The Divisional Director
Eskom Transmission Division
PO Box 1091
2000
09/12/2003
Att: MR. J. Geeringh
Dear Sir
In response to the letter you forwarded to us from Mr. J. K. Haumann, Director PD Naidoo and Associates, the firm which undertook the environmental impact report (EIR) for the proposed Gamma-Omega 765kv Transmission Line, the Eskom Transmission Line Action Committee (ETLAC) would like to tender the following comments: -
This response will comment directly on sections of the above-mentioned letter and will at times refer to headings, page and paragraph numbers.
Introduction/Page1/Par.2
While the full environmental study of the line concerns all of those affected along its length, members of this community in Tulbagh, as represented by ETLAC, are concerned primarily with the effect on this community. We would also like to make the point that we are fully aware of the report and its contents as it affects Tulbagh and its surrounds.
Study Programme and Public Consultation Process/Page 3
In both studying this report and the letter from P D Naidoo and Associates it would seem that the collection of data for the body of this report, including that used to formulate most of the environmental impact assessments, was undertaken before January 2000, with subsequent updates after consultations with effected parties. We make this comment for two main reasons. Firstly, and in response to the final paragraph of this section (page 5), and after careful consultations by the members of ETLAC with as many of the people mentioned in the extensive list provided in the aforementioned letter as possible, including Mr. Patrys Theron and other members of the Farmers Association, we are concerned that the facts as referred to by Mr. Haumann are not those as understood by the vast majority of those consulted, specifically as regards the preferred Central Route. The Central Route was presented by Eskom as far more to the south than is now the case, and consented to on that basis by the Farmer's Association, and, most importantly, it was understood by virtually everyone that the preferred route was the Southern Route. It is only now, after Mr. Danie Boshoff's arrival and the subsequent public meeting with Eskom officials, that the preference of the Central Route as it is now presented, has became apparent. This is why the individuals and offices concerned did not make use of the opportunities afforded to them at the time to oppose the now preferred route.
Secondly, there have been vast changes in this valley subsequent to this report, both environmental and social, changes that we will outline later in this response and which materially effect the conclusions of the report.
We would also like to comment on Mr. Haumann inference that ETLAC's response is an attempt to frustrate the process. We would suppose it is fairly easy sitting in an office in Gauteng to make such a remark, unfortunately this power line will directly impact in every way on the community of this valley and it is our constitutional as well as moral right to oppose its construction on our doorstep. We are attempting to participate in this process in good faith, as he suggests, but if he means by that that we should merely make our comments and then just accept the outcome as concluded in the report, then again we take exception in the strongest terms to these remarks.
To conclude our comments on this section of the letter we would suggest Mr. Haumann study the S.A. constitution and the rights of its citizens far more closely than he appears to have done before he presumes to lecture the ETLAC members on the content and intentions. Mr. Haumann is not a constitunial lawyer and should this matter of the route of the power line end up in litigation we would urge all officials concerned to attend carefully to the preferred route proposals made to the various parties in the process of the aforementioned “extensive” consultations, specifically to the reason for the understanding of all consulted parties that the Southern Route was the preferred one and the Central Route was far more to the south.
Route Selection
Although we take the point that the `environmental consultant' should have no vested interest in the conclusions of the report we would like to point out the following: -
1. This report was commissioned by Eskom, which does have a principally commercial interest in the route.
2. Just because P D Naidoo and Associates have produced this report
does not automatically mean that it is necessarily correct.
We would like to put on record that it is the intention of this community to commission its own environmental report as pertaining to the effect of the power line on this valley and we reserve the right and time to do so.
Summary of Assessment/Page 7
After reading the relevant chapters and sections in the report we make the following comments in response to this part of the letter; -
We would agree that the southern route is the most advantageous in terms of bird life but would like to point out that a pair of nesting Cape Vultures has taken up residence on the mountain ridge above the quarry on the route of the Central Line. This fact has been reported to the Cape Vulture Society and other relevant authorities.
We would assume that in 2003 Eskom is much more environmentally sensitive and efficient in its erection of power lines than when it built the existing 400kw line on the Southern route and therefore if the new line were built on this route, would impact on flora far less. Therefore the assumption is that the indigenous flora would recover far more quickly and effectively than it did before.
In comparison, the Central Route has far more potential to be disruptive, both economically and visually, in a sensitive tourist-dependant area like Tulbagh. Farms will be traversed, crops destroyed, fences torn down and rebuilt, and land values ruined. In addition to this the Central Route would also include the traversing of mountain ranges, with the attendant disruption to indigenous flora. Whether there is more or less indigenous flora in the Central or Southern route, and which is more environmentally sensitive is not fully explored or exactly quantified by the report.
While erosion might be quantifiably more on the Southern Route, most of it will be out of sight, while erosion on the exposed Central Route will be there for everyone to see. As to better access to the Central Route as opposed to the Southern Route we strongly disagree - while access will have to be established to the pylons etc. on the Central Route with the attendant damage to farms as well as the indigenous flora on the mountains, surely that access has already been established for many years to the existing Southern Route. We would also assume this access has been well maintained in accordance with Eskom's correct business practices and therefore little vegetation or the like will have to be disturbed.
The disturbance of the Geometric Tortoise habitation is one of the main concerns that the report has not fully explored. The Geometric Tortoise is on the World Wildlife Fund's list of the 25 most endangered turtle species in the world. The Tulbagh area is an established conservation area for the tortoise, a fact that seems to be missing from the report. It has been observed that in the last few years the tortoises have migrated further into the Tulbagh valley and are now found in the northern as well as southern reaches. There is an ongoing programme with local people in the valley to preserve this endangered creature and there is talk of making the tortoise the symbol of Tulbagh. Tortoises are found on all of the farms that the Central Route proposes to traverse and have even been spotted in people's gardens in town. This is one of the important aspects that the proposed environmental report commissioned by ETLAC will explore.
We would suggest to you that `careful placement and management' of the towers on the Central Route as regards minimizing visual impact on important heritage sites on the Central Route is unattainable. The reality is that towers of approx. 45m and attendant lines in close proximity to these sights would be calamitous to `the sense of place' of these sites and would materially affect their historical significance. This impact warrants far more study and will be referred to the newly constituted Historical Commission of South Africa for an assessment. Tulbagh is a town deeply rooted in its past and it has more significant historical sites than almost any comparable area in South Africa. This is one of the principal attractions of Tulbagh to tourists and one of the major reasons why tourism and other business bodies and individuals are implacably opposed to the power line and towers in such a prominent location.
In the time the report has been produced Chris Hani Settlement has been formalized and demarcated. There has also been much development in adjacent areas. The proposed central line will now be adjacent to both communities, directly and materially affecting their properties values, views and expansion. There is recent precedence and ruling in South African courts to this aspect and we have advised representatives of all effected communities on the southern side of the town to this fact. In response Chris Hani Settlement has assigned a representative to serve on ETLAC.
The Central Route as now proposed would cross two high ridges, both of which would be highly visible from anywhere in the valley. In this regard the Southern route would obviously be far less obtrusive.
After consultation with Patrys Theron and the Farmers Union by ETLAC it would seem they differ materially from the assertion by Mr. Haumann that they agreed to the Central Route as now presented. Rather they believed that the Southern Route would be the preferred one and acquiesced to the Central Route because it was presented as being much further south by Eskom officials. After learning of the preference of the Central Route as it now stands they have instructed their representative on ETLAC, Mr. Anton van Zyl, to express their opposition in the strongest terms. We would also like to point out that Steinthal School is in a potential transition phase with an educational trust represented by Gary Kirsten and funded by overseas interests negotiating to acquire it. The proposal is for Steinthal School to be transformed into an environmental orientated institution for the rehabilitation and housing of street children. We would also like to point out that the governing council of Steinthal is vigoursly opposed to the sighting of pylons on the school's land. ETLAC is investigating how the proposed Central Route will effect these negotiations and the funding thereof by investors. As regards the visual impact, Mr. Haumann always attempts to minimize this while in fact this line will he highly visible from all points of the valley.
Tourism has grown markedly since the publication of this report. Along with many others, one of the examples is that the Wine Route has registered as Proudly South African and signboards are to be put along the R46 attesting to this fact. Tulbagh depends heavily on revenues from tourism, revenues that have been growing steadily. The impact of this line on tourism cannot be overly stated and the newly appointed head of the tourism board, Mr. Andrew Buttle, has joined ETLAC. He is preparing a report in consultation with his members on the effects of this proposed Central Route. We would also suggest that the reason why certain tourism bodies in Tulbagh did not initially participate as suggested in the report was for the very same reason as the perceived co-operation from the Farmers Union, i.e. they thought the line was to follow the Southern Route. You will find that since learning of the preferred Central Route this non-participation has changed.
Fire fighting is another very important point that seems not to have been fully explored by the producers of this report. While it is true that fighting fires under power lines is not safe this is far more relevant to the Central Route than the Southern Route. Careful study of past fires in this area will reveal that most fires begin at roads, especially the R46, and firefighters try and extinguish these fires as close as they can to where they begin. The close proximity of the Central Route to this road means that the potential for the hindrance to firefighters is far greater than that of the Southern Route where there is much more space to work, back burn etc. There is far more potential for lives and property to be lost on the Central Route.
It would be interesting to find out how many times the existing 400kw power line has been switched off due to fires. Comment should be reserved on this particular matter until correct data is obtained.
As regards the summation of the various impacts towards the bottom of page 5 of Mr. Haumann's letter we refute much of the conclusions reached. To reiterate:-
We believe the impact on the social fabric of the Tulbagh area is far more wide ranging than this report details and therefore whether it is more or less disruptive to the social fabric of those areas affected by the Southern Route cannot be concluded until a more up to date environmental report is produced. What is true is that the Tulbagh area is developing far more rapidly than the Ceres-Wolseley route, which already hosts an existing line.
Again we must reiterate that the safety issues regarding fire fighting are much more relevant to the Central Route where most of the fires start.
We refer you again to our contention that the renosterveld flora rehabilitates itself far faster than potential damage to farms and areas near expanding developments.
The contention therefore that the Central Route offers the least impact is wrong. We believe the opposite to be true.
The impact on birds does not take into consideration the Cape Vultures.
We would hope along the entire route of the power line that potential ecological damage would be avoided as much as possible.
Erosion is of concern wherever the route is taken, whether more or less on the Southern or Central Route is a mute point, what is true is that it will be far more noticeable on the Central Route.
The impact on tourism has not been assessed correctly at all and whether it is safe to have a power line of this magnitude near to where many people are living has not been proved. The contention that until proved otherwise the power line is safe for people and animals is shortsighted in the extreme and has invited litigation worldwide. There are many court cases going on in areas like the USA, Europe and Japan on this very subject and there is as much data available suggesting that there is harm to humans and animals as that that suggests there isn't.
This Central Route will materially affect the historical significance for which Tulbagh is internationally known - there is no way you can lessen the impact of towers and lines of this magnitude.
Conclusion
To end we would like to address the point Mr. Haumann makes in the second last paragraph of page 13 of his letter where it is suggested that everyone on the ETLAC committee was on his database and knew about the preferred route. Firstly, other than Ds. Dreyer, only one of the farmers directly affected by the power line is detailed on that list. The first any of the rest of us knew of the power line was the surprise visit of Mr. Danie Boshoff. Secondly, as we have already contended, all of the organizations and most of the people on that database were of the belief that the preferred route was the Southern rather than Central Route. Also, that the Central Route was much further south than it now is. If it's the contention of Mr. Haumann that everyone should have been aware of the Central Route as it now stands because the report was lying in libraries or appeared on peoples computers then we would say that the only fault of those people lucky enough to have received a final report is that, instead of reading the massive tome, they believed what they had been told by officials.
We await your response.
Yours faithfully,
Chairperson
The ETLAC Committee.