attachments: LETTER OF OBJECTION CONCERNING River Club Redevelopment PreApplication BAR.pdf

To Army Hill

Please see attachment.

Kind Regards Chavonne Snyman From: Wendy Urquhart To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 17:05:17 Attachments: My Letter of Objection River Club Development.docx

Dear Amy

Re: River Club Redevelopment Pre-Application BAR

· Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) · Reference numbers a. DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b. HWC Case No.: 15112504WD1217E c. DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

Wendy Urquhart Cell: 072 458 3077 Email [email protected] From: Francine Becker To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 17:11:34 Attachments: River Club Redevelopment Pre-Application BAR.pdf

Attached please find my comments on the River Club Redevelopment Pre-Application BAR

Regards Francine Dieckmann From: jason cadle To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 17:37:44

Dear Amy Hill

My name is Jason Cadle

Address: I live at 10 Willow Road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for almost 4 years. Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at *14 Cambridge Road* I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

It is not too late.

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

Regards

Jason Cadle 10 Willow Road Observatory From: Christopher Mellor To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 18:32:57

Dear Amy Hill With reference to the above, kindly note the following: I am totally opposed to any development of Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

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

I have no direct, personal, business financial or other interest in the application. It looks ghastly and is detrimental to the environment. Kind regards Adv. Christopher Mellor 078 070 8053 [email protected] From: Sarah Bullen To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Saturday, 14 September 2019 19:45:49

My full name is: Sarah Bullen

Address: 17 Westfort Rd Hout Bay

Please contact me via email: [email protected]

My phone number is: 082 373 6129

DATE: 14 September 2019

ATT: Whomsoever Bears the Responsibility of Office of The City of Cape Town with Regards to the following Referred to below as Myself, a Civic Member of the Community The City of Cape Town.

LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre- Application BAR

This letter of objection is in respective of the following erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

I refer too to the following reference codes for your convenience to action:

a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16

b) HWC Case No.: 15112504WD1217E

c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

I , unequivocally and without influence, other than my own sovereign conscience, disregard and reject the above-mentioned planned development on the following grounds; I do not have any business interests which could influence my personal feeling with regards to the proposed development that I am objecting against.

My reasons for this objection are stated below:

DESIGN

The size/scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO (South African Astronomical Observatory) have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which hasNational Heritage Site status.

The height and density of the buildings are grotesque. They are laid out without environmental concern or urban integration development imagination (taking into account the environmental/urban design that architects have access to globally) and rather resemble an army barracks or Lego towers. LAND USE ISSUE

The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space.

Undeveloped, well-located land exists outside of the park, where development could take place.

The River Club owners have no entitlement to development rights. They bought the land with the existing zoning.

The current local spatial development plan does not allow for this development. While deviations may be applied for, there must be cogent motivation to justify such deviation. No such motivation has been provided.

For the development to go ahead, the City must permit the developers to lease or purchase portions of land owned by the City. 11 (eleven) portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose.

POLICY COHERENCE

The contribution to affordable housing is only 4% of the development, in total. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application.

HYDROLOGY AND FLOODING

Flooding will be more frequent.

The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant.

We know that Climate Change will bring increasing likelihood of extreme weather events.

PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for runoff of the floor waters. Where will this water go now?

HERITAGE ISSUES

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

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

Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. They have done so because of the significant intangible heritage value that has been confirmed for the site.

COST AND FEASABILITY OF PROPOSED DEVELOPMENT

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

Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough.

FLORA AND FAUNA

If you are a flora and fauna enthusiast/expert, look up the reports on BAR website at

https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar (see Appendix G2 in two parts) and see if you can muster specific arguments.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

Thank you,

Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

Sarah Bullen writing coach + literary agent thewritingroom.co.za +27 82 373 6129

From: Maryke Olivier To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 10:04:35

Good day,

With regards to:

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

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

Objections to the River Club redevelopment BAR proposal:

1. Design Issues The scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed. (see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are grotesque. They are laid out without imagination and resemble an army barracks or lego towers. The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc.

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

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

Regards Maryke van Lill [email protected] From: Susan Gredley To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 10:22:53

Dear Amy

My name is Susan Gredley Address: I live at 8 Cambridge Road, Observatory, Cape Town and have lived in Observatory since 2008. Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 8 Cambridge Road I am immediately affected by this development, this includes being immediately affected in relation to:

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

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

2. FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park.

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

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

It is not too late.

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

Regards

Susan From: Katrin Bohlender To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 10:27:28

Dear Amy Hill

My name is Kurt Schoonraad

Address: I live and own the property at 20 Cambridge Road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, both here and in Milner Road for 15 years. Email: [email protected]

My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 20 Cambridge Road I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially and illegally annexed and privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved.” The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.

It is not too late.

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

Regards

Kurt Schoonraad 20 Cambridge Road Observatory

-- Kurt Schoonraad office +27 21 447 4114 e: [email protected] From: Katrin Bohlender To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 10:24:30

Dear Amy Hill

My name is Katrin Bohlender

Address: I live at 20 Cambridge Road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, both here and in Milner Road for 19 years. Email: [email protected]

My preferred method of communication is: email

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

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved.” The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.

It is not too late.

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

Regards

Katrin Bohlender 20 Cambridge Road Observatory

katrin bohlender. producer. africade productions. kipling place. unit 5. 337 lower main road. observatory. 7925 mobile +27 84 5807615 e: [email protected] w: www.africadeproductions.com skype: katrin.bohlender Company VAT Number: 479 021 0654 Company Registration Number: 2002/046029/23 From: Emily Vining To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Tuesday, 17 September 2019 18:03:16

To whom it may concern, I Emily Vining ( Id number 8805010017089)

Object to the proposed development effecting the following sites: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

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

You may send me correspondence and notifications via email at this address [email protected]

I am objecting as I am a concerned citizen living in the broader Cape Town city bowl area.

Reasons for objecting: 1. Design Issues The scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed. (see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are grotesque. They are laid out without imagination and resemble an army barracks or lego towers. The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc.

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

5. Heritage Issues The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations – Maiden’s Cove, Princessvlei are examples. Why should theCcity not take that position here?

6. Cost and Feasibility The reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

7. Flora and Fauna The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.” An Obs resident also raised the problem of a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction (on the SANBI website at http://pza.sanbi.org/moraea-aristata).

I await your confirmation of receipt regards Emily --

Emily Vining Implementation and Impact

m: +27 72 482 4029 e: [email protected] s: emily.vining3 w: www.andwider.com b: ethicalsupplychainsblog From: Penny Morrell To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 10:34:19

My full name is: Penelope (Penny) Morrell Address: 13 Kotzee Rd, Observatory Please contact me via email: [email protected] My phone number is: 021-448 1947 DATE: 15 September 2019

ATT: Ms Amy Hill, SRK Consulting

LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre-Application BAR

a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16

b) HWC Case No.: 15112504WD1217E

c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club I , unequivocally and without influence, other than my own sovereign conscience, disregard and reject the above-mentioned planned development on the following grounds; I do not have any business interests which could influence my personal feeling with regards to the proposed development that I am objecting against. My reasons for this objection are stated below:

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

POLICY COHERENCE The contribution to affordable housing is only 4% of the development, in total. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application.

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

COST AND FEASABILITY OF PROPOSED DEVELOPMENT The reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they must build so densely. If they accepted a small, but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

Thank you,

I sign by my email. Should you have any queries about my identity please contact me to request proof of my identity as a citizen – and local ratepayer. Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

Penny Morrell

13 Kotzee Rd, Observatory, 7925 [email protected] / [email protected] 021-448 1947 082 771 2373

Virus-free. www.avast.com From: Kira Gajjar To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 11:27:50 Attachments: My Letter of Objection River Club Development.pdf

Good Day,

Kindly refer to objection letter attached, with reference to below:

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

Reference numbers DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club You may contact me via this email address.

Thank you.

Regards Kira From: Sandra Meyer To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 11:58:34 Attachments: My Letter of Objection River Club Development.docx Importance: High

I agree wholeheartedly with the objection document attached. rgds, Sandra Meyer From: Claudia Batschari To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 12:23:16

Dear Amy Hill

My name is Claudia Batschari

Address: I live at 25 Trill Road, Observatory, Cape Town and have lived here for 14 years.

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

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

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers.

Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved.” The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.

It is not too late.

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

Regards

Claudia Batschari

"We would be happy to assist you with the planning of your safari too! Please have a look at our safari website here: www.exclusive-safaris.com" zanzibar retreats claudia batschari tel: +27 21 448 9611 cell: +27 82 459 5348 [email protected] www.zanzibar-retreats.com

From: Mark Stead To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 12:44:18

To: Amy Hill

This serves as an objection to River Club Redevelopment Pre-Application BAR.

It relates specifically to these ref numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175).

It also references these numbers: a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

I am Mark Stead and you can contact me via email ([email protected]).

I have a personal interest in this application, as I live at 1 Ossian Road - the top of a whole road that will be influenced most directly by flooding as a result of any development on the River Club site. This report from the Pre-application BAR itself (Appendix G3 Surface Water 1A)shows on page 94 the difference between the 20 year flood line with and without the development having taken place. Our house is clearly in the red zone (see image) proving we will be flooded as a direct result of development in a 20 year flood but NOT if the development is stopped. This is a very simple, but very serious argument for us, and we think this should be enough of a reason to stop this development from taking place at all.

In addition, I also represent the whole Stead family: Mark, Joe and Jack Stead. We have been living at 1 Ossian Rd since 1999 (and in 6 Ash Street for two years before that). We feel very lucky to be able to live so close to the river and we spend time engaging with nature, the river, the Vlei and the mountain and feel we are able to connect to the very fabric of this land in this manner. The fact that people have been living here (on this site and most likely on the site my house is situated) for centuries and that our countries very roots date back to this site just add to the richness of that experience, and the importance as to why it should remain open to all and undeveloped by no-one.

The experience we have is in fact supported by a number of official bodies. There are moves to declare the TRUP area a UNESCO heritage site and as far back as 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received support from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. After all, it’s the open space and the area itself that is the heritage.

This image (see above) shows just how much of an impact the development will have on the space. There is no going back from there.

Yours sincerely, The Stead Family

PS. Direct Link to 20 year flooding report (p94) https://www.srk.co.za/sites/default/files/images- 20181122/South_Africa/Public_Documents/RiverClub_Redevelopment/Appendices/Appendix_G3_Surface_Water_IA.pdf

creative director Mark Stead mobile: +27 83 556 1999 office: +27 21 447 3768 From: Tanya M To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 12:50:56

Dear SRK

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

Dear Amy Hill

My name is Tanya Moosmann and I have resided here in the Hartleyvale area of Observatory for more than 20 years.

Address: 41 Duke Street, Observatory, Cape Town Email: [email protected] My preferred method of communication is: Email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 41 Duke Street I am immediately affected by this development, this includes being immediately affected in relation to: · Flooding!!!

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

· Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure.

· High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

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

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

Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the intended buildings is obscene and unacceptable.

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

FLOODING We know that Climate Change will bring increasing likelihood of extreme weather events. Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain.

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

There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received support from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations –Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here?

It is not too late.

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

Regards

Tanya Moosmann 41 Duke Street Observatory From: Ashley McLean To: [email protected]; Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 13:01:54

Erf numbers:

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

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

NAME: ASHLEY MCLEAN, [email protected], 3 ONDERNEMING, 19 DANE STREET, OBSERVATORY, 7925

I OBJECT TO THIS DEVELOPMENT. NO DEVELOPMENT IN A HERITAGE/WETLAND AREA. YOU ARE DESTROYING OBS. I DON'T WANT A HUGE DEVELOPMENT IN THIS SUBURB. WE DON'T NEED ONE. From: Andrew Bowden To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 13:32:50 Attachments: Letter of Objection River Club Development_Andrew Bowden.pdf

Dear Amy Hill,

Please find attached my letter of concern about the River Club Development Basic assessment report and my statement of objection to the development.

Kindly consider my queries and let me know how they are being dealt with.

Yours sincerely,

Andrew Bowden From: Alex Rodrigues To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 14:36:47

Dear Amy,

My name is Alexandre Rodrigues and I prefer to be contacted by: email.

• My first objection is based on the design found on pages 51-57 of the main report as well as Appendix G6.

The building is extremely high at 50m and will obscure views and negatively effect the aesthetics of the skyline/ views.

The scale and concentration of the development clashes with and detracts from the various heritage aspects of the Observatory site and surrounds, including the ecologically important and sensitive river.

• Social housing cannot be touted as a benefit to this development as the very construction impinges on the heritage of the Khoi and the sacredness of the site and poses a risk to inhabitants due to the floodplain points below and so weakens the need / motivation for this application (no net community upliftment - that language has been used to obscure pure commercial gain)

• Building on a flood plain is both risky and damaging to not only fauna and flora but to people living in the areas, including the old and children, and poses a major threat when there is rainy weather and extra concrete that doesn’t allow for adequate drainage. The plans to rehabilitate the river area doesn’t mitigate this flood risk and no development should be allowed on a floodplain as it reckless since such an area needs to remain undeveloped to channel excess water which would otherwise cause major damage to surrounds (buildings, vulnerable humans, nature etc) if not absorbed.

• As per above points, the site has national and international importance especially for the Khoi and in relation to their culture and history - this commercial undertaking and its magnitude would devastate such an important site and infringe on the rights of a vulnerable minority group.

• A further objection is to the fact that the erf was not sold on an arms length basis as the valuer and investor have a conflict of interest since the former was hired by the latter and so Investec (the investor) was able to purchase the public land at a 90% discount. Reference to feasibility and cost are thus twister as the fiscus has actually been robbed of prime, important ecologically and culturally significant land in the short sighted self interests of money grubbing developers. The true value of the land should have been obtained and the state could have reused said proceeds to instead better protect the area from abuse such as this.

• Lastly, if the TRUP development is allowed, it will cause devastation to an ecologically sensitive and important area that serves as the home to over 5,000 plants, boasting a rich biodiversity (referred to in pages 18-83) of fauna and flora that will be under certain permanent threat and possible extinction if allowed to proceed. Given the spiritual and cultural plus historical significance of the area for the Khoi, this is further reason to call off the development. The Cape Floristic region of which the Two Rivers area is part has soul that hosts very endemic and sensitive vegetation that is under threat of annihilation as well as being the home to the Western Leopard Toad and other animals that would be affected by this build.

I therefore wholeheartedly oppose such a densification of this ecologically and historically important area as it threatens the long term sustainability of the plan and animal species here, endangering our posterity, as well as posing as a significant flood risk to locals and surrounds.

Regards

Alexandre Rodrigues 082 497 6453 Owner: Cottage at - 27 John Street Mowbray [email protected] From: Kallie Doran To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Tuesday, 17 September 2019 12:26:05

To whom it may concern

I am a business owner operating from Lower Main Road in Observatory. I am aware that my submission is a day late, but i have been outside of reception the past week and unable to communicate. Please can you consider my mail despite the late submission.

I refer to the proposed development at

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

In connection with the following references

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

My primary concern is that the roads. As they stand now they are barely able to handle the volume. Lower Main Road is congested daily from around 4 pm as people shortcut through to reach various major highways. I have had my car taken out, and i have seen two other stationary vehicles written off due to reckless driving on Lower Main road as there are no road markings, policing or even visible speed limit signs. To add a massive residential complex will compound this issue. And road makings and signage will not be enough. I am afraid to park my car outside my workplace along this road due the frustrated reckless drivers that pass through this route daily, and so i now park in the side roads instead, although this comes with another threat of break in.

There are already two blocks of flats going up along Lower Main Road and at some point the road will not be able to provide a safe route. I don't see room for expansion or the addition of lanes as there is simply nowhere to extend to.

Thank you for the space to speak.

Kind Regards

Kallie Doran 0844451670 Business Owner and resident in Observatory

Email is best.

-- Kallie Solo Goldsmith 084 445 1670 Kallie McLaren License : APO7609/1

------From: Carmichael Guesthouse To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 14:38:20 Importance: High

Dear Amy, My name is Yves Ducommun. Should you require to contact me, please do so by return of e-mail: [email protected] Re: Erf 151832, Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175), DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16, HWC Case No.: 15112504WD1217E, DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club, Cape Town 1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area. The buildings will completely change the local environment and will affect the experience and view from the national heritage site at the Observatory and surroundings areas. It will detract from existing walkability along the rivers and the potential for improved access and walkability is not attractive as the development is largely commercial and so busy in the day and empty at night. 2. My objection is based on the policy coherence because social housing needs to be included in all developments so this benefit is not a benefit that adds to this application in particular. 3. My objection is based on the flood risk and hydrology. I object to increasing the flood risk and reducing the ability of the river to adapt to climate change by adding several meters of concrete into the very soil sponge of a floodplain that currently absorb the increasingly risky weather events. This shifts the greater risk and uncertainty on ratepayers, residents and commuters in the whole catchment area of the Black and Liesbeek Rivers and tributaries. The proposed river ‘rehabilitation’ does not offset the loss of flood absorption capacity and sets a dangerous precedent for future development in floodplains, giving others the right to do the same, and further reducing our ability to adapt to extreme weather. If the city must densify, it should be outside the floodplain where it could get the same benefits without the uncertain amount of risk and reduction in our ability to adapt to climate change. 4. My objection is based on the heritage (pages 123 to 270) of the site of national and potentially international importance, and of particular value to the cultural practices and history of the Khoi. Commercial buildings of the proposed size and nature are not compatible with these practices and memory. There are presidents of Princess Vlei and Maiden’s Cover where the city has outweighed the broad general public benefits of the cultural and heritage value of a place over profits of development for a few. The social benefits of housing and jobs could be achieved elsewhere, and should be, at sites without such irreplaceable heritage value. 5. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial. 6. My objection is based on the flora and fauna (pages 18 to 83). The historical and cultural heritage of the site is intimately tied to the soil, flora and fauna as part of colonial historical conflict narrative, and the spiritual landscape and practices of the Khoi. The flora of the Cape Floristic Region are of international biodiversity heritage significance, hosting more than 6000 plants that are found nowhere else in the world. The site soil of TRUP currently has the potential to host three vulnerable and endangered vegetation types. Reducing the soils’ potential to recover in the future by adding concrete to it and making it more alkaline is not acceptable since the target preservation of all the three vegetation types, Western Leopard Toad and Morea aristata have not yet been met. Risking to lose this conservation potential is not worth taking since there are other less sensitive sites more suitable to such dense development. As the confluence of two rivers and the ultimate meeting point of several river tributaries, the rivers here are important for the movement of several avian, aquatic and mammal species throughout Cape Town. Such dense development is not compatible with the long term survival of these ecological functions. Sincerely / Yves 076 231 7752 11 Wolmunster Road 7700 Rosebank [email protected]

From: PB Melly To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 15:36:03

To Amy Hill SRK I would like to lodge my objection to the proposed development at the River Club on the following erven

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

The basis of my objection is that it is an important heritage site that should be preserved as public open space as part of the greater TRUP. Also there are important environmental concerns such as protection of the cape otter and leopard frog. There are also concerns about the flood plain. In regard to these issues please refer to the following a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

I live in Sybrand Park but am very concerned about the impact these developments are going to have on areas close by as a result of a domino effect.

Patrick Melly 082 822 5873 021 696 5854

Virus-free. www.avast.com From: jean.s.ramsay To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 16:00:12

Proposed River Club development

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

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

Dear SRK team,

I would like to strongly object to the proposed redevelopment of the river club. In this I do not believe I am alone, because despite attending all your meetings, I have yet to hear even one person, who is not being paid be the development team, agreeing that even one aspect of the plan is a good idea.

In your documents, although some of the objections have now at least been acknowledged, every one of them is seen to be of little relevance and can just be mitigated with some platitude. The First Nation People's concerns are just swept away as being irrelevant. The destruction of the Western Leopard toads' environment is 'mitigated' by creating a small area of 'ideal habitat'. How any toads will survive having their living area covered with meters of rubble is a mystery. I did read the bit about how they would be removed before that, but given that that job would presumably be assigned to the same people who care so little about the destruction of the last large green area near Cape Town, there is not much faith in that process. The otters are not even seen as worthy of a mitigation plan.

There is not even a mention in the environment study of global warming, of how green spaces in cities are important, how building in a flood plain is just not acceptable. All the comments are about how the flooding will be mitigated and how many centimetres higher it will or will not be. Many people attended one of the previous River Club meetings where the hydrologist admitted that his study had (an obviously unintentional) flaw and that the flow from the Liesbeek was completely incorrect. Has that study been redone? Either way, how anyone can even contemplate building in a floodplain and risking the nearby wetlands systems delicate balance - as admitted in the environmental study - beggars belief.

It is not as if there are no other nearby options available where development would be welcomed and appropriate. Anywhere in Ndabini and along Voortrekker road would be a highly viable option. Or SaltRiver or Woodstock. Just pick somewhere that is not in the floodplain, next to a wetland and a green area.

The effect on the South African Astronomical Observatory is also seem as irrelevant to the development plans. How building enormous structures, totally out of keeping with any surrounding development, can be deemed appropriate is mind boggling to anyone not making money from the development. The Observatory is in the process of being proclaimed as a UNESCO site. Yes, that is how relevant the rest of the world thinks it is. Maybe its historical views and sense of place might just be worth preserving?

In the proposal, the building of the SKA on part of the site is stated as if it is a done deal. It is not and has not been approved at any level at all. The building of the Berkley road is also stated as if it is a done deal. It has been opposed for years. How does building across a wetland suddenly become a done deal with no environment impact assessment?

The bottom line is, other than the developers, who have a financial incentive, and the city of Cape Town, who want new roads and infrastructure paid for by the developers, nobody else wants or needs this development. It is an utter disgrace building in a flood plain next to a wetland, removing our last green space near the city that will never be able to be replaced. And no, the couple of hectares that are not being actively covered in enormous slabs of concrete are not an equivalent to the lost green space.

Regards

Jean Buckley, Resident at SAAO, Member of the Western Leopard Toad Committee. I have no financial or business interest in this proposal Please acknowledge receipt of this objection via email, which is my preferred means of communication, at [email protected]

From: David Buckley To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 16:31:37 Attachments: HIA-comments-15Sep19.pdf

Dear Ms Hill,

Please find attached my objection to the proposal Riverclub development.

Your sincerely,

David Buckley. From: David Buckley To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 16:28:29 Attachments: HIA-comments-15Sep19.pdf

Dear Ms Hill,

Please find attached my objection to the proposal Riverclub development.

Your sincerely,

David Buckley. From: Flippers Swim School To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 17:07:17

Nikki Britz 083 747 9196 [email protected]

To whom it may concern Regarding the below reference numbers for the River Club development application, I join the growing group of concerned citizens. I am a small business owner in Observatory, and if this gets the go ahead my business, as well as many others, will suffer. Observatory will become undesirable – ugly, lack of parking, pollution during construction, increased crime, lack of space and fresh air. Not to mention that one of the last natural parks in our city will be destroyed. We are so lucky to have frogs and otters breeding in walking distance, and the abundant bird life. Our kids have been able to appreciate this as well as use the area for school projects etc. We will be just another overcrowded, overdeveloped city in the world. We have something special, we need to keep it. Stop the development Nikki Britz 0837479196 [email protected]

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

Nikki Britz 083 747 9196 [email protected]

Virus-free. www.avg.com From: pam britt To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 17:59:06 Importance: High

For att: Amy Hill

RE: STAKEHOLDER COMMENT PERIOD: PRE-APPLICATION BASIC ASSESSMENT REPORT FOR THE PROPOSED REDEVELOPMENT OF THE RIVER CLUB IN OBSERVATORY, CAPE TOWN

DEA&DP Reference Number: 16/3/3/6/7/2/A7/17/3104/16

HWC Case Number: 15112504WD1217E

DWS Reference Number: 16/2/7/G22/A/11 and WU9026 River Club

SRK Project Reference Number 478320

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

Project Title Basic Assessment Process for the Proposed Redevelopment of the River Club in Observatory, Cape Town

Name Pam Britt Contact Details 12 St Michael's Road, Observatory, 7925 Mobile 076 775 9419 Email [email protected] Preferred method of communication email Interest Resident of Observatory

Following publication of the reports comprising the River Club Redevelopment Pre- Application BAR and the call for stakeholder comment I submit the following in my personal capacity as a long standing private homeowner/resident in Observatory, having no other interest in the matter.

Contextual Comment

The entire proposal is framed and driven by financial feasibility (as defined by the developer) in the context of development on a flood plain. The developer has consistently maintained an "all or nothing" position:

... The developer has investigated reasonable (mixed -use) development alternatives identified by stakeholders and has assessed these to be not financially viable. The developer has further calculated that the floor area currently proposed is the minimum required to ensure financial feasibility.... (page 6, Appendix K).

This rigidity imposes design and other constraints on development, resulting in a Century City-like built environment that is completely out of scale and harmony with its location. As such, I wholly reject the proposed development - it does not belong in TRUP; not today, not tomorrow, not ever.

In this context there are:

Design, Planning and Policy Issues

There is nothing in the surrounding area that comes any where near the scale and density of the proposed development, and it will be in complete contrast to the small scale Victorian character typical of Observatory's domestic housing fabric. This proposal speaks not to people, place, history, heritage or the future of the city, but to the imperative of making development on a flood plain pay.

The design aesthetic is monolithic, monotonous, out of scale with everything in the surrounding area - and particularly, the SAAO, which has heritage status - and uninteresting; row upon row of tall or taller buildings squeezed into the space, one version or another.

The scale of impacts (pages 5-6. Table 2: Summary of Impacts, Appendix K) places greater emphasis on economic growth than it does on place, visuals, gentrification, historical character, heritage, biodiversity and other factors. Yet it is clear from the visuals (Appendix G6 Visual IA, pages 51,52,53,56,57] that this development would have massive impacts on those aspects in perpetuity. Such changes would be irreversible; economic growth, by contrast, cannot be predicated with equal certainty, especially in current economic conditions.

Housing forms only 20% of the development and is therefore not the engine for the development. Does the City really need another mega development tipping the scale towards retail/commerce proximate to at least three other similarly commercial enterprises - Century City (which is only marginally larger in floor space than the proposal) Northgate and the V&A Waterfront? Does the City not need more rather than less green spaces that balance the onrush of urbanisation, pollution and climate change?

Affordable housing constitutes 4% of the overall development. This aligns with the City's policy of including affordable housing in all new developments of this kind and therefore it should have no bearing on the merit of the application.

Environmental and Heritage Issues

Infilling can only mitigate potential flooding of the Liesbeeck River, not prevent it. If the Liesbeeck River comes down in flood the water will have to go somewhere, infill or not. A possibility that climate change will impact flooding in ways as yet unknown cannot be discounted.

The heritage of the area is well recognised and worthy of protection. Committing to a monument to heritage, such as a museum or cultural centre, within the development, will do little to restore the loss of sense of place and history that the area is steeped in.

The TRUP is an asset to the City and is accessible to anyone. It is an harmonious environment that brings together earth, water and sky in a long, open vista from one end to the other Looking from south to north the tallest structure is the River Club, which is low rise and fronted by gables that give it character and charm. Looking from north to south nothing there are no dominating structures that obstruct the views along the river paths. This harmony and gentleness would be disturbed and lost if it abutted a mega development such as proposed.

The River Club building itself is considered of low heritage value by the developer yet it is in keeping with the other old buildings dotted around the area, notably at the SAAO, Valkenberg, the Courtyard Hotel and The Wild Fig. A large part of what makes this area unique is the presence of these old buildings and their human scale. None of this finds any kind of echo in the proposal; it fails to acknowledge the environment in a human way.

The area is host to threatened species of flora (Moreae Aristata) and fauna (The Western Leopard Toad. the Cape Clawless Otter) and is rich in bird and aquatic life. Prolonged construction work and other disturbances are likely to have a negative impact on all the creatures that visit TRUP and worst case would be some mishap that causes loss of irreplaceable species.

Zoning Issues

If approved - which would require the City to negotiate the lease or purchase of land it owns within the TRUP with the developer - this development would effectively privatise what is currently public open space.

Under the current local spatial development plan this development is not permitted. A deviation may be applied for that requires cogent motivation. The developer has not provided such motivation.

Please confirm receipt of this email.

Sincerely Pam Britt

12 St Michael's Road Observatory 7925 From: Duncan Moore To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 18:42:18

Dear Amy Hill

My name is Duncan Moore, I live at 7 Crown Street, Observatory, Cape Town and have lived here for 22 years. Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: I have no personal, business, financial or other interest in the application.

The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application- bar.It As resident in the near vicinity of this development I object to the following: Traffic and congestion, already a daily occurrence at the intersection of Station Road and Liesbeek Park Way would be further heightened, whether the entrance to this development be made further up Liesbeek PKW or at the Station road intersection.

The zoning of this land is currently open space for good reason, it is below the flood plain, and it is on a wetland.

Environmental Impact: The carefully planned Two Rivers Urban Park (TRUP) plan for the area took this into consideration, this proposal seeks to use landfill to get the buildings above the floodplain, the effects of which would negatively affect the neighbouring wetlands. Pollution during the course the development would almost certainly negatively affect the wetland.

Once this area is destroyed it can never be undone.

Please note my strong objections to this development, any development on the Riverclub land should be in line with the TRUP planning.

Regards Duncan Moore From: Jane English To: [email protected]; Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 18:49:06 Attachments: LETTER OF OBJECTION CONCERNING River Club Redevelopment PreApplication.PJEnglish.pdf

Please find my objection attached.

A/Professor Jane English Head: Professional Communication Studies University of Cape Town

Disclaimer - University of Cape Town This email is subject to UCT policies and email disclaimer published on our website at http://www.uct.ac.za/main/email-disclaimer or obtainable from +27 21 650 9111. If this email is not related to the business of UCT, it is sent by the sender in an individual capacity. Please report security incidents or abuse via https://csirt.uct.ac.za/page/report-an-incident.php. From: Martin Power To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 18:53:53

Hello,

My name is Martin Power and I have local resident of Cape Town and a citizen of South Africa. I can be contacted via email using the address [email protected]

Business Interest As an flat owner in the nearby ObsCourt (UNIT 404, OBSCOURT - CCT014500100122), the proposed development and construction will obstruct the north facing view from the flat, tarnishing the existing aesthetic and the unobstructed views towards Tygerberg Hill. This would directly impact the value of my property going forward (please see supporting image attached). Furthermore, the impact of the traffic and unsightly road development in the area will add strain to the already congested road network and also affect the desirability of the unit.

The current zoning of the park disallows any major residential and commercial development and this considered when purchasing the flat in 2018. I formally object to the proposed development as this will negatively impact my investment.

Personal and Public Interest The proposed development plan does not take into account the significant impact that would be caused by such a large development on the supporting wildlife and already strained river system. The current wetland and surrounds are a critical part of a highly important river system and should be preserved as it currently serves and supports the Liesbeeck River and its wildlife.

After studying the report by SRK I believe that in addition to developing upon the wetland itself, the filling in the current Liesbeeck River would be disastrous as it would destroy the wildlife and natural beauty of the area that has, until now, existed for thousands of years. This is unacceptable.

Additionally, the negative impact on tourism and desirability of the area will be undeniable and change the character of this unique and special part of the world forever. It is the publics best interest to protect as much of what little natural environment remains in our urban cities, so we can all enjoy our natural environment (its most valuable resource), now and in the future.

Kind Regards, Martin Power

I reference the documents found this web page (https://www.srk.co.za/en/za-river-club- redevelopment-pre-application-bar) and reference the properties and relevant departments/project/case numbers below.

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

Refer to the following reference numbers: DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 HWC Case No.: 15112504WD1217E DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club From: Mellissa le Fèvre To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 19:12:59 Attachments: River Club Redevelopment Pre-Application BAR.pdf

Dear Amy Hill

Please find attached my letter of objection to the LLPT’s application to develop the River Club site.

Kind regards

Dr Mellissa le Fevre From: Carolyn Neville To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 19:24:56

Dear Ms Hill

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

I wish to object to the proposed development of the above area in Observatory on the following grounds:

1. I am a local resident in Observatory and value and enjoy walking in the open spaces in my neighbourhood - namely the Liesbeek river area. There are precious few open spaces available in the Cape Town area, and it seems inconceivable that such a development would take place, thereby robbing the city of Cape Town from its ‘lungs’.

In addition, the current zoning for this area is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. The River Club owners bought this land with the existing zoning, and so therefore, they have no entitlement to development rights - unless they were promised that this would be ‘arranged’ during the time of their purchase. If this were to be the case, I would suggest a case of corruption should be investigated.

2. There is plenty of undeveloped, well-located land outside the TRUP, where development could take place. The area DOES NOT NEED another shopping complex, more upmarket apartments for ’swallow’ foreigners and more offices that will cause an increase in traffic (which is already at untenable proportions during rush hour periods), increased strain on infrastructure and a loss of such precious open spaces.

3. The proposed development is in a flood plain - why would the authorities allow interference with a flood plain and agree to development in this area - at huge cost? This is possibly the reason why the bulk proposed is so dense - to pay for interfering with Mother nature, taming the environment to pay for human greed.

I find this application abhorrent, and remain deeply suspicious of the sale of the PRASA land to private individuals at a non-market related cost in the first place. I believe there is corruption of some form involved in this affair.

Please acknowledge receipt of this objection by using my email address: [email protected]

Regards Carolyn Neville From: Rol Hunter To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:03:09

My full name is: Roland Hunter Address:10 Norwich Avenue, Observatory Please contact me via email: [email protected] My phone number is: 072 437 0921 DATE: 15 September 2019 ATT: Ms Amy Hill, SRK Consulting LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre-Application BAR This letter of objection is in respective of the following erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) I refer too to the following reference codes for your convenience to action:

a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club I , unequivocally and without influence, other than my own sovereign conscience, disregard and reject the above-mentioned planned development on the following grounds; I do not have any business interests which could influence my personal feeling with regards to the proposed development that I am objecting against. My reasons for this objection are stated below: DESIGN The size/scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO (South African Astronomical Observatory) have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which has National Heritage Site status. The height and density of the buildings are grotesque. They are laid out without environmental concern or urban integration development imagination (taking into account the environmental/urban design that architects have access to globally) and rather resemble an army barracks or Lego towers. LAND USE ISSUE The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current local spatial development plan does not allow for this development. While deviations may be applied for, there must be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City must permit the developers to lease or purchase portions of land owned by the City. 11 (eleven) portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. POLICY COHERENCE The contribution to affordable housing is only 4% of the development, in total. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. HYDROLOGY AND FLOODING Flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for runoff of the floor waters. Where will this water go now? HERITAGE ISSUES The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledged to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. They have done so because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

Thank you,

I sign by my email, sent to you via this objection from, which is attached to this document. Should you have any further requirement of my identity you are required to contact me via email at the above-mentioned address to request further proof of my identity as a citizen. This includes your requirement of my signature to this document prior to Monday 16 September 2019.

Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

Roland Hunter

From: Paul J Light To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:03:56

Dear Amy Hill

My name is Paul Light, I live at 13 Lower Collingwood Road, Observatory, Cape Town and have lived in Observatory, for 3 years.

Email: [email protected] My preferred method of communication is email

This email is with regard to the following:

Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3 This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 13 Lower Collingwood Road,

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

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

Further issues that I wish to raise include:

3. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers.

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

6. FLOODING Have you forgotten the flooding of 5 August 2004? Do you remember that Barloworld sued the River Club for 2 million rands after 15 of its vehicles were damaged in the flooding. There have been many more recent example. Who can I sue when my house is flooded? Or when I cannot get access to my house because there is only one entry into lower Observatory via Ossian Road? When Ossian Road is flooded, how will we get into Lower Observatory? Who is liable for damage in this case? The developers? The City? Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain. We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now?

7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations – Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here?

9. COST According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. I agree with this. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent. Cape Town already has a bad reputation for being in the pockets of the developers. Bo-Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding. It is not too late.

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

Regards,

PJ Light [email protected] From: Steiner, Tina, Prof [[email protected]] To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:17:38 Importance: High

Observatory, 15 September 2019

Robert and Tina Steiner

6 Oxford Road, Observatory, 7925

Sent via E-MAIL TO Amy Hill of SRK

Re: Objection to Proposed River Club Development

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

Reference numbers:

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

Dear Ms Hill,

As longstanding residents of Observatory, we would like to lodge our strong objection to this proposed development for the following reasons:

1. Design:

The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed. The height and density of the buildings are grotesque. They are laid out without imagination and resemble army barracks or lego towers. The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities.

2. Land Use

The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. The current local spatial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose.

3. Policy

The contribution to affordable housing is only 4% of the development as a whole. This is such an insignificant percentage that it is clearly disingenuous.

4. Hydrology and flooding

Flooding will be more frequent.

5. Heritage Issues

The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the rivers. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence.

In 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage.

6. Flora and Fauna

The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.” A rare plant species Moraea aristate, occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction (on the SANBI website at http://pza.sanbi.org/moraea-aristata). As far as we can tell, the specialist reports make no mention of this plant. Clearly the rivers themselves, as well as the significant birdlife will be affected, too.

We sincerely hope that this development will not be given the go-ahead as it is clearly not in keeping with the social and natural needs of the area but presents a profit-making venture of the most unimaginative kind.

Sincerely,

Robert and Tina Steiner

***

Associate Prof Tina Steiner, PhD English Department Stellenbosch University Private Bag X1 7602 Matieland, South Africa

+27 21 8083653 (w) +27 72 1595120 (c)

Editor: Eastern African Literary and Cultural Studies

http://www0.sun.ac.za/english/staff/prof-tina-steiner/ https://sun.academia.edu/TinaSteiner

The integrity and confidentiality of this email are governed by these terms. Disclaimer Die integriteit en vertroulikheid van hierdie e-pos word deur die volgende bepalings bereël. Vrywaringsklousule From: Jakob To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Tuesday, 17 September 2019 09:48:35

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

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

Jakob Slabbert [email protected] +2783232588 (Contact through email only) From: Sarah Bassett To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:25:27

My full name is: Alison Sarah Bassett Address:10 Norwich Avenue, Observatory Please contact me via email: [email protected] My phone number is: 0766852230

DATE: 15 September 2019 ATT: Ms Amy Hill, SRK Consulting LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre-Application BAR This letter of objection is in respective of the following erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175) I refer too to the following reference codes for your convenience to action:

a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16 b) HWC Case No.: 15112504WD1217E c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club I unequivocally and without influence disregard and reject the above-mentioned planned development on the following grounds; I do not have any business interests which could influence my personal feeling with regards to the proposed development that I am objecting against. My reasons for this objection are stated below: DESIGN The size/scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO (South African Astronomical Observatory) have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which has National Heritage Site status. The height and density of the buildings are grotesque. They are laid out without environmental concern or urban integration development imagination (taking into account the environmental/urban design that architects have access to globally) and rather resemble an army barracks or Lego towers. LAND USE ISSUE The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current local spatial development plan does not allow for this development. While deviations may be applied for, there must be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City must permit the developers to lease or purchase portions of land owned by the City. 11 (eleven) portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. POLICY COHERENCE The contribution to affordable housing is only 4% of the development, in total. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. HYDROLOGY AND FLOODING Flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for runoff of the floor waters. Where will this water go now? HERITAGE ISSUES The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledged to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. They have done so because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

Thank you,

Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

Sarah Bassett

T: 076 685 2230 From: Tamryn Mac Nair To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:29:11

Dear Amy Hill

My name is Tamryn Mac Nair,

Address: I live at 6 Lynton Road, Observatory, Cape Town and have lived here in the Hartleyvale area of Observatory, for 1 year. Email: [email protected] My preferred method of communication is: email

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

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

It is not too late.

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

Regards

Tamryn Mac Nair 6 Lynton Road Observatory Student at UCT From: mikekau1 . To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:29:27

To: [email protected] Cc: [email protected] Title: River Club Redevelopment Pre-Application BAR Dear Amy Hill My name is Mike Kaufmann

Email: [email protected] My preferred method of communication is: email

This email is with regard to the following: Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3 This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club Increased Traffic in an already congested city and a suburb with tiny roads. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of exercise as a user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler. The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It I believe that the scale of the River Club development means that the entire populace of Cape Town is entitled to comment. I believe that all entities are entitled to object. This proposal impacts thousands of people and intangible heritage that belongs to all South Africans. The Khoi heritage is one that I support and uphold, same for the environmental heritage of the rivers, flood plain, endangered species of plant and wildlife that is ours to protect. In this regard, no comment is irrelevant. Once this area is destroyed it can never be undone. TRUP is also a land parcel where the entire City is considered stakeholders. The Kyoto Protocol sets internationally binding emission reduction targets which was adopted in December 1997 and acceded to by South Africa in July 2002. The Protocol recognises that developed countries are principally responsible for greenhouse gas emissions as a consequence of decades of industrial activity. South Africa needs to adopt further ambitious actions by 2050. Developing a wetland is the worst thing that you can do. Further issues that wish to raise include: 1.FLORA Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 make no mention of this plant! 2. FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park. 3. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers. 4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. 5. POLICY I don't believe that playing the affortable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. 6. FLOODING Have you forgotten the flooding of 5 August 2004? Do you remember that Barloworld sued the River Club for 2 million rands after 15 of its vehicles were damaged in the flooding. There have been many more recent example.

We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now? 7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations –Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here?

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

Cape Town already has a bad reputation for being in the pockets of the developers. Bo-Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding. It is not too late. Please note my strong objections to this development and desire to protect this area. Regards Mike Kaufmann From: Keith Barker To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:37:39

Dear Amy,

My interest in the River Club is purely that of a citizen of Cape Town who lives in the Mowbray area. I do not have any personal, business or financial interest in the application to develop.

1. My objection is based on the flood risk. The River Club area is a flood plain and I personally can recall the place being under water. The soil and vegetation is there to act as a soak away. Concrete buildings and paved surfaces will deflect the flood waters away doing unforeseen damage at another location. This will effectively shift the risk onto the city or other land owners.

2. My objection is based on sea level rise. The River Club area historically was an estuary. We know at king tides the water backs up into this area. The predictions of further sea level rising with climate change is of concern to the city. It is highly likely that a major development in the River Club area will experience flooding during its lifetime, with increasing regularity in the decades to come. Major new development at near sea level is ill advised due to the elevated risk to property owners buying into such a development.

3. My objection is based on the Khoi heritage site. Disrespecting the culture and history of the Khoi by radically altering the area with concrete office buildings and hard surfaces, comes at a tremendous cost to our community and risks alienating the descendants further.

4. My objection is based on the soft cost to the city and its inhabitants. Developments such as these in a sensitive wetlands with rare flora, radically changes the feel of the area. The quick profit to the developer and additional rates to the city does not offset the social, environmental and social-economic benefits that a healthy wetlands offer. Building office parks in a flood plain for its aesthetics value sets a bad precedent for future development in other prime locations of natural beauty. There are less sensitive areas ripe for development.

5. Adding a social housing quota to this development proposal is not an attractive benefit. It is a poor location given how inaccessible it is to public transport hubs and the risk of flooding.

I can be contacted by email.

Regards

Keith Barker From: Barbara Dupuy To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 20:42:14

Dear Amy, My name is Barbara Dupuy and I prefer to be contacted by email ([email protected]).

1. My objection is based on the policy coherence because I strongly believe social housing needs to be included in all developments in this city going forward. This benefit is therefore not a benefit that adds to this application in particular.

2. My objection is further based on the heritage (pages 123 to 270) of the site of national and potentially international importance, and of particular value to the cultural practices and history of the Khoi. Commercial buildings of the proposed size and nature are not compatible with these practices and memory. There are presidents of Princess Vlei and Maiden’s Cover where the city has outweighed the broad general public benefits of the cultural and heritage value of a place over profits of development for a few. The social benefits of housing and jobs could be achieved elsewhere, and should be, at sites without such irreplaceable heritage value. The museum mentioned in the application is vaguely described, with no clear, valued commitment from the developers.

3. My objection is also based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area. The buildings will completely change the local environment and will affect the experience and view from the national heritage site at the Observatory and surroundings areas. It will detract from existing walkability along the rivers and the potential for improved access and walkability is not attractive as the development is largely commercial and so busy in the day and empty at night.

4. My objection is then based on the flood risk and hydrology. I object to increasing the flood risk and reducing the ability of the river to adapt to climate change by adding several meters of concrete into the very soil sponge of a floodplain that currently absorb the increasingly risky weather events. This shifts the greater risk and uncertainty on ratepayers, residents and commuters in the whole catchment area of the Black and Liesbeek Rivers and tributaries. The proposed river ‘rehabilitation’ does not offset the loss of flood absorption capacity and sets a dangerous precedent for future development in floodplains, giving others the right to do the same, and further reducing our ability to adapt to extreme weather. If the city must densify, it should be outside the floodplain where it could get the same benefits without the uncertain amount of risk and reduction in our ability to adapt to climate change. 5. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial.

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

Sincerely

Barbara Dupuy 076 900 8076 Unit 1, Long Street, Mowbray 7700 [email protected] From: Nicole Rasmussen To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 21:02:28

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

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

Objection to the re-developement of the River Club Observatory.

Design Issues

The scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed. (see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are grotesque. They are laid out without imagination and resemble an army barracks or lego towers. The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. Land Use issue The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current local spatial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. Policy coherence

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

Flooding will be more frequent The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now? Heritage Issues The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations – Maiden’s Cove, Princessvlei are examples. Why should theCcity not take that position here? Cost and Feasibility The reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1)(b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent. Flora and Fauna The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.”

Context for the current BAR process For the River Club development to get the go-ahead, there are many processes involved. You may feel you have done this before but don’t get confused and, most certainly, don’t sit back and do nothing! Here is a brief overview and timeline: The River Club initiated an application for development at the River Club in 2016. Under the National Environmental Management Act (NEMA), an environmental impact assessment was required. The Provincial Department of Environmental Affairs and Development Planning (DEADP) will decide whether to approve the development or not as an outcome of the EIA. In 2016: First Draft Scoping Report released for comment. Many Obs residents attend the somewhat unsatisfactory presentation at the River Club by the consultants. Many comments and objections are made. A Revised Scoping Report, which should have taken account of the many comments from Interested and Affected Parties (I&APs), is released for comment in Jan 2017. Many comments and objections are made. As part of the NEMA process, the developers have to conduct a Heritage Impact Assessment. This HIA is first presented for comment to the OCA in Feb 2018. Many comments are made. A revised HIA is produced in April 2019 and released for public comment. For most I&APs, the revised HIA fails to take heritage matters into any substantive account. Many comments are made. The HIA is then submitted to Heritage Western Cape (HWC) for their comments in August 2019. HWC will send their comments to the DEADP for inclusion in the decision-making process. Bear in mind that if HWC turn down the HIA, the DEADP can still decide to support the development. In parallel to the NEMA process are two other processes: Heritage: Because of the high heritage value of the site, HWC decide in Feb 2018 to issue a provisional protection order for the River Club site which would prevent any development without explicit permission of HWC. They do so on the basis that initial heritage studies suggest substantial heritage resources at the site and therefore further assessment of the site is necessary to decide on a heritage grading. The provisional protection order is gazetted in April 2018. The order is appealed by the developers, the City of Cape Town, the DEADP and the Department of Public Works and Transport. A Ministerial Appeal Tribunal considers the appeals through a series of sittings and a site visit between October and December 2018. Both the appellants and other I&APs are able to make submissions to the Tribunal. The Tribunal’s directive is issued in Feb 2019 and directs the parties to engage with each other, and for HWC to provide an opportunity for the appellants to have their appeals heard, and to return to the Tribunal if no agreement is reached. In May 2019, HWC reconsiders the matter of the protection order and reaffirms the need for the protection order is still valid. The matter must now return to the Tribunal for decision. A date is still awaited. Zoning (City of Cape Town process): While the Appeal Tribunal is underway (Sept 2018), the applicants approach the City to have the site rezoned to permit the development. The rezoning is advertised for public comment and many objections are made. The City indicates to the OCA in June 2019 that the applicants have suspended their application for rezoning while the Heritage appeal and the Basic Assessment process are under way.

Kind Regards,

Nicole Rasmussen

1 Arnold St, Observatory, Cape Town 082 469 7259 / 021 448 2297 [email protected] (please communicate via email) From: Maura Talbot To: Amy Hill Cc: [email protected]; Kris Marais Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 21:07:46

Dear Amy Hill With regard to the above mentioned pre-application BAR (reference numbers: a) DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16, b) HWC Case No.:15112504WD1217E, and c) DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club) on the following properties in the Observatory area: Cite the Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175. My partner (Kris Marais) and I, as residents of observatory wish to lodge our strong objection and grave concern about the proposed intensive urban development on the river club site. We have a number of concerns, namely:

1. the development is being proposed on one of the few remaining wetland areas within the city, and one of the last places where the endangered leapard toad still clings to life, 2. it is proposed to be located in a high flood risk area, and an important a storm water attenuation area, 3. it is proposed on an important first people's heritage site. 4. it is also highly likely to significantly increase the already challenging traffic congestion situation in this area which is adjacent to the confluence of the M5, N2 and M3 highways. Here we are referring to the traffic congestion on the highways and in Observatory. 5. The construction of so many large concrete buildings will require the use of large volumes of water which is in short supply 6. The development will either enable the further growth of population and increase demand for scarce water resources and increase the strain on already stretched sanitation and waste disposal capacity in the city) or it will undermine the economic viability of existing developments elsewhere in the city.

We trust these concerns will be recorded and taken into consideration in the assessment of these applications and the decision making around whether to allow such a development to be approved. Please include us on your list of interested and affected parties for this project and keep us informed of the process. Regards Maura and Kris 14 Howe Street, Observatory, Cape Town.

Maura Talbot [email protected] SA Mobile:+27 (0)72 386 0537; SA Home: +27 (0)21 448 9440 Skype: maura.talbot2 From: Anthony Kaufmann To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 21:18:19

To: [email protected]

Cc: [email protected]

Dear Amy Hill

My name is Anthony kaufmann

Email: [email protected]

My preferred method of communication is: email

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

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

· Flooding.

· Pollution during the course the development and additional pollution due to increased traffic.

· Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area.

· Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road.

· The deprivation of exercise as a user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC)

· High Heritage value of the site in terms of the history of the Khoi

· High Heritage value in terms of the first parcel of free-settled farms.

· The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area.

· Flora and fauna and the destruction of the breeding areas of endangered species.

· Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

I believe that the scale of the River Club development means that the entire populace of Cape Town is entitled to comment. I believe that all entities are entitled to object.

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

1.FLORA

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

2. FAUNA

3. DESIGN ISSUES:

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

4. LAND-USE ISSUE

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

5. POLICY

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

6. FLOODING

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

7. KHOI HERITAGE

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

8. EUROPEAN HERITAGE

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

9. COST

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

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

It is not too late.

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

Regards

Anthony E. Kaufmann @ Ease Properties www.easeproperties.co.za e: [email protected] m: 072 02 66 210 t: 08 77 028 727 cid:[email protected] In association with Magner Property Group This e-mail and any attachments are confidential. If this e-mail is not intended for you, please delete it and its attachments and notify the sender immediately. If you are not the intended recipient, you may not use, disclose, distribute and/or copy this e-mail or its attachments. The sender accepts no responsibility whatever for any viruses or other damaging or corrupting material which may accompany, be contained in and/or transmitted with this e-mail and/or any of its attachments. The opening of this e-mail or its attachments is done entirely at your own risk. This disclaimer is deemed to form part of this message under Section 11 of the Electronic Communications and Transactions Act, No. 25 of 2002. https://www.privyseal.com/ From: Katie Huston To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 21:27:08 Attachments: Letter of Objection River Club Development KHuston.docx

Hello,

Please find my letter of objection to the River Club development proposal.

Sincerely

Katie Huston mobile: +27 (0)735 071 464 From: Louisa Williamson To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 21:41:04 Attachments: L Williamson_TRUP Objection_14 September 2019.docx

Dear Amy, My name is Louisa Williamson and I prefer to be contacted by email. Attached find my objection to the TRUP development.

Regards Louisa Williamson 10 Thicket Road Mowbray, Cape Town

From: Carol Cragg To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 21:43:12 Attachments: River Club submissions Sept 2019.docx

Dear Ms Hill Please find my submission re the River Club Redevelopment Pre-application attached.

Regards C Cragg From: Caro De Waal To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 22:06:13 Attachments: Caro_signature.png

My full name is: _Caro Jesse______

Address: 46 Arnold Street, Obseervatory, 7925______

Please contact me via email: [email protected]______

My phone number is:_0726588801______

DATE:_September 15th 2019______

ATT: Ms Amy Hill, SRK Consulting

LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre- Application BAR

I refer too to the following reference codes for your convenience to action:

a) DEA&DP Ref. No.: 16/3/3/6/7/2/A7/17/3104/16

b) HWC Case No.: 15112504WD1217E

c) DWS Ref. No.: 16/2/7/G22/A/11 and WU9026 River Club

My reasons for this objection are stated below:

DESIGN

LAND USE ISSUE The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space.

Undeveloped, well-located land exists outside of the park, where development could take place.

The River Club owners have no entitlement to development rights. They bought the land with the existing zoning.

POLICY COHERENCE

HYDROLOGY AND FLOODING

Flooding will be more frequent.

The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant.

We know that Climate Change will bring increasing likelihood of extreme weather events.

HERITAGE ISSUES

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

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

COST AND FEASABILITY OF PROPOSED DEVELOPMENT

Moreover, the notion that a net first year return under 9% is unacceptable is questionable - there are many investors who would look at 7-8% investments if the quality is good enough.

FLORA AND FAUNA

If you are a flora and fauna enthusiast/expert, look up the reports on BAR website at

https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar (see Appendix G2 in two parts) and see if you can muster specific arguments.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

Thank you,

Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

From: Mark Abrahams To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 22:08:28

Dear Amy Hill My name is Dr Mark Abrahams Email: [email protected] My preferred method of communication is: email This email is with regard to the following: Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3 This objection is in relation to: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club Increased Traffic in an already congested city and a suburb with tiny roads. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of exercise as a user of the Two River Urban Park and Malta park (which has already been unofficially privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler. The objection that I am lodging is in relation to: The Basic Assessment Report is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It I believe that the scale of the River Club development means that the entire populace of Cape Town is entitled to comment. I believe that all entities are entitled to object. This proposal impacts thousands of people and intangible heritage that belongs to all South Africans. The Khoi heritage is one that I support and uphold, same for the environmental heritage of the rivers, flood plain, endangered species of plant and wildlife that is ours to protect. In this regard, no comment is irrelevant. Once this area is destroyed it can never be undone. TRUP is also a land parcel where the entire City is considered stakeholders. The Kyoto Protocol sets internationally binding emission reduction targets which was adopted in December 1997 and acceded to by South Africa in July 2002. The Protocol recognises that developed countries are principally responsible for greenhouse gas emissions as a consequence of decades of industrial activity. South Africa needs to adopt further ambitious actions by 2050. Developing a wetland is the worst thing that you can do. Further issues that wish to raise include: 1.FLORA Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 make no mention of this plant! 2. FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park. 3. DESIGN ISSUES: The sparsity of housing in the development (only 20%) means that it will not be a comfortable space to live. One will have to transact one’s social life in and around deserted office buildings at night. There are few social amenities, no pre-schools, no creche, etc. I disagree with the development in that the density and scale of the proposed development is completely out of scale with the surrounding area. It is not appropriate to the existing zoning either. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The visual impacts on people and travellers around the site will be enormous given the size and density of the development proposed.(see the images taken from Appendix G6 pages 51 to 57). Many of the proposed benefits (e.g. better walkability, public access) could be achieved by a different kind of development. The height and density of the buildings are ugly. No imagination. They are laid out without imagination and resemble an army barracks or lego towers. 4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spacial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. 5. POLICY I don't believe that playing the affortable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. 6. FLOODING Have you forgotten the flooding of 5 August 2004? Do you remember that Barloworld sued the River Club for 2 million rands after 15 of its vehicles were damaged in the flooding. There have been many more recent example. Derek Hanekom, Tourism minister, said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Parish Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. We cannot keep our cities cooler, we cannot mitigate the effect of global temperature increases if we continue to develop wetlands. Especially this wetland which is bordered by two rivers and is a floodplain. We all know that flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land continuing to act as a receiving site for run off of the floor waters. Where will this water go now? 7. KHOI HERITAGE The Khoi heritage has already suffered the indignity of being ignored and forgotten in post Apartheid South Africa. This is such an important site for them. A burial ground and the site of the first resistance to European influence. Do you really think that a little memorial surrounded by enormous tall buildings is appropriate? What an insult. People of the land memorialised and surrounded by concrete? This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site. Similarly, the Berkley Road extension will pass close by that confluence. It will be acknowledge to be noisy as a result and what is not stated, likely to generate litter and pollution. This will be visited not on the residents of the 50m apartment buildings but on the museum or cultural centre below, and on any visitors or community members performing any outdoor rituals. Heritage WC have signalled their intent to investigate the heritage grading of the site based on preliminary heritage assessments for the wider TRUP. The have done do because of the significant intangible heritage value that has been confirmed for the site. The commitment to establishing a museum or cultural centre appears to be an afterthought. There is no height attributed to this building (unlike the profit generating apartments and offices) and employment in this centre is not mentioned under potential benefits. It appears that this offer is a token to placate first nation groups outraged at how they are being again genocided in the name of private profits. There are moves to declare the TRUP area a UNESCO heritage site and the Department of in 2013, DCAS earmarked the area between the Black and Liesbeek Rivers as a possible National Resistance and Liberation Heritage Route (NHLHR). This was supported by cabinet and spearheaded by Dept of Arts and Culture and in conjunction with National Heritage Council. It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage. There are precedents where the City has recognised that cultural and heritage importance outweighs financial motivations –Maiden’s Cove, Princess vlei are examples. Why should the city not take that position here? 8. EUROPEAN HERITAGE The first free burger settlements in South Africa are right on the other side of the Liesbeeck. (this includes Valkenberg Farm on the affected side) This is where I live and will be affected by the flooding. Coornhoop, Westoe, Raapenberg, Bellvliet, Molenvliet, and the heritage nature of the largely Victorian and Edwardian houses that surrounds these farms reflects the wide diversity of history that results in our country. Coornhoop was the site of key negotiations at the end of Apartheid and this area. Coornhoop makes an important contribution to the local character and identity and was proclaimed a national monument in 1966. Finally, the Observatory itself is a key historic landmark. 9. COST According to the OCA, the reason the development is so dense is because the site lies in a floodplain, resulting in the construction of any development requiring massive infill, which escalates the cost. Because the developers want a 9% return on their investment, they have to build so densely. If they accepted a small but still substantial profit margin, they could build a less dense development. The valuation and estimation of first year profits does not take account of the land price that was paid at the time of purchase which was considerably lower than market value and considerably lower than what they have used in this estimate. Had they had included the actual price paid then their initial yields would have increased significantly. I agree with this. The assumption that feasibility is simply economic feasibility is not correct. Under Section 240(1) (b)(iv) of the National Environmental Management Amendment Act, alternatives must be reasonable and feasible. However, feasibility is not just determined by financial returns. Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced –including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable -there are many investors who would look at 7-8% investments if the quality is good enough. The valuation which forms the basis of the River Club’s claim that only Alternatives 1 and 2 are ‘feasible’ was authored by a valuator who has a major conflict of interest since she is employed predominantly by Investec who are the financiers of the project. She can hardly be independent. Cape Town already has a bad reputation for being in the pockets of the developers. Bo-Kaap is a classic example. We have had enough of corruption, rampant consumerism and profiteering at the expense of the people who pay their taxes and are law-abiding. It is not too late. Please note my strong objections to this development and desire to protect this area. Regards Dr Mark Abrahams From: Alison Roomaney To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 22:29:57 Attachments: LETTER OF OBJECTION CONCERNING River Club Redevelopment PreApplication BAR.docx

To whom it may concern

Please find my letter of objection attached.

Best Regards, Alison Roomaney From: Charmaine Smith To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 23:10:22 Attachments: RC-Redev-Pre-Application_BAR-C.Smith.pdf

Dear Amy

Please find attached my input on the above redevelopment.

Yours sincerely,

Charmaine Smith From: kayley smith To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Sunday, 15 September 2019 23:43:37 Attachments: My_Letter_of_Objection_River_Club_Development.pdf

Dear Amy

Please find attached my objection to the River Club development.

Please contact me via email should you have any questions.

Kind regards Kayley

------Forwarded message ------From: Kayley Smith Date: Sun, 15 Sep 2019, 11:39 PM Subject: My_Letter_of_Objection_River_Club_Development.pdf - signed with DocuSign To: kayley smith

Securely signed with DocuSign®. From: John Lanham To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Tuesday, 17 September 2019 09:41:20

Dear Amy,

My name is John Lanham and I prefer to be contacted by email: [email protected]

I was forwarded a template to use in my letter of objection. I had planned to write my own objection based on my own thoughts and reactions to the proposed development. However I find myself in complete agreement with the points laid out in the template. I have simply edited and added where I thought it necessary.

1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area. Let's stop this wanton uglification of our city. The area is in the view of thousands of Capetonians every working day. The measure of calm and pleasure it brings, while not quantifiable, is tangible and priceless.

2. My objection is based on policy coherence, because social housing needs to be included in all developments, and this benefit is not added to this application in particular.

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

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

5. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial.

Sincerely

John Lanham 3 Cross Road Rosebank 7700 021 689 9258 [email protected]

Disclaimer - University of Cape Town This email is subject to UCT policies and email disclaimer published on our website at http://www.uct.ac.za/main/email-disclaimer or obtainable from +27 21 650 9111. If this email is not related to the business of UCT, it is sent by the sender in an individual capacity. Please report security incidents or abuse via https://csirt.uct.ac.za/page/report-an-incident.php. From: Melanie Alperstein To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 00:08:41

Dear Amy Hill

My name is Melanie Alperstein.

Address: I live at 20 Ash Street, Observatory, Cape Town and have lived here for 8 years presently and also lived in this street in the 1980s and 1990s. Email: [email protected]

My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: as a de facto direct neighbour living at 20 Ash Street, I am immediately affected by this development, this includes being immediately affected in relation to: · Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. · Flooding. · Pollution during the course the development and additional pollution due to increased traffic. · Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. · Light pollution due to increased amount of dwellings and development. · Additional stress on the sewerage infrastructure. I have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. · The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially and illegally annexed and privatised by John Comittis of CtFC) · High Heritage value of the site in terms of the history of the Khoi · High Heritage value in terms of the first parcel of free-settled farms. · Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which may be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. · The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. · Flora and fauna and the destruction of the breeding areas of endangered species. · Destruction of a vital wetland and green lung which helps to keep our cities cooler.

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

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

Once this area is destroyed it can never be undone.

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

Further issues that wish to raise include:

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

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

It is not too late.

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

Regards

Melanie Alperstein 20 Ash Street Observatory Retiree From: Tracy Blues To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 01:33:42 Attachments: image.png image.png

Dear Ms Hill

I live at 10 Ivy Street, Observatory, Cape Town. My family and I have lived here for more than 21 years.

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

I wish to register my objection to DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b) HWC Case No.:15112504WD1217Ec) DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club. The objection that I am lodging is in relation to The Basic Assessment Report on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application- bar

As a resident and homeowner, I will be directly affected by the proposed development. In particular, my family and I will be impacted by:

· Increased traffic Cape Town is an already congested city and Observatory is a suburb with tiny roads. I live on a one-way street. It is a one-way street because it is too narrow to accommodate two-way traffic. My house and all the other homes in our road were built in the early 1900s before cars were a means of transportation. Observatory was simply not designed for road traffic. I travel by car to take my children to school and to go to work. I already feel like I am risking our lives running the gauntlet of traffic every day. Any increase in the amount of traffic is untenable.

· Flooding In our 21 years in Observatory, we have witnessed many floods at the River Club and surrounding areas as the Liesbeek River bursts its banks. This is hardly surprising since the River Club is built in the river’flood plain. The 2004 flood when all those cars were damaged and the River Club was sued for millions is a case in point. This is a photo I took of the August 2013 floods so you can see what I mean. With the proposed development, flooding will be more frequent. The increased level of future floods of 15 cm is discounted as insignificant, whereas for those who will be affected, it will be highly significant. We know that Climate Change will bring the increasing likelihood of extreme weather events. PRASA have submitted an application to develop on their land. If approved, this will prevent PRASA land acting as a receiving site for run off of the flood waters. There would be nowhere for the flood waters to go except into lower Observatory. If the flood waters reach Ossian Road, we will effectively be cut off from our homes because it is the only entry into lower Observatory.

· Pollution During the construction of the development there will be pollution and the pollution will continue after the construction phase. There will be additional air pollution due to increased traffic. Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. Light pollution due to the increased number of dwellings and other buildings in the development.

· Stress on the sewerage infrastructure We have been informed by Paddy Chapple, our ward councillor, that the current sewerage infrastructure is expected to reach capacity soon as a result of the development towards the Main Road. This is even before the introduction of this development.

· The loss of public open spaces for exercise and recreation My family and I are regular users of the Two Rivers Urban Park and Malta Park for exercise and recreation. This development would result in the loss of access to these public open spaces.

· The disregard for the high Heritage value of the site The site of this proposed development is very important in terms of the history of the Khoi and as the first parcel of free-settled farms. The Khoi heritage has already suffered the indignity of being ignored and forgotten in post-Apartheid South Africa. This is such an important site for them. This site is a burial ground and the site of the first resistance to European influence. This is a site of intense cultural and heritage significance. Development here will destroy the sense of place at this site.

The National monument of Coornhoop dates back to 1657 and there are other historic farm houses in the area. A modern development shows a total disregard for that heritage and the heritage value of the entire area.

I live in a Victorian house. I specifically chose to buy a Victorian house and live in Observatory because of the historical charm of the houses and the area. A huge modern development is totally out of place in this neighbourhood. The density, scale and design of the proposed development are completely out of keeping with the surrounding area.

· The devaluation of our property My Victorian home and all the other heritage homes in lower Observatory will lose value if there is increased traffic, increased pollution, an unstable sewerage system, more frequent flooding and a destruction of the character of the suburb. The height and design of the proposed development are completely out of keeping with the surrounding area.

· The threat to flora and fauna This development would destroy the breeding areas of endangered species. Morea aristata is a critically endangered species of plant in the genus Moraea, that is endemic to the City of Cape Town and is now restricted to the area near the Liesbeek River. It is on the verge of extinction (see SANBI report on their website). Your specialist reports App. G2 do not even mention this plant. The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.” This is a photo of one of these beautiful creatures that I took in our garden last year. There are river otters, porcupines, squirrels, water mongoose and birds which are found in the area near the two rivers. Raapenburg Bird Sanctuary is a sanctuary which is intended to form a large integrated natural area in Cape Town and form part of Two Rivers Urban Park.

· The destruction of a vital wetland and green lung The Kyoto Protocol sets internationally binding emission reduction targets. South Africa is a signatory to the Protocol that recognises that developed countries are principally responsible for greenhouse gas emissions as a consequence of decades of industrial activity. South Africa needs to adopt further ambitious actions by 2050. We need green lungs so our city can “breathe”. Destroying a wetland by excessive development of that environment further “chokes” our city.

When Derek Hanekom was Tourism Minister he said, "During the past few years South Africa has experienced devastating weather events. Several regions in our country faced their worst drought in decades. The impact was felt more severely by the poorest and most vulnerable sectors of our society...our duty to the current and future generations is to provide a platform for progression on all issues in the Paris Agreement to ensure that the Global Goals are achieved. The Paris Agreement central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.” We cannot keep our cities cooler nor mitigate the effect of global temperature increases if we continue to develop in wetlands. This is especially true of this wetland which is bordered by two rivers and is a floodplain.

· The inappropriate use of land The development is not appropriate to the existing zoning. The SAAO have already pointed out that the huge buildings of up to 50m will be visible from the SAAO site, which is a national heritage site. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spatial development plan does not allow for this development.

While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. Eleven portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space.

The City needs affordable housing but only 4% of the development as a whole provides for affordable housing. The City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, but 4% is a negligible contribution. Undeveloped, well-located land exists outside of the park, where development could take place.

Please record my strong objections to this development and my desire to protect the area where my family and I live.

My email is [email protected] and my preferred method of communication is email.

Yours sincerely Tracy Blues

-- Tracy Blues 021 448 0532 082 452 8683 [email protected] From: Neil Harrison To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Tuesday, 17 September 2019 09:41:17 Attachments: River Club Objection Neil Harrison.pdf

My full name is: NEIL WILMIN HARRISON Address: 3 London road, Observatory, Cape Town Please contact me via email: [email protected] My phone number is:072 186 3403

DATE: 16 September 2019

ATT: Ms Amy Hill, SRK Consulting

LETTER OF OBJECTION CONCERNING: River Club Redevelopment Pre-Application BAR This letter of objection is in respective of the following erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

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

My reasons for this objection are stated below:

DESIGN The size/scale and density of the development is not appropriate to the existing zoning, nor to the surrounding environment.

LAND USE ISSUE The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space.

Undeveloped, well-located land exists outside of the park, where development could take place. The River Club owners have no entitlement to development rights. They bought the land with the existing zoning.

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

HERITAGE ISSUES The development will forever destroy the sense of place at the site. It will hugely alter views looking in to the site and views looking out across parts of Cape Town. The site is of intense cultural and heritage significance for the Khoi. Memorialising by erecting a museum or cultural centre will not compensate for erecting huge buildings overlooking the confluence of the river. The confluence of the two rivers is the epicentre of intangible heritage and is likely to house whatever memorial is established on the development. Yet the design of the development has some of its tallest buildings near this site, looming 30, 40 and 50 m over the confluence. This is insulting to the first nations and demeaning of their values.

It also received supported from the African Union, given its strategic importance for the African Continent. UNESCO may consider this a global heritage site. In light of this much wider and very high-level cultural interest, it is grossly inappropriate to permit this development to go ahead, which will permanently destroy this heritage.

Feasibility must be demonstrated in respect of social, environmental and (socio) economic considerations which must be balanced – including the impact on heritage resources. Moreover, the notion that a net first year return under 9% is unacceptable is questionable – there are many investors who would look at 7-8% investments if the quality is good enough.

FLORA AND FAUNA The Western Leopard Toad (WLT) is an endangered species and its only known breeding area is the Raapenberg wetlands. The biodiversity report states that “Significant mitigation is required to limit the impact of the proposed development, and to ensure the long-term viability of this WLT population.” There are also Cape Clawless Otters (Otter holt with young pups) that have been sighted on the Liesbeek River, on the River Club bank side of the river confluence where the development is proposed. These are an endangered species and a gift to our river as their presence here indicates the status of the river’s water quality. An Obs resident also raised the problem of a rare plant species Moraea aristate, which occurs in remnant Peninsula Shale Renosterveld vegetation. The species is currently limited to a single subpopulation near the Liesbeek River in the suburb of Observatory. Despite its location within a protected area, it is on the verge of extinction (on the SANBI website at http://pza.sanbi.org/ moraea-aristata). As far as we can tell, the specialist reports (Appendix G2 in two parts) make no mention of this plant.

I do not have any business interests which could influence my personal feelings with regards to the proposed development that I am objecting to.

Thank you,

I sign by my email, sent to you via this objection from, which is attached to this document. Should you have any further requirement of my identity you are required to contact me to request further proof of my identity as a citizen. This includes your requirement of my signature to this document prior to Monday 16 September 2019.

Should you require further information regarding my objection, kindly contact me as per above.

Kind Regards

Neil Harrison From: Cameron Barnes To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 06:59:48 Attachments: Signed Letter of Objection - River Club Development.pdf

Dear Ms Hill,

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

Please do not hesitate to contact me if you need any further information.

Many thanks,

Cameron Barnes From: Marion Smallbones To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 07:26:42

Dear Amy Hill

My name is Marion Smallbones, I live at 7 Crown Street, Observatory, Cape Town and have lived here for 22 years. Email: [email protected] My preferred method of communication is: email

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

Declaration of any direct personal, business, financial or other interest in the application: I have no personal, business, financial or other interest in the application.

The zoning of this land is currently open space for good reason, it is below the flood plain, and it is on a wetland.

Once this area is destroyed it can never be undone.

Please note my strong objections to this development, any development on the Riverclub land should be in line with the TRUP planning.

Regards

Marion Smallbones Education Consultant: Education Design and Innovation | Research and Development | Training

+27 828026616 [email protected] LinkedIn Based in Cape Town, South Africa. From: Gill Lanham To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 08:22:46

Dear Amy

My name is Gillian Lanham. My preference for any communication is via email: [email protected].

Introduction:

My husband's family bought a small block of flats (Pillans Court) on the banks of the LIesbeek River, in the early 1980's. It was built as 'social housing' during the depression in the 1930's. It is a structural and damp nightmare. My 92 year old mother, lived in York Road Rosebank, as a girl, and remembers the houses flooding on the flood plain, before the canalisation of the Liesbeek in the area, and the construction of the Liesbeek Parkway. Flood plains need to be respected.

As a long time member of the Friends of the Liesbeek, resident in Rosebank, with most of my 30 plus years as an educator in the Mowbray/Observatory area, I know the area very well. Since my retirement, I have spend a lot of time in, and around the river between the N2 and the Alma Road/Liesbeek Parkway intersection. Much of it was spent cutting back vegetation and cleaning filth and neglect around the site of the office complex on the Mowbray banks of the river, so that too has been of interest to me. It is small in comparison with what is being proposed on the River Club site, yet many of the offices are now being vacated - one must ask the question - 'why?' and if there is indeed a need for further office space in the area. https://www.property24.com/commercial-property-to-rent/mowbray/cape- town/western-cape/8677

Objection:

1. My objection is based on the bulk, height, scale and density of the design which is completely inappropriate to the historical setting of the South African Astronomical Observatory, founded in 1820, as well as to the Liesbeek River itself - the most important river in South African history. The site, as is well known, is sacred to the descendants of the indigenous occupants. (Appendix G6 pages 51 t0 57 refers to the height, scale and density of the development) (Pages 123 to 270 to the heritage issues)

That the view and the aesthetic will be changed forever, amounts to the same as a development that would block out the iconic view of Table Mountain from the Blouberg area.

2. Our most critical need in South Africa, and especially Cape Town right now, is social housing. This certainly is not addressed in this project.

3. Even with no expertise on climate change, water management etc, the thought of an increased flood risk willingly undertaken, is beyond comprehension. This will have implications, not only for the immediate residents of Observatory, but on the broader residential and commuter population of Cape Town.

4. It is high time that the voices of residents of the City of Cape Town are taken into account. The financial disaster, which is the Cape Town Stadium, is testament to that.

5. The matter of the original sale of the site, for an unrealistic amount, has still not been resolved to the satisfaction of many residents of Cape Town.

6. Cape Town sells itself to tourists, based on its natural beauty, plant and animal diversity. Much will be destroyed it this development goes ahead. Already, civic unrest, crime, xenophobia, lack of maintenance of historical buildings are having an influence on tourism which is vital to our economy.

A development of this size and function, in these times, will be nothing short of a disaster.

Yours faithfully

Gillian Lanham

Tel: 021 689 9258

3 Cross Road, Rosebank 7700 email: [email protected] From: Roelien To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 08:37:55

To whom it may concern,

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

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

My name is Roelien Theron, and I am a property owner in Alfred, Observatory, in the area between the Liesbeeck River and the railway line (Erf 26628). I can be contacted via email ([email protected]).

My principal objections are to the number and height of the buildings proposed for the site, the small percentage allocated to housing and even smaller percentage allocated to social housing, and inadequate parking facilities in relation to the vast number of buildings (and thus office space) proposed. I also have some comments to make on the preservation of the site’s cultural heritage.

To start with the last issue. The proposal to cut down on the parking facilities (even in the context of City bylaws and development frameworks to do so) will most probably result in an overflow of motorists seeking parking in the neighbouring suburb (much as office workers and shoppers park their vehicles throughout the Bo-Kaap). Given that many homes in this area have only street parking, the daily and nightly influx of people to the proposed development will seriously impact on the limited parking currently utilised by residents. The reliance on public transport for commuters to compensate for the inadequate number of parking spaces in the proposed development is unrealistic and definitely off the mark for night-time visits. The drawings submitted as part of the preapplication documentation do not indicate any parking areas (for example, in Century City there are two large open areas where office workers can park; this is in addition to basement and outdoor parking being available for most buildings). In addition, if the model is for all parking to be paid parking, chances are even more likely that visitors will be looking to park on the streets in the neighbouring area.

The plans also show a maximum total of 21 buildings on the site, with only 20 per cent of that allocated to housing and even less to social housing. Why not calculate into the equation affordable housing to buy, in order to create a stable residential neighbourhood in the area. This is one of the many housing needs in the city: affordable properties for people (especially a younger generation) to buy. The small percentage of housing is disproportionate to the number of business premises – which is simply a pretence at creating a ‘live-work-play’ ratio. The number of buildings on a relatively small space makes for a sterile environment. Even Century City, where I work everyday, has more open green spaces between buildings than what is shown in the plans for the River Club development. At Century City, in many parts, the business buildings (most not higher that THREE stories) are arranged in crescents – buildings arranged in a more or less ‘circular’ shape around a central area with lots of greenery and water features and walkways. Even so, it is still a very sterile environment after hours (despite the business-residential mix). Also, unlike Century City, the plans do not show any pre-school facilities, crucial if working parents want to drop off their children close to home and in a safe and nutting environment.

From a heritage point of view, I do understand and support the idea of a heritage centre (a good model is the Museum van de Caab on Solms-Delta farm in Franschhoek, which is a multimedia project that includes oral histories of the people who live on the farm). Something innovative, dynamic and modern can be done here. Another is to incorporate sculptures and/or other works in public spaces that can serve to commemorate the history of the area – which can include a commemoration of the battle between the Khoi and D’Almeida’s forces and a representation of the almond hedge (as a reminder of the impact and consequences of exclusionist policies). More consultation with affected communities can help to find creative ways of remembering the past.

Please do let me know what you will be doing with the objections and whether there will be a public website where they can be viewed.

Thanks Roelien Theron From: Aretha Cooper To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 09:00:49 Attachments: My Letter of Objection - River Club Development - Aretha.pdf

Dear Ms Hill,

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

Please do not hesitate to contact me if you need any further information.

Many thanks,

Aretha Cooper Ph.D. (Cell Biology) (UCT) 082 468 6516 From: Barry Badenhorst To: Amy Hill Cc: [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 09:14:38 Attachments: My Letter of Objection - River Club Development.pdf

Good day Please find attached --

Barry 0845537601 From: Mark Neame To: Amy Hill Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 09:16:58

River Club Redevelopment Pre-Application BAR * Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)

reference numbers

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

Mark Neame Contact [email protected]

Sent from my iPhone

Disclaimer

Please note: This e-mail and its contents are subject to a disclaimer which can be viewed at http://www.woolworths.co.za/disclaimer. This Disclaimer forms part of the content of this email in terms of section 11 of the Electronic Communications and Transactions Act, 25 of 2002. Should you be unable to access the link please e-mail [email protected] and a copy of the disclaimer will be e- mailed to you. NOTICE: If received in error, please destroy and notify sender. Sender does not intend to waive confidentiality or privilege. Use of this email is prohibited when received in error. From: Kimenthrie Pillay To: Amy Hill; [email protected] Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 09:29:16

Dear Amy,

My name is Kim Pillau and I prefer to be contacted by the email above. I do not have any personal, business or financial interest in the application to develop.

1. My objection is based on the design (in main report and Appendix G6 pages 51 to 57). The height of 50m, scale and density of the development will impact the local area in changing the view and aesthetic of the area. The proposed walkability benefits are possible and better with other the no development and lower density development scenarios.

2. My objection is based on the policy coherance because social housing needs to be included in all developments so this benefit is not a benefit that adds to this application in particular.

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

5. My objection is based on the feasibility and cost. Legal feasibility refers to social, environmental and socio-economic considerations. Feasibility in this report refers only to the costs to the developers as a deciding factor in which version of development is built. The relevant erf of public land was sold to the private land owner for close to 10% of its market value and that saving is not reflected in the valuation. The valuator deciding on this financial feasibility is employed by Investec, the major investor in this project so her evaluation cannot be considered impartial.

Kind regards,

Kimenthrie Pillay Director: Thrie Energy Collective [email protected] www.thrienergycollective.com +27 81 256 5578

“There comes a point where we need to stop just pulling people out of the river. We need to go upstream to find out why they are falling in” - Archbishop Desmond Tutu