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Objection against the positive Record of Decision on the Pelikan Park development

19 Mar 2009 Posted by in Environment | 1 comment

ANNEXURE 1: STATEMENT – GROUNDS FOR APPEAL

The False Bay Ecology Park (FBEP) includes two nature reserves, sensitive wetlands, an Important Bird Area and supports critically endangered fauna and flora. The FBEP is the site of the majority of the City’s environmental education programmes and provides disadvantaged urban children the opportunity to experience nature. It is also home to the only hippos in the wild on the Cape Peninsula.

The additional 12-15 000 residents and approximately 3 455 units of Pelican Park Extension ‘Phase 1 will not have a detrimental impact on the environment’ [EIA p 12] ONLY if DEADP guarantees:
•    the operational capacity of the Cape Flats Waster Water Treatment Works (CFWWTW)
•    the implementation of an effective environmental management plan.

This proposed development will be built upon the western part of the Cape Flats Aquifer, an important future water source. The Cape Flats Aquifer has the potential to supply more than two-thirds of Cape Town’s basic water needs [Segun Adelana and Yongxin Xu: ‘Contamination and Protection of the Cape Flats Aquifer, South Africa’ in Groundwater Pollution in Africa, UNEP, 2006]. The EIA notes that the groundwater is particularly susceptible to pollution. [EIA, p33] Yet the CFWWTW is already a major contributor to pollution of the vlei. Liz Day and Southern Waters note that a significant proportion of leachate comes from the CFWWTW. [EIA, Pg 33:] Where pressure is increased, the situation will worsen. Yet, no provision has been made to upgrade the sewerage works. The capital budget for 2009/10 (R7mill) is half that of 2008/9 (R14,351mill).

The City of Cape Town claims that the CFWWTW has sufficient capacity to treat extra effluent. [EIA, p39] While this may be true in theory, practice indicates otherwise. There are already persistent and increasing mechanical failures and emergency repairs at the treatment works. In addition, the City of Cape Town (CoCT) is understaffed – for example, the post of District Manager of Operations remains unfilled. The EIA acknowledges that winter flow rates already exceed design capacity, [EIA, p39] but insist that the CFWWTW is able to manage them due to the system of ponds available. However, in the last five months, the treatment works has had to dump septic sludge ‘directly to on site emergency sludge lagoons’— and this during the dry, low-flow, summer months. [See Annexure 2: Record of Latest Malfunctioning of the CFWWTW, Annexure 8: FoZR Site Visit, 4 March 2009 and Annexure 9: Community Complaints re: Sewage Smells]

We further note that DEADP did not pay any site visits before issuing a positive ROD. The FoZR site visit on 4 March 2009 is documented in Annexure 8 and shows rivers of fresh sludge in the back dunes north and east of the CFWWTW. The CFWWTW is demonstrably in breach of the terms of its DWAF operational licence. ‘Sewage smells or other solid sewage waste shall be handled, stored, transported, utilised or disposed of in such a manner as not to cause any odour, insects or other nuisance, health hazard or secondary pollution.’[Exemption 1504 B, DWAF to City Engineer, Municipality of Cape Town, 19 Feb 1992]

The City contends that excess sewerage will be diverted to Athlone WWTW if need be. However, Athlone, like most of the aging wastewater treatment plants around the country, is experiencing its own set of challenges:
•    Effluents that are non-compliant with DWAF standards
•    Disposal of wastewater sludge to land
•    Stockpiled sludge in lagoons and maturation ponds
•    Stormwater infiltration into sewers
•    Lack of sufficiently skilled staff
•    Resultant sub-standard operation/maintenance
•    High capital funding requirements
•    Odour control
•    Aging equipment in need of replacement
•    Risk of asset stripping through sustained inadequate capital funding
•    Housing developments in certain areas are outpacing the ability to provide adequate treatment capacity.
[Samson K, ‘Wastewater Treatment: Best Practices for Operations and Maintenance – From challenges to opportunities’, June 2007]

The Pelican Park development will shift pressure onto the Black River system, which already receives unacceptably frequent raw sewage spills from the Athlone WWTW. In a media release of 14 January 2009, Councillor Justus of the CoCT confirmed that towards the end of November 2008 there had been a malfunction in the sludge handling mechanism at Athlone. ‘To reduce the load on the Athlone works, a portion of the inflow was successfully diverted … into the main outfall sewer to the Cape Flats Waste Water Treatment Works.’ [See Annexure 7: City of Cape Town Media Release ‘Smell from Athlone Waste Water Treatment Works’ – 14 January 2009]. This was done at a time when the CFWWTW itself was experiencing problems with its own sludge handling section. [See Annexure 4: CoCTs response to ZCA complaint - 20 November 2009] The CFWWTW cannot manage the current demand.

In addition to the extra strain on the CFWWTW, the 12-15 000 people in Phase 1 Option A will place further pressure on Zeekoevlei because of stormwater runoff. The stormwater management plan is based on a scoping report of 2001. No new stormwater study has been undertaken to take into account the current (and increasing) environmental pressures being imposed on the Zeekoevlei catchment area. Detailed consideration of the implications of the proposed location of the stormwater system on the Zeekoevlei Nature Reserve needs to be undertaken.

The proposed development will place greater recreational pressure on the vlei and the adjacent two nature reserves, which are currently in the process of applying for RAMSAR status. Again, the ROD makes no provision for additional nature reserve staff, equipment or an adequate maintenance budget. The ROD does provides for ‘suitable fencing’. However, this mitigation measure is inadequately defined. What does ‘suitable’ fencing mean? Who is going to pay for it and maintain it?

DEADP has a statutory mandate to monitor the performance of every water services institution and every applicable development plan, policy statement or business plan in order to ensure compliance with all applicable national standards prescribed under Chapter VIII of section 62 of WS Act, 1997. However, no evidence of the CFWWTW’s compliance with DWAF’s operational licence has been presented, despite requests from the I&APs.

In summary, the EIA fails to satisfactorily address the following concerns of the I&APs:

•    Does the Cape Flats Sewage Works always comply with Department of Water Affairs (DWAF) effluent standards / operational licence?
•    Does the CFWWTW have sufficient operating capacity to handle the increased demand?
•    Can excess effluent be effectively processed in the face of electricity supply disruptions?
•    Is there a potential risk that partially processed effluent will, from time to time be discharged into receiving water bodies when capacity is exceeded or pump stations fail?
•    What are the potential impacts to the environment in the event of temporary non-compliance associated with increased supply of raw sewage to this facility?
•    What mitigation or preventative measures are in place to deal with such situations?
•    Will there be funding to manage as well as implement the necessary mitigations for waste water?
•    Will there be funding to manage as well as implement the necessary mitigations for conservation?

  1. MoonDance03-19-09

    Laurianne you are a classact, thanks for all the work and your dedication to the cause, and I aint just talking sh1t!

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