Prepared by Arnia van Vuuren, BirdLife Port Natal committee member.

This includes background as well as comments and challenges on the amended EIA.

Background:

Clairwood Racecourse (CRC) has been sold to Capital Property Fund who intends to develop it into a logistics park with warehouses where goods imported / exported through Durban will be unpacked and repacked. The Environmental Impact Assessment was done in 2013 and BLPN registered as an Interested and Affected Party (I&AP). We submitted comments on the original EI Report. This EIR was rejected by the Dept. of Environmental Affairs because of several inadequacies and major objections raised by eThekwini Municipality’s EPCPD. Some of these issues have been addressed but not all.

Clairwood Racecourse (CRC) is the only site left for the Racecourse Lily (Kniphofia pauciflora) and it does not occur in the wetland but in the main soggy, grassy area in the middle. According to the new Environmental Management Programme they will move all specimens of the lily to the wetland area.

Dr Jeanne Tarrant will determine now (October 2014) whether Pickersgill’s Reed Frog occurs at the CRC. If they do, the developer wants them removed to an off-set area further down the South Coast.

The CRC is also home to a resident pair of Grey Crowned Cranes and a resident pair of Black Storks, among a host of other birds including a big heronry. The developer will donate money to the KZN Crane Foundation for buying extra land at their property in the Midlands as off-set for the loss of the Grey Crowned Cranes at the CRC. The cranes cannot be relocated as that has proved unsuccessful elsewhere so they will have to move. It is unclear whether the Black Storks will remain with all the disturbance. The developer has agreed to set aside about 7ha in the north-east corner of the site as a wetland area plus a buffer zone to contain all species which will lose habitat when the entire rest of the area is paved over for trucks, containers and warehouses.

The Amended EIR was released in September 2014 and BLPN has again submitted comments on this. Although there are improvements there are still several issues outstanding. For example, the Environmental Management Programme states that solid waste and grease in the stormwater (which will increase because everything is now paved over) will be dealt with through traps in the pipes, but then adds that the stormwater drains into the Amanzimnyama canal anyway which drains into Durban Bay so that will solve the problem. The issue around the frogs are not settled yet and in Dr Tarrant’s initial estimates she has had to propose the off-set/alternative that will be the cheapest for the developer. The developer has proposed to spend two million rand on education in the surround communities but this includes the development of the wetland area.

In our comments we focused on the major issues.

COMMENTS ON THE AMENDED ENVIRONMENTAL IMPACT ASSESSMENT REPORT

INTRODUCTION:

Thank you for the opportunity to peruse the Amended Environmental Impact Report and to comment.

We acknowledge the attempts regarding the wetland conservation area in the north-east corner of the proposed development. However, developing the existing green area as a logistics park and just setting aside a small corner for natural habitat does not constitute sustainable development. In the same way herding inconvenient species into a corner so as not to interfere with a development does not make for a biodiversity hotspot.

COMMENTS:

1. Traffic Impact Assessment (TIA):

1.1 Pedestrian traffic

In our initial comments we raised the issue of the high number of school children at the interchanges where Basil February Road enters the Clairwood Racecourse. We note that the Traffic Specialist did additional counts and included pedestrian traffic. However, the pedestrian count was done on Monday 2 December 2013 and according to the tables in Appendix 8, pp149-156 very few school children were encountered on that date. This is not surprising since it was after the end-of-year exams and two days before the start of a major school holiday when very few children still go to school.

The Traffic Impact Assessment evaluated the morning and afternoon peak hour traffic only, but the tables show, even without the scholars on the road, that Basil February Road and the interchanges carry high numbers of pedestrians all day.

The traffic specialists contend that by widening the pedestrian sidewalks and extending the greening time for pedestrians on the traffic lights would be sufficient to ensure the safety of all road users.

It is our contention that the developer has chosen Basil February Road as main entrance to the logistics park as it is the most convenient and cheapest for the developer and his tenants due to its proximity to the M4 despite the fact that it is in a residential area with high pedestrian and other traffic volumes. As the tragic accident on Fields Hill, Durban on 6 September 2013 illustrated dramatically – trucks do not belong in residential areas.

1.2 Other developments and traffic flow:

The report mentions the planned extension of Grimsby Road/Higginson Highway over the R102, through Clairwood Racecourse to connect with the M4 but the specialist decided not to consider it in the TIA as the timeframe for the extension is unknown (App. 8, TIA, p3).

In the same manner the specialist decided to exclude the impact of increased (heavy vehicle) traffic generated by the proposed dig-out port at the old Durban International Airport (DIA) site from their assessment and ten year forecast for the Traffic Impact Assessment as the port has not been approved yet (App. 8, TIA, p3).

We consider the decisions to exclude these two developments from the TIA of serious concern. While there are unknowns regarding these two developments, both will have major impacts on traffic flow, air quality, noise pollution and general living conditions for residents in the area surrounding Clairwood Racecourse and they would be left with little recourse to do anything about the situation after the fact.

In the words of the TIA specialist (p30): “It has been assumed that the distribution of this additional traffic generated by the proposed development will be approximately in a similar distribution to existing traffic flows on the M4 to and from the north and south except that there will be slight bias to the south due to the proposed new dug out port which will eventually be a major trip attractor.” (our emphasis)

As in the assessment of the environmental impacts, the potential long-term economic and financial benefits of wider developments like the dig-out port and Grimsby Road extension for the current applicant have been considered, but the specialists rigidly consider only the immediate impacts of the logistics park on the natural and social environment.

2. Environmental Impact Assessment:

2.1 Loss of Clairwood Racecourse as green space

Regarding the visual impact and loss of visual aesthetics of the proposed development the Final Environmental Management Programme, Impacts Table states: “There will be a loss of open space previously associated with the racetrack. 44% of the respondents in the SIA stated that they personally benefit from the open space provided by the Racecourse. Visual aesthetics is a subjective impact however 7 460m2 of open space has been allocated to wetland habitat conservation, which will be aesthetically pleasing. This area will be accessible to the public. The architect has also provided design concepts of what the proposed infrastructure will look like (Figure 1C and 1D), with the buildings appearing more aesthetically pleasing compared to surrounding land uses, “Green ideas” will also be incorporated into the buildings with indigenous trees and vegetation improving the aesthetics across the remainder of the site.” (p40)

To state that “visual impact is a subjective impact” would imply that there are people who enjoy the sight of a logistics park filled with trucks, containers and warehouses opposite their homes. The statement also smacks of an arrogant dismissal of the opinions of the 44% of the residents who stated that they personally benefit from the current open space.

Further, to state that the proposed warehouses will be more aesthetically pleasing compared to surrounding land uses” is true, but in comparison with the existing green space the statement is palpably untrue and shows a worrying attitude by the environmental consultant to the community – their area is degraded but they should be grateful for what they will lose because they will now get nice buildings to look at.

The developer and environmental consultants are also placing an immense burden on the small wetland conservation area: it has to function as natural area and receptacle for all inconvenient species, assist with stormwater attenuation, placate environmentalists, satisfy the demands of NEMA and compensate local communities for all they will lose.

2.2 The logistics park development in relation to other developments in the area

While it is true that an EIA process is based on a specific activity/development developers tend to plan strategically in determining the economic benefit they will derive from their proposed activity. In the current instance Capital Property Fund has stated that a logistics park will give them the best return on their financial investment without the proposed dig-out port at the old DIA site, but they are fully aware of their increased profit should the proposed port developments be authorized.

It is when it comes to environmental impacts that consideration should always be limited to the immediate activity only and wider strategic thinking is discouraged. However, the consultants admit: “The various development proposals for the South Durban will have a positive impact on the KZN economy but a negative cumulative impact on the remaining ecology of this area.” (Reply of consultant to our comments on the Final EIR, dated 8 November 2013 and not included in the current document.)

The Amended EIR also states: “The best environmental option would be to retain and manage the entire wetland for conservation purposes and this is considered in the no go option. This is not, however, aligned with the aim of the proposed activity i.e. to develop the site for financial gain.” (Clairwood Summary Final Amended EIR, p1)

In the response from KSEMS to our comments to the Final EIR they mention that the Bluff Golf Course and Treasure Beach remain as green areas and potential habitat for species displaced by the Clairwood logistics park development together with “pristine [sic] coastal and dune forests” along the coast. Apart from the fact that forests do not constitute suitable habitat for red data species like Grey Crowned Crane and Black Stork, we would like to point out that Bluff Golf Course is now also under threat of being lost as a green space leaving no alternative habitat for the Clairwood Grey Crowned Cranes. It remains to be seen if the Black Storks will remain with all the projected disturbance and the reduced habitat.

CONCLUSION:

The south Durban-basin is under increasing pressure with development proposed for the expansion of various port activities in Durban Bay, the dig-out port at the old Durban International Airport site and Clairwood Racecourse which will all impact massively on the extent of green open space left in the south of Durban. The activities associated with these developments will result in bigger and more ships entering the port(s) and more trucks in the south of Durban all contributing to more air pollution at the same time as industries like Sapref and Engen are applying for postponement of their compliance with minimum emission standards.

Each developer claims that their development will bring economic benefit for the communities and each environmental consultant tries to placate environmentalists and local communities with a little mitigation and small off-sets elsewhere. The reality is that what remains of the green spaces, natural habitats and the biological diversity that has managed to survive in the South Durban Basin against all odds, together with the associated ecological goods and services are systematically wiped out. And the local communities are left to bear the environmental, health and ultimately social costs of this destruction of remaining natural ecosystems.

We therefore still cannot support the proposed development of Clairwood Racecourse into a logistics park.