From: Kath Hall To: Amy Hill Cc: [email protected]; Leslie London Subject: River Club Redevelopment Pre-Application BAR Date: Monday, 16 September 2019 19:32:06 Dear Amy Hill My name is Katharine Hall ĚĚƌĞƐƐ: I live at 1 Lower Trill Road, Observatory, Cape Town and have lived in this house, which I co-own with my husband, for nearly 20 years. Before that I lived at 2 Cambridge Road Observatory for three years. ŵĂŝů: [email protected] WƌĞĨĞƌƌĞĚŵĞƚŚŽĚŽĨĐŽŵŵƵŶŝĐĂƚŝŽŶ͗ email dŚŝƐĞŵĂŝůŝƐǁŝƚŚƌĞŐĂƌĚƚŽƚŚĞĨŽůůŽǁŝŶŐ͗ Erf numbers: Erf 151832, City of Cape Town, and adjacent properties (Erf 26426, ERF 108936, Erf 26427, Erf 15326 Rem, Erf 26169, Erf 26170, Erf 26171, Erf 26172, Erf 26173, Erf 26174 and Erf 26175)4.3 dŚŝƐŽďũĞĐƚŝŽŶŝƐŝŶƌĞůĂƚŝŽŶƚŽ: DEA&DP Ref. No.:16/3/3/6/7/2/A7/17/3104/16b)HWC Case No.:15112504WD1217Ec)DWS Ref. No.:16/2/7/G22/A/11 and WU9026 River Club ĞĐůĂƌĂƚŝŽŶŽĨĂŶLJĚŝƌĞĐƚƉĞƌƐŽŶĂů͕ďƵƐŝŶĞƐƐ͕ĨŝŶĂŶĐŝĂůŽƌŽƚŚĞƌŝŶƚĞƌĞƐƚŝŶƚŚĞĂƉƉůŝĐĂƚŝŽŶ: As a de facto direct neighbour living at 1 Lower Trill Road I am immediately affected by this development. This includes being immediately affected in relation to: Increased Traffic in an already congested city and a suburb with tiny roads. As someone required to travel by car to accommodate my work travel during the day this is a vital issue for myself and others. Flooding. Pollution during the course the development and additional pollution due to increased traffic. Noise pollution due to the increased amount of traffic and the significant increase in businesses transacting in the area. Light pollution due to increased amount of dwellings and development. Additional stress on the sewerage infrastructure. I have been informed through the Observatory network that the current sewerage infrastructure is expected to reach capacity shortly even before the introduction of this development as a result of the development towards the Main Road. The deprivation of my exercise as a regular user of the Two River Urban Park and Malta park (which has already been unofficially and illegally annexed and privatised by John Comittis of CtFC). High Heritage value of the site in terms of the history of the Khoi. High Heritage value in terms of the first parcel of free-settled farms. Heritage value in terms of the VIctorian houses in the area, especially those in lower Observatory which be affected in many different ways, including flooding, lack of access to their properties, increased traffic and congestion. The National monument of Coornhoop which dates to 1657 and other historic farm houses in the area. Flora and fauna and the destruction of the breeding areas of endangered species. Destruction of a vital wetland and green lung which helps to keep our cities cooler. dŚĞŽďũĞĐƚŝŽŶƚŚĂƚ/ĂŵůŽĚŐŝŶŐŝƐŝŶƌĞůĂƚŝŽŶƚŽ͗ The Basic Assessment Report, which is on the SRK Website at https://www.srk.co.za/en/za-river-club-redevelopment-pre-application-bar.It 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. I am however directly affected as I live within 500 meters (directly) and 700 meters by road of the development. This proposal impacts thousands of people and intangible heritage that belongs to all South Africans. 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 airport hangar. 4. LAND-USE ISSUE The River Club owners have no entitlement to development rights. They bought the land with the existing zoning. The current spatial development plan does not allow for this development. While deviations may be applied for, there has to be cogent motivation to justify such deviation. No such motivation has been provided. For the development to go ahead, the City has to permit the developers to lease or purchase portions of land owned by the City. 11 portions of land are involved, including four portions zoned as public open space. This represents an alienation of public land to serve a private purpose. The current zoning is for Open Space with consent uses. It is a component of the Two Rivers Urban Park. Approving this development will deprive all Cape Town residents of a park space. Undeveloped, well-located land exists outside of the park, where development could take place. 5. POLICY I don't believe that playing the affordable housing card has any merit since the actual contribution to affordable housing is only 4% of the development as a whole. Notably, the City has moved to ensure that all new developments of this kind will be required to provide a component of affordable housing, so this is immaterial to considering the merits of the application. 6. FLOODING 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.