Yesterday, the South African Heritage Resources Authority (SAHRA) visited the Two Rivers Urban Park (TRUP) as part of their process of grading the site as a National Heritage Resource. SAHRA’s grading follows the February 2020 nomination by the the Goringhaicona Khoi Khoi Indigenous Traditional Council (GKKITC), Observatory Civic (OCA) and the Two Rivers Urban Park Association (TRUPA) to Heritage Western Cape (HWC) to grade the TRUP as a Provincial Heritage Resource. It is distressing that more than a year and a half has elapsed since the nomination was made to recognise the critical heritage importance of the entire area. During this time, the City and Provincial authorities approved the redevelopment of the River Club. As a 14.7 ha triangle of land at the junction of the Liesbeek and Black Rivers, the River Club site is a particularly significant part of the TRUP.

A 2015 report by heritage consultant ACO Associates] noted that “The valley of the Liesbeek, Black rivers, the confluence and remnants of the Salt River estuary, exist today. In the context of the history of South Africa this is an historical place and falls clearly within the ambit of the National Estate as ‘landscapes and natural features of cultural significance.’ … The confluence of the Black and Liesbeek Rivers has special significance as this is possibly the last untransformed wetland in the study area … The present day wetland at the confluence of the Liesbeek and Black Rivers, with the small area of high ground occupied by the Royal Observatory and the River Club, amount to the last surviving elements of this historical landscape.”

The Report recommended that “As a first step, the identification of land for heritage grading and the restitution of wetland areas will go some distance to honouring events of the past.”

That was in 2015.

Six years later, the Liesbeeck Leisure Properties Trust (LLPT) are constructing a mega-development of 18 buildings up to 44 m tall on the site as fast as they can. If allowed to proceed, this historical landscape will be transformed into dense melee of high-rise buildings to house Amazon HQ as the anchor tenant.

Ironically, one of the authors of the ACO Associates report jointly drafted the LLPT’s 2019 Heritage Impact Assessment (HIA) that comes to a diametrically opposite conclusion to the ACO report of 2015. The HIA argued that placing 150 000 square meters of concrete on a site of “special significance” would enable the development to honour “events of the past” seemingly because, “apart from the Liesbeek River, the site itself has little obvious heritage significance.”  While the HIA consultants for the LLPT conceded that the placing of 18 buildings of up to 44m in height on the site “may be a significant visual impact”, they dismissed this impact as being “of relatively low heritage significance.” It is this cognitive dissonance that led HWC to reject the HIA as failing to meet the requirements of the National Heritage Resources Act.

It’s quite clear that the LLPT wanted a heritage narrative that would enable the redevelopment to proceed unhindered, which is what they achieved through their consultants’ HIA.  However, HWC called this an assessment of significance that was “tailored to arrive at mitigation for the development rather than an assessment of significance that would assist in informing an appropriate development.”  They noted that “the HIA fails to assess the impact of the development on the most important heritage resource: The site's open, green qualities as a remnant of landscape that has considerable intangible historic and cultural heritage significance … The HIA has unfortunately reduced this significance to a set of ecological values, provided for the most part to post-rationalize a wholly intrusive development model, rather than inform appropriate development.”

If LLPT were really concerned about heritage, they could have taken the heritage of the site seriously in considering what development might be consistent with heritage indicators suited to the site before imposing a 150 000 square metre concrete footprint on the site.

At yesterday’s inspection, it was SAHRA’s statutory duty to familiarise themselves with the entire TRUP site. However, SAHRA was informed by the LLPT that their officials could enter the River Club property, but that the nominators (the GKKITC, OCA and TRUPA) were not allowed on the site. So much for LLPT’s commitment to transparency or respect for heritage processes.

Moreover, the representative for the Department of Transport and Public Works (DTPW) – one of the landowners in the TRUP – read out a statement which questioned the validity of the SAHRA process (see picture above, the DTPW official is second on the left). This is the same government department which has taken the Ministerial Appeal Tribunal to the High Court to review its findings on the River Club Provisional Protection Order - and, in particular, to expunge its comments about government departments ganging up to suppress heritage processes. It is deeply ironic that DTPW is again seeking to do exactly the same thing it was critized for doing during the Appeal Tribunal – where the Tribunal bemoaned the fact that “instead of aligning the scarce resources, with experience skills and expertise to cooperatively solve complicated heritage issues cooperatively, internally, and in good faith”, government departments engaged in “fruitless and wasteful contestations” and “political posturing.”

Thankfully, the SAHRA officials were not deterred by this transparent attempt to derail a legitimate process under national law. The heritage grading process and the consideration of provisional protection under the National Heritage Resources Act are firmly on SAHRA’s agenda now.

That does not mean we will hold off on the legal challenge to halt the development.

And we do need your financial support to pursue this court challenge. Please consider assisting us with the legal fees. You can contribute at our fundraising site or directly via EFT here.

You can also visit our website and follow the Liesbeek Action Campaign on twitter: @LiesbeekAction.

Now is the time to Make the Liesbeek Matter!