Comments ETLAC HIA

<body topmargin=0 leftmargin=0 marginheight=0 marginwidth=0> <table cellpadding=0 cellspacing=0 border=0><tr> <td valign="top" rowspan="2" width=30 BGCOLOR="#0066CC" TEXT="#080000"> <bR> </td> <td valign="top" height=76 style=" border-bottom: 1px solid #3366CC;" BGCOLOR="#0066CC" TEXT="#080000"> <div> <B>Tulbagh Info Information</B></div> <div> Comments ETLAC HIA</div> <bR> <bR> <bR> <bR> <bR> <div> </div> </td> <td valign="top" rowspan="2" width=28 style=" border-top: 1px solid #0066CC; border-left: 1px solid #0066CC;border-right: 1px solid #0066CC; border-bottom: 1px solid #0066CC;" BGCOLOR="#0066CC" TEXT="#080000"> <bR> </td> </tr><tr> <td valign="top" height=404 width="100%" style=" border-left: 1px solid #3366CC;" BGCOLOR="#000066" TEXT="#F7F7FF"> <div> <TABLE BORDER="0" CELLPADDING="1" CELLSPACING="1" WIDTH="120" BORDERCOLORLIGHT="#C0C0C0" BORDERCOLORDARK="#808080" FRAME="BOX" RULES="ALL" HSPACE="0" VSPACE="0" > <tR> <tD VALIGN=CENTER BGCOLOR=#0099CC HEIGHT= 15 ><NOBR><div> <A HREF="local_news.htm" TARGET="_top" TITLE="Tulbagh News Page 1"><U>Back to Local News</U></A></div> </NOBR></tD> </tR> </TABLE></div> <bR> <div> 12 January, 2009</div> <bR> <bR> <div> Messrs PD Naidoo & Associates (Pty) Ltd</div> <div> 25 Scott Street</div> <div> Waverley</div> <div> 2090</div> <bR> <div> Fax<B> </B>086 543 0235</div> <bR> <div> Under protest, duress and submitted provisionally</div> <bR> <div> Attention Mr. Ken Haumann</div> <bR> <div> Dear Sirs,</div> <bR> <div> <B>Comments in terms of the National Heritage Resources Act (Act 25 of 1999) and request for a further extension of time</B></div> <bR> <div> Herewith my initial comments in terms of the above Act for the Gamma Zenith HIA application.</div> <bR> <div> We consider that the time given for comment is inconveniently timed (by design or otherwise) to coincide with the December Holiday period and 12 January, 2009 is a date to early to give proper comment. The time period should have been extended to 30 January, 2009 as requested.</div> <bR> <div> Eskom or its consultants have failed to adequately consult with the community that could be affected by the line in terms of the laws governing an HIA application in terms of the Act. I am of the knowledge that ONLY the interested and affected parties in the Tulbagh were consulted. Most certainly, I&AP's in the Gouda, Upper Witzenberg, Ceres and Prince Alfred's Hamlet areas have apparently not been consulted. Since the HIA application is a separate issue to the original EIA application, I believe that all the communities should have been made aware of the HIA application by presentations in all the towns, along the route of the proposed power line and not just Tulbagh. I am aware that certain Appellants against the Line in the Ceres and Upper Witzenberg were not and still may not be aware of the HIA application at all.</div> <bR> <div> Requests to Eskom and it's consultants to provide better photographs than those that were depicted in the Mapping Document placed in the local library (which were totally inadequate, hardly visible and doubted to be accurate depictions of the proposed power line and the Tulbagh valley), or to suggest where they may be obtained in order that we could ascertain the visual impact adequately, or use to facilitate our own computer aided Visual Impact material has fallen on deaf ears. An email written to you prior to the initial 24 December, 2008 cut-off date requesting this information remains unanswered. In fact a few verbal requests by the writer to Mr. Groenewald of Eskom at various meetings - even whilst the EIA process was still underway - to provide an adequate computer generated model of the power line to properly inform the public - were easily agreed to but such a model has never been provided and we are now being forced to generate our own to inform the public but this task cannot be completed by 12 January, 2009.</div> <bR> <div> The Scoping document refers to Critical Viewpoint Analysis and yet no such analysis is evident in the data discs provided where they could be properly analysed by magnification or in greater resolution, or in a format that could be disseminated to interest groups (by design or otherwise?).  The said Critical Viewpoint Analysis photos in the document are misleading to the public for two reasons;</div> <bR> <div> 1.   The viewpoint in respect the Gouda/Tulbagh/Wolseley/Ceres/P A Hamlet areas for instance, is taken from such a height so as to limit the real visual impact. The viewpoint should have been taken at ground level where the impact on people would be greatest and from various angles and critical locations such as Gouda village, on the R46 at the entrance to the Nuwekloof Pass, upon entering the Tulbagh Valley, looking west from where the line is expected to cross the road linking the R46 to Tulbagh, from the highest placed southern suburb of Tulbagh, from Tulbagh west (Witzenville) towards the Witzenberg Mountains, at Steinthal, Wolseley (if there is a possibility that the southern route is to be used), anywhere in the Upper Witzenberg valley, Prince Alfred's Hamlet looking north, east and south (if there is a possibility of the southern route being used) and Bellavista looking north and east (if there is a possibility of the southern route being used). </div> <div> 2.   The power line structures depicted in the photographs do not appear to relate to the type and size of the intended power line structures and appear to rather be standard photos taken of 25m 400kv power lines such as those near Wolseley.</div> <bR> <div> Attorneys acting on behalf of many of the appellants are on leave, you were apparently on leave, the Municipality is in recess, there were numerous public holidays in the periods given for comment and many of the community and I&AP's are away on holiday. Hardly the right time to start a `consultative' process I would think?</div> <bR> <div> This Power Line project is of immense importance to all who will suffer from the sight of it as well as other negative impacts - not least probable health issues. In a Tulbagh context, It is believed that the very nature of the valley, the scenic beauty, the appeal of the charming historical town, the sense of pride that this community has in its heritage, the architectural treasures and their place of pride, will be lost to posterity and will also be lost to this community forever - should this power line be allowed to visually impact on this environment and the sense of place and well-being that is enjoyed and cherished by all as it is now.</div> <bR> <div> Eskom has used what I would term `underhanded and bullying' tactics from day one of the EIA application process. Officials telling farmers “you can sign the Servitude document as your neighbour has signed” when in fact this was not true, was one of those tactics. Limiting the consultation to a select `chosen few' whom they determined would be I&AP's such as farmers unions (who did not represent all the farmers) was another. Refusing to give information to a Tulbagh resident (myself in this case) as the Eskom official determined that since I was in town and not in the path of the intended power line and I had no right to the information, was another. When I suggested that he was making a mistake by his attitude, he displayed his arrogance in then suggesting that “I will have the whole lot signed up within a day or two anyway”. Seemingly, an attempt to `rush' this HIA application through with a flawed consultative process at this time of the year, was yet just another tactic to limit participation or consultation.</div> <bR> <div> The current route map has apparently deviated substantially towards Gouda from initial route maps provided by Eskom and in fact will now traverse a residential area?  That community had not been consulted about the impact of the power line then and now with the this HIA application either. Thus how can I&AP's in that area be determined in terms of the HIA application?</div> <bR> <div> An airstrip that has been used for years by the farming community of the Tulbagh valley for their crop spraying needs, has not been indentified. The requirements of the Civil Aviation Authority regarding the lighting of structures over 50 meters and other power line identifying mechanisms for aircraft such as orange balls hanging from the lines, the possibility that the tops of the power line supports have to be painted in bright colours etc. are other negative visual cultural landscape and sense of place impacting aspects and aircraft warning mechanisms that have not been alluded to at all in the scoping document.</div> <bR> <div> Most of the consultative process has revolved around the north and north centre of the valley of Tulbagh, on the assumption that only communities and I&AP's threatened by the Preferred Route need be consulted and provided for in the HIA documentation. Should the alternative route be chosen, will the communities on the south of the valley be consulted?</div> <bR> <div> Hardly anyone in the path of the preferred route who stand to be visually impacted by the power lines in the Ceres, Prince Alfred's Hamlet and Gydo Pass areas as well as southwards in the Riebeek Valley, even know of the intended power line, the route it will take, how high it will be and what it would look like and no proper Critical Viewpoint Analysis documentation has been provided to those communities. They are being denied the opportunity to comment in terms of the HIA application, as they were in terms of the EIA application. This begs the question - If the alternative route is chosen and the existing corridor is used, will the communities of Wolseley, Ceres, Bellavista and Prince Alfred's Hamlet be consulted prior to that line being approved? Will Critical Viewpoint Analysis documentation be provided for them?</div> <bR> <div> Nobody at the Witzenberg Municipality apparently knew about the HIA application until I made them aware of it. They are major role players. Were they specifically invited to attend the presentation on 24 November, 2008? Where they on the I&AP's list? I believe not?</div> <div> Was every one or every organization who have appealed against the ROD invited as I&A Parties? I believe not? </div> <bR> <div> Using the guidelines set out in the Act as below, my further comments are as follows;</div> <bR> <div> <B>NATIONAL HERITAGE RESOURCES ACT (ACT 25 OF 1999)</B></div> <div> <I>Cultural significance means historical, architectural, aesthetic,  social,  technological and or scientific value (NHRA 1999). </I></div> <div>  </div> <div> The NHR Act outlines the following broad criteria for assessing the heritage significance of a place:   (such as Tulbagh and this valley in this instance)</div> <div>  </div> <div> 1.     Its importance in the community or pattern in South Africa's history.</div> <div> 2.     Its possession of uncommon, rare or endangered aspects of South Africa's natural or cultural heritage.</div> <div> 3.     Its potential to yield information that will contribute to an understanding of South Africa's natural or cultural heritage.</div> <div> 4.     Its importance in demonstrating the principal characteristics of a particular class of South Africa's natural or cultural places or objects.</div> <div> 5     Its importance in exhibiting particular aesthetic characteristics valued by a community or cultural group.</div> <div> 6.     Its importance in demonstrating a high degree of creative or technical achievement during a particular period.</div> <div> 7.     Its strong or special association with a particular community or cultural group for social, cultural and or spiritual reasons.</div> <div> 8.     Its strong or special association with the life or work of a person, group or organization of importance in the history of South Africa. </div> <div> 9.     Sites of significance relating to the history of slavery in South Africa.</div> <bR> <div>  </div> <div> 1.     Its importance in the community or pattern in South Africa's history.</div> <div>  </div> <div> The importance of the history of the community of this valley and the town of Tulbagh is very high. Tulbagh and the Valley has a rich and cherished history spanning over 300 years since the arrival of the first settlers in the Dutch Colonial era and before then, with the indigenous communities such as the Obiqua and Zonqua tribes who resided in the area. This valley and town was hitherto hardly touched by modern innovations or interventions such as the proposed power line, and our abhorrence to this possibility cannot be understated.  </div> <div>  </div> <div> 2.     Its possession of uncommon, rare or endangered aspects of South Africa's natural or cultural heritage.</div> <div>  </div> <div> The Town and valley possess historic monuments and many other surviving examples of the pre-1969 earthquake cultural and architectural history. The very appeal of the Town and many of the farms, is the almost intrinsic value of these buildings to not only the local, residents but to the broader public of the Republic of South Africa, for whom our cultural, architectural and historical heritage in entrusted into the care of this community and the Government of South Africa. The Government and many other benefactors went to great expense and effort to restore many of the buildings after the earthquake in an effort to preserve these structures for the benefit of all. This heritage is in danger of being relegated into obscurity, with the prospect of this ugly power line visually and physically impacting on this valley. The only appeal that this valley has to tourists from both this country and overseas, is its beauty and the chance to 'walk through a page in history'. I do not believe that anyone would even feel encouraged to visit this valley in a `post power line' era. This will of course be devastating to a community where the unemployment rate is probably well over 40%, work is by and large seasonal and the opportunities for increased job and wealth creation probably rely solely on tourism and developments that would be stimulated by tourism (three of which are directly threatened by the power line) and be sustained by ongoing tourism. Moreover, the very appeal of the Cape Vernacular / historic theme that exists and which developers are endeavoring to maintain, is an indication of the `buy in' by all to preserve the character of the valley. The Eskom power line will fly in the face of all of this.</div> <div>  </div> <div> The mountain ranges surrounding Tulbagh are of extreme natural beauty as a backdrop to the scenic beauty of this valley and all who benefit by looking at them and they are an integral part of the heritage of the valley. A power line that will `creep alongside and cross the mountains on both sides of the valley will spoil forever what we have taken for granted and what is so attractive to visitors and residents. The mountains form part of our sense of place and contentment. This will be destroyed with the visual and physical impact of the power line. Eskom has never shown any sensitivity to anything in my experience. The shortest and easiest route has always been preferred. I know of one instance whereby an old gun or cannon emplacement on the mountain, was destroyed by one of the existing power lines on the Witzenberg range. </div> <div>  </div> <div> First impressions last - so they say. My first impression of this valley and one which attracted me to the valley enough to migrate here to become a resident, was entering the Historical Nuwekloof pass and upon entering the valley from the Pass and seeing the pristine and beautiful valley open up before my eyes. What is proposed will destroy that welcoming sight for all time. Visitors will be welcomed by having to go under or alongside those monstrosities of power lines three times in the local context - once in the beginning of the lovely historic pass (designed and built by Thomas Baine), once upon entering the valley (one would have the power line in one's face for about two kilometers) and on the road to Tulbagh near to the fruit factory) where one would be caused to sense the real magnitude of the power line at ground zero (almost the equivalent of a 13 story building), as one goes under it. The visual and physical impact on the entrance to the Pass and valley will be soul destroying and a gross pollution of this environment and it should not be allowed to happen.</div> <div>  </div> <div> 3.     Its potential to yield information that will contribute to an understanding of South Africa's natural or cultural heritage.</div> <div>  </div> <div> Tulbagh and the valley is of such historical and cultural value and the potential for this rich heritage to be shared or imparted upon all South Africans and contribute to and understanding of South Africa's natural or cultural heritage, will be and is already immense. Tulbagh and the valley, must be seen to be appreciated and the benefits understood. Only as an attractive destination will South Africa and the world benefit by its preservation. A valley such as this one - straddled by horrible power lines could hardly attract visitors and the valley and the community would hardly be in a position to yield anything towards an broader South African understanding of our natural or cultural heritage when it fact the opposite will apply in the `post power line era' - an apparent and total intransigence by the Government and Eskom towards cultural and natural heritage preservation?</div> <div>  </div> <div> 4.     Its importance in demonstrating the principal characteristics of a particular class of South Africa's natural or cultural places or objects.</div> <div>  </div> <div> Tulbagh, unique in its beauty and historical character, demonstrates without qualification an historical `treasure chest' with an immense cultural heritage.</div> <div> The valley is dotted with cultural places or objects, which of course will have little or no appeal and benefit to anyone if Tulbagh is not visited and appreciated. The visual and physical impact of the power line would ensure that the appeal of the town and the valley is diminished to such an extent that demonstrating what we have to anyone will be well nigh impossible.</div> <div>  </div> <div> 5     Its importance in exhibiting particular aesthetic characteristics valued by a community or cultural group.</div> <div>  </div> <div> The aesthetic characteristics of this valley with its historical and protected buildings and monuments, represent a legacy of  residents of Dutch / Hugenot from the Dutch Colonial era, as well as superb examples of Victorian architecture from the British Colonial era. The unspoilt mountains and the fynbos were enjoyed by the original inhabitants of the valley, where they resided, grazed their herds, hunted and left their mark with the many stone age implements left behind as witness to their occupation. This heritage is valued by appreciating and sensitive newcomers to the valley as well as actual descendents of these people who were here, or who came here long before the advent of power lines and other ugly harmful, unhealthy and un-aesthetic modern interventions into their lives and sense of well-being and of whom many still live here to this day. They of course value their heritage and their values should be protected. </div> <div>  </div> <div> 6.     Its importance in demonstrating a high degree of creative or technical achievement during a particular period.</div> <div>  </div> <div> One cannot argue that a high degree of creative or technical achievement during the per-colonial, the colonial periods and up to the present day, is apparent in this valley. Examples of design and workmanship in respect of many of the buildings in the valley bear testament to this. The effort to create tools, buildings with notable and sometimes unique design criteria, plaster moldings, gables, joinery and other achievements, illustrate the ingenuity of the residents of this valley. No other valley that I can think of, has such a concentrated indication of the talents of a community. We should be sensitive to this effort and not spoil it with an interposing of a grossly ugly power line.</div> <div>  </div> <div> 7.     Its strong or special association with a particular community or cultural group for social, cultural and or spiritual reasons.</div> <div>  </div> <div> Tulbagh is renowned for its association with the original historic Church that was built to satisfy the spiritual needs of the community and which formed the catalyst for the development of the town as we know it today. The descendents of the first organized religious groups still practice their religion in the new church on Van der Stel Steet to this day. There are other historic places of worship that have architectural social and cultural significance. Notable examples of institutions that were created to satisfy the spiritual needs of this community are the Steinthal Mission (whose property the power line is intended to traverse) and the cut stone Anglican church probably built by Italian prisoners of war. This is by and large a God-fearing community and religion forms the cornerstone of this community. I have no doubt that the quality of design and build of the various places of worship were inspired by the peace, tranquility, beauty and sense of place that the community felt in this environment. I do not believe that an ugly power line would honour these feelings or the efforts of the community to build such a sense of place. It should not be allowed in infringe on the spiritual ambiance which these religious grouping have enjoyed and wish to continue enjoying.</div> <bR> <div> Kindly also accept this letter as a formal request to have the deadline for comment to be extended to 30 January, 2008</div> <bR> <div> <IMG SRC="ad296670.png" border=0 width="150" height="103" ALIGN="BOTTOM" HSPACE="0" VSPACE="0"></div> <bR> <div> John Veschini</div> <div> ETLAC</div> <div> Tulbagh     </div> <bR> </td> </tr></table></body>