The developers must really be desperate. Their latest response in the form of a letter to the Cape Argus of simply repeats assertions they have made before in the hope their ‘facts’ will be taken at face value. Let’s see how their claims stand up to closer scrutiny. To quote their words, “here are the facts:”
Claim 1: The River Club site is in fact severely under-utilised, closed to the public and degraded, with some parts being used as a rubbish dump - hardly a “precious part of our city”, as disingenuously claimed by the OCA.
Fact 1: The River Club site is graded as Open Space with some Consent Uses. As an Open Space, it is appropriately utilized as a mashie golf course, restaurant and conference centre. It is only ‘severely under-utilised’ if you want to use if for different purposes. The problem is that the developers bought the property at sub-market price because it was sold without development rights (bare dominium). There is nothing under-utilised about it unless you want to change the zoning, build a massive mixed development on the site, destroy the landscape and invent a new river. Under-utilised? No.
Fact 2: The developer has frequently claimed parts of it are used as a rubbish dump. This is a peculiar claim because if you have been to the site, you will know that the only access to the site is one road past a security gate staffed by security guards. If intruders are coming into the site and dumping rubbish, that can only be because of poor management of the site by the developer himself. Alternatively, intruders must be making a special effort to cross a river to deliberately dump garbage on the River Club side of the river. Why they would want to make a special effort to cross the river to dump on the River Club site and not simply dump their garbage in the river makes no sense. We have never seen this garbage that the developer likes to talk about. In any event, there is no logic in saying you must develop 150 000 square meters of concrete to deal with poor waste control. As we have previously said, you can manage waste better without imposing an inappropriate and destructive development on the site.
Fact 3: The developer might think that there is nothing “precious” about the site, but that is an opinion, not a fact. It is an opinion which was roundly rejected by Heritage Western Cape when it commented that the River Club EIA “has downplayed the green, riverine character of the site which contributes to the intangible heritage experience.” They went on to point out that “the fact that the site has been considerably disturbed in the latter half of the 20th Century does not in any way take away the meaning of the site as a historic frontier or point of containment, conflict and contact or its significance to the region.” Even the developer’s own Khoi supporters note that “the proposed development is a most sensitive location both in terms of its ecology, as also its deep heritage significance.” As HWC note, the site’s “most important heritage resource” is the “site’s open, green qualities as a remnant of landscape that considerable historic and cultural heritage significance.” The developer might reject there is anything precious about the site but, if that is the case, then he clearly has no understanding of the heritage resource that is the site he owns and should not be seeking to develop it.
Claim 2: 65% of the site dedicated to open green spaces
Fact: As we pointed out, the BAR claims that 65% of the site will be Open Space. It does not call this space Green Space, even though the developer has tried to present it as such. But on closer examination, here are the facts, taken directly from the BAR itself. Of the 14.7 ha site, podiums comprising the buildings and their covered parking cover 8ha of the site, and internal roads and bridges 1.5ha. That leaves about 5.2ha, which is about 35% of the site rather than 65% for potential open space. Take a look at the picture above, drawn directly from the BAR, which shows the extent of the footprint of the development. Compare the footprint of the River Club to the adjacent sites. Across the canal to the East is South African Astronomical Observatory site, with sparse buildings and lots of green space. Across the canal to the North is a corner of the PRASA railyard densely populated with railsheds. The River Club development had no similarity to the SAAO site but lots of similarity to the PRASA site. Where is that green space? Obviously, the developer must be practicing some kind of magic by covering parking podiums with greenery to create the image of 65% green space. But a forest can’t be a forest if it is planted over an underground parking lot.
It’s interesting to note that the developer has changed his initial claims of 65% “Green Space” to now talk of 65% “Open Green Space”. This was after our second update pointed out that he actually was wrong to refer to Open Space as Green Space. So, his solution is to create something called ‘Open Green Space’ which must be a ruse to enable him to create a fiction that the site will have more green and less building. Let’s be clear, the site is densely built – 65% of the surface area taken up by concrete. Even if you put some greenery in pots or soil over the plinth of a parking lot, it is not by any manner “Green”.
Claim 3: It will see the major environmental rehabilitation and upgrading of the area
Fact: First, it will see the entire destruction of the area, and any archeological remnants that may be present underground will be permanently destroyed, in spite of the recommendations of HWC to ensure a proper archeological survey of the area, and the recommendations of the TRUP Baseline Study that “any open land within the study area … should be considered to be potentially archaeologically sensitive and should be screened/surveyed before any transformation or development.” Second, tonnes and tonnes of infill will be trucked into the site to artificially lift the development out of the flood line. That infill will have to arrive by truckload, after truckload, after truckload, for days, weeks or months on end. Each truck will release organic pollutants and ozone depleting chemicals, dust, and add to road risks and damage to roads. What environmental rehabilitation will be done after this monumental engineering works will hardly offset the harms of the construction in the long-term.
Claim 4: It will showcase the Liesbeeck River, which has cultural and heritage significance.
Fact 1: Actually, the developer simply omits the fact that the development will fill in the original river course and recreate the river in the course of the current artificial canal. If the cultural and heritage significance of the site is so important to the developer, how does he explain the fact (not an opinion, not a misrepresentation) that any view of Lion’s Head from the confluence of the Black and Liesbeek Rivers will be blocked by some very, very large buildings. You need only take a look at the image on this petition site at the start of this campaign to see what you might expect to see from the river confluence once the development has done with it. And these are the developers' images!
Fact 2: The developer and his Heritage Consultants have consistently ignored the fact that the heritage of the site cannot be reduced solely to the River. HWC IACOM stated clearly that “it is not just the riverine corridor … but the entire TRUP valley including the riparian corridor which is noted as highly significant and is expressed in both its tangible and intangible qualities.” Yet the developer continues to rely on the notion of some kind of ‘refurbishment’ of the river as taking care of the cultural and heritage damage which their development will inflict.
Claim 5: Extensive and independent biodiversity assessments were conducted by a team of experts who found that the rivers surrounding the site were severely degraded.
Fact: There is no dispute that the rivers are currently degraded. However, the degradation is a function of how the entire course of the river is managed. Moreover, the recent report by Aziz and Winter, to which we previously referred, points out that concreting the site will result in Cape Town forfeiting the opportunity to use the site to recharge the aquifer, a critical strategy to render Cape Town water resilient.
Claim 6: The proposed development will drastically improve the environment.
Fact: Actually, what biodiversity assessment in the BAR stated was far more modest. It said that “Implementation of this alternative would, from a biodiversity and general aquatic ecosystems perspective, be a positive impact, and its implementation is recommended.” The word ‘drastic’ does not appear anywhere in the report.
Secondly, the biodiversity report qualifies this positive impact by saying “This positive outcome has not however been rated as of high significance – this reflects the acknowledged risks of implementation, as well as the impacts to any sensitive natural ecosystems that would be associated with a development of the scale of the proposed River Club development.” In other words, the biodiversity specialists downplay the significance of this positive impact as being of modest importance.
Thirdly, and the developer will not say this, the biodiversity report has a very important qualifier on the second page. It states “… the findings of this study are based on a number of important assumptions that, if unfounded, would require substantial components of these findings to be reconsidered.” One of these assumptions is that “the findings of the hydrological study… are accurate.” Since we will show (tomorrow) that there are serious flaws in the hydrology report, there can be no basis for claiming that the biodiversity report gives any support to a claim that this development will “drastically improve the environment.” In fact, the biodiversity experts leave themselves the opportunity to turn around and reconsider the findings entirely if their assumptions are not founded.
********
Tomorrow we will respond to the hydrology and public participation claims. Watch this space …