No, it’s not the 1975 Booker Prize-winning novel by Ruth Prawer Jhabvala nor the 1983 Ivory-Merchant film version of the famous novel we are talking about.

What we are talking about is the likely impact on the environment if the hugely destructive development goes ahead at the River Club, currently part of the Two Rivers Urban Park. Heat and Dust. Lots of it...

Let’s explore what it will really mean to build a 150 000 square metre development on a 14.7 hectare plot requiring 3 metres of infill at the site.

It is obvious that the construction required with be much more demanding and much more intensive than if the same size development were to be put up somewhere other than a floodplain.

Firstly, The Geotechnical Report (Annexure C11 from the Rezoning Application) notes in its Conclusions that “The presence of the water table at depths of as little as about 1,50m below present ground level, coupled with the high permeabilities of the saturated soils, are perhaps the most critical factors that can affect the construction time and cost of the basement structures.  Excavation below the water table will require intensive dewatering using closely spaced well-points in the sides and across the floor of the excavations. This is on account of the often sandy permeable nature of the site soils. Localised problems can be expected where the open-voided fill materials will act as water conduits with unmanageable inflows…Lowering the basement level below the water table implies that large scale dewatering will be required to facilitate, not only construction in the dry, but excavation with a trafficable surface.”

So, digging around in a soaked water table is not impossible but it will add to the complexity and duration of the work.

Then, secondly, the developer’s Visual Impact Assessment notes that there will be a “high volume of trucks transporting fill material and other construction material to the site” which “will also contribute to an altered sense of place (increased visual clutter, noise). Dust generated at the site will be visually unappealing and may further detract from the visual quality of the area.” Ironically, the VIA makes the most pathetic recommendations for mitigation, which hardly qualify as measures to reduce ‘medium risk’ to ‘low risk’ but here they are: “Avoid excavation, handling and transport of materials which may generate dust under high wind conditions. Consolidate the footprint of the construction camp(s) to a functional minimum. Screen the yard with materials that blend into the surrounding area.  Keep construction sites tidy and confine all activities, material and machinery to as small an area as possible.” This is a 14.7 hectare site, not a backyard construction. Anyone who has seen the multiple constructions going up all over Observatory (all much smaller) will know that builders can't control, and generally don’t care where the dust ends up and they certainly don’t bother mitigating anything. And the South Easter blows most days from October to March and often very strongly.

Bizarrely, the developer’s Transport Impact Assessment report is completely silent on the extent of increase truck traffic during construction and dismisses any significant impact of construction vehicle traffic on the basis that “if the contractor is restricted to do hauling outside peak hours the impact will be significantly reduced.”  There is no analysis of the frequency of trips needed. The idea that huge trucks laden with infill will only barrel onto site at night is weird to say the least.

So, how much truck traffic will be needed?

The site is 147 000 square metres. The Environmental Management Plan notes that the site will need to be raised 3m because of the flooding risk. This means that approximately 440 000 cubic metres of infill will be needed. Some of that might come from excavations, but then the full development footprint extends beyond the River Club’s erf to 27 hectares or 270 000 square metres. So, let’s be conservative and guesstimate that only 360 000 cubic metres of infill will need to be brought onto site.

There is no other way to bring infill onto site other than a truck, a very large diesel truck. An average construction truck 10 Ton Tipper Truck) is said to contain 10 to 18 cubic metres. To be conservative in our estimates again, let’s use the upper limit of 18 cubic metres; that means the requirement to move 360 000 cubic metres will involve about 20000 truck trips - solely to deliver  the infill alone. This is in addition to the truck movements that will be needed for bringing the concrete or fittings onto site. Meaning that simply coping with the infill needed to build this massive development in a floodplain will add 20 000 truck trips overall.  Depending where they are bringing infill from, that’s maybe 400 000 to 800 000 km of diesel truck travel.

This means that the incremental construction truck traffic is huge. This is not a task that can be reduced to “hauling outside peak hours” so that “the impact will be significantly reduced”. This will be a huge impact.

What impacts will that have?

Firstly, the US Environmental Protection Agency reported in 2018 that 28% of all Greenhouse Gas emissions in the US arose from the Transportation Sector and 23% of that is associated with medium and heavy-duty trucks.  Diesel smoke consists primarily of black carbon, which has a much stronger climate warming impact than that of carbon dioxide (nearly 3,300 time more). An additional 20 000 truck trips using diesel is therefore not a climate-friendly consequence. Because of the threat posed for GHG emissions, the World Bank has proposed 8 In-Use emission reduction strategies to address truck related impacts on Climate Change one of which is simply limiting vehicle operations in certain regions. In contrast, this proposal will simply ramp up diesel emissions on a huge scale in an ecologically sensitive area.

Amazingly, the so-called independent consultants, Promethus, who were called in by the developers to provide an assessment of their Climate Change responses made the claim that “due to the nature of the proposed redevelopment of the River Club property, it is our opinion that the greenhouse gas emissions related to the construction phase of the development will be minimal.”  Their opinion seems to ignore 360 000 cubic metres of infill, 20 000 additional diesel-powered truck trips and 400 000 to 800 000 km of diesel-powered truck travel, let alone the ‘normal’ emissions generated by a less complicated construction project of this size. Or perhaps they weren't asked to look at issues the BAR avoided examining in the first place.

Moreover, while the City’s Environmental Management Department says the environmental authorisation does not give due consideration to Climate Change impacts and resilience and that the City’s own resilience to floods will be diminished through infilling the Liesbeek river and floodplain, Prometheus is able to pronounce that the rehabilitation of the Liesbeek River will “improve stormwater drainage on the site and surrounding areas and will in fact improve the resilience of the area.”

Did they even read the report before trumpeting this Greenwash? Or was the mandate given to them constrained by what was in the BAR? But it's clear that the developers have been stung by the criticism that they have failed to address Climate Change. 

Secondly, we know that construction is known to be one of the most hazardous occupations in South Africa. Vehicle accidents are a major contributor to injuries in construction. Every road trip, whether loaded or not, increases the risk of an accident. Injury rates in the construction sector were estimated by the National Institute for Occupational Health in South Africa at about 30 to 40 injuries per 100 000 workers per annum. Fatalities associated with motor vehicle accidents in construction are about four times more common than other types of injuries.

Given that the developers anticipate approximately 157 170 person-months of temporary construction work over a 30-month period, one can work out the additional burden of work-related injuries that are incurred because of having to add this massive infill on a flood plain.  Without the additional 20 000 truck trips, the construction would be expected to incur about two deaths over a 30 month period; with the additional trucking in of infill, the  fatality risk for motor vehicle accidents applied (four times the general construction accident fatality rate), the fatalities likely to arise in the construction phase will double to about 4 per annum. This means that the incremental impact of additional construction work required to build in this setting could be of the order of two fatalities per annum.

The ratio of fatal to non-fatal but disabling injuries in the construction industry was about 1:10 in 2019. This means an additional 20 disabling injuries per annum. Further, the ratio of fatal to non-disabling injuries in 2019 was about 1:125, meaning an additional 250 non-disabling injuries per annum related to the additional construction burdens.

The Federated Employers Mutual Assistant (FEM), which provides compensation for injury and illness in the Construction Industry in SA, estimates the average cost per accident in 2020 was R 40 501, which means an additional 250 accidents will cost about R 1 billion as a result of the additional injury burden. So, while the development will generate short-term jobs, it will also increase the risk of injury and related cost to the economy.

And just to confirm that MVAs are a driver of construction-related injury, a steady rise in Motor Vehicle Accidents has been noted in the South African construction industry since 2001. This development will require massive increases in truck traffic because of the massive earthworks required – the infill can only be delivered by truck.

So, trying to build this monumental and dense construction will come at a cost – including the cost of human life and human injury.

Of course, none of this is reported in the Developer’s specialist study on Socio-economic assessment which only trumpets the so-called benefits. Another ‘independent’ report, obviously.

What about the dust? Well, it’s not possible to quantify the extent but anyone living in Observatory will know from constructions much smaller than that proposed at the River Club that you just have to get used to dust everywhere – on your window sills, in your clothes hanging on the laundry, stuck to your car’s windscreen and body work – caking every surface that is not closed off. The South Easter whips it along and there is little one can do to mitigate its impact and the trucks drying the dirt on the road simply stir up the dust for the wind to send on its way.

Our neighbours in Salt River have that to look forward to – 18 months of dust everywhere.

But more to the point is heat. An Urban Heat Island (UHI) is an urban area that is warmer than the areas surrounding it. When houses, shops, and industrial buildings are constructed close together, it creates a UHI. Eighteen buildings of 20 to 46 m high comprising 150 000 square meters of floor space represent a LOT of concrete and it is all concentrated on a relatively small space.

Concrete buildings will act as heat sinks, absorbing heat during the day and emitting heat at night. They will block heat coming from the ground from rising into the cold night sky.  Because the heat is trapped on lower levels, the temperature is warmer. UHIs also affect water quality because when warmed water from a UHI flows into the next watercourse, it stresses the native species that have adapted to life in a cooler aquatic environment.

In fact, the South African Astronomical Observatory, in their appeal against the Environmental Authorisation [LL14] , describe the “densely packed individual buildings” as creating an ‘urban wall’ which confirms that placing 18 large buildings in a relatively small site is simply creating a perfect Heat Island! And Heat Islands are a key contributor to Climate Change in urban cities. So, from being Green Open space, the River Club will be transformed into a Heat Island that cannot be compensated for by putting some trees on top of the underground parking lots.

When the City says it wants to building a Water Resilient City and its Environmental Management Department says that this proposal will lead to ‘loss of climate resilience’ because of infilling the floodplain, the heat island effect and anticipated increases in rainfall intensity and sea level rise due to Climate Change, how does the LLPT think it can convince us that the proposed development is good for Climate Change? The documents submitted by the developers for the rezoning did not address climate change directly and the only comments on Climate Change are not from the developers but appear as complaints from objectors to which the developer respond, with the bland but unsupported assertion that climate change was taken into account in the Hydrology report.

Perhaps that is why the developers felt the need for more Greenwash to pretend that they really do care about Climate Change. Their track record of dumping into the Liesbeek River in 2013, pictured above, is grounds for grave concern.