A draft Basic Assessment Report has been compiled and made available for a 30-day commenting period.
The commenting period commences on 21 August 2020 and closes on 21 September 2020.
Should you wish to provide comment on the draft report, you may do so by emailing: firstname.lastname@example.org, or telephone: 021 422 0999, or fax: 021 422 0998, or WhatsApp (messages only): 060 761 5729, or by post: PO Box 945, Cape Town, 8000.
Please provide comment or register as an Interested and Affected Party by 21 September 2020.
INTRODUCTION AND BACKGROUND
A draft Basic Assessment Report (BAR) has been compiled in support of an Environmental Impact Assessment being undertaken for the proposed construction of a housing development on a portion of Farm 920 in Sir Lowry’s Pass Village. The City of Cape Town intends to develop between 574 and 634 residential units on the northern portion of Farm 920. The remainder of the property (being approximately 43% to 40% of the site respectively) is set aside for public open space and environmental conservation. The development aims to assist in meeting the need for low-cost housing.
The site is located 80 metres south of the Old Sir Lowry’s Pass Road and immediately west of William Sergeant Street in the suburb of Sir Lowry’s Pass Village. A railway line lies adjacent to the northern boundary of the site and the Sir Lowry’s Pass River runs along the southern boundary of the site. Please see Appendix A1: Locality Map
Please refer to Appendix A1 for the map showing the location of the proposed activities. The proposal is to develop between 574 and 634 residential units on the northern portion of Farm 920. The development proposed will provide affordable housing.
The proposed housing development will include the following (please see Appendix B1: Site Plans):
- Development of the northern portion of the site for low-cost housing consisting of both single storey and double storey houses
- Incorporation of three existing houses into the new development for community use
- Construction of the access road for the development off Bloubos Road (approved but not as yet constructed)
- Removal of the dam currently located in the centre of the site and management of the underlying spring
- No development on the southern portion of the site except for inter alia stormwater retention and amelioration, play areas and community gardens – this area (south of the man-made dam) is characterised by wetland features, floodplains and drainage channels
- No development below the 1:100 year flood line, other than the access road, which would have water throughflow conduits below the road.
Apart from the above, the proposed development includes associated internal roads and service infrastructure, as well as areas for recreational use. Bulk water and sewer services will be provided by the City of Cape Town. The Municipality will also manage the solid waste generated by the development, and Eskom will supply the required electricity services.
Sewage generated from the proposed development will feed into the Macassar Wastewater Treatment Works (WWTW) which is being upgraded for completion in 2025/26. A phased approach is currently proposed, with limited inflow from the development into the WWTW until the upgrade is complete.
Vehicular access to the site will be provided for via one access road off the approved Bloubos Road from the southwestern boundary of the site. It is proposed that the development will not have vehicular access to/from the adjacent residential area to the east (other than for emergency purposes). However, two pedestrian accesses are proposed to connect the development to the Sir Lowry’s Pass Village to the east. Additionally, it is recommended that minibus taxi services operate within the Development in order to provide future residents with access to public transport.
The Basic Assessment Report available for comment during the pre-application public participation process includes two layout alternatives for housing development as follows.
The first alternative consists of 574 residential units with standard plot sizes of 75 m2. The primary difference between the first and second alternatives is with regard to the freshwater resources on the site. Alternative 1 does not propose the construction of residential units over the natural spring which feeds the man-made dam currently located at the centre of the site. Instead, it proposes to redress the historical loss of seep conditions, by spreading flows from the spring feeding the dam through slow percolation downslope, towards the floodplain wetlands. As such, it comprises fewer residential portions than Alternative 2.
The second alternative consists of 634 residential units with standard plot sizes of 75 m2. Unlike the first alternative, Alternative 2 proposes the construction of residential units on the area currently occupied by the dam. In order to do so, it proposes to identify the spring outlet point, and capture and convey this water to a point lower down on the site.
The below table presents a summary of each layout alternative including the percentages of the property which would be developed and set aside for public open space and environmental conservation for each of the layout alternatives. In both alternatives, the intention is to preclude backyard dwelling by allowing no potential space for the illegal influx of backyard dwellers.
|Layout alternative:||Number of residential units:||Development footprint:||Development area (approximately):||Public open space and environmental conservation area set aside (approximately):|
|Alternative 1||574||97 100 m2||57%||43%|
|Alternative 2||634||103 100 m2||60%||40%|
National Environmental Management Act (107 of 1998)
The 2014 NEMA Environmental Impact Assessment Regulations of 2014, as amended, apply to the proposed development and necessitate a Basic Assessment Process. The proposed development includes activities listed in GN983 of the 2014 EIA Regulations, as amended. These are:
Listing Notice 1 (GNR 983 of 2014, as amended)
The development of infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs –
(a) within a watercourse;
(b) in front of a development setback; or
(c) if no development setback exists, within 32 meters of a watercourse, measured from the edge of a watercourse.
The infilling or depositing of any material of more than 10 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 cubic metres from a watercourse.
Residential, mixed, retail, commercial, industrial or institutional developments where such land was used for agricultural, game farming, equestrian purposes or afforestation on or after 01 April 1998 and where such development will occur outside an urban area, where the total land to be developed is bigger than 1 hectare.
National Water Act (36 of 1998)
The National Water Act is applicable to the proposed development. As the development on Farm 920 will result in the infilling of wetlands, Sections 21 (c) and (i) of the Act are applicable to this activity, referring to the impeding or diverting the flow of water in a watercourse, and altering the bed, banks, course or characteristics of a watercourse, respectively. Section 21 (j), which refers to the removing, discharging or disposing of water found underground, is also applicable as it is assumed by the freshwater specialist (Day, 2020) that subsurface drainage measures are to be included in the development design. Consequently, a Water Use License will be applied for with the Department of Water and Sanitation. The application procedure is phased. Thus, proof of the final application submission cannot currently be provided. However, proof of commencement of the submission of the Water Use application will be provided in the Final BAR.
The development does not include any activities listed in Listing Notices 2 and 3 (GNR 984 and 985 of the 2014 EIA Regulations, as amended). Furthermore, there are no activities relevant to the proposed development as are listed in terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004) or the National Environmental Management: Waste Act (Act No. 59 of 2008).
POTENTIAL IMPACTS IDENTIFIED AND ASSESSED
Below is a summary of the impacts identified and assessed in the draft Basic Assessment Report.
Planning and Design Phase 
- Loss of Wetland A (Day, 2020)
- Loss of portions of Wetland C and B (Day, 2020)
- Loss of and further degradation to a portion of Wetland C and E as a result of the access road (Day, 2020)
- Loss of standing water habitat associated with the dam (Day, 2020)
- Changes in hydroperiod and flow regime in downstream wetlands (C, B, E and D) (Day, 2020)
- Increased risk of wetland pollution as a result of the alignment of the sewer connection (Day, 2020)
- Wetland degradation as a result of development in close proximity to wetlands (Day, 2020)
- Wetland degradation as a result of a layout favouring poor servicing of households and resultant passage of contaminated water into the stormwater system (Day, 2020)
- Damage to and loss of existing remnant natural vegetation on site (Emms, 2019)
- Socio-economic impact of the provision of affordable housing
- Compatibility of the proposed development with surrounding land uses
- Loss of sense of place
- Visual impact of buildings and infrastructure resulting in a change in the visual character of the area
- Loss of heritage resources due to the demolition of a structure older than 60 years (O’Donoghue, 2020)
- Impact on services as a result of the proposed development
Construction Phase 
- Wetland disturbance as a result of removal of the dam (Day, 2020)
- Degradation of wetland areas and the Sir Lowry’s Pass River as a result of physical disturbance and pollution associated with general construction activities including laying of the sewer external connection and the access road (Day, 2020)
- Waste management impacts during the construction phase
- Dust impacts during the construction phase
- Noise impacts during the construction phase
- Visual impacts of construction activities and vegetation clearing
- Traffic impacts due to construction vehicles
- Employment opportunities during the construction phase
Operational Phase 
- Watercourse degradation as a result of the operational phase of the proposed development (Day, 2020)
- Potential health risks due to damp conditions resulting from the construction of housing on wetland areas with perched water conditions (Day, 2020; Yates & Jones, 2014)
- Noise impact resulting from the proximity of the housing development to a railway line, the Old Sir Lowry’s Pass Road and the N2 Freeway
- Impacts on traffic flow during peak hours due to increased operational traffic (GIBB, 2020)
- Increased road safety and access to public transport for future and existing residents due to improvements to transport infrastructure (GIBB, 2020)
Public participation is a key component of the environmental assessment process as it introduces the proposed activity to the public and provides an opportunity for comments and concerns to be raised. Public participation will be undertaken in terms of Section 41 of the 2014, NEMA: EIA Regulations, as amended.
For a concise yet comprehensive summary of the Basic Assessment Report, please see this Information Sheet.
Comments on this report may be submitted on or before 21 September 2020 to:
The Environmental Partnership
P O Box 945, Cape Town, 8000
Tel: 021 422 0999; Fax: 021 422 0998
WhatsApp (messages only): 060 761 5729
- Status: Draft Basic Assessment Report
- Start date: Friday, 21 August 2020
- End date: Monday, 21 September 2020
- Draft Basic Assessment Report
- Appendix A1 – Locality Map
- Appendix B1(i) – Site Plan Alternative 1
- Appendix B1(ii) – Site Plan Alternative 2
- Appendix B2 – Sensitivity Map
- Appendix C – Site Photographs
- Appendix D – Biodiversity Overlay Map (Aquatic) (Updated!)
- Appendix D – Biodiversity Network Map (Terrestrial) (Updated!)
- Appendix E1(i) – NID Submitted to HWC
- Appendix E1(ii) – NID Response from HWC
- Appendix E16(i) – Water and Sewage Confirmation Letter
- Appendix E16(ii) – Solid Waste Confirmation Letter
- Appendix E20 – Proof of Agreement of the Specialist Studies Conducted
- Appendix G(i) – Specialist Aquatic Ecologist Report (Day, 2020)
- Appendix G(ii) – Botanical Statement (Emms, 2019)
- Appendix G(iii) – Botanical Baseline Study (Helme, 2014)
- Appendix G(iv) – Geotechnical Investigation Report (Yates & Jones, 2014)
- Appendix G(v) – Baseline Report on Freshwater Ecosystems (Day, 2014)
- Appendix G(vi) – Heritage Statement (O’Donoghue, 2020)
- Appendix H – EMPr (with annexures)
- Appendix I – Screening Tool Report
- Appendix K – Need and Desirability Document
- Appendix L – Engineering (Bulk Services) Report
- Appendix M – Traffic Impact Assessment
- Appendix N(i) – Architectural Input – Single Storey
- Appendix N(ii) – Architectural Input – Double Storey
- Appendix O – Site Sensitivity Verification Report
- Appendix P(i) – Public Participation Plan submitted to DEA&DP
- Appendix P(ii) – Public Participation Plan response from DEA&DP
- Appendix Q – Curriculum Vitae of EAP