ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND …rhdhv.co.za/media/201210/Final Enviromental...

ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW ROUTE P166-1/2 IN NELSPRUIT MBOMBELA

1 I&AP AND STAKEHOLDER ISSUES AND RESPONSE REPORT

ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED NEW

ROUTE P166-1/2 IN NELSPRUIT

COMMENTS & RESPONSE REPORT FOR SCOPING PHASE

SEPTEMBER 2013

INDEX TO ISSUES IN THIS TABLE

ECONOMIC ISSUES

LAND ISSUES & AGRICULTURE

ECOLOGICAL ISSUES

TECHNICAL ISSUES

WETLAND

SOCIAL ISSUES

GENERAL ISSUES



ITEM

ISSUE

SOURCE

RESPONSE

ECONOMIC ISSUES

The proposal affects the viability of some farm portions, or

the existing investment made on properties, or the

development potential

Mr. Hennie van

Rensburg, Nuplan

Development Planners,

Comment & Registration

Form

If the route running through these properties is

approved by authorities, SANRAL will engage

in negotiations with the affected owners in

order to agree on the compensation and

relocation if necessary.

Mr. Riaan van Doorn has a manufacturing business that is

located across the road from Casterbridge and below

Bagdad Cafe. The new road P166-1/2 as shown on the

aerial photos is going to pass right in the middle through

the business. 24 people are employed at the factory. What

do I stand to do regarding these employees future and my

business?

Mr. Riaan van Doorn,

Spectacular Concrete

Works, Comments

Emailed

The manufacturing business on Remainder of

Portion 9 of Nooitgedacht 62-JU is inside the

declared road reserve. If the route running

through the business is approved by

authorities, SANRAL will engage in

negotiations with the affected owners in this

matter.

Alternative 1 will run through my property and will affect the

value of my property and influence our daily lives

negatively.

Agriculture is our livelihood and we give work to many

workers.

If this project goes ahead, many productive trees are in the

way of the P166 route.

Mr. Gehardus

Engelbrecht Comment &

Registration form,

Emailed






Total water supply in jeopardy to a Sawmill, a Transport

Company & Forestry Harvesting & Transport Company with

the total employment of 450 workers and housing 150

tenants.

We receive our only supply of drinking water from a natural

Carel Jacobsz,

Comments and

Registration form,

Emailed




order to agree on how water supply will be

maintained to ensure that it will still be



spring exactly in line where option 1 alternative is due to

pass over.

Our only industrial water supply from a canal for our above

needs are pumped from 3km away which will now be

inaccessible for maintenance & control and maybe totally

cut-off as a supply source. This will enforce a shutting

down of the entire above-mentioned facility.

available for the company.

(Note Phumlani Alternative 1 will not be

assessed further in the EIAR phase of the

project )

The proposal affects the viability of some farm portions, or

the existing investment made on properties, or the

development potential.

Hennie van Rensburg,


form Emailed





relocation if necessary, if this has not already

been done as part of earlier declaration and

compensation. however some farmers were

already aware that that the servitude has been

proclaimed and this is stipulated in their leases

LAND ISSUES & AGRICULTURE

The proposal affects our primary dwelling directly (locality

and other information not in detail and clear) as well as

our farming activities. We oppose the current proposal and

alignment

Jurie Piso, Comment &

Registration Form,

Emailed





relocation if necessary, if this has not already

been done as part of earlier declaration and

compensation.

This route would destroy a significant amount of irrigable,

valuable, productive farm land, which in a country which is

battling to produce enough food, is not acceptable.

Allan Luus, Mercy Air

Comments Emailed

The potential impact of certain of the project

alternatives, in particular Phumlani Alternative

1 is recognised, and is reflected in the

agricultural potential study. It should be noted



Farmer's fields will be physically cut into smaller un-

economical parcels, that will result in destruction of irrigible,

usable land that will be in excess of the actual land

destroyed by the road.

The original, declared servitude runs through an area that is

poor farm land, that has no irrigation, and therefore a far

smaller amount of arrable land will be destroyed. The fact

that the Msholozi illegal settlement will have to be disrupted

is a problem, but how can an illegal settlement disrupt the

legal, planned law abiding processes of the country?

Property values in the whole valley will be negatively

effected by the "Alternative 1 " running through the valley.

We carefully investigated these sort of servitudes before

buying our land, and find it un-acceptable that a road can

now be moved right onto our doorstep because of an illegal

settlement that has sprung up in the past 2 years, in the

middle of your planned, declared route. There are many

servitudes and rights-of ways across different farms in the

Heidelberg valley and these would all need to be carefully

considered to make sure nobody is accidentally cut-off.

The Sand River Irrigation Scheme would be seriously and

negatively impacted by the road. The scheme has

registered servitudes, surely you cannot just disrupt these

servitudes?

that for environmental reasons, the Phumlani

Alternative 1 has been discarded and will no

longer form part of the project scope as

investigated in the EIAR phase.

The potential impact of the proposed road on

agricultural activities is recognised, and as

such an agricultural potential study was

commissioned for the scoping phase of this

EIA. The social study has also identified the

potential impact of a loss of income due to

sterilisation of agricultural land. These issues

will be further assessed by the respective

studies in the EIAR phase of the project.

A number of I&APs have raised the issue that

parts of the Msholozi-Phumlani settlement

were allegedly “illegally” settled. Nonetheless a

housing development & community now exists

within certain parts of the servitude and wider

area (in which alternatives to the existing

servitude in the Msholozi area are being

considered) and as such the potential social

impact of the proposed road on this community

needs to be considered by this EIA and

compared with the impacts of the alternative

alignments.



What will happen if a truck carrying hazardous chemicals

crashes off this road and the chemicals are spilled into the

canal and are inadvertently pumped onto hundreds of

hectares of farm land, permanently contaminating the land?

will SANRAL pay for this?

The existing servitude for the P166 is the shortest route with

the slowest gradient and makes the most sense from a road

point of view.

Increased run-off during periods of high rainfall resulting in

erosion and further loss of farmland.

Potential pollution of surface water receptors

and agricultural infrastructure by spillage from

vehicles is an important environmental issue,

and will be further investirgated in the EIR

phase of the project, and particularly in the

context of the EMPr that will be compiled in the

EIR phase. The risk of such an event

transpiring in the Heidelberg valley would be

greatly lessened by the discarding of the

Phumlani Alternative 1 as an alternative in the

EIR phase of the project.

Run-off from hard surface of the road and

associated stormwater outflows into adjacent

land (including agricultural land) is an

important potential issue in the context of the

agricultural potential aspects of the affected

environment. Accordingly this issue has been

flagged as an issue for further investigation

during the EIR phase, and relevant mitigation

measures will be identified for inclusion in the

EMPr.

Seriously affected party by P166 - it cuts through our farms.

Huge disruption – how will evaluation be conducted to

determine compensation?

Try to identify another alternative as P166 cuts through

valuable commercial, agricultural property.

P van Rooyen,

Comments, Emailed






Impact of the proposed project on agricultural clients Stefan Scheepers, If the route running through these properties is



banking with FNB. Comments, Emailed




relocation if necessary; however some farmers

were already aware that the servitude has

been proclaimed and this is stipulated in their

leases.

ECOLOGICAL ISSUES

The contents of the draft scoping report is concerning as the

Mpumalanga Biodiversity Conservation Plan, does not

appear to have been consulted in this initial, mostly desk-

top based Scoping assessment.

The protected area expansion areas must also be

considered.

The presence of existing bird sanctuaries has not been

considered.

The presence (possibly destroyed) of Aloe simii populations

in the Phumlani and Impala Road area need to be

considered. Focus should be on habitat preservation, not

species.

There are KNOWN Aloe simii populations in the proposed

routes.

Andrew Rossack,

Comments ,E-mailed

The Mpumalanga Biodiversity Conservation

Plan, POSA, SARCA, SABAP1 and SABAP2

data was consulted in the preliminary scoping

assessment which was based mainly on a

desktop survey as well as a single site

visitation.

The protected area expansion areas will be

considered as well as the presence of any

existing bird sanctuaries or nature reserves

within the final ecological report.

The presence (possibly destroyed) of Aloe

simii populations in the Phumlani and Impala

Road area need to be considered.

In relation to the Aloe simii populations, he

consultant observed several specimens along

a valley bottom wetland within White River

during a recent survey. We would appreciate



The assessment must be based on sound data collection,

not subjective opinion and species lists.

The assessment must be repeatable

The assessment must conform to the MTPA guidelines for

ecological assessments.

It is suggested that past EIA ecological and wetland studies

from the area, e.g. Pumlani and Fiddlewood, should be

consulted and incorporated.

any additional information regarding the

Critically Endangered Aloe simii populations.

This information will be confidential and only

forwarded to Professor Leslie Brown who

undertook the vegetation aspect and

highlighted within the final sensitivity map.

The assessments are based on sound data

collection, not subjective opinion and species

lists and are repeatable. The proposed route

was analysed prior to the field survey for

available literature and database information

pertaining to the vegetation and threatened

species of the study area. The Braun-Blanquet

survey technique to describe plant

communities as ecological units was used for

this study. It allows for the mapping of

vegetation and the comparison of the data with

similar studies in the area.

Previous EIA ecological and wetland studies

from the area, e.g. Pumlani and Fiddlewood,

will be consulted and incorporated if

information is readily available. The ecological

specialist study will include the likely habitat

fragmentation and provide mitigation

measures for the road.

It is acknowledged that there is a high reptile



The ecological specialist study must include the likely

habitat fragmentation and provide mitigation measures.

Various Red List species such as rock python and plated

lizards are known to occur in the area.

diversity between Nelspruit and White River

with 81 species recorded during the South

African Conservation Assessment (SARCA).

This will be further assessed in the EIAR-

phase biodiversity study.

Judy De Villiers has read through the draft scoping report,

and has already found a problem with section 5.5.6, with

regards to the amphibians.

In the report it is mention that NO THREATENED FROG

SPECIES were found.

I live next to the wetland North of White River where the

proposed road must run through the wetland. I live next to

the White River Bird Sanctuary, and have found the Spotted

Shovell Nose Frog on a few occasions. This frog is listed as

to only be found in the Northern Region of the KwaZulu

Natal Coastline, but yet has found its way to White River. I

have e-mail Professor Louis Du Preez of the North West

University who is the writer of the book Frogs & Frogging in

South Africa (STRUIK), to notify him that I have found this

rare and sensitive frog in my garden. I attach to my mail

photos of the last frog I found in my swimming pool in

February 2013.

Judy De Villiers,

Comments E-mailed

The frog has been identified as a Mottle

Shovel-nosed Frog (Hemisus guttatus) by

Prof. Louis du Preez and ecological specialist.

This is the first record of the species in White

River with the nearest locality being

approximately 180 km away around Piet

Retief.

The biodiversity report will be amended to

include this red listed species in the report.

The wetland area was identified as highly

sensitive due to the presence of the red listed

Gunnera perpensa as well as the ecological

and hydrological functions of the wetland. The

wetland has been heavily impacted on by

recent high density residential developments

as well as small-scale agricultural activities

(ploughing of soils) within the seasonally

inundated zone.



I also find no mention of the fact that the road on the

Northern side of White River is going to run next to the

White River Bird Sanctuary.

If you could please pass this information on to the person

who is doing the further Ecological Studies.

The protected area expansion areas will be

considered as well as the presence of any

existing bird sanctuaries or nature reserves

within the final ecological report.

The response was provided by the ecological

specialist, as this information had been passed

onto him for comment.

It takes no brains to see that the proposed route through

White River Creek would carry severe consequences to

humans, plants and wildlife in the White River Nature

reserve.

Peter Doble, Comments-

Emailed

An ecological study has been identified as one

of the studies to be undertaken for this study

and the specialist will provide

recommendations based on his finding during

the EIA phase.

TECHNICAL ISSUES

This route would destroy a significant amount of irrigable,

valuable, productive farm land, which in a country which is

battling to produce enough food, is not acceptable.

Negative Impact on wetlands and wildlife.

Farmer's fields will be physically cut into smaller un-

economical parcels that will result in destruction of irrigable,

usable land that will be in excess of the actual land

destroyed by the road.

The original, declared servitude runs through an area that

Mark Attwood,

Comments, Emailed

The EIA study will look at all possible impacts

that may be caused by the proposed project

and mitigation measures will be proposed in

order to ensure that the environment is

protected.

All alignment alternatives have been designed

to limit the impact of fragmentation of land to

the minimum. Agricultural and soils potential

study is being undertaken and a more detailed

study will be undertaken in the EIA phase and

mitigation will be proposed.



is poor farm land, that has no irrigation, and therefore a far

smaller amount of arable land will be destroyed. The fact

that the Msholozi illegal settlement will have to be disrupted

is a problem, but how can an illegal settlement disrupt the

legal, planned law abiding processes of the country?

Property values in the whole valley will be negatively

affected by the "Alternative one" running through the valley.

We carefully investigated these sorts of servitudes before

buying our land, and find it un-acceptable that a road can

now be moved right onto our doorstep because of an illegal

settlement that has sprung up in the past 2 years, in the

middle of your planned, declared route.

There are many servitudes and rights-of ways across

different farms in the Heidelberg valley and these would all

need to be carefully considered to make sure nobody is

accidentally cut-off.

The sand river irrigation scheme would be seriously and

negatively impacted by the road. The scheme has

registered servitudes; surely you cannot just disrupt these

servitudes.

What will happen if a truck carrying hazardous chemicals

crashes off this road and the chemicals are spilled into the

canal and are inadvertently pumped onto hundreds of

hectares of farm land, permanently contaminating the land?

Will SANRAL pay for this?

The existing servitude for the P166 is the shortest route

with the slowest gradient and makes the most sense from a

Due to the issues associated with the P166

servitude in the White River area as identified

by specialists and various stakeholders alike, a

new alternative has been created (to be fully

assessed in the EIAR phase of the project) in

the White River area as a way of potentially

mitigating environmental impacts associated

with the P166 servitude in the White River

area.

It should be noted that for environmental

reasons, the Phumlani Alternative 1 has been

discarded and will no longer form part of the

project scope as investigated in the EIAR

phase. As a result, social-related issues of a

potential loss of property value in the

Heidelberg value are unlikely to materialise

due to the proposed road development.



road point of view.



I hereby notify yourselves that I am an interested and

Affected Party

I object strongly to the proposed road running through the

Heidelberg Valley for the following reasons:

Additional Noise pollution to our area

Additional pollution from vehicles and industry which may

develop as a result of the road

Detrimental effects on our natural wetland systems which

we have been trying so hard to conserve

Disruption to our wildlife in the area, it has only been

recently that we are starting to see an increase in endemic

species such as Grey Rhebok, Porcupines, Mountain

Reedbuck, jackal, Cape Hares, Striped Polecats and

Bushpig.

The road will bring with it criminal elements to the area as

with all other areas flanked by a major road

The pollution will disrupt crops and live stock which are

grown and reared on organic principles by introducing

foreign chemicals into the environment

Lloyd Turck, Managing

Member, Medical

Fundamentals,

Comments, Emailed

In the context of noise-related impacts one of

the most sensitive receptors are the noise-

sensitive residential areas, and these areas

will be the main focus of the noise impact

assessment study in the EIAR phase. The

noise levels from the projected traffic volume

will then be compared with the prevailing

ambient noise level to determine the intrusion

level at the different noise sensitive areas and

mitigation measures will be suggested.

Air pollution controls will be provided as

mitigation measures in the EIA phase.


wetlands has been assessed in the scoping-

phase wetland report, and will be further

refined in the EIAR-phase study.

Agricultural and soils potential study is being

undertaken and, more detailed study will be

undertaken in the EIA phase and mitigation will

be proposed.



The risk of major Hazmat spills increases exponentially

further threatening our conserved areas and our live stock

The proposed route would also reduce the production

capacity of the area significantly, which based on the

current food status in the country is detrimental to the

economy.

I join my fellow residents of the valley in stating that the

original route through the Msholozi area should be followed

as this was earmarked at the beginning of the project, the

area was illegally settled and the occupants were officially

and legally served eviction notices by the state, it is now the

state‟s responsibility at state expense to relocate these

settlers and route the P166 through its original route. I am

confident that should the P166 still route through the

Heidelberg Valley the residents will band together and take

up legal action.

I am not willing to have my home, my view and my

livelihood ruined for the sake of government convenience.


reasons, the Phumlani Alternative 1 that runs

through the Heidelberg Valley has been



phase. As a result, social-related and

biodiversity-realted issues as highlighted

above in the Heidelberg value are unlikely to

materialise due to the proposed road

development.

I am a resident at 22 Tafelberg Street, Colts Hill, in White

River and am concerned about the considerable increase in

traffic noise from the road which will pass right through an

established residential area.

I know that road noise is a consideration for any such

developments and in this case it will have a disastrous

impact. The enormously negative impact this will have on

the future value of my property also cannot be

underestimated.

Neil Malherbe,

Headmaster Penryn

Preparatory School and

Resident of White River

Comments Emailed





assessment study in the EIAR phase.

The noise levels from the projected traffic

volume will then be compared with the

prevailing ambient noise level to determine the

intrusion level at the different noise sensitive



It concerns me too that the proposed road will pass through

a wetland area, which is a space of natural beauty, with

numbers of species of wildlife which depend on the area for

their survival.

areas and mitigation measures will be

suggested.

The socio-economic study has identified the

potential negative effect of the road through

the White River area on property value. This

will be further assessed in the EIAR-phase

social study.

The sensitivity and potential impact of the

proposed road on the wetland running through

White River has been identified as a key issue,

to be assessed further by the EIAR-phase

wetland study.

.

It is interesting that three alternatives are being proposed

because of the informal housing which has sprung up near

the Rocky‟s Drift area, yet no others have yet been

proposed for the White River valley, where the road would

be most detrimental.

It is my suggestion that an alternative route be found further

to the east, which would allow a bypass of the White

River/Nelspruit urban area.

Neil Malherbe,

headmaster Penryn

Preparatory School and

Resident of White river

Comments Emailed









area.



The proposed route down the valley in White River through

the "Bird Sanctuary" passes right by my two town houses in

Impala Street: the restricted width of the valley and the

standard road reserve of 80 m would result in the road

being right up against my property's boundary;

The noise, vehicle fumes and general traffic disturbances

would be extremely unpleasant and would also greatly

reduce the value of these properties, should I wish to sell;

The ground structure in this valley is certainly quite

unsuitable to any road construction;

The valley is a natural storm water drainage system: any

road construction here would be extremely dangerous and

unwise, especially should we have a repeat of the type of

storms experienced in the last two years;

More importantly, I cannot see the justification of routing

this road through White River from the West: it would make

more sense to take the expected heavy traffic on the East of

White River, along the Spioenkop road, down through to

Plaston, past the KMI Airport and then on to Karino to join

A R McQueen,

Comments, Emailed









area.





social study

The design of the road in this area if this part

of the route was authorised for development,

SANRAL would need to take into account

stormwater inputs and drainage issues, as well

as the suitability of founding material. It should

be noted that there are a number of

biodiversity and social-related issues

associated with the development of the road

through the White River wetland which need to

be further assessed in the EIAR phase.



the N4; it would also serve to give access to important

industrial zones envisaged in this area;

It would be much wiser to upgrade the present R40 and a

lot less expensive: this road, in any case, is in urgent need

of upgrading;

The traffic on the R40 originates and terminates mostly from

either White River and surroundings or from traffic that

needed to do some business in White River even if it did

come from Hazyview; this does not include the heavy

vehicles currently coming from Phalaborwa

Since this latter traffic (the heavy trucks) will continue and

need the road bypassing White River, all efforts should be

made to upgrade the Plaston alternative as soon as

possible;

I do not believe the traffic between Hazyview and Barberton

is so great that it needs a new, expensive road such as the

P-166; rather the direct connection between White River

and Nelspruit is far more important; the relatively little tourist

traffic this road would take is also not a justification for the

road as most of the tourists would, in any case, want to stop

in either Nelspruit or White River.

I cannot see the residents of White River using the P-166 in

preference to the R40 as it would mean going out of your

way to join the road and to exit it to go to town: the route is

only advantageous for out of town business;

The routing of the P-166 would exclude trade for both

The project need and desirability under

Section 1.2 of the scoping report addresses

the issue of why R40 cannot be upgraded in

detail.



Nelspruit and White River businesses: not a good thing.

At the end of the day, I simply cannot see the justification

for this road on its presented suggested route. Yes, such a

road would be progressive but only if it directs heavy vehicle

traffic away from the towns and if the present road R40

were seriously upgraded. Are you aware that there are,

currently, intersections on this R40 between the outskirts

only of Nelspruit and White River? Some of these will soon

be so busy that they will be causing extremely dangerous

crossings.

Please take a note of these objections: they are all very

real!!

Need and Desirability

I find this section to be, at best, very sketchy, with a lack of

any indicators of need or desirability.

Please explain the significance of reference to the N2 in this

section? “In addition the R40 link to the other National Road

2 (N2) route is important as it is the main corridor from the

Richards Bay and Durban harbours.”

Please explain how the P166 will “relieve future N4 traffic

congestion”. This statement makes no sense as the

proposed P166 is a north-south alignment and the N4 is

east-west.

The Need and Desirability seems to be loosely based on

highly subjective opinion and contains no factual data at all.

Andrew Rossack,

Comments, E-mailed

The need and desirability section 1.2 in the

scoping report have addressed the issue in

details


parts of the Msholozi-Phumlani were allegedly

“illegally” settled. Nonetheless a housing

development & community now exists within

certain parts of the servitude and wider area

(in which alternatives to the existing servitude

in the Msholozi area are being considered)

and as such the potential social impact of the

proposed road on this community needs to be

considered by this EIA.

The Phumlani Alternatives were introduced



Furthermore it appears to contain numerous errors.

Based on the provided Need and Desirability, there is

clearly no need for the proposed road.

No evidence was presented of there being significant traffic

from the Hazyview area desiring to travel to Barberton.

The need for a direct route from “the south” to the north of

White River for tourism and goods transport via Badplaas /

Barberton is perplexing. The need for tourism is from KMIA

(airport) to Hazyview and destinations north. The need for

heavy transport is from Carolina / Machadodorp on the N4,

or from Hazyview to the N4 travelling east / west.

The planned route for the P166 undermines potential to

create an industrial zone near KMIA and to the east of

White River.

The planned route does not take into account existing

authorisations for business and residential developments in

the Karino area of White River – to the east.

Phumlani alternative

a. The report does not mention that the Msholozi settlement

is likely to be an illegal settlement (according to papers and

statements from Public Works and the municipality, and

lack of any EIA or authorisation).

The report and presentation at the public meetings indicate

a reluctance to move or alter the illegal informal

during scoping in order to allow for an

alternative solution to (mitigation for) the social

impacts relating to the relocation of a number

of households from the servitude and other

social issues such as the bisecting of a

community by a high-speed road. It is

recognised that the alternatives to the

servitude would be associated with other

environmental issues, especially social and

agricultural potential issues. In comparatively

assessing alternatives, all environmental and

technical parameters have been taken into

account. From an environmental perspective

Phumlani Alternatives 1 and 3 have been ruled

out and will not be considered in the EIAR

phase of the project. This means that the

existing servitude and Phumlani Alternative 2

will be assessed in greater detail in the EIA.

It should be noted that due to environmental

issues Phumlani Alternative 1 has been

discarded and will not be considered in the

EIR phase.



settlements, established in the servitude, and this is the

motivation for alternative routes. The provided alternatives

are through unproclaimed areas of high productivity

agriculture and on land where owners are existing

employers, rate and tax payers and whose industry is food

security and export. This appears to be unjust and morally

indefensible.

Phumlani alternative 1 is directed through an area of

irreplaceable habitat (see later regarding ecology). This

area was proposed and accepted in an RoD as an offset for

wetland and biodiversity loss caused by the Phumlani

development. (The RoD was appealed, but the MEC has

failed to address the appeal). I would like to know if this

assessment is able to „override‟ the past EIA‟s in terms of

this and other set aside areas.

Other alternatives

The report and proposals contain very little in the way of

alternatives. I do not feel that alternatives to small sections

of the road are a proper alternative. Does this meet the

requirements of NEMA? The entire routing should be

examined for alternatives, both on the east and west side of

the R40.

Alternative activities should also be considered. It is

suggested that the improvement of intersections and fly-

over‟s on the R40 would achieve considerable better traffic

flow and traffic safety.

Through the conducting of the P166 EIA the

proponent SANRAL has stated that the

authorisation of a route based on the existing

planning is being sought. However alternatives

have been identified in areas of identified

environmental sensitivity in order to allow for

the mitigation of significant environmental

issues associated with the existing servitude.

The identification of issues and impacts is an

iterative process and as such so is the creation

of alternatives – as a result of issues raised in

the scoping-phase public participation process;

a new alternative, the White River North

Alternative has been created, and will be

comparatively assessed against the existing

servitude in the EIAR phase of the study.

The application for environmental authorisation

is for confirmation of an existing planning and

partial declaration (“servitude”), whilst

considering adjustments for specific identified



Scoping study

The question of tolling needs to be considered in the

assessment. It is well documented from other toll roads in

the country that heavy vehicles often choose to avoid the

toll roads. Thus if tolling is applied, it is possible the road will

not carry the traffic intended. The tolling options need to be

modelled and included in the risks and need and desirability

sections. The current situation regarding the transport of

stone aggregate for the Spring Grove Dam on the N3/ R103

between Howick and Mooiriver has relevance here.

The history and development of White River needs to be

considered in context of the proposed routing. There has

been comment from municipality in the past that the wetland

sections would never be suitable for a road – this may have

affected decision making and subsequent township

development. Dating back at least 10 years, efforts have

been made by various parties, through the Mpumalanga

Wetland Forum, to have the servitude through the wetlands

de-proclaimed. The Department of Water Affairs (Then

DWAF, now DWA) commented in this connection, that the

construction of the bypass would never be allowed to go

ahead through the wetlands.

environmental concerns. The purpose of the

route, route alternatives and upgrading of R40

are all addressed in the need and desirability

section.

Tolling is a funding consideration, which will

only become relevant once construction of the

route is being considered. Issues related to

possible toll avoidance will be part of the

considerations at that stage. The current

application is limited to definition of an

acceptable route and accurate determination

of the road reserve required for the road.

Need and desirability has been expanded in

the document, including issues raised. The

need for both R40 and P166 is confirmed

therein. Traffic between Nelspruit and White

River can make use of P166 via the

interchanges proposed at all major road

crossings. Upgrading of connecting roads may

be considered during detail design, but does

not affect need for P166 route in principle.



Fatal Flaws

Access to road. Should the road be constructed as

proposed, it is felt that it is unlikely to alleviate any of the

existing traffic congestion.

This is for the following reasons:

i. (from a local view point it seems that) Traffic congestion is

largely time sensitive (mornings and evenings) and much of

this traffic is short distance within town (mostly school

related) or between the towns (White River, Kanyamazane,

Nelspruit). It is unlikely that anyone wishing to travel north

from Nelspruit to White River will travel south first to link into

the proposed P166.

ii. The current linkage to the N4 bypass is through a maze

of traffic circles and poorly utilized.

iii. The internal road network is congested prior to linking in

with any part of the proposed P166. The access roads to

the proposed P166 are likely to be inadequate for

reasonable access or preference over the existing R40.

Without considerable road development and improvement

within White River and Nelspruit, it is likely that the P166

would never carry the envisaged traffic. There has been no

evidence presented to suggest otherwise.

Landscape

It is likely that the development of the P166 would destroy

much of the existing landscape. Many landowners

purchased and developed in the peace and tranquillity

A number of I&APs have raised visual-related

issues. This comment refers specifically to the

potential impact of the proposed road on the

„sense of place‟ in the area. In order to

address these concerns, a visual impact

assessment study will be undertaken in the

EIAR phase of the project.

The conducting of an integrated transport

assessment is being proposed to the applicant

to consider the issues relating to traffic flows

and potential growth / change in traffic streams

in the future. This will examine issues relating

to the wider area, as raised by this comment.

The existing road proclamation covers a short

section at the southern start of the project, the

completed section between the old N4 and the

new N4 bypass, as well as the full section from

Rocky‟s Drift up to the northern end of the

project. The transport and economic study will

be conducted in the EIA. This should be

adequate to cover the need for this route.

Development and needs of the region, as well

as alternatives, have been addressed in the

expanded “Needs and Desirability” section.



offered in the agricultural environment. Many rely on their

properties for income. There would be no possible

compensation for the changes the P166 would make on

their enjoyment of their land or their ability to continue

farming etc.

Access and existing servitudes to various properties will be

destroyed or made inaccessible in some sections of the

proposed P166. These are not considered, but must be

extensively investigated.

Proposals

The principals of NEMA must be addressed and considered

in their entirety in the assessment. This is in addition to the

regulations. All mitigations and options MUST meet these

principals. The EIA must endeavour to record the entire

baseline environment (all aspects) in a repeatable method.

The proposed routing of the P166 appears to be guided by

some short existing servitudes, and not the development or

needs of the region. The correct need determination and

siting should be undertaken through and EMF and SEF.

Alternatives to the east of the R40 should be fully

considered and included in the EIA.

All specialist and EAP‟s CV‟s must be included in the

scoping and EIA documents.

Access to all affected properties will be

reinstated or alternatively compensated.

The EIA 2010 regulations guidelines are being

used to undertake this study.

CV‟s will be included as an appendix to the

Draft final scoping report.



Since WESSA has had no feedback regarding other areas,

such as the Maggiesdal alternatives, WESSA has no

comment to make on these issues.

Regarding Umsholozi, and the alternatives discussed, it is

our understanding that the entire township is illegal and

that an eviction order has been granted, but is unlikely to

be enforced. Therefore WESSA has no view on which is

the best alternative.

Regarding the alignment of the P166 through White River,

SANRAL should reconsider its designated route. Further it

should not try to bend environmental legislation in its favour

by failing to be totally honest about the route along the

wetland and its effect on that wetland. It is accepted that a

by-pass for White River has potential benefit but not as

currently proposed.

The route was planned in the 1980s. At the time there was

no environmental legislation in place, covering the

protection of wetlands and in any case the route was

outside White River, rather than through it. The wetland

area was once declared as a bird sanctuary by the then

White River authority.

Simon Evered, Wildlife

and Environment

Society of South Africa

(WESSA) Lowveld

Region, Comments

Emailed


parts of the Msholozi-Phumlani were allegedly

“illegally” settled. Nonetheless a housing

development & community now exists within

certain parts of the servitude and wider area

(in which alternatives to the existing servitude

in the Msholozi area are being considered) and

as such the potential social impact of the

proposed road on this community needs to be

considered by this EIA.

The potential significant impact of the

proposed road on the wetland in the White

River area is acknowledged, and will be further

assessed in the EIAR-phase wetland

assessment.



The road was planned as a by-pass, and therefore should

not go THROUGH the town now that the town has grown.

According to feedback provided by the

applicant on this comment “Bypass” is

somewhat of a misnomer, as it is not

necessarily intended to bypass a town like

White River. The issue really is to define a

mobility road along a corridor that is viable

(technically and environmentally) and

affordable, and because a route through

already built-up areas is in most cases neither

environmentally nor financially viable, a route

is often defined around the developed area.

That is why the P166 planning was done pro-

actively in the 1980‟s, to define a route that

would be viable and could be implemented

when required, and this planning was intended

to guide and inform development accordingly.

If the route is moved northwards, the same

“bypass” argument may likewise be raised

against such realignment in 20 or 30 years

time. That is the nature of development – it

targets new areas that become attractive as

circumstances change, and development will

therefore over time straddle any route. Many

examples exist where mobility roads were

planned and eventually implemented through

erstwhile rural or semi-rural areas that have

since been fully developed all along the route

(e.g. N1 through eastern areas of Pretoria or

the N1 Johannesburg ring road, and more

recently the N1 at Polokwane). The Mbombela



Residential dwellings along Impala Road are close to the

proposed alignment, some actually adjoining. This

includes the new township in Kingsview Extension, where

homes will be bordering the servitude.

There will therefore be a huge noise impact all along the

2km of wetland that SANRAL plans to invade. This is

unacceptable for residential townships.

Two additional townships are planned for the north west

side of the wetland valley, each of which will effectively

adjoin the planned route.

Property values will be seriously affected negatively all

along Impala Road and in the Kings view Extension. This

is in spite of the fact that the existing plan has been known

about for some time.

NEMA and the regulations explain what conditions and

measures must be considered when CROSSING a

wetland. Nowhere in any environmental legislation is the

concept of routing a road ALONG a wetland, as SANRAL

seem to think is acceptable, considered. SANRAL is being

Spatial Development Framework, which

includes White River, has recognised and

accepted the P166 concept and proposed

alignment over many years, and defined the

spatial planning accordingly.

Residential development abutting any major

route will be subject to noise impacts. As the

route has been public knowledge for many

years, this factor should have been taken into

consideration in developments like Kingsview

Extension. Noise mitigation will be considered

during detail design of the road. THE EIAR-

phase noise study will consider the potential

impact of the proposed road on the noise-

sensitive receptors in the White River area.





social study

The potential significance of the impacts due to

the proposed alignment of the P166 road

longitudinally through the wetland in White

River has been raised in the scoping-phase

wetlands study, and it is acknowledged that

roads that traverse wetlands longitudinally



stubborn in trying to run the road "alongside the wetland" in

order to preserve their paid-for servitude and to save

themselves work in a redesign.

SANRAL admits to a required servitude of 80 metres to

build such a road, which will eventually have four lanes.

They also say this can be reduced to 60 metres in special

circumstances. Since the valley is not more than 150

metres wide, the building of a road even of 60 metres width

“along one side” will reach the stream at the bottom of the

valley, considering that a large amount of fill will be

required to level the roadway itself, and construction

vehicles will need room the operate. Thus all wetland

features on the south east side including the valley bottom,

will be destroyed.

It is accepted that at the lower end of the valley the wetland

has been considerably compromised by micro farming

activities, presumably by residents of the new township.

This is NOT the case for the remainder.

From a purely ecological point of view, there exists in the

wetland a rare species of shovelnose toad, and rare Aloe

simii exists there. These alone are good reasons to

reconsider the alignment.

rather than crossing them perpendicularly are

likely to be associated with much greater

impacts. This issue will be further assessed in

the EIAR-phase surface water study, and is

one of the considerations in the creation of a

new alternative to this section of the existing

servitude in the White River area.

The actual footprint of the road will be

determined by the vertical and horizontal

alignment of the road as well as the width of

the road. At this stage the ultimate design is to

provide for a 6 lane divided road. This can

however be mitigated by special designs

which we believe will need to be provided in

due process and as required.

The presence of these 2 species is

acknowledged and has been considered by



SANRAL must therefore recognize that the road as

planned is entirely out of date and environmentally

unacceptable, in spite of their servitude and expropriations

in place. Another route must be considered.

It is therefore counter-proposed that the road be re-aligned

further to the north-west, past all existing smallholding and

through forest land next to Uplands. It is accepted there is

water there and this must be properly studied to mitigate

impacts and decide the best route.

The Hazyview to Barberton kind of thinking is also out of

date. Traffic coming from the northern Lowveld mostly

wants to get onto the N4 and go to Maputo. It is thus also

counter-proposed that a White River by-pass be routed to

the east of the town, using existing roads such as the short

section connecting the Karula-Plaston road to the Numbi

the biodiversity study. Biodiversity issues

relating to the wetland were one of the key

factors in the consideration and creation of a

route alternative to the existing servitude in the

White River area.










iterative process and as such so is the creation

of alternatives – as a result of issues raised in

the scoping-phase public participation process;

a new alternative, the White River North




Please refer to response above regarding

route planning.



section of the R538. Thereafter the R538 to Karino can be

widened and straightened to the required standard.

WESSA thus insists that a full ecological examination of the

wetland through town and any other water bearing land, be

carried out without bias to the SANRAL plan. Further traffic

studies must be updated so that the destinations of traffic

through White River are understood. I can assure you that

Barberton is not high on that list. The noise impact on those

homes adjoining the existing alignment must be fully

reported in the scoping report and the residents so affected

should be advised of their future expectations.

An integrated transport study is being

proposed to address the traffic flow issues

relating to the proposed road and the future

traffic flow needs. The R538 as an alternative

has been discussed in the „Needs and

Desirability” section of the Draft Final Scoping

Report.



A major concern for me is the process by which this

recommendation was reached, as well as the

recommendation itself. The previous proposal to follow the

servitude was made available before the scheduled meeting

at Bundu Lodge, and many landowners in the Heidelberg

valley expected the impact to be relatively small for them.

No mention was made of a road to go through the actual

valley. So many landowners did not attend the meeting as

they regarded themselves as being not greatly affected.

It seems to me that a recommendation was reached that the

Heidelberg Valley route was to be preferred, and that further

“alternatives” were designed in such a way as to justify that

recommendation. So they are not really alternatives at all.

This is at best disingenuous. To give an example: part of

alternative 3 is shown cutting in a straight line through a

number of smallholdings from the R537 Sabie road thus

exaggerating the impact there. If the route south from the

servitude between Kosmos Macadamia and the complex

opposite on the R537 Sabie road were to follow a gentle

arc, to the point where the proposed route continues as a

long sweeping arc around the koppie to the Rocky Drift -

Heidelberg road, the impact is dramatically reduced. It

would appear that 4 or landowners would be affected. The

impact on the number of farms, and property owners would

appear to be fewer than the Heidelberg Valley route should

this small deviation be followed.

Of course this does not include illegally occupied land. But

why should property owners in Heidelberg Valley suffer

Dave Goodwin ,

Comments, Emailed

Phumlani Alternative 1 affects the Heidelberg

Valley. The Phumlani alternatives were

introduced early in the scoping process, as a

result of potentially significant issues raised by

certain project team specialists. These were

then scoped by all of the specialists as part of

their scoping-phase specialist studies, and

these alternatives were included in the draft

scoping report that was released prior to the

meetings alluded to.

The comparative assessment of alternatives

has been undertaken by considering inputs

from all of the different specialist disciplines in

terms of a preferred alternative from their

specialist perspective. Technical

considerations have also been taken into

account. In the case of the Phumlani

alternatives 1 and 3 that traverse the

Heidelberg valley and the smallholdings

respectively have been ruled out from an

environmental perspective by the proponent

and will not be taken further into the EIR phase

of the project.







when they have followed correct legal procedures,

purchased their properties, and invested in the

infrastructure and improvements to these properties and

paid levies and municipality rates for many years to the

benefit of the wider community?

Alternative 3 skirts a large, established, growing industrial

area (Rocky Drift) and then follows an existing peri urban

corridor for a significant part of the route. A relatively small

amount of isolated agricultural land would be affected, and

this land is so positioned that it is likely to become part of

the peri urban corridor in the not too distant future. One

would expect that this alternative road would not be out of

place as part of the infrastructure and development of an

industrial and peri urban area: the fact that the original

proposed route followed a series of established or proposed

townships, or informal settlements, was used previously to

justify its close proximity to these. The impact of this

alternative should be reassessed in the context of the

industrial and peri urban environment and development,

and deviations to the shown route explored.

There are many other issues that come to mind -

Proposed alternative 1 will destroy a large area of existing

highly productive agricultural land, far more than either of

the two other alternatives. In addition, it would also fragment

much land so as to become unviable agricultural holdings.

It will impact badly on wildlife habitat and natural wetlands,

which are particularly precious as they are so close to urban








alignments. As stated above, the Phumlani

Alternative 1 has been discarded.

The current EIA aims to find a solution that is

as environmentally sustainable as possible,

taking into account the impact on all affected

parties, including factors such as capital

expenditure into properties, and their



and industrial areas.

There will be no benefit to the residents of the valley, in fact

it would badly affect the environment, with increased noise

and air pollution, and would also affect the property values

of those who have paid for their land and not illegally

occupied it. It would appear that more property owners will

be impacted by alternative 1 than by either of the other

alternatives.

The proposed “alternative” routes, along with the original

servitude route, should be revisited in an open, transparent

and inclusive forum; with a view to assessing their viability

as alternatives, not merely manipulated as justification for a

suspect decision that appears to have been already made.

associated value.

The social study has considered such factors

in the comparative assessment of the

Phumlani alternatives. These factors have also

been taken into account in the technical

evaluation of the alternative by the proponent –

these factors have contributed to this

alternative being ruled out from an

environmental perspective entailing that it will

not be taken further in the EIR phase of the

project.

This EIA has attempted to comparatively

assess alternatives in an equitable and fair

manner that takes all environmental and other

factors into account. For environmental

reasons two alternatives (Phumlani Alternative

1 & 3) have been ruled out for consideration in

the EIR phase of the project.

We reside at Mount Anderson Street, W/River, & the

proposed alignment will be directly adjacent to our

complex.

The route will go through a wetland area.

The current sense of place would be disturbed.

Leandri Joubert,

Comments &

Registration form

Emailed

The potential impact of the road on wetlands

has been scoped in the wetland study, and a

number of potential impacts have been

identified. These impacts will be further

assessed in the EIR-phase wetland study.






„sense of place‟ in the area. In order to address

these concerns, a visual impact assessment

study will be undertaken in the EIAR phase of

the project

Effect on water source (borehole).

Safety & security, noise pollution and wild life in the area.

Is this project economically viable – most traffic on R40 are

commuters working in Nelspruit.

Route & number of affected properties.

Linda Liversage,

Comments and

Registration form

Emailed

Residential development abutting any major

route is subject to noise impacts, but the route

has been public knowledge for many years.

Noise study has been undertaken and detailed

assessment will be undertaken during the EIA

phase.



the White River area on property value and

other social issues such as safety and security.

This will be further assessed in the EIAR-

phase social study


proposed in order to examine transport-related

issues regarding the proposed route and how it

relates to existing arterial routes such as the

R40 road

I wish to object to the proposed route in its entirety and

suggest the plan is anachronistic, unnecessary and ill-

considered. I would submit that the whole plan be dismissed

as a waste of time and public money and that an inter-

departmental think tank be established to look at the best

Peter Doble, Comments

E-mailed

The need for the route, and the alternative to

upgrade R538, have been addressed in the

updated “Needs and Desirability”‟ section of

the Draft Final Scoping Report. An integrated

transport study is proposed in order to address



way of meeting the challenges of economic growth,

transport management, traffic volumes for the future.

I would further suggest that more time and effort goes into

reinforcing, redefining and developing the current road

systems than spending vast sums on parallel routes which,

in current form, will totally destroy and disrupt the

communities on which they encroach.

There is absolutely no evidence that a new north/south road

is required and it should be incumbent on SANRAL and the

national and provincial departments of roads and transport

to conclusively prove that a case exists before even

allocating funds or going through the public participation

process.

As outlined in the White River Residents Association

response, with which I concur, there is no actual or

economic reason for the link between Hazyview and

Barberton. The redeveloped Port of Maputo is the entrepot

of choice for the northern hinterland and has been

championed by Mathews Phosa through the MCLI. Most

major transport is diverting to the north of White River to

Karino and the N4 eastbound. The pressing issues are the

misuse of smaller provincial roads and the future congestion

of the N4 especially at the Crocodile Gorge. There is no

economic or certainly environmental benefit to linking with

Richards Bay and Durban.

The effect of a north/south bypass – in any form close to

the traffic flow-related issues that have been

raised.

A social study has been undertaken which

highlights issues related the potential

presence of an arterial road through the White

River area. These issues will be further

investigated in the EIAR-phase social study

and mitigation measures will be provided if

relevant.



habitation - will be devastating to White River and its

population, fragmenting the community and ruining its

surroundings.

Having lived in Europe where traffic volumes hugely exceed

South Africa, it has proved obvious that increasing roads

and their capacity simply breed more volume and greater

problems. The human cost to mental and physical health is

incalculable.

The noise factor and stress levels have not in my opinion

been addressed in the slightest, particularly as there is

nothing remotely comparable in the ambient environment.

While the route(s) through the illegal township of Msholozi

effectively dismisses the destruction and loss of vital

wetlands, it painfully struggles to find a way through the

morass of congested human habitation which has been

allowed to grow unchecked. If Sanral and government

authorities were so keen to preserve this planned roadway

route perhaps earlier and stronger action should have been

taken to secure it. Now it just becomes a series of

expensive twists to minimize the mess to which it has

contributed.

The proposal as it stands makes a joke of the words

“environmental impact.” It should not even have been

submitted but returned to the proposer as an affront to

intelligent planning and human dignity. It breaks every rule

The preliminary noise sensitivity analysis of the

study area was conducted on the proposed

P166 main route and its alternatives. The

results of the preliminary analysis are

discussed in section 8.2.2 of the scoping report

and more detailed assessment will be

undertaken in the EIA phase.



in the environmental handbook.

In conclusion, I would propose that the question of the P166

in any guise should be returned to the drawing board and

re-assessed with vision and a collective responsibility to

construct a form of integrated planning without historical

fixations, financial constraints or detriment to the

established communities. Any future route which can be

justified simply needs to use the enormous external space

beyond the current area of residential development.

Notwithstanding the above, and with due consideration of

the fact that the above township is a proclaimed and

developed township for industrial purposes, residential

purposes and special uses, the aforesaid township and

development is directly and extensively affected by the said

road proposal.

Our client strongly objects to the said proposal for the route

determination as it is currently presented for the following

reasons:

Since 1988 the circumstances and conditions relating to the

property on which Stonehenge Extension 4 was proclaimed

have changed extensively to the extent that the

Mpumalanga Department of Public Works, Roads and

Transport supported the said township confirming the

expectation that the by-pass road will never be constructed.

The township was subsequently approved and proclaimed.

The erven in the township has been developed for

industrial/commercial and business related uses which


Nuplan, Comments

Emailed

SANRAL, being the applicant in this project,

have obtained legal opinion on the validity of

the existing declaration. According to this

legal opinion, the declaration of the road

across Stonehenge Extension 4 was never

rescinded and is therefore still valid. The land

owner at that time was compensated for the

impact of the declaration. Any further dispute

in this matter will need to be resolved through

legal processes.

SANRAL, being the applicant in this project,

have obtained legal opinion on the validity of

the existing declaration. According to this

legal opinion, the declaration of the road

across Stonehenge Extension 4 was never



constitutes income generating properties of high value.

Further information obtained from the above consultants

confirmed that Stonehenge Extension 4 is extensively

affected by the current proposals, especially the proposed

Cromdale Intersection which will probably result in the

following:

i. Total ignorance of the legal status of the township

and the developed state thereof as confirmed by

the capital investment made in respect of buildings

and structures.

ii. A legal process with regard to the validity and

legality of the township as supported by the former

custodian of the then provincial road namely the

Mpumalanga Department of Public Works, Roads

and Transport.

iii. A valuation process to determine the value of the

investment made in terms of buildings,

infrastructure, improvements, including possible

relocation factors to relocate what currently

comprises the township. This may amount to a

value that will be detrimental to the present route

determination.

The alternatives as presented in the Environmental Scoping

Report dated February 2013 (Fig 4: Locality Map with

Alternatives) does not present any alternatives for the

Cromdale Intersection. In terms of the general requirement

for alternatives this requirement should also apply to the

Cromdale Intersection as it have an extensive and drastic

rescinded and is therefore still valid. The land

owner at that time was compensated for the

impact of the declaration. Any further dispute

in this matter will need to be resolved through

legal processes.









financial and practical impact on Stonehenge Extension 4

and the surrounding areas. The aforesaid alone justifies the

presentation of alternatives for the said intersection in

relation to the township. Our objection is therefore also in

respect of the lack of alternatives for the Cromdale

Intersection.

According to information relating to the Cromdale

Intersection no indication is given as to how the township

will obtain access should the Cromdale Intersection

proposals be implemented. The lack of proposals in respect

of access to the township, of which ease and convenience

of accessibility, including visibility and exposure is extremely

important, is disturbing to say the least.

It cannot be expected from an affected land owner to

positively or otherwise comment or react on the route

determination process when detail lacks.

Although a route determination process is followed, it is

flawed in the following manner:

i. The route determination process is of a holistic

nature without sufficient detail as to how individual

properties are affected; meaning that in certain

instances fatal flaws may not have been identified

or determined yet. What if flaws are found in the

future?

ii. If the route has been determined and authorized by

the relevant authority, this authorization is followed

by further environmental impact assessment



The Maggiesdal Alternative was created to

address soci-economic issues related to the

existing servitude in the sout-western part of

Mbombela. The issue relating to the potential

socio-economic impacts on Stonehenge

Extension 4 will be further assessed in the

EIAR phase study.


iterative process and as such so is the

creation of alternatives; should fatal flaws be

identified by the further aspects of the study in

the EIAR phase, potential mitigation and ways

in which to avoid the impact will be examined

by the study.



processes and detail designs with a view to

construction. What if fatal flaws are found then and

a re-determination of the route or sections of the

route is required? This is a very important aspect

and should not be ignored as far as it relates to the

Cromdale Intersection and Stonehenge Extension 4

as potential impacts and implications cannot be left

for future environmental impact assessment

processes relating to the design phase. It creates

an element of uncertainty.

iii. The lack of sufficient detail does not allow affected

land owners to appropriately comment on the route

determination process and to assume that detail

aspects and future implications will be dealt with in

the future where and when further opportunity for

participation and input may be too late.

You are therefore informed by this letter of presentation that

the registered owner of Erven 799, 800 and 801 is not in

support of the route determination process for the proposed

P 166-2 by-pass road as the proposals, and especially the

proposed Cromdale Intersection have an extreme impact

and implication on the properties and development

comprising Stonehenge Extension 4.

I am a resident at 22 Tafelberg Street, Colts Hill, in White

River and am concerned about the considerable increase in

traffic noise, from the road which will pass right through an

established residential area. I know that road noise is a

consideration for any such developments and in this case it

Neil Malherbe,

Comments E-mailed

The potential impact of the road on noise-

sensitive receptors has been highlighted in the

scoping-phase noise specialist report. The

White River area has been highlighted as a

noise-sensitive receptor location, and as such



will have a disastrous impact. The enormously negative

impact this will have on the future value of my property also

cannot be underestimated. It concerns me too that the

proposed road will pass through a wetland area, which is a

space of natural beauty, with numbers of species of wildlife

which depend on the area for their survival.

Its interesting that three alternatives are being proposed

because of the informal housing which has sprung up near

the Rocky‟s Drift area, yet no others have yet been

proposed for the White River valley, where the road which

would be most detrimental.

It is my suggestion that an alternative route be found further

to the east, which would allow a bypass of the White

River/Nelspruit urban area.

will be further investigated in detail in the EIA

phase.

Based on specialist inputs as well as public

comment and feedback relating to areas of

environmental sensitivity, a number of

environmental issues were identified in the

area where the P166 servitude traverses the

White River area, in particular relating to where

the servitude runs directly through a wetland.

Accordingly a new alternative, the White River

North Alternative has been created, and will be



Devaluation of property

This property, at the moment, is defined as an agricultural

property and the proposed road would be cutting the

property in half. Unfortunately, this property is not of a size

that can handle this and would have major drawbacks not

only in the day to day running of the property but also

should we wish to sell. A small portion of this property has

already been cut off by the present White River / Hazyview

Road and the proposed new road would be again cutting

the property but this time more drastically.

John Millett, Comments

Emailed

The study takes into account the rights of all

landowners, as well as taking into account

factors such as capital expenditure into

properties, and their associated value.

In addition, the socio-economic study has

identified the potential negative social and

economic effects of the road, in particular on

property values. This aspect will be further

assessed in the EIAR-phase social study. This

issue raised will be further investigated by the

social specialist in the EIR-phase social study.



Environmental Impact

The proposed new road would interfere with a present

wetland and no proper research has been done as to

whether there are any endangered species either of plant

or animal.

Fire Hazard

As mentioned earlier the proposed new road would be

cutting this property in half and should a fire occur amongst

the timber both traffic and people would be in danger of

If this issue is determined to be

environmentally significant, mitigation

measures to prevent the impact will be sought.

This may include the consideration / revision of

alternatives. It should be noted that the

creation if alternatives is an iterative process

that is not necessarily restricted to the scoping

phase of the project.

It should be noted that a new alternative to the

existing servitude in the White River area has

been created, and this alternative would have

a different impact on the said property.

The scoping-phase wetland and biodiversity

studies have identified high-level impacts on

wetlands and the biodiversity contained within

them. Certain areas have been identified for

further more detailed assessment; this

includes areas of high sensitivity and in a

biodiversity context where endangered species

are known to occur.

Safety and fire issues will also be considered

in the EIAR phase and mitigation will be



losing their lives.

When a fire breaks out in the area all the surrounding

neighbours come to help and it would mean a lot of traffic

crossing to and from on your proposed road. I am sure you

will know how dangerous fires are in this area. Very often

the helicopters are called out to help extinguish the fires

and traffic on the road could by accident have a bucket of

water thrown on them. Smoke from the fires could also be

a hazard.

Timber

This property has a fair amount of timber and this would

mean that labourers, tractors and lorries would be

constantly crossing your proposed road in order to carry

out their duties. This, of course, could be a major problem.

Should a bridge be built either over or under the proposed

road this could become a fire hazard as should the fire be

too close to the bridge the appropriate vehicles would not

be able to attempt to contain the fire which could then run

amok causing untold damage.

Run off water

One wonders what the contamination of agricultural land

would be as a result of the proposed road.

provided including those that are raised by the

I&APs.

Runoff of contaminated stormwater could be

an issue with the new road, especially if storm

water containing pollutants such as oils or

other hydrocarbons were to be discharged into

adjacent agricultural lands. The EMPr which

will be developed in the EIAR phase of the

study will specify mitigation measures relating

to stormwater issues and effect on adjacent



Noise pollution

The amount of noise experienced from the White River /

Hazyview road is phenomenal and with the proposed new

road on the other side of the present dwellings this could

become a problem.

Safety of the present buildings

I would like to point out that my present dwelling was built

80 years ago (and has been in the family for three

generations) since when the quantity of traffic has

considerably more than doubled during that period. The

effect of the number of passing vehicles could be

responsible for a number of cracks appearing in the walls

and floor. Should the vibrations from vehicles commence

from the opposite side of the house (as per the proposed

new road) this could do immense damage to the dwelling.

Having pointed out the dangers of the route of the

proposed road I would now like to propose alternative

routes.

From looking at the map I would suggest that the proposed

road continues on the N4 and then branches off towards

Plaston onto the R538. This route could then have a flyover

agricultural land. The EMPr will specify

procedures for remediation of spills of

hazardous materials as well as for sustainable

storm water drainage.

The noise-related issues in this area are also

recognised in this area. These issues will be

further investigated in the EIAR phase

specialist studies, and potential mitigation

measures sought.

The issue of the R538 road as alternative has

been addressed in the updated “Needs and




towards the KMIA airport which would be advantageous to

the tourist industry. This route is also the most direct route

to Hazyview and would be utilized by the trucks carrying

magnetite which are at present doing so much damage to

the White River district roads which were not built for this

purpose. An added advantage would be a well built road to

the Numbi gate, again an advantage for tourists and income

to the area.

Another suggestion would be for the proposed road to join

the Hazyview road at the new Casterbridge roundabout.

However, the former alternative proposed route seems to

me the most sensible one and I feel that there would be far

less objection from the local community. This is also the

shortest route to Maputo harbour which would save the

country foreign exchange from the consumption of fuel.

Report.

An integrated transport planning study has

been proposed to examine issues relating to

traffic flows and how the proposed

development will affect the baseline scenario,

and to assess whether it satisfies the future

network planning requirements of the area.

We also would like to emphasise that the route of the P166

through the northern suburbs of White River is undesirable

and unacceptable. This would create a major impact on the

wetlands and declared reserved areas of the town,

especially during the construction period. Apart from the

noise of general traffic, as a general nuisance, the

congestion on the limited access points at peak times would

be equally undesirable. The planned route is neither serving

the White River community nor far enough removed from it

to be acceptable.

We reiterate the desirability of our preferred eastern bypass

of White River, to reinstate the R538, devastated by heavy

traffic. This restoration will reinstate access to tourist lodges

Robin Clanahan, White

River Ratepayers

Association, Comments

E-mailed

The open area to the north of White River

through which the existing servitude passes

has been identified as an area of potential

impacts in a number of contexts by a number

of the EIA project team specialists, including

the biodiversity, wetland, and social specialist.

The noise-related issues in this area are also

recognised in this area. These issues will be

further investigated in the EIR phase specialist

studies, and potential mitigation measures

sought.

The R538 road as an alternative has been

addressed in the updated “Needs and




in the area, which have been critically impacted by this, to

the extent of some being forced to close.

The DSR addresses alternatives as being alternatives to the

selected route within sections of the route. This is neither

the letter nor the intention of the law – alternatives to the

whole route and the necessity for the development have to

be addressed, as is acknowledged in the DST by the short

discussion on the “No Go” alternative.

Report. Alternative routes have been

addressed in the updated “Needs and


Report. Although it has been considered in

the draft scoping report, the No Go alternative

will be explored in further detail in the EIR

phase An integrated transport study has been

proposed in this context to examine issues

relating to traffic flows and how the proposed

development will affect the baseline scenario,

and to assess whether it satisfies the future

network planning requirements of the area.

It should be noted that due to the above-

mentioned environmental issues associated

with the existing servitude through the White

River area, have resulted in the creation of an

alternative to the north of White River, to be

assessed in the EIAR phase of the project.

The construction of the P166 as a non-toll road is in

general supported.

The purpose of the P166 road should be revisited. It should

not mainly be a by-pass road for traffic around Nelspruit

and White River but provide a meaningful alternative route

for traffic between Nelspruit, Rocky Drift and White River.

Sufficient and functional accesses onto and from the P166

must be provided along the alignment. Feeder roads to and

from the P166 must also be upgraded as part of the scope

of work for the P166 to ensure easy utilisation of the road.

Kruger Lowveld

Chamber of Business

and Tourism, Comments

E-mailed

Tolling is a funding consideration, which will be

fully investigated once construction of the

route is being considered.

Regular access via interchanges is planned



The alignment of the road along the originally planned

servitude through White River is not supported. The

environmental and socio-economic costs of this proposal

will be unacceptably high.

An alternative alignment north-west of White River, linking

the Sabie road with the R40 near Caster Bridge should be

investigated. This alternative must be included in the

Scoping Process and not only during the EIA evaluation

Alternative 2 (just west of original alignment) for alignment

pass Phumlani is supported. Alternatives 1 and 3 are not

seen as viable and will have significant socio-economic

implications.

The original planned alignment for the southern section

(Maggiesdal) is likely the most viable. Further consultation

with land owners is however required. A targeted

consultation meeting with the Members of the KLCBT is

requested.






White River area, in particular relating to

where the servitude runs directly through a

wetland. Accordingly a new alternative, the

White River North Alternative has been

created, and will be comparatively assessed

against the existing servitude in the EIAR

phase of the study and the identified I&AP will

be consulted.

In the case of the Phumlani Alternatives 1 & 3

these have been ruled out from an



of the project.

The scoping-phase public participation period

has passed. However the Kruger Lowveld

Chamber of Business and Tourism is

recognised as being an important stakeholder

and will however be encouraged to submit

their comments in writing and the EAP will

ensure that the Kruger Lowveld Chamber of

Business and Tourism is fully involved in the



EIR-phase public participation process.

I object to the current proposed route for the P166 Road

from where it crosses the road to Sabie and passes through

the wetland and joins up to the R40 next to the Casterbridge

Lifestyle Centre.

My objections to this part of the proposed route is on the

following grounds:

This route will have a massive negative impact on the

precious wetland which it is going along - not through or

across. Not only is this a green lung for White River and a

Nature Reserve much used by the community, but all

wetlands are vital to the health of our precious rivers. There

is no design possible that could keep the road going

through that Wetland without irreversibly destroying it.

In addition I am aware that it is one of the few places that

Aloe simii are still found in their natural habitat. Plus there is

a Rare frog inhabiting the wetland. These are very

significant facts that should immediately prevent this route

Kate Barnett, Chairman

of the Environmental

Committee of Uplands

College, Comments e-

Mailed







where the servitude runs directly through a





phase of the study.

The potential significance of the impacts of the

road on the wetland running through White

River has been raised in the wetlands report.

This is one of the primary reasons for the

creation of an alternative route to the existing

servitude for consideration in the EIAR phase.

The presence of Aloe simii in the wetland has

been noted in the scoping-phase biodiversity

report, and the presence of the threatened frog

species has been included based on I&AP

input.



being used and any other route that passes along a

wetland.

This route is proposed as a BYPASS of White River and

Nelspruit, however the route is not a bypass of White River

at all. It is cutting between a number of suburbs and a large

number of houses that lie not only adjacent to the wetland

route, but also the large number of Estates and houses that

have been developed slightly further to the North and North

West of White River since the road was originally proposed.

I suggest that since there has been significant development

to the west of White River the number of people being

affected by this road is much larger that originally realised.

The Estates I am referring to are WHite River Country

Estate - a suburb of White River, Sheffield, Summer

Breeze, Pomeshana, Recoletta, Sonyaka, Longmere

Estate.

From the Public Meeting held at White River Primary , I

gathered that it was originally intended that this route link up

with the road to Numbi Gate and the Masoyi area as that

road was thought to become the main route to Hazyview

etc. The R40 is now the planned main arterial road to

Hazyview and beyond and so the P166 no longer needs to

rejoin the R40 at that intersection next to Casterbridge.

Therefore many other options further west and north

become available if you are still seeking a Westerly or

Northerly route around White River and can join the R40

further north. I urge SANRAL to consider alternative routes

Potential visual issues relating to the road

have been raised by a number of Interested

and Affected Parties, and as such the need to

undertake a visual study has been raised in

the plan of Study for EIA.

An integrated transport study has been

proposed for the next phase of the EIA in order

to address issues relating to traffic flow needs

and whether the proposed P166 route satisfies

the needs of the wider area in this context.







phase.

The current proposal maximally utilises the

existing proclaimed and compensated road

reserve. The alternative avoiding the wetland

may however link up with R40 further to the



that are actually bypasses.

We are already affected by the massive number of haul

trucks on the R40 in terms of noise pollution and reduced

safety on the roads into and through Whiter River and so I

object to a road that increases both these aspects.

There is already a proposed plan and route for a bigger

road to the east of White River for which landowners were

also already paid. The area around the KMIA airport is

proposed or even scheduled as an industrial area and the

Kabokweni Industrial area is spreading west. For this

reason SANRAL should be investigating moving this bypass

to the East of White River not insist ondeveloping it through

the residential suburbs of White River.

north. Connection of R538 to Numbi with

P166 will however still be required.

The proposed road is planned as a mobility

road, which would improve accessibility and

mobility between the White River and

Mbombela / Barbeton areas. As such the road

is proposed to reroute long haul traffic off the

local accesses through White River, and the

road may have a positive impact in this

context.

R538 as alternative has been addressed in the

updated “Needs and Desirability” section of the

Draft Final Scoping Report

Consultants to liaise with Sembcorp Silulumanzi regarding

future services – sleeves are to be provided for this

purpose.

Existing services within the reserves are to be identified, if

relocation is required service drawings are to be submitted.

Way leaves are to be submitted for sections inside the

Nelspruit Town Area

Aneesa Haroon,

Scientific Services

Department, Comments

E-mailed

SANRAL will utilise a proclaimed road reserve

for the road, or proclaim a new road reserve if

necessary services protection or relocation

and way leaves will be addressed during detail

design.

My concern is with the proposed portion between R537 and

the R40, which passes just north of Ext 18, then between

the two portions of Ext 16 and below Kingsview extensions

Mr. Llewellyn Hunt,

Faxed letter:






2 & 3 and below Sondersog. The original planning of this

route was done before 1983 and as far as I could ascertain

it was a political decision also influenced by vested

interests.

This portion of the route is in a region of extremely

unsatisfactory ground conditions for building anything on, if

I were to be asked to value the portion, I would most

probably decline.

An excellent example of the type of terrain is to be seen at

Erf 21 Parkville, at the corner of Elands & Impala Streets

and the unimproved land opposite.

There is a spruit running the length of the route and it

would need to be crossed a few times at narrow angles.

There are also a number of dams in the spruit which are

shown on the 1:50000 topoadastrial map which would be

adversely impacted by such a road.

Concerning the soil conditions, I need to draw attention to

the book by Dr. A.B.A. Brink, Engineering Geology of

Southern Africa, pages 72 to 77, where he records the

leaning of the old water tower due to the fact that the

residual granite had a collapsible grain structure and the

measures made to correct this.









The alignment of the existing servitude through

the White River wetland and the channel

(spruit) contained therein has been highlighted

by the scoping phase wetlands study as an

issue of potential significance that needs to be

assessed in greater detail, due to the

significance and high intensity of the potential

impact.

The nature of the substrate in the area around

and within the wetland in White River is

acknowledged as a potential issue. The

comparative assessment of the existing

servitude through the White River area and

the newly created White River Alternative will



These conditions are encountered all along the valley from

the water tower at the top end of Frank Townsend Street in

the west, to and beyond the White River in the east and to

build a road along this route would require the removal of

millions of cubic metres of these thixotropic soils and

importing many more suitable to build up to the levels

required.

Such a road could be built by constructing an elevated

highway, but to construct such a double carriage way wide

enough and strong enough to handle the heavy ore trucks

heading for Maputo, would be greater in great cost than the

elevated railway sections of the Gautrain, and then it would

still not Bypass the town.

take into account environmental, as well as

cost and technical issues such as are raised

here.

The project affects resale of my property. Cannot see the

benefits of this road. Not justified in light of the alternatives.

Rob McQueen,


Form: White River Public

Meeting,

• The socio-economic study has

identified the potential negative effect of the

road through the White River area on property

value. This will be further assessed in the

EIAR-phase social study

I support that Phumlani 2 Alternative should be selected.

Cllr. Kenny Khoza

Comment &

Registration Form:

Phumlani Public

Meeting

The environmental team will assess all the

alternatives and will recommend those that are

feasible based on the environmental

assessment and comments from the public. It

should be noted that Phumlani Alternatives 1

and 3 have been discarded for the EIAR

phase due to environmental issues associated

with them.



Unsuitable soil conditions along K.V. (Kingsview) X3.

To build anything along this spruit is economic insanity.

Llewellyn Hunt,

Comment &

Registration Form: White

River Public Meeting

Feedback from SANRAL on this point

indicates that construction methods and costs

associated with the existing servitude through

the White River area are regarded as

acceptable, but this will be assessed in more

detail during detail design. Nevertheless a new

alternative, the White River North Alternative

has been created, and will be comparatively

assessed against the existing servitude in the

EIAR phase of the study.

It is better to select a safe road alternative, i.e. Phumalni 2

Alternative. The original proposed route will have a

negative impact to the public.

Amos Ndlovu, Comment

& Registration Form


identified alternatives and will recommend

those that are feasible based on the

environmental assessment and comments

from the public. Safety as a social issue in the

context of an arterial road passing through a

community will be assessed in the context of

both the existing P166 existing servitude and

Phumlani Alternative 2 in the EIAR-phase

social study

If the proposed road is constructed through the Heidelberg

Valley I fear that there might be:

Destruction of wetlands

Disruption to functioning of irrigation canals

Difficulty for farmers to access sections of their

farms

Traffic noise

Traffic pollution

Sheila Tebbit, Comment

& Registration form


reasons, the Phumlani Alternative 1 that runs

through the Heidelberg Valley has been


project scope as investigated in the EIR phase.

It is thus highly unlikely that any of these

issues raised in this point will materialise, and

these potential impacts in this part of the study

area have been avoided



Destruction of good farmland and property de-evaluation in

the immediate area.

The original proposed route is far better suited and

generally disruptive/damaging.

Negative impact on wetland and wildlife.

Farms will be cut into smaller uneconomical parcels that

will result in destruction of irrigable, usable, land that will be

excess of the actual land destroyed by the road.

The fact that the Msholozi illegal settlement will have to be

disrupted is a problem, but how can an illegal settlement

disrupt the legal, planned law abiding processes of the

country.

Property values will be negatively affected by the

alternative 1 running through the valley.

The sand river irrigation scheme would be seriously and

negatively impacted.

Servitudes and rights of-ways across different farms in the

Heidelberg valley need to be carefully considered.



Allan Luus, Comment &

Registration form

The potential impact of certain of the project

alternatives, in particular Phumlani Alternative

1 is recognised, and is reflected in the

agricultural potential study. It should be noted

that for environmental reasons, the Phumlani

Alternative 1 has been discarded and will no

longer form part of the project scope as

investigated in the EIAR phase.

Thus all issues pertaining to the Heidelberg

Valley and Phumlani Alternative 1, as raised

here are unlikely to materialise.












alignments.




reasons, the Phumlani Alternative 1 has been



phase. As a result, social-related issues of a

potential loss of property value in the

Heidelberg value are unlikely to materialise

due to the proposed road development.

The property owners dispute the right of the South African

National Road Agency and /or any other entity to construct

a road as proposed under route P166-1/2 or otherwise

Major portions of the proposed route are environmentally

sensitive and will irreparably harm wetlands and sensitive

environmental areas

Wiekus Petrus du Toit,

Wiekus du Toit

Attorneys, Comments

Emailed

Based on feedback from the proponent Sanral,

the route has been declared through White

River. Further legal verification will follow later

as part of land acquisition and compensation

process.

The scoping phase study has been based on a

number of specialist studies that have

identified areas of particular environmental

sensitivity in the context of one, or more

disciplines. In such areas alternative routes

have been created in order to allow the

mitigation of the issues.

I live in Magaliesberg Street, right on wetland nature

reserve. The road will be 5m away from my garden fence.

How can you build a road through a wetland nature reserve

as an environmentalist?

What happens to the property values when the house we

bought on a nature reserve suddenly changes to a house

Tracy Brooks,

Comments Emailed









on a toll road? where the servitude runs directly through a





phase of the study, as a mitigation measure to

avoid the potentially significant biophysical

effect of the proposed road on the wetland,

and certain socio-economic issues such as

impact on property value.

I represent the owner of Portions 18, 20 and 21 of the farm

Cromdale 453-JT situated south of Nelspruit and affected

by the proposed road P 166-2.

It has come to the attention of the owner and ourselves that

an EIA process commenced in respect of which land

owners were informed of the process and who were invited

to register as interested and affected parties. Applications

for registration apparently closed on 21 September 2012.

In terms of the Regulations you are required to:

1. Inform all land owners that are directly affected by

the proposal of such a proposal and include such

owners as a participant in the process. Proof of

such notification must be submitted to the

Department.

2. PLEASE provide us with acceptable proof that the

registered owner, or his representative, or

occupiers of the said properties have been informed

of your process.

3. Notice of the process must also publicly be given by

means of notices in the daily or weekly press, and


Nuplan Development

Planners, Comments

Emailed

A site visit was conducted on the 31st July

2012 and site notices were placed.

Thereafter, RHDHV started receiving

enquiries about the project and started

distributing project background information

documents. There was a closing date on the

registration form to encourage people to

complete the registration form and send back

to us at their earliest convenience so to start

establishing the database.

We also aimed that by Mid September 2012

we would have identified all the landowners

and I&AP‟s affected. You are welcome to

register as an I&AP on the database.

It is very important to note that registration of

I&AP‟s does not stop until the project ends.

The EAP is aware of all of the regulations and

guidelines for conducting public participation,



preferably the local press.

and will comply with these throughout the EIA

process.

.

Why do alternatives have to be considered and is this due

to recommendations from the screening phase process?.

Mr Peter Sonemann,

Minutes of the Focus

Group Meeting,

Mbombela Local

Municipality

Mr. Da Cruz responded that the process was

to identify the feasible route, and it is a legal

requirement to have alternatives to the main

route to be assessed. He explained that each

specialist had to identify significant impacts

along the main route and along the

alternatives in order to come up with

mitigation measures for each. A number of

significant potential issues relating to the

social environment, wetland, surface water

environment, and biophysical environment in

terms of fauna and flora, have been identified

in the area through White River. The

comments from the public also raised some

concern regarding their properties relating to

potential loss of value, damage to the wetland

and the presence of threatened species that

would be lost in that area. These brought

about the potential need of considering an

alternative to the identified servitude.

Wwhichever alternative will be considered, great care

should be taken that they are technically feasible before

presenting these to the public.

Why there no alternative proposed for the White River area

Mr Peter Sonemann and

Mr. Frans Greyling


Group Meeting,

Mbombela Local

Municipality

Mr. Da Cruz responded that alternatives

identification through the EIA process is an

iterative process. When a proponent puts

forward a route for environmental

assessment, that proponent would not

necessarily be aware of all environmental



as compared to other areas?

issues that maybe associated with the

proposed route.

Mr. Da Cruz explained that a screening

exercise undertaken at the start of the scoping

phase of the project has identified the

environmental issues in the White River area;

an alternative may be considered which will

be assessed in detail in the EIAR phase.

It is important to note that based on specialist

inputs as well as public comment and

feedback relating to areas of environmental

sensitivity, a number of environmental issues

were identified in the area where the P166

servitude traverses the White River area, in

particular relating to where the servitude runs

directly through a wetland. Accordingly a new

alternative, the White River North Alternative

has been created, and will be comparatively



When the EIA report will be submitted?

Mr Frans Greyling


Group Meeting,

Mbombela Local

Municipality

Ms. Ntseketsi Lerotholi informed the meeting

that if all goes well the report should be

finalized in six months from now.

Mr Frans Greyling commented that they will need to see

this report submitted as soon as possible so that the

municipality should be able to approve some of the

Mr Frans Greyling


Group Meeting,

Mr. Da Cruz responded that it is possible that

some of the suggested alternatives may be

withdrawn based on the assessments that



developments that have been applied for along the

proposed route. He informed the meeting that he prefers

Phumlani option 2 and that Phumlani option 3 is not

feasible and should be withdrawn. He wanted to know if all

alternatives will be assessed in the EIA phase

Mbombela Local

Municipality

have been carried out during screening

process.


reasons, the Phumlani Alternative 1 and 3

have been discarded and will no longer form

part of the project scope as investigated in the

EIAR phase.

An attendee enquired if the alternatives have been tested.


Group Meeting,

Mbombela Local

Municipality

It should be noted that all alternatives are

technically feasible.

From an environmental perspective this EIA

has attempted to comparatively assess

alternatives in an equitable and fair manner

that takes all environmental and other factors

into account.

The Phumlani alternatives were introduced

early in the scoping process, as a result of

potentially significant issues raised by certain

project team specialists. These were then

scoped by all of the specialists as part of their

scoping-phase specialist studies, and these

alternatives were included in the draft scoping

report that was released prior to the meetings

alluded to.















of the project.

The current EIA aims to find a solution that is

as environmentally sustainable as possible,

taking into account the impact on all affected

parties, including factors such as capital

expenditure into properties, and their

associated value.

He commented that time should not be wasted by

investigating non-feasible alternatives as this will be a

waste of money. He recommended that costs should also

be considered for each alternative in order to try to be cost

effective.

Mr. Stephan Pienaar,


Group Meeting,

Mbombela Local

Municipality

All alternatives have been determined to be

technically feasible.

The Environmental scoping process has

comparatively assessed all alternatives and

two alternatives (Phumlani Alternatives 1 and

3) have been determined to not be

environmentally feasible, and will not be

subject to further, detailed studies, and have

thus been discarded.



Mr. Greyling said if there is going to be a deviation from the

existing servitude, there would be problems which will be

encountered and another concern is that not all these

alternatives can be considered as there are already

development applications in place.

Mr. Greyling commented that Phumlani 2 Alternative would

be feasible at this time. He further commented that

Phumlani 3 Alternative should be discarded and time

should not be wasted on it.

Mr Frans Greyling


Group Meeting,

Mbombela Local

Municipality

The Phumlani alternatives and Maggiesdal

Alternative were introduced early in the

scoping process, as a result of potentially

significant issues raised by certain project

team specialists. These were then scoped by

all of the specialists as part of their scoping-

phase specialist studies, and these

alternatives were included in the draft scoping

report that was released prior to the meetings

alluded to.













of the project.

Referring to the bottom (southern) section of the map, he

enquired if the road was still going to be constructed as per

map as there have been applications received to develop

the area into a rural residential area.

Mr. Frans Greyling,


Group Meeting,

Mbombela Local

Municipality

The existing P166 servitude in this part of the

study area is being considered for

development; however there is an alternative

the Maggiesdal Alternative which has been

created to avoid a number of new

developments.



Mr Frans Greyling commented that there are alternatives

for the development of the R40 around Hazyview and

enquired why officials responsible for Hazyview have not

been invited to the meeting.

Mr. Frans Greyling,


Group Meeting,

Mbombela Local

Municipality

Mr. Klaus Schmid responded that the route

through Hazyview will be considered in a

separate EIA process and is part of this

application

Mr Frans Greyling enquired why is it still necessary to

conduct an EIA studies for a servitude that has been

proclaimed.

Mr. Frans Greyling,


Group Meeting,

Mbombela Local

Municipality

Mr. Da Cruz said the existing servitude was

proclaimed in 1980s before the implementation

of the environmental regulations and

subsequent NEMA regulations. He explained

that the route determination of P166 falls

under one of the listed activities of the

regulations whereby an EIA need to be

conducted and authorization sought.

Mr. Frans Greyling wanted to know how long it takes for the

authorities to grant an authorization once the EIA

application for authorization has been submitted to the

department.

Mr. Frans Greyling,


Group Meeting,

Mbombela Local

Municipality

Mr. Da Cruz responded that it would take

approximately 2 to 3 months to get

authorisation.

Mr Frans Greyling enquired as to how long the

authorization is granted for.

Mr. Frans Greyling,


Group Meeting,

Mbombela Local

Municipality

Mr. Da Cruz responded that typically the EIA

authorization is valid for about 5 years and that

construction would need to commence within

that period. The timeframe of validity of the

authorization depends on the conditions set

out by the department in the authorization.



Mr Frans Greyling asked as to where the final report will be

submitted to or if it first goes to SANRAL to make final

decision of the route.

Mr Frans Greyling expressed the municipality‟s support for

the project and indicated that they will not be submitting

written comments.

Mr. Frans Greyling,


Group Meeting,

Mbombela Local

Municipality

Mr. Da Cruz responded that the final report will

be sent to the DEA for the final decision.

Ms. Vivien Rossack asked that clarification be provided in

respect of the declared and undeclared land section from

the maps.

Ms. Vivien Rossack,

Minutes of the

Landowners Focus

Group Meeting, Bundu

Lodge

Mr. Klaus Schmid from SANRAL explained

that some areas of the existing route are

declared and some are not and that he does

not know why this was the case as the P166

route was inherited from the Transvaal

Provincial Administration (TPA).

Ms. Vivien Rossack wanted to know if the team has

considered widening the R40 instead of building a new

road.

Ms. Vivien Rossack,

Minutes of the

Landowners Focus

Group Meeting

Mr. Schmid responded that SANRAL have

realized that there is a need for the proposed

bypass road as traffic is increasing in the area.

He mentioned that this is proposed to be a

mobility road for longer distance traffic, and

that the purpose of the proposed road is to

reduce the time taken to travel between

Barbeton and White River. This would be

different to the R40 which accommodates all

traffic that goes into/out of town. He informed

the meeting that there is concern about the

increase in truck traffic from Phalaborwa to

Maputo that uses the R40.

Alternatives, including upgrading of the R40,

have been addressed in the updated “Needs

and Desirability” section of the Draft Final



Scoping Report

Andrew Rossack commented that they have been asked to

submit their comments regarding the draft ESR. He wanted

to know if the same would be done with the final ESR

before submission to the authorities

Andrew Rossack,

Minutes of the

Landowners Focus

Group Meeting

Paul Da Cruz said in terms of the EIA

regulations, the final ESR will be made

available to the public for 21 days. The public

should check if their comments made on the

draft scoping report had been captured and

responded to in the issues trail.

He said that Mr. Da Cruz had earlier stated that SANRAL

has a legal right to develop the road whereas SANRAL has

no legal rights to do this and secondly there was no

alternative suggested for White River. Has wanted to know if

any alternative has been considered for White River.

Mr. Wikus Du Toit,

Minutes of the

Landowners Focus

Group Meeting

Mr. Da Cruz responded that SANRAL was

undertaking the EIA to determine a route for

the proposed P166 road, and to determine the

environmental feasibility of the existing

servitude. He further assured the meeting that

due to comments received, mitigation

measures for the issues identified in the White

River area, including the possible identification

of a route alternative in the White River area

will be assessed.

It should be noted that due to the issues

associated with the P166 servitude in the

White River area as identified by specialists

and various stakeholders alike, a new

alternative has been created (to be fully







area.

Mr. Heinrich Kammeyer commented that some of the

issues are not mentioned in the report. He mentioned that

the footprint of the road in the White River area hosts

known communities of the endemic Red data aloe species

Aloe simii which should be taken into consideration during

this process. He mentioned that there are also small

streams feeding into the wetland. He informed the meeting

that the management of the Lowveld Chambers will be

having a meeting within the coming week and written

comments will be sent to the consultants.

He further commented that if an alternative for the White

River area is not considered, this will be definitely a fatal

flaw in the scoping report. Mr. Kammeyer recommended

that an alternative be provided before going to the EIA

phase of this project as the area is sensitive. He

recommended that SANRAL should identify an alternative

further to the west which will go through the plantation area

as this would not be close to the residential area. Although

the alternative would have to cross wetlands, rivers, water

supplies, etc, it would be preferable as it would cross these

water resources at a 90 degree angle, thus affecting a

small area of the wetland, as opposed to the current

servitude that runs through the wetland.

The socio-economic impact associated with the road on the

properties in White River adjacent to the servitude would

be significant and noise has been one of the indentified

Mr. Heinrich Kammeyer,

Minutes of the

Landowners Focus

Group Meeting,

The presence of Aloe simii in the wetland has

been noted in the scoping-phase biodiversity

report.














the White River area. This will be further

assessed in the EIAR-phase social and noise



impacts. studies

Mr. Kammeyer commended that it is good to avoid the

Phumlani area by considering alternatives but one of these

alternatives is running alongside a wetland that will be

destroyed by the construction of the road if this alternative

is developed.

Mr. Kammeyer, Minutes

of the Landowners

Focus Group Meeting,

Mr. Da Cruz informed the meeting that he has

been to this area in Phumlani and found that

the community has dug trenches in the

wetland to try and drain the water away and

make the area less inundated.

Mr. Andrew Rossack commented that this road would only

benefit the Hazyview people travelling to Barberton. But for

people staying in White River travelling to Nelspruit, this

road will not have value. He mentioned that the

intersections at Casterbridge, near Impala Street, or at

Bahadi there are already major problems. He commented

that this road will be a white elephant as there will be no on-

ramps and people from White River will not be able to use

this road to travel to Nelspruit.

He further commented that it would not be easy to get to

the Casterbridge interchange from this road due to the

existing traffic. It would not solve the problem experienced

by R40 beyond (north of) White River. Even if this road can

be constructed, problems will still exist on either side of it.

He emphasized that no problems would be solved by this

P166 road. He cautioned that this road is going to upset a

lot of people.

He requested that more data on the need and desirability

be provided.

Mr. Andrew Rossack,

Minutes of the

Landowners Focus

Group Meeting

Mr. Schmidt responded by saying that the road

is not only to serve people travelling from

White River to Nelspruit but mainly to take the

long distance traffic like the trucks from

Maputo to Phalaborwa off the R40. There will

be an interchange at Casterbridge where the

major roads connect.

He commented that the final decision will be

made by the authorizing department based on

the need and desirability of this road. He

mentioned that the same comments came up

during the EIA for construction of the N4 and

N1 roads.

. The project need and desirability issues have

been subsequently updates and are

addressed under Section 1.2 of the scoping



report

Mr. Eduard Mellaart commented that this road will not be

user friendly as the proposed on/off-ramps make it

impossible to take the most convenient road.

Mr. Eduard Mellaart,

Minutes of the

Landowners Focus

Group Meeting

Mr. Da Cruz responded that this will be

directed to the social specialist who will be

looking at social issues.

The conducting of an integrated transport

assessment is being proposed to the applicant

to consider the issues relating to traffic flows

and potential growth / change in traffic streams

in the future. This will examine issues relating

to access, as raised by this comment.

Mr. Robin Clanahan raised a concern that they would be

providing their comments in writing. He further said he was

not satisfied with the need and desirability for the project as

presented in the slides.

He asked if the proposed road will be tolled or not,

expressing his view that that if the road were to be tolled

trucks will still use the old road as they would avoid paying

the tolls.

He mentioned that should Phumlani 3 Alternative be

selected, much harm will be done to the industrial area

adjacent to the R40 as the proposed road would take up a

huge area of this development. The access for the

Mr. Robin Clanahan,

Minutes of the

Landowners Focus

Group Meeting

Mr. Schmidt responded that the issue of tolling

has not been decided.

Tolling is a funding consideration, which will

only become relevant once construction of the

route is being considered. Issues related to

possible toll avoidance will be part of the

considerations at that stage. The current

application is limited to definition of an

acceptable route and accurate determination

of the road reserve required for the road.


reasons, the Phumlani Alternatives 1 and 3

have been discarded and will no longer form

part of the project scope as investigated in the



Phumlani residents would be disrupted, and the area could

be better used to accommodate school/shops etc.

He wanted to know the width of the servitude and how

much it will cost to build the road.

He raised a concern that areas for sourcing of construction

material should be adequately determined as sometimes

material is sourced out from Pietermaritzburg or Estcourt

and this results in huge impact on the roads and people.

EIR phase.

Mr Schmidt responded that the servitude width

is a nominal figure of 80m depending on filling

and cutting. Mr. Schmid explained that it is still

too early to determine the cost of the road

construction.

Mr. Schmidt responded that this will be

considered in future EIAs that would be

undertaken for listed activities relating to

construction of the road.

Mr. Hennie van Rensburg reminded the meeting that the

authorization applied for is for determination of the route.

Planning and design would have their own processes. He

said after the road has been determined, there would be

another fatal flaw regarding the properties and the property

owners that will be affected.

He asked whether the land owners would be provided with

more information especially in the Maggiesdal area where

an intersection is proposed in order for them to comment

on the road alignment before it is too late.

Secondly the meeting speaks about the servitude that was

declared in the 1980s and road proclamation. He was

concerned that these are two separate issues in his mind

Mr. Hennie van

Rensburg, Minutes of

the Landowners Focus

Group Meeting

Mr. Da Cruz informed the meeting that one of

the objectives in conducting the EIA process

for route determination of the proposed road is

to adequately assess the issues and how

people will be affected.

SANRAL will receive an authorization for a

certain route alternative or servitude. Should

the designers in the design phase identify a

problem with this authorization, they will have

to apply for the route amendment in this regard

subject to what the department has stipulated.

In spite of this, the EIA is being conducted at a

level at which issues regarding property; in

particular certain areas of concern have been



and do not want to confuse the two.

raised.

The social specialist has identified particular

problem areas where there are structures that

may be affected by the servitude. The detailed

EIA study and the social study will consider

these issues.

Mr. Schmidt responded that this was a legal

question but the way he understands it is that

“declaration” means “to define and reserve the

strip”. This was only published in the Provincial

Gazette and that is where the process ended

apart from the land compensation. It was not

registered on the title deed up until in the

1990s, and also when SANRAL transferred

and registered ownership.

Mr. Rossack informed the meeting that the Phumlani

development underwent an EIA process and a RoD was

issued. One of the conditions of the authorization was that

there was an offset for a certain part of the developed

area as part of the impacted area is classed as

irreplaceable under the Mpumalanga Biodiversity

Conservation Plan (MBCP). This is not reflected anywhere

in the scoping report by Dr. Brown. By putting an

alternative through the area protected as part of the offset

for the Phumlani development it means the previous EIA

is no longer valid. This portion is put under the protection

of the Municipality and classed as an offset that is

Mr. Rossack, Minutes of


Group Meeting,

Mr. Da Cruz promised that Mr. Rossack‟s

comments will be addressed in the detailed

studies during the EIA phase.

The Mpumalanga Biodiversity Conservation

Plan, POSA, SARCA, SABAP1 and SABAP2

data was consulted in the preliminary

biodiversity assessment which was based

mainly on a desktop survey as well as a single

site visitation. It should also be noted that the

Mpumalanga Biodiversity Conservation Plan

has been consulted in the revised draft Final



irreplaceable by the Mpumalanga Biodiversity

Conservation Plan. He was concerned that Dr. Brown, the

ecological specialist, did mention a rare species such as

rock python and plated lizards that are known to occur in

the area. This emphasized that a detailed ecological study

should be undertaken and this should be specific to the

site as proper management measures will have to be

implemented during the construction of this road.

He further said one of the important things why wetlands

are important is ground water discharge and that this

issue was not covered adequately in the scoping report.

He raised a concern that some alternatives traverse

wetland areas and this will create problems to the road as

it will fall apart causing potholes. He mentioned that most

of the wetlands in the area are sources to the White River

or to Nels River which feeds to the Komati and the

Crocodile Rivers and that the wetlands are critically

important in the area. He mentioned that close to 50% of

these have already been lost due to developments either

legal or illegal. He raised the concern that this proposed

road is going to destroy another 50% of what is left such

that in 15 years time they will have lost about 75% of the

wetlands in the area. He recommended that cumulative

impacts need to be addressed in the wetland study.

Scoping Report, and implications for the route

and proposed project scoped.

In the context of the offset referred to, It should

be noted that due to technical and

environmental issues Phumlani Alternative 1

which would have affected this offset area has

been discarded and will not be considered in

the EIR phase.

It is acknowledged that there is a. high reptile

diversity occurs between Nelspruit and White

River with 81 species recorded during the

South African Conservation Assessment

(SARCA). This will be further assessed in the

EIAR-phase biodiversity study.

Linda Liversage informed the meeting that there was an

archaeological site and graves within the proposed route

Linda Liversage,

Minutes of the

Mr. Da Cruz thanked Ms. Liversage for her

comments and promised to see to it that these



alternative that also needs attention.

Landowners Focus

Group Meeting

issues are assessed by the heritage specialist.

This issue has been flagged and will be

considered in the EIAR-phase heritage study

Mr. Rossack requested for a copy of the specialists CVs

and a decent map showing the alignment in full.



Group Meeting,

CV‟s will be included as an appendix to the

Draft final scoping report.

Mr. Mellaart commented that Phumlani 3 Alternative was

going to divide some properties and the Phumlani

community will not be able to access the R40 due to this

road.

Vivien Rossack commented that one of the alternatives

would be running close to her property, or even cutting it

into half. She pointed out that they will be impacted by the

fumes and noise from fast moving vehicles. She wanted to

know if there would be compensation paid to landowners.

She also informed the meeting that some people in

Phumlani were warned that they were occupying the land

illegally at their own risk. She was concerned that now

SANRAL wants to penalize people who legally own land

has spent a lot of money to purchase land with no

assistance from the state, in order to accommodate those

that are illegal.

Mr. Rossack, in addition to the above comment, said

SANRAL is trying to promote illegal activities by

accommodating the residents of Msholozi who are

Mr. Mellaart, Minutes of

the Landowners, Focus

Group Meeting

Mr. Da Cruz informed the meeting that the

situation with respect to the Msholozi

settlement was complex. He explained that

irrespective of whether the settlement was

legally or illegally settled, they are settled in

the area and relocation of people is associated

with a raft of social issues that will need to be

considered.


issues Phumlani Alternative 3 has been

discarded and will not be considered in the

EIAR phase, thus the potential for access to

the Phumlani community being disrupted by

the proposed road will not occur.









occupying land illegally. servitude in the Msholozi area are being





alignments.

Mr. Da Cruz responded that Phumlani

Alternative 1 has been identified as cutting

through an area of high agricultural potential.

This has been taken into account. SANRAL

does not favour this alternative from a

technical perspective because it is longer than

the other two alternatives and there are

steeper slopes that would result in a more

costly road to build.

Mr. van Rensburg asked as to when the road will be built.

Mr. van Rensburg,

Minutes of the

Landowners, Focus

Group Meeting

Mr. Schmid responded that time frame is not

yet known as they will have to wait for the

authorization of the route determination before

making any decisions regarding

implementation. Under the best case scenario,

should it happen, the construction will not start

earlier than the end of next year (2014). This

construction can take a period of about 2

years. To have this road functional would

therefore take in excess of 3 years from now.

Linda Liversage raised a concern that this road will affect

her property negatively yet she was not informed about the

development. She was concerned about the noise during

Ms. Linda Liversage,

Minutes of the

Landowners, Focus

Mr. Da Cruz thanked Ms. Liversage for her

input and reminded the meeting that the social

specialist should be looking at these social



construction and that some of her property will be part of

the road. She also raised a concern that people who will

benefit are those who would be driving on this road around

town not the property owners. She wanted to know how

compensation will be undertaken and if this will be

negotiated with landowners or if SANRAL will just decide

on how they will compensate landowners.

Group Meeting, issues and that SANRAL will negotiate with

landowners on the compensation to be

granted for each property affected.
















Mr. Leon van Zyl commented that he obtained the property

from his father and has just received a title deed for this

property. He wanted to know if there could be other

alternatives rather than the one that cuts through his

property.

Mr. Leon van Zyl,

Minutes of the

Landowners Focus

Group Meeting

Mr. Da Cruz said the alternatives are not yet

final and that alterations could be made to the

proposed route in further areas of

environmental sensitivity.



Mr. Rossack enquired as to why SANRAL wants to use the

servitude rather than looking for a new area in which to

construct the road.

Mr. Rossack suggested that SANRAL should use the

available money to rehabilitate the existing provincial roads

rather than to construct the P166 which does not benefit

the community.



Group Meeting

Mr. Da Cruz responded that being the

environmental consultants‟ responsibility is to

assess the provided route and alternatives and

provide recommendations so that SANRAL

can make a decision if this is feasible or not to

proceed with their intention of developing the

road.

The application for environmental authorization

is for confirmation of an existing planning and

partial declaration (“servitude”), whilst

considering adjustments for specific identified

environmental concerns. The purpose of the

route, route alternatives and upgrading of R40

are all addressed in the need and desirability

section.

Mr. Simon Evered enquired if the meeting was going to

look at the route in detail as he had comments regarding

the White River area.

Mr. Simon Evered,

Minutes of the

Stakeholders Meeting,

Mr. Paul Da Cruz suggested that the meeting

should look through the White River map to

address the concern.

Mr. Evered informed the meeting that the map at hand did

not reflect the new developments in the area. The

proposed route was going to cut through household

properties which are not indicated on the map.

Mr. Simon Evered,

Minutes of the

Stakeholders Meeting

Mr. Da Cruz informed the meeting that the

1:50 000 cadastral map has been used as a

background on the map and there is a

possibility that the date of publication of the

map entailed that subsequent developments

would not be reflected on this layer. He

promised to look at the last update of this map.



He informed the meeting that he could not understand why

the proposed route still stands as it was proposed before

the implementation of the environmental laws in the early

1980s. He informed the meeting that he does not

understand why a wetland should be destroyed to

accommodate this route as this wetland is treasured by the

people of White River and that the previous council has

designated the area as a bird sanctuary. Mr. Evered

warned the meeting that there would be strong objection to

this road in the White River meeting the following day.

He informed the meeting that another set of

maps had been developed using aerial /

satellite images as a background. He promised

that clearer maps would be made available in

the website. He informed the meeting that the

topo-cadastral maps are used as they indicate

the location and farms affected. A good

example is that they showed the Dingwell

Farm in the Phumlani/Msholozi area. He

informed the meeting that they have

developed the maps using the aerial image

background to show a more up-to date picture

of development in the area.

He explained that the road servitude was

proclaimed in the 1980s and this does not

automatically allow SANRAL to proceed with

development without authorization from the

National Department of Environmental Affairs

under the National Environmental

Management Act EIA Regulations thus

SANRAL is seeking the authorization to

proceed.

Mr. Schmidt informed the meeting that the land

as defined in the declaration was reserved for

the road and that land owners were

compensated for their land. He informed the

meeting that he understands the concern

shown regarding the wetland but commented

that he has seen subsistence farming taking



place in the wetland and he wanted to know

how pristine the wetland is as he wanted to

understand the issues relating to the wetland.

He also explained that if this is not feasible

SANRAL will have to start all over again with

road planning, land acquisition and all these

have financial implications. He informed the

meeting that they are aware of the challenges

of the wetland, Phumlani and the area south of

Nelspruit.

Mr. Evered thanked Mr. Schmidt for the explanation and

commented that a 2-3km stretch of the wetland will be

affected by this road. He also commented that the road will

be built within the flood line and noise will also be an impact

in this area. He recommended that this should be

addressed in details in the EIA phase of the project.

Mr. Simon Evered,

Minutes of the


Mr. Schmidt confirmed that part of the wetland

would be affected. He explained that the

proposal was to minimize and mitigate the

impact on the wetland as much as possible.

He further explained that the road would be

crossing the wetland where the stream turns

towards the bridge and then lower back to the

R40

Mr. Da Cruz responded that the wetland issue

is a significant potential issue. What the

specialists look at in terms of the wetlands is

how roads cross them. The optimum crossing

of the wetland is at the shortest point and it

should be perpendicular to the flow of water.

The issue relating to this wetland is that the

road will be running longitudinally to the flow

and a large area could thus be impacted. This



has been flagged for further investigation in

the EIA phase.

Mr. Da Cruz thanked Mr. Evered for raising

this concern and indicated that they are aware

of the social (i.e. noise, safety) and

environmental issues (such as existence of

vulnerable sensitive frog) raised by the I&AP

and these will be addressed in details in the

EIA phase.

Mr. Da Cruz promised the meeting that once

the EIA phase is complete, feedback meetings

will be organized whereby the public will be

informed about the investigations undertaken

and the mitigation measures that will be taken

to address these impacts.

Mrs. Mary Evered wanted to know what the situation is

regarding the Environmental Law because the road reserve

was declared before the EIA Regulations had come into

being.

Mrs. Mary Evered,

Minutes of the


Mr. Da Cruz responded that if the road was

constructed prior to 1997, the 1997 EIA

Regulations would have not been applicable

but since that EIA regulations under NEMA

have been promulgated which require that

certain listed activities need to be authorized,

such authorization needs to be granted before

the road can be constructed. He informed the

meeting that the same principle would also

apply to the water use license.



Mrs. Evered asked if there is a chance that the project can

be rejected by the authorities.

Mrs. Mary Evered,

Minutes of the


Mr. Da Cruz responded that the authorities

have a duty to consider the impacts that would

be caused by the proposed development and

their decision will be based on these.

Mrs. Lerotholi (RHDHV) reminded the meeting

that the department can either accept or reject

the application based on the studies that were

undertaken.

Mr. Evered raised a concern that consultants most of the

time (99.5%) are biased towards their clients as they are

remunerated by the proponent and that they thus ignore

comments from I&APs. He informed the meeting that he

was not against the road as it is a necessity but he is

against it running through the wetland.

Mr. Simon Evered,

Minutes of the


Mr. Da Cruz responded that the purpose of

the public participation process is to record all

the comments raised and submit this to the

authorities so that informed decision can be

made. He also assured the meeting that the

environmental team is independent. He

responded that it is difficult for an alternative

in the White River area in that there are a

number of environmental, physical and

constraints in terms of placing a road either to

the east or west of the town. He however

assured the meeting that the EIA team will

look at this in detail and come up with a

feasible way of mitigating the identified

impacts that may include the creation of a new

alternative

It should be noted in the context of this

comment Based on specialist inputs as well as

public comment and feedback relating to areas

of environmental sensitivity, a number of











Mr. Louis Sidubela commented that Phumlani 2 Alternative

was most preferred as it has shown little negative impacts

to the area and will not affect any households from the

community. He further enquired if there would be access

roads to this bypass.

He raised a concern that this road would have no value for

the Phumlani community as there will be no access to

Phumlani Village.

Mr. Louis Sidubela,

Minutes of the Phumlani

public meeting,

Mr. Wihan Venter of Endecon explained that

according to SANRAL, the bypass would have

no access road to Phumlani Village. This will

serve as a freeway access only at the planned

interchanges, and no further intersections or

traffic lights would be provided as the road is

planned to shorten the travelling time between

Nelspruit and White River.

Mr Venter said should the declared reserve be

used, under- or over-pass bridges may have to

be built to help the community to move

between either sides of the bypass.


issues Phumlani Alternatives 1 and 3 have


the EIR phase.



Cllr. Mkhonto commented that this was still a study in

progress. SANRAL should be informed about the wishes of

the community in gaining access to this road. He also

made an example of the access road constructed on the

N4 bypass. This could also be possible for this project.

The community felt that the Phumlani 2 Alternative was

best preferred as no residential buildings would be affected

Cllr. Mkhonto, Minutes of

the Phumlani Public

Meeting

The detailed EIAR-phase socio-economic

study will examine the issues relating to the

potential routing of a highway (arterial road)

through, or alongside a settlement such as

Msholozi.


issues Phumlani Alternatives 1 and 3 have


the EIR phase.

Mr. Hein Guile enquired if it is possible to have an

alternative in White River and where this could be located.

Mr. Hein Guile, Minutes

of the White River Public

Meeting

Mr. Da Cruz responded that one of the issues

that made it difficult for an alternative in the

White River area is that there are a number of

environmental, physical and technical

constraints in terms of placing a road either to

the east or west of the town. He however

assured the meeting that the EIA team will

look at this in detail and come up with a

feasible way of mitigating the identified

impacts that may include the creation of a new

alternative

Mr. Wihan Venter informed the meeting that

initially, no alternative was considered for

White River but this will be looked into.

In the context of this comment, based on

specialist inputs as well as public comment

and feedback relating to areas of












Mrs. M Evered informed the meeting that there is a

threatened plant species identified at the bird sanctuary.

She wanted to know how this plant would be protected.

(Post meeting note – this refers to Aloe simii)

Mrs. M Evered, Minutes


Meeting

Mr. Da Cruz responded that the plant has

been identified to be an aloe species in the

Fauna & Flora report. The Environmental

Management Programme might prescribe the

need for plant rescue and relocation plan. The

threatened species will be protected but if

there is a need for relocation, this will be done

as a last resort. A number of potential

mitigation measures such as avoiding areas

where populations of that species occur would

be considered. He explained that the

ecological specialist will carry out detailed

investigations in the EIA phase of such

species and identify in which areas they exist.

Mr. John Millett enquired if all land/farm-owners were

informed about the road that will affect their farms.

Mr. John Millett, Minutes


Meeting

Mr. Da Cruz responded by saying that the

Public Participation Process Team have used

a deeds search to identify as many land-

owners as possible that appear on the system,



and that the team visited the area to identify

the land owners along the proposed route. Mr.

Da Cruz mentioned that although the team has

done its best to identify as many landowners

as possible, it is a difficult task on a linear

project to initially acquire the contact details of

all potentially affected landowners. He asked

the meting that should it be the case that there

are some land-owners that were not

contacted, it would be appreciated if these

could be brought to the attention of the project

team so as to make necessary arrangements

to consult with them.

Mr. Millett further informed the team that there were people

pegging his property about 100 meters away from his

house, and that he believed that this was to do with the

proposed P166 project, but that he had not yet been

consulted.



Meeting

Mr Wihan Venter confirmed that SANRAL was

undertaking no such pegging of any properties

along the route.

Mr. Llewellyn Hunt informed the meeting that this route was

planned approximately 30 years back without

environmental studies for the proposed road having been

undertaken. He added that the soil conditions along the

P166 servitude in the White River Area are not suitable for

construction of the road. It will be economic insanity to build

the road along this road as it has collapsible structure.

Millions of cubic metres of the soil will have to be removed

and replaced by the building material

Mr. Llewellyn Hunt,

Minutes of the White


Mr. Da Cruz responded that the engineers will

consider this issue during planning. Mr. Da

Cruz confirmed that he is aware that there is a

chance that there were hydric soils along

certain portions of the road. He thanked Mr

Hunt for raising this issue.

Feedback from SANRAL on this point

indicates that construction methods and costs

associated with the existing servitude through



the White River area are regarded as

acceptable, but this will be assessed in more

detail during detail design. Nevertheless a

new alternative, the White River North




Mrs. Judy de Villiers wanted to know how far the road

would be constructed from her home as she can see that

she would be affected. She also wanted to know if there

would be a buffer zone from the road for safety reasons

and what the size of the buffer zone is.

Mrs. Judy de Villiers,



Mr. Venter informed the meeting that the

road reserve is 80m wide and the edge of the

road reserve falls on the edge of the

boundaries of some properties. He explained

that buffer zones will be provided and issues

of the buffer zones will be taken into

consideration for example that the reserve

can be reduced to 60m width, as to provide a

20m wide buffer zone .

Mrs. De Villiers raised a concern that should 80m be the

width of the road reserve that the road reserve was going

to run through the wetland area. The road will be flooded

during the first rains of summer.

Mrs. De Villiers, Minutes


Meeting

Mr. Da Cruz responded that the engineers‟

designs would have to consider how the

existing storm water outlets would be

incorporated into the road design. Mr. Da

Cruz commented that there is an engineering

and environmental issue on how this storm

water will be attenuated. He confirmed that

there is seepage in the area and promised

that this issue will receive detailed attention

in the EIA phase of the project.



Mr. Alastair Nachil wanted to know if this was going to be

an elevated road and how the road would be constructed in

relation to the Danie Joubert crossing across the wetland

area that was already elevated itself – would the new road

be elevated above this existing road. He commented that

the road should be built to the west of the residential area.

Mr. Nachil asked for a more detailed need and desirability

for the proposed road.

Mr. Alastair Nachil,

Minutes of the River

Public Meeting

Mr. Da Cruz responded that the details of the

road are not available at this stage but will be

provided during the environmental studies for

the construction of the road. He explained that

the public is allowed to object to the proposed

project through DEA and submissions should

be done with reasons. The EIA has a

responsibility to consider what the need and

desirability in order to explain why the project

is required.

This comment refers to the potential visual

and noise impacts related to a raised road. In

the context of visual impacts a number of

I&APs have raised visual-related issues. In

order to address these concerns, a visual

impact assessment study will be undertaken in

the EIAR phase of the project, and this study

will take into account the visual intrusion that

would be caused by such a potentially raised

road.













In the context of need and desirability, it

should be noted that the project need and

desirability issues have been updated

addressed under Section 1.2 of the draft final

scoping report

An attendee asked why the route is not developed on the

road running to the Kruger Mpumalanga International

Airport and then cut through on the existing roads.

An attendee, Minutes of

the White River Public

Meeting

Mr. Da Cruz commented that this point has

been raised by a number of parties in other

meetings however SANRAL‟s approach was

that the P166 servitude had been in

existence since 1983 and was carried forth

by the Mbombela Local Municipality spatial

planning. He responded that SANRAL will

look into the mitigation of these concerns

looking at the developments in the area.




traffic flow needs. The R538 as an alternative

has been discussed in the „Needs and


Report.



Mr. Simon Evered, commenting on behalf of the Wildlife

and Environment Society of South Africa (WESSA),

commented that the proposed road should not go through

the wetland within White River; SANRAL should realize that

opposition is very strong and should listen to this

opposition. He commented that by SANRAL not suggesting

an alternative for White River, it appears that SANRAL

have made up their minds that they are going ahead with

the existing servitude and that attitude will not work. He

mentioned that he was leaving this matter in the hands of

the consultants to make a case to preserve the wetland. He

advised that an alternative should be considered for the

wetland in order to ensure that this wetland is conserved.

He believes that there are rare species within the wetland

that need to be protected in the area.

Mr. Evered suggested that there is a need for traffic study

to be conducted in the area. It was also mentioned that an

eastern alternative was recommended to cater for heavy

vehicles travelling from the Northern Lowveld to Maputo,

which currently use this easterly route. He suggested that a

western alternative in the White River area which would not

affect residential areas be considered. He was concerned

that noise will be one of the impacts associated with this

development, hence a detailed study should be provided.

Mr Evered commented that wetland delineation should be

undertaken for all alternatives.

Mr. Simon Evered,



Mr. Da Cruz responded by saying that the

wetland issue has been identified as a

significant issue. In most cases, roads would

cross the wetland area / river perpendicularly

to the direction of flow but the P166 road will

be running longitudinally through the wetland

and will have the potential to transform large

areas of the wetland. He thanked Mr. Evered

for raising this point and informed the

meeting that wetland delineation will be

conducted which will be part of the EIA-

phase wetland study in order to identify the

percentage of the wetland that will be

impacted.

Post meeting note:




Scoping Report. An integrated transport study

is being proposed to address the traffic flow

issues relating to the proposed road and the

future traffic flow needs.

Further to this comment and others, based on














Mr Hilton Ford, from the White River Rate Payers

Association, asked as to why the team did not consider the

route from Karino to Hazyview bypassing White River to

the east, going past the KMIA Airport. He commented that

he suspects this proposed development has suddenly

come up because of the truck-related issues which are

causing problems all the way from Bushbuck Ridge to

Karino. He was concerned that this road was not going to

be beneficial to the community but to the truck companies.

Mr. Ford also enquired if there was any indication that this

would be a toll road.

Mr Hilton Ford, Minutes


Meeting

Mr Da Cruz informed the meeting that the

question of tolling was raised in one of the

previous meetings and that a SANRAL

representative, who was in that meeting but

not present at the current meeting, responded

that it, was too early to determine if the road

will be tolled or not as they were still in the

planning stage. He informed the meeting that

tolling was still a heated issue in a national

context at this stage.

Mr. Da Cruz responded that the process was

still to obtain authorization for the proposed

project, which is focused on route

determination. Should the project receive

authorization from DEA, there will be a

separate EIA process conducted for

construction at which time the more detailed

designs will be available.

Mr. Wihan Venter commented that there were



issues regarding the e-tolling system that

SANRAL has to address. He made an

example about the N17 which also have

problems about the tolling and informed the

meeting that an EIA process separate to this

one would be a necessity before tolling could

be implemented.








Mr. Rob McQueen expressed concern about the road going

through the wetland next to the bird sanctuary as he

resides just opposite this sanctuary. He wanted to know if

the study relating to the need for the road was done.

Currently there is need to take trucks down to Phalaborwa

and Maputo and running through town is not going to solve

this problem.

He recommended that the alternative of taking this road

through past Uplands College is a viable option but still

questioned whether the road was really necessary. The

existing R40 has at least 11 take offs between the Nels

Mr. Rob McQueen,

Minutes of the River

Public Meeting

Mr. Venter responded that SANRAL looks at

accessibility and continuity. Mr. Venter further

said that SANRAL is looking at the future

scenario in which SANRAL would not want

people driving from Hazyview through to

Barberton to have to pass about 20 traffic

lights and/or stops, similar to the current

situation for a motorist driving from

Johannesburg to Potchefstroom, as an

example. The stretch of the R40 between

Nelspruit and White River is the busiest road in

Mpumalanga and will be severely congested in

the near future. SANRAL does not want such a



River bridge and Casterbridge. The money that SANRAL is

going to use on the proposed P166 should be taken to

improve and expand the R40 by introducing bridges and

fly-overs, making it accessible for people who are willing to

use it.

Mr. McQueen raised a concern that he does not believe

that the number of people travelling from Hazyview would

warrant the need to develop this road.

He suggested that taking the heavy traffic around to the

eastern side of White River would make sense.

situation to materialize. This P166 was

declared road servitude by the old Transvaal

Provincial Administration (TPA) and SANRAL

wishes to utilize this existing servitude to

alleviate the increasing traffic in the area.




traffic flow needs.















Mr. McQueen informed the meeting that the Mpumalanga

Newspaper has indicated that the amount of traffic coming

from Hazyview side is about 300 vehicles per day and this

will increase to between 500 & 700 a day. Should this road

be built, all this traffic will be diverted onto the new road

and the noise level impact will increase in the part of White

River traversed by the new road.

He suggested that SANRAL upgrade the Plaston road

which is already proclaimed as this will cost SANRAL less

money than what will be spent on a new road. He

commented that when the road was proclaimed in 1983,

there were no developments that are currently in place

such as the KMIA Airport and Maputo corridor. The road

should be linked to these areas as well as to the Ka-

Bhokweni Industrial Area (which is not yet operational). He

mentioned that there are already applications for different

developments along the route such as the mine application

in the Heidelberg area, applications for the up-market

developments and approximately 2748 houses depending

on the availability of water and electricity in the area which

are also going to affect this project negatively

Mr. McQueen, Minutes


Meeting

See response above.







phase.








Mrs. Judy de Villiers wanted to know if people would still be

getting notification about the planned road as it seemed

that there were people who are still not informed about this

road, such as schools and businesses. She stated that this

road is going to cause job losses because tourists would be

taken away from White River.

Mrs. Judy de Villiers,



Mr. Da Cruz responded that an effort would be

made going forward on the project to reach as

many I&APs as possible by using existing

channels such as mail distribution networks of

the Rate-Payers‟ Association, & Chamber of

Commerce (if there is one). Going forward into

the EIR phase Royal HaskoningDHV will



advertise the EIA process. In addition the BID

and flyers were distributed to the properties on

the boundary of the wetland that are directly

affected. The advert was also placed in the

local newspaper. Going forward the EIA

comment process will also be advertised in the

newspapers.

Mr. Riaan van Doorn mentioned that his business will be

directly affected by the road and wanted to know what will

happen to the business.

Mr. Riaan van Doorn,



Mr. Da Cruz responded that the social

specialist would look at these issues, and she

will be notified of social issues such as this

that have been flagged as part of the public

participation process

In terms of compensation, Mr. Venter

responded by saying that there is an

expropriation policy in place and this will be

followed. He informed the meeting that this

expropriation is a legal issue that involves

negotiations with affected people and this will

be a transparent process.






Mr. De Villiers enquired from Mr. Venter about time frames

of the project going forward.

Mr. De Villiers, Minutes


Meeting

Mr. Da Cruz responded that environmental

authorization is only likely to be issues by late

2013/early 2014.



Mr. Venter responded that after receiving the

authorization, SANRAL would go into the

design phase. He explained that affected

individuals would also be contacted in order for

SANRAL to negotiate declaring of the

servitude etc. Mr Venter advised that the

affected individuals should check if the road

servitude appears on their title deeds. He

informed the meeting that this would take

another period of about 5 or more years before

the road is constructed.

Mr. Mike Chankin commented that the servitude should be

moved about a kilometer to the west from the wetland to

avoid the road construction causing damage to the wetland.

He suggested that SANRAL should be persuaded to

undertake engineering planning properly, having considered

all the issues raised in the meeting and to come up with a

much better solution to the problem.

Mr. Mike Chankin,





by specialists and various stakeholders alike,

a new alternative has been created (to be fully





area where the wetland is located..

Mr. John Millett wanted to know where exactly the

proposed road would join the Hazyview Road (R40).



Meeting

Mr. Da Cruz responded that the planned

intersection would be just to the south of

Casterbridge and indicated this point on the

map.

Mr. Millett explained that he lives close to Hazyview road

and there are lots of accidents on this road. He was

concerned that this is going to push more traffic on the

already existing road which has lots of accidents. He

Mr. Millet,Minutes of the

White River Public

Meeting

Mr. Venter responded that originally, the P166

road was meant to link with the R538 road

that heads east from Casterbridge towards the

Numbi area, but that under the current



suggested the road be moved to the east of Hazyview to

avoid accidents.

situation this is not considered optimal as the

R538 cannot function as a high mobility road

operated by SANRAL. The P166 would thus

join with the R40 Hazyview road at Caster

Bridge.

Mrs. Candy Guile raised a concern about the size of the

notices that were displayed alongside the area regarding

the EIA process for this proposed project. She has sent

some comments to the PPP team and did not get

response. She also asked if SANRAL would compensate

the affected property owners and how long the affected

people would be given before being moved from the

affected areas.

Mrs. Candy Guile,



Mr. Da Cruz apologized if the size of notices

placed was considered to small to be

practically visible and said this would be

looked at for the PP process going forward.

Mrs. Kate Barnett commented that there is no major need

for the P166 to connect to the R538 and to the R40 in the

Casterbridge / Baghdad Café area as a bypass. She

suggested that this bypass can be connected to the R40

further away from White River. She also informed the

meeting that there would be another wetland that would be

damaged if the road moved 1 kilometer to the west.

Mrs. Kate Barnett,
























Mr. Da Cruz responded that due to the nature

of drainage in the area, it is difficult to develop

a road without affecting any wetlands. He

however informed the meeting that the team

will considered all suggestions regarding

alternatives in detail.

Mr. Alastair Nachij raised a concern that the ESR refers to

economic growth and population growth but did not say

exactly where this is happening. He informed the meeting

that the population density in the area is highest in the

townships to the north that extend all the way to

Bushbuckridge, and in the areas to the east to Ka-Bhokweni

and along the Airport road. These areas thus present the

highest traffic flows, thus the proposed road should be

routed down to the eastern side of White River.

Mr. Alastair Nachij,










Mrs. Disington from the White River Ratepayers‟

Association mentioned that she has seen all the EIAs

being carried out against the communities‟ objections.

She advised that South Africa is a dry country that needs

water hence wetlands should be conserved. She

suggested that an alternative should run within the area

covered by plantations.

Mrs. D Disington,
















Mrs. Shareen reminded the meeting that when the R40

was constructed in Nelspruit, they commented and

objected to the crossings of big wetlands. She informed

the meeting that people from overseas paid a lot of

money to stay in areas with a beautiful view from their

houses but government has undertaken developments

destroying wetland and birds habitats. She commented

that what the community is saying will not make any

difference at all as SANRAL will go ahead with the

proposed project.

Mrs. Shareen, Minutes


Meeting,

Mr. Da Cruz responded that the community

has the right to object and to appeal, but

should put forward their reasons for objecting

to the proposed developments

WETLAND

Please note – the wetland area as traversed by the existing road servitude in the area between White River and Colts Hill is referred to as the “White

River Wetland” in the responses below

One of the alternative routes is through part of our

scheduled rateable areas, i.e. areas with an existing water

allocation from the water distribution scheme. It is all high

productivity farmland. Removing some of this land out of

the scheme has the potential to upset the viability of the

affected farming enterprises, which will result in impacts all

water users from the scheme as it is funded by all irrigators.

Removing some will place a greater financial burden on

remaining irrigators.

There is no indication how the Board‟s servitudes may be

impacted. This proposed road of roughly 80 meters wide

will severely impact on the waterworks as well as the

Barry Carlse, Sand

River Irrigation Board,

Comments E-mailed


agricultural activities is recognised, and as such

an agricultural potential study was commissioned

for the scoping phase of this EIA. The social

study has also identified the potential impact of a

loss of income due to sterilisation of agricultural

land. These issues will be further assessed by

the respective studies in the EIR phase of the

project.

The EIA project team does not have the

servitudes of the Board in order to determine

how these would be affected. A request has



maintenance and management of the water works owned

and managed by the SRIB.

The location of a major road close to the water works can

lead to potential damage to the canal system, pollution of

the water; either during construction or during road use

(consider spills). Responsibilities and losses incurred by

irrigators using polluted water needs to be accepted by the

road operator and sound mitigation measures need to be

included in the EIA report.

The proposed P166 impacts on many wetlands - travelling

the length and not crossing in most cases. These wetlands

are critical components of the various catchments of the

White River, Nels River and Sand River, all draining into the

Crocodile River. The importance and critical function of

these wetlands for flood attenuation, ground water

recharge, sustained water release, ecological flows and

river health are well recognized.

The Crocodile River is currently over allocated by ± 200 000

cubic metres per annum (120%). Shortages of water will

severely impact municipalities (and residents) of White

River, Nelspruit, KaNyamazane, Matsulu, Malelane,

Hectorspruit, Marloth Park, Komatipoort as well as

Mozambique, the neighbouring country. It is therefore

essential that the loss of these wetlands be considered on a

much broader scale - and particularly in respect of river

been made to the board to acquire these. It

should be noted that Phumlani Alternative 1 has

been discarded for the EIR phase of the project,

and this may have implications for whether these

servitudes are affected or not.

If relevant (based on the final proposed

alignment and whether canals could potentially

be affected), these mitigation measures will be

included in the EMPr.

The ecological and hydrological functioning of

wetlands in general, and in the context of the

study area is recognised, and is discussed in the

scoping-phase wetland report.

The Catchment Management Context is

recognised, especially the role that wetlands

perform in ensuring quality, and in some

respects quantity of water available. The scope

of this EIA is to consider the impacts that would

result from the proposed road, if developed, but it

is fully acknowledged that cumulative impacts

need to be taken into account. Although it is



health and impact on downstream water users. It is

suggested that a complete modelling of the wetland losses

be undertaken to predict the impact associated with high

and low rainfall years and the loss of the wetlands. There

has already been a significant loss of wetland functionality

through the development of informal settlements in the area

and the P166 will only compound the situation.

The SRIB has not seen, or is aware of, any mitigation

measures to address these critical factors and therefore

strongly opposes this development.

beyond the scope of this study to undertake a full

catchment-level hydrological modelling exercise,

the cumulative impacts in terms of potential

wetland area loss related to the proposed road

will be investigated in the EIR-phase wetland

study

If relevant (based on the final proposed

alignment and whether canals could potentially

be affected), these mitigation measures will be

included in the EMPr.

“The valley is a natural storm water drainage system: any

road construction here would be extremely dangerous and

unwise, especially should we have a repeat of the type of

storms experienced in the last two years”

(Note – the valley referred to is the White River Wetland)

Rob McQueen

Comments E-mailed

It is acknowledged that storm water from the

adjacent suburbs of White River is discharged

into the wetland area, as evidenced by a number

of storm water outflow pipes into the wetland.

The management of this storm water if a road

were to be developed through this area is not a

specific wetland-related issue, but the design of

the road through the wetland (if the road is

approved to pass through this wetland) will have

to consider storm water implications. Potential

impacts of the road in terms of storm water

creation and the resultant impact on wetland

hydrology will be one of a number of potential

impacts of the road that will be further



investigated in the EIA-phase wetland report.

I am concerned about wetland encroachment and

traffic routing.

Robin Clanahan

Comments &

Registration form

Emailed

The importance of wetlands in terms of their

ecological functionality, especially in terms of

being located in a landscape transformed to a

large degree by agricultural activities is

supported. The ecological importance of

wetlands as movement corridors is discussed in

the scoping-phase wetland report.


wetlands along alternatives considered in the

EIR phase will be further assessed in the EIR-

phase wetland study.

The route through White River: Planned to pass through a

wetland, “bird-sanctuary” and too close to my properties.

Rob McQueen,

Comments Emailed

The significance of the potential impact of the

proposed road on the White River wetland is

recognised. In this context, due to the issues

associated with the P166 servitude in the White

River area as identified by specialists and

various stakeholders alike, a new alternative has

been created (to be fully assessed in the EIAR

phase of the project) in the White River area as a

way of potentially mitigating environmental

impacts associated with the P166 servitude in

the White River area.

“There are many other issues that come to mind

It (Proposed alternative 1) will impact badly on wildlife

habitat and natural wetlands, which are particularly precious

as they are so close to urban and industrial areas.”

Dave Goodwin,

Comments Emailed

The importance of wetlands in terms of their

ecological functionality, especially in terms of

being located in a landscape transformed to a

large degree by agricultural activities is



supported. The ecological importance of

wetlands as movement corridors is discussed in

the scoping-phase wetland report.


wetlands along alternatives considered in the

EIR phase will be further assessed in the EIAR-


“My points of concern are as follows

Negative Impact on wetlands and wildlife.”

Mark Attwood,

Comments Emailed

The potential impact of the road on wetlands has

been scoped in the wetland study, and a number

of potential impacts have been identified. These

impacts will be further assessed in the EIAR-


“My points of concern are as follows

2) Negative Impact on wetlands and wildlife.”

Alan Luus, Comments

Emailed

The potential impact of the road on wetlands has

been scoped in the wetland study, and a number

of potential impacts have been identified. These

impacts will be further assessed in the EIR-


Scoping study

The history and development of White River needs to be

considered in context of the proposed routing. There has

been comment from municipality in the past that the

wetland sections would never be suitable for a road – this

may have affected decision making and subsequent

township development. Dating back at least 10 years,

efforts have been made by various parties, through the

Mpumalanga Wetland Forum, to have the servitude through

the wetlands de-proclaimed. The Department of Water

Affairs (Then DWAF, now DWA) commented in this

connection, that the construction of the bypass would never

be allowed to go ahead through the wetlands.

Mr Andrew Rossack

Comments E-mailed

We cannot comment on previous comments

made by the Department of Water Affairs made

on matters not directly related to the current EIA.

Nonetheless the point made is recognised, that

the proposed road servitude through the White

River wetland has the potential to result in a

significant impact on this wetland as a large area

of wetland could potentially be affected. This has

been flagged as an important issue in terms of

the scoping-phase wetland study, and will be

further investigated in the EIR-phase scoping

study, which will include a delineation to

determine the extent of the wetland area affected



Wetlands

The importance of wetlands in the area cannot be over

emphasized. With the establishment of the Phumlani and

Msholozi areas, large wetlands have been impacted,

channelized, and degraded. The study MUST look seriously

at the CUMULATIVE impacts of the wetland impacts for the

whole area.

The wetlands must be fully delineated, including all the

common hill seeps as well as the wetland catchments (and

impacts therein).

The flood attenuation and ground water recharge are critical

functions of wetlands in the White River area. Many

by the servitude.

The cumulative historical and recent loss of

wetlands in the wider area is recognised. As

such cumulative impacts related to the proposed

development, especially in terms of wetland

transformation and loss will be assessed in the

EIR-phase wetland assessment.

The scope of this EIA relates to the route

determination of the proposed road. The

proponent has stated that separate processes

(Basic Assessment studies) will be undertaken

for other listed activities associated with the

construction of the road. Detailed delineations of

all wetlands along the finalised route will be

undertaken as part of this process. However in-

field delineation is being undertaken as part of

the present wetland studies where required in

order to determine the degree of impact on

affected wetlands and in order to characterise

the wetlands potentially affected. As such in-field

delineation will be focussed on prioritised

wetlands in order to determine the degree of

impact of the road on these key systems.

The ecological and hydrological function of



residents are dependent on groundwater due to limited

municipal supply.

The wetlands largely feed the Nels and White River – both

tributaries of the Crocodile River. The Crocodile River is

under extreme stress, being over 120% allocated. Wetland

report must therefore consider carefully their function in the

ecosystem, importance of maintaining ecological flow.

Wetland assessment must model the impact of their loss on

stream flows and flood attenuation.

Wetland assessment must consider climate change and the

function and risks of wetlands and downstream activities

under climate change scenarios.

wetlands has been addressed in the scoping


The Catchment Management Context is

recognised, especially the role that wetlands

perform in ensuring quality, and in some

respects quantity of water available. Functionality

of potentially affected wetlands will be

considered in the EIR-phase report.

The scope of this EIA is to consider the impacts

that would result from the proposed road, if

developed, but it is acknowledged that

downstream impacts need to be taken into

account (downstream impacts are discussed in

the scoping-phase wetland study). Although it is

beyond the scope of this study to undertake full

catchment-level hydrological modelling exercise,

potential downstream impacts in terms of

potential wetland transformation related to the

proposed road will be investigated in the EIR-

phase wetland study

The scope of this study is limited to a

consideration of the impact of the proposed road

development on wetlands and other surface

water resources within the affected area. The

effects of climate change are long term and there

is much uncertainty attached to climate change

scenarios. Due to the difficulty of applying the

effects of possible climate change at such a fine



scale, a consideration of climate change

scenarios is not possible as part of the current

study.

“Almost the whole of the section through White River

northern suburbs is in wetlands that would be moderately to

severely impacted. The “spot” water course / wetland

crossing points on the DSR maps are a poor representation

of the extent of these impacts. The geological formation in

the conservation area and wetlands is most unsuitable for

the construction of a heavy duty road.”

Mbombela Ratepayers

Association – White

River Branch

The extent of the potential wetland area that

could be affected / impacted by the proposed

road servitude through the northern part of White

River is acknowledged. This area has thus been

highlighted as a priority wetland for further

assessment.

The ““spot” water course / wetland crossing

points” as referred to in the comment were used

on the maps in the report to provide an indication

of the number of wetlands crossed per

alternative at a high-level scale. Boundaries of

wetlands along the alternatives being assessed

in the EIR phase will be indicated in the EIR-

phase wetland study maps.

“I object to the current proposed route for the P166 Road

from where it crosses the road to Sabie and passes through

the wetland and joins up to the R40 next to the Casterbridge

Lifestyle Centre.

My objections to this part of the proposed route is on the

following grounds:

I. This route will have a massive negative impact on

the precious wetland which it is going along - not

through or across. Not only is this a green lung for

White River and a Nature Reserve much used by

the community, but all wetlands are vital to the

health of our precious rivers. There is no design

possible that could keep the road going through that

Kay Barnett,

Comments

E-mailed

The first point in 1) raised is an important one, as

the way in which a road crosses a wetland is

very important in terms of the nature and

intensity of the impact on the wetland. This

relates to the relative spatial area of the wetland

that is impacted upon / transformed by the road;

when crossed perpendicular to a typically linear

wetland / drainage feature, the area transformed

is much smaller than if the road runs through the

wetland area obliquely or along the feature. In

the context of the White River wetland, this issue

has been noted as a very important potential

issue that will need to be further investigated in



Wetland without irreversibly destroying it.

II. In addition I am aware that it is one of the few

places that Aloe Simii are still found in their natural

habitat. Plus there is a rare frog inhabiting the

wetland. These are very significant facts that should

immediately prevent this route being used and any

other route that passes along a wetland.”

the EIR-phase of the study to determine the

nature of the impact of the proposed road on the

wetland along the entire stretch of the road as it

traverses the wetland.

The critical functionality of wetlands in ensuring

river health is acknowledged, and has been

discussed in the scoping-phase wetland report.

In response to point 2), The ecological

importance of the wetland has been raised by a

number of parties. The presence of threatened

species and the provision of habitat for these

species within the wetland increase the

importance of the wetland in terms of an

assessment of its functionality (in terms of

ecosystem goods and services provision) and its

current state.

In the context of this comment, based on

specialist inputs as well as public comment and

feedback relating to areas of environmental

sensitivity, a number of environmental issues

were identified in the area where the P166

servitude traverses the White River area, in

particular relating to where the servitude runs

directly through a wetland. Accordingly a new

alternative, the White River North Alternative has

been created, and will be comparatively





“While the route(s) through the illegal township of Msholozi

effectively dismisses the destruction and loss of vital

wetlands, it painfully struggles to find a way through the

morass of congested human habitation which has been

allowed to grow unchecked.”

Peter Dobble,

Comments Emailed

It should be noted that wetland impacts across

all of the Phumlani Alternatives, including that

along the existing servitude, have been

considered, and will be further considered in the

EIR-phase wetland study.

Please register me with the project in my personal capacity.

I suggest you also ensure that the Rate Payers association

is also registered and WESSA Lowveld.

I have briefly looked at the BID map - it is much too small

and lacks necessary detail. Please re-issue the BID with

maps that clearly identify the proposals. It is unclear what

section of road the application is for.

You need to provide more information.

Your BID does not make any reference to alternative

activity or alternative locations

You need to consider additional activities in 544.

I am very familiar with the area. I suggest that as an

absolute minimum, and prior to the scoping report being

released, you undertake the following regional studies:

Current wetlands

2. Current wetland functionality.

Mr. Andrew Rossack,

Comments Emailed

You have been registered on the project

database and you will receive all information

regarding the project.

The Rate Payers Association WESSA has been

registered on the project database.

The information provided in the BID document is

basic and not too technical to ensure that people

of all level of education can understand the

message. The Scoping Report will provide much

detailed information required. Should you

require any technical information which is not

covered in any of our public documents Kindly

request it and it will be sent to you.

A separate Basic Assessment process/es will

be undertaken to address GNR544 activities (this

EIA is only route determination and only the

route determination activity will be authorised by

DEA)

In answer to your request for regional wetland

studies, the project team would like to point out



3. Wetlands lost since 2000

4. Wetlands lost since ECA and NEMA acts were signed

into force.

I suggest you will find that mapping the wetlands and

joining them will follow the road route almost exactly. You

may also be able to confirm my initial studies that indicate a

greater than 60% wetland loss since 2000 for the greater

White River area, as well as significant losses of

irreplaceable habitat (as per the MBCP).These factors have

to seriously be considered as part of the cumulative

impacts.

The existence of servitude, acquired prior to an

understanding of wetland function (1960's) and the

desirability of such is not a basis for failing to seek out a

more favorable route. In this respect, we are dealing with a

lasting footprint, and thus cost is the least concern.

the scope of this project in terms of being an EIA

for the route determination of a proposed road

that would be operated by SANRAL. The EIA is

focused on the alternative routes that have been

proposed for the road routing and the areas

traversed. As part of the surface water study, all

wetlands potentially affected by the proposed

road have (and will be) considered by the

surface water study. This includes the wetlands

within the proposed road servitude footprint, but

also downstream and other immediately adjacent

surface water features. The study will include a

high level examination of the functionality of the

affected wetlands using the framework provided

by the WET-EcoServices Tool.

Unfortunately it is not part of the scope of this

EIA to determine or quantify regional trends of

wetland loss, and how many wetlands have been

lost since 2000 or since certain laws were

passed into effect. Any EIA focuses on the

spatial scale of the proposed development and

as EAPs and specialists we are mandated to

examine all possible impacts relating to the

proposed development and how these can be

mitigated. Unlike strategic, wider level

assessments such as Environmental

Management Frameworks, State of the

Environment Reports or Strategic Environmental

Assessments EIAs do not quantify trends of

wetland loss in a spatial context wider than the



potentially affected area. Studies assessing /

quantifying regional wetland loss in an area such

as the Mbombela LM would need to be

undertaken as part of one of these wider-level

studies,.

However the EIA process obliges us to examine

cumulative impacts, and as such the EIR-phase

wetland study will need to examine how the

proposed project may cause / exacerbate

cumulative impacts, such as area-wide /

catchment-wide wetland loss.

I would like to confirm that alternative routes are

being considered; the original routing is an old

provincial servitude and alternative routings have

been identified in areas of environmental

sensitivity (both biophysical and social), and the

wetland study will include a comparative

assessment of these routes to propose a

recommended routing from a wetlands

perspective. The consideration of a preferred

routing will also take into account any measures

to avoid significant impacts on wetlands.

The route will go through a wetland area, the current sense

of place would be disturbed

Leandri Joubert,

Comment &

Registration Form,

Emailed,

The potential impact of the road on wetlands

has been scoped in the wetland study, and a

number of potential impacts have been

identified. These impacts will be further

assessed in the EIR-phase wetland study.



My concern is that the project encroaches on a wetland and

affects traffic routing

Charles Robin Hugh

Clanahan, Comment

& Registration Form,

Emailed

This factor is recognised, however the current

EIA is being undertaken in terms of updated

legislation that requires the impact of a

proposed development on environmental

features such as wetlands to be fully considered.

As such the impacts on wetlands will be fully

assessed in the EIA. The EIA process is bound to

identify suitable mitigation measures for all

impacts identified; in the context of wetlands,

this includes routing, design changes, and even

the consideration of alignment alternatives.

I‟m concerned about degradation of wetlands, road

crossings / overpass designs.

Robin Clanahan,

Comment &

Registration Form,

Emailed, White River

Ratepayers

Association

The way in which a road crosses a wetland is

very important in terms of the nature and

intensity of the impact on the wetland. This

relates to the relative spatial area of the

wetland that is impacted upon / transformed by

the road; when crossed perpendicular to a

typically linear wetland / drainage feature, the

area transformed is much smaller than if the

road runs through the wetland area obliquely or

along the feature. In the context of the White

River wetland, this issue has been noted as a

very important potential issue that will need to

be further investigated in the EIR-phase of the

study to determine the nature of the impact of

the proposed road on the wetland along the



entire stretch of the road as it traverses the

wetland.

SOCIAL ISSUES

Needs of the low income population of Mbombela which lies

east of the Hazyview/ KMIA axis

Expand development between the Kruger National Park

boundary, with its parallel rail line and the Hazyview/ KMIA

axis”

The issues of HIV/AIDS have little relevance in this report

“The key strengths of the Ehlanzeni DM and Mbombela LM

have to be enhanced, to cater for the very large population

of unemployed, with a high proportion of illiteracy. These

have little to no bearing on the route selection.”

We also consider the area between the Msholozi

(Dingwell/Phumlani) informal settlement and the R40 to be

suitable for industrial development the alternative Phumlani

3 route would largely eliminate this feasible development”

Robin Clanahan, CRH

for White River

Ratepayers

Association,

comments Emailed

This project is meant to promote positive growth

and development, as in the vein of most

infrastructure projects. This project looks at the

development of a new route linking White River

to Nelspruit and thus the N4. R538 as alternative

route has been addressed in the “Needs and


Report.

Profiling the vulnerabilities of a community

(Mbombela) or local municipality should include

all aspects of social and economic relevance.

HIV/AIDs are of both social and economic

relevance. This is after all a Scoping report –

which is meant to set the scene for the impact

assessment to come.

Profiling the vulnerabilities of a community or in

this case the LM should include all aspects of

social and economic relevance. Unemployment

and illiteracy is of both social and economic

relevance. This is after all a Scoping report –

which is meant to set the scene for the impact



The alternative Phumlani 1 route through the upper section

of the farm Heidelberg passes through valuable agricultural

land Rendering them unviable for agricultural process”

Should the P166 be tolled, there would be a number of

large vehicles passing through White River central area.

The drivers of which are pocketing the toll fees

assessment to come. The SIA will have to

investigate how Phumalani 3 could impact on

potential industrial development in the area

between the informal settlement and the P9/2

road.

The Phumlani Alternatives 1 and 3 have been

discarded as they are not regarded

environmentally feasible, and will not be

considered further.

Tolling of P166 is a funding issue which will only

be considered once implementation is due. This

does not have any effect on the route as

proposed.

These property owners will be affected by this road in the

following ways:

a) Noise pollution from the road

b) Unsightly flyover road visible right next to their houses

and from afar

c)Property values will be hugely reduced as a result of this

road, especially those closest to the current route.

Kate Barnett,

Chairman of the

Environmental

Committee of Uplands

College, Comments E-

mailed

In the context of noise-related impacts one of the

most sensitive receptors are the noise-sensitive

residential areas, and these areas will be the

main focus of the noise impact assessment study

in the EIAR phase. The noise levels from the

projected traffic volume will then be compared

with the prevailing ambient noise level to

determine the intrusion level at the different

noise sensitive areas and mitigation measures

will be suggested.




„sense of place‟ in the area. In order to address



these concerns, a visual impact assessment

study will be undertaken in the EIAR phase of

the project.


potential negative effect of the road through the

White River area on property value. This will be

further assessed in the EIAR-phase social study

The Cromdale Intersection, from a planning and

development perspective, is situated to close to already

highly densified rural residential areas, other economic land

uses and agricultural activities. The locality of the Cromdale

Intersection should be reconsidered for the following

reasons:

It will form an unacceptable physical barrier at the southern

edge of the current semi-urban area and future residential

areas as provided for in the approved Mbombela Spatial

Development Framework, 2011 (SDF). Future urban

development according to acceptable town-planning

proposals will be drastically impacted upon and ignored if

consideration is not given to alternatives for the Cromdale

Intersection.

Areas proposed in the SDF for future development,

especially residential development will be physically

separated and divided in terms of access, services

provision, urban integration and implementation of planning

principles and policies if the Cromdale Intersection remains.

Further alternatives for the Cromdale Intersection and the


Nuplan, Comments

Emailed

The P166 route as presently defined has formed

an integral part of the Mbombela SDF for many

years. The Mbombela roads master plan has

been defined to incorporate P166 and define

access for the Cromdale area via class 2 and 3

roads.



section of road P 166-2 north thereof is there for justified.

There is a governance disaster in the making at Msholozi

squatter camp where Mbombela is accommodating an

unstructured land grab which could:

i. Either impact negatively on the routing of the road.

ii. Or cause unnecessary social upheaval if handled heavy

handed.

Theunis Steyn,

Registration form,

Emailed

Matters relating to impacts that involve the

informal settlement will be investigated during

the social impact assessment.


parts of the Msholozi-Phumlani settlement were

allegedly “illegally” settled. Nonetheless a









alignments.

GENERAL ISSUES

Concerned about the effect on water sources (borehole).

Concerned about safety and security, noise pollution, wild

life in the area.

Concerned about the route and numbers of affected

properties. Most traffic on R40 is commuters working in

Nelspruit. Is this project economically viable/necessary

Linda Liversage,

Comment &

Registration Form,

Faxed

An EIA is being undertaken for the proposed

project to determine whether the development of

a road would be environmentally sustainable.

The EIA and associated specialist studies will

look into these issues raised.

Uplands are an Independent Co-Educational school in close

vicinity to the proposed P166 Road. We would like to be

Katia van der Merwe,

Uplands Collage,

The school have been registered as one of

interested and affected parties and they will be



kept posted on any development as it might affect our

educational environment

Emailed included in all communication regarding the

proposed project

From early December 2012, at first notice, I have requested

improved maps for the proposed development. These were

only supplied AFTER the public participation meeting. Prior

to the meeting, it was unclear as to where the roads were

intended to go. It is most unfortunate that this error may

have meant some parties were not aware and thus have not

attended the first round of public meetings.

In the public participation meetings (repeated and I did not

attend the first), there was incorrect processes shown in

that it was indicated that the public would not have an

opportunity to review and comment on the final scoping

report.

Andrew Rossack,

comments E-mailed

This error in the presentation is acknowledged

and was corrected for subsequent presentations

Report back by I & AP's from some of the public meetings

has been the impression gained from the EAP is that the

proposed P166 is a fait accompli.

Andrew Rossack,

comments E-mailed

The claim that the proposed road is a fait

accompli is incorrect. An EIA is being undertaken

for the proposed project to determine whether

the development of a road would be

environmentally sustainable.

The route determination process now under consideration

has not presented exact details as part of the public

participation process but only presented approximate

alignments as per Plan No N 2317 – Locality Map prepared

by Endecon Ubuntu Engineering Consultants.


Nuplan, Comments

Emailed

Full details of the public participation undertaken

will be made available in the Draft Final Scoping

Report made available for public review.

In our email correspondence of 23 and 26 November 2012,

we requested to be registered I & AP's to which you replied

that we would be kept informed. It has now come to our

attention that numerous public meetings were held in the

Barry Carlse, Sand

River Irrigation Board,

Comments e-mailed

RHDHV acknowledge the negative impact this

miscommunication had on your organisation and

project. We truly believe that your role in the

project is critical hence your organisation was



week of the 11th March.

Can you please explain why we received no notification of

these meetings? We believe irrigation boards are important

stakeholders, representing the interests of various parties.

What measures do you intend to undertake to address this

serious flaw in your public participation process? It is also

unclear as to where you wish correspondence to be

addressed to your Cape Town office or Johannesburg

office?

identified as one of the critical stakeholders when

the project commenced.

Your organisation is registered in the project

database and you will receive project

correspondence. We acknowledge the

seriousness of the matter and its consequences

for the environmental study being undertaken

and sincerely apologised for the inconvenience.

All project correspondence should be sent to our

Johannesburg Office

I appreciate having roads constructed but request that the

local public be employed.

Safety of the public is my concern, so I think Phumlani 2

Alternative will be right.

Thabo Dube,

Comment Form

Minutes of Phumlani

Public Meeting,

The employment of people will be carried out

during the construction phase of this project and

SANRAL will follow the existing labour legislation

and regulations or guidelines.



feasible based on the environmental assessment

and comments from the pubic. In the context of

this comment it is important to note that due to

environmental issues Phumlani Alternatives 1

and 3 have been discarded and will not be

considered in the EIAR phase.

Selection of Phumlani 2 Alternative is recommended December Ndziane,

Comment Form:

Minutes of Phumlani

Public Meeting











Selection of Phumlani 2 Alternative is recommended Jeoffrey Mthethwa,

Comment Form:

Minutes of Phumlani

Public Meeting









Selection of Phumlani 2 Alternative but also to be shifted

away from the community.

Lucky Lukhele,

Comment Form: P

Minutes of Phumlani

Public Meeting

The environmental team will assess this

alternative including the recommendation and

will recommend where the best line should run

based on the environmental assessment. In the

context of this comment it is important to note

that due to environmental issues Phumlani

Alternatives 1 and 3 have been discarded and

will not be considered in the EIAR phase.

Selection of Phumlani 2 Alternative. This will create jobs for

the community.

Caris Ndhlovu,

Comment Form:

Minutes of Phumlani

Public Meeting




and comments from the public. In the context of





Selection of Phumlani 2 Alternative. This will empower the

local community.

Oupa Mokoena,

Comment Form:

Minutes of Phumlani






Public Meeting 13

March 2013







local community.

Linah Biya Mathebula,

Comment Form:

Minutes of Phumlani

Public Meeting










local community.

Lucia Mathebula,

Comment Form:

Minutes of Phumlani

Public Meeting









Selection of Phumlani 2 Alternative is recommended

Margaret Mudaka,

Comment Form:

Minutes of Phumlani

Public Meeting











Selection of Phumlani 2 Alternative.

Consider the human nature.

Louis Sidubela,

Comment Form:

Minutes of Phumlani

Public Meeting:










This will create jobs for the community.

Sonto Nkosi,

Comment Form:

Minutes of Phumlani

Public Meeting









We need this road in the area. Comment form from

the Minutes of

Phumlani Public

Meeting

The need and desirability of the proposed project

has been indicated in the report and assessment

of all alternatives will be undertaken whereby the

final decision will be the responsibility of the

DEA.


Robert Lekhuleni,

Comment Form

Phumlani Public

Meeting:











This will create jobs for the community.

We need more safety to the area.

Bigboy Khumalo

Comment Form:

Phumlani Public

Meeting

Job creation and road safety will be addressed

during detail design. Impact of Phumlani

township on road safety is one of the reasons for

consideration of alternative alignments.

With regard to yesterday's meeting at Phumlani Village, we

as members of the community and ANCYL BTT we were

not happy about the unconstitutionality of the meeting, the

meeting was non political but it was chaired by a political

appointee of the community, in our capacity as ANCYL BTT

we found that to be improper and unconstitutional in so

many levels, we want the RHDHV to come back and host a

proper meeting chaired by them, Not DA, not ANC.

As the ANCYL BTT we are going to do everything in our

power to ensure that OUR community's interests are put

before anyone else‟s, as it was evident in yesterday's

meeting that you(RHDHV) have already chose people to

work with and excluded others. We want to talk as ANCYL

BTT with you, to correct your mistake moving forward.

Ngumazino Khoza,

ANCYLBTT

coordinator)

Comments Emailed

The involvement of local ward councillors is a

standard public participation procedure in

environmental impact studies conducted across

South Africa and it is also a legal requirement of

the Environmental Impact Assessment (EIA)

Regulations (2010), R54(b)iv. As an elected

official representing the community, RHDHV

requested the councillor to open and close the

public meeting.

We understand through your e-mail

correspondence that you are uncomfortable with

the fact that the ward councillor was involved in

the facilitation of the public meeting for the

Scoping phase and this is noted as part of our

public participation records for the project. Your

concern will also be conveyed to our Client, the

local council and the environmental authorities.

Your issue in this regard was not raised during

the public meeting itself and we see no merit in

holding an additional meeting at this stage.

There will be a further meeting during the next

consultation phase of the EIA and we will seek to

find a way to accommodate your concerns in

running this next meeting in Phumulani.

ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND …rhdhv.co.za/media/201210/Final Enviromental...

Documents

Transcript of ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND …rhdhv.co.za/media/201210/Final Enviromental...