UWC needs to recognize that it is a steward of critically threatened ecosystems of
international significance. Consequently it is accountable to Cape Town’s residents as
well as international conservation organizations and communities when seeking to
develop on critically endangered habitat. While the institution has been careful to adhere
to legal frameworks, the issue that it is destroying a critically endangered habitat when it
was avoidable is not an ethically responsible decision. Further, UWC has been
successful in securing a ROD that has virtually no mitigation (safeguarding a rather small
piece of disturbed habitat is rather small price to pay). The small price that UWC has to
pay is even more worrying given the suggested costing of biodiversity offsets. The
proposed offset for a critically endangered ecosystem is a ratio of 30 to 1, so if applied to
the BAR application of 0.89ha this would mean the UWC needs to finance the purchase
of 26.7 ha of equal or better habitat of the same ecosystem. Since Cape Flats Sand
Fynbos only occurs in the Greater Cape Town boundaries this would be an
astronomically high purchase price. Since the ROD has now had the lodged appeal
withdrawn a precedent is set that virtually any landowner can develop their critically
endangered ecosystems while incurring virtually investment to the environment. . Of
course future society has been compromised by the greed of this society in so many ways,
not just extinction of entire ecosystems, but the entire climate change issue. This and
UWC’s application and the final ROD means that Cape Flats Sand Fynbos is condemned
to extinction. Had there been no alternative space for the building then there might have
been some justification but only after a real biodiversity offset had been established at say
Blauuwberg. This ROD not only damages the conservation status of our biodiversity it
appears to have the following irregularities:
1) Information on alternative sites, as legal requirements of the act, were not investigated
and reported on.
3) While the original notification stated only 0.89 ha was to be developed the final foot
print of the development extends well beyond thisarea. Since the area stated in the Basic
Assessment Report BAR is to be used to calculate the amount of biodiversity offset – this
also set a precedent for landowners to cheat the system.
2) No ecological/biodiversity assessment was undertaken, which is part of the Terms of
Reference provided by Cape Nature, who basically opposed the development.
3) The BAR contained acknowledged factual misrepresentations which it repeatedly
failed to changed with respect to the status of the vegetation (high water table, seasonal
wetland and presence of invasive species)
4) No evidence exists that any research into restoration of this ecosystem can be
successfully undertaken. The consultants stated, “Regrettably EnviroAfrica can neither
comment on this nor state an example of where such an operation has been conducted in
the past” in response to the viability/success of the proposed search and rescue operation
which it actually proposed as the mitigation.
5) The inputs of I&APs were not adequately addressed and were misrepresented.
The NEMA act requires that developments in sensitive environments such as this to
A) Avoid –Not done despite at least three really viable alternative sites that have no
biodiversity value.
B) Minimize –No attempt to even to shift slightly the location of the building was
entertained, had even a 80 m shift be entertained a significant reduction in the
impact of the development would have been secured.
C) Repair – only here has a very modest mitigation been entertained, namely to
include 2.9115ha of disturbed Cape Flats Sand Fynbos (that has been ploughed,
excavated and formerly was heavily invaded with invasive species into the
existing CFNR. Also to construct a security fence around the new additional land
plus a search and rescue and relocation of the top 20 cm soil that is to be
conducted by a suitably qualified botanist. This is probably a futile exercise.
D) Offset – there has been none.
While the appeal has been withdrawn in good faith UWC has failed to provide Drs
Eugene Moll and Bruce McKenzie with any real vision for future biodiversity
conservation on campus as promised. Consequently I am going to suggest the following
for UWC to possibly acknowledge and thereby to more precisely define the institution’s
rather vague commitment to environmental and sustainable practice, and to increase its
campus community engagement together with increased positive interaction with civil
society.
Action points for UWC for addressing environmental/biodiversity concerns
1) UWC needs to admit that it’s original notification to develop only 0.89ha of the Dog’s
leg area as per the EIA process and participated in by the I&APs and reported in
submitted and final BAR is substantially more now that the final plans for the building
have been signed off. It needs to confirm exactly how critically threatened ecosystem is
to be lost through this development and survey this out so everyone is fully aware of what
is to be lost. UWC also needs to confirm that its intention to build on a critically
endangered ecosystem is known by its overseas funder of the developer and that the fully
appreciate what has been sacrificed. Chuck Feeney of Atlantic Philanthropies needs to
openly acknowledge that he has been fully informed on the biodiversity issues in the
funding of the new Life Science building and to be asked whether he is prepared to
contribute some additional funds for the reconciliation of the building within the natural
environment.
2) UWC when it submitted its Master Plan for development in support of the proposed
development claimed that no alternative sites were available other than the dog’s leg for
the new Life Science complex. In this plan the remaining natural vegetation of the
“dog’s leg” remains largely undeveloped. UWC needs to confirm that no further habitat
of the dog’s leg is to be entertained for future development as per its own submitted
Master Plan. This is consistent with the need of NEMA for full disclosure of
development footprints to prevent future piece-meal erosion of a critically endangered
habitat.
3) As per the Record of Decision (ROD) the search and rescue and the removal of 20cm
top soil to help with the rehabilitating of an additional 2.9115 ha of degraded land to be
adjoined to the CFNR is to be undertaken. UWC to confirm that a new security fence is
to be erected to include the additional land ceded to the CFNR. Further according to the
ROD UWC needs to implement and maintain an alien species eradication programme.
The rehabilitation problem will need to be maintained for at least 20 years of active
investment/funding for its management and ongoing research if any success is to be
secured for this intervention. Without a clearly prescribed long-term funding
commitment from UWC the potential for successful rehabilitation will be compromised.
4) The consensus of the I&APs recommend that the search and rescue and soil removal is
split equally with one portion being used to attempt the rehabilitation of the new land
addition to the CFNR and another equal portion to add to the landscaping around the
proposed building and up to the old UWC entrance within at least the15m building
setback. This area is to be designated as an ecosystem reconciliation project in an
attempt to research the mitigation of development in highly acidic, low nutrient
ecosystems. It is recommended that UWC will need to invest a minimum of R250 000
per year for this management and research monitoring programme for a minimum period
of 20 years. This area is also to be used as part of on campus interpretive programme to
inform the wider campus community about the unique biodiversity that UWC is a
steward of. It needs to recognize that a truly natural ecosystem cannot be re-created but
such sites could be used to restock and rehabilitate the natural areas.
5) The Record of Decision indicates the landscaping around development is to use only
species endemic to the dog’s leg part of the CFNR. This activity needs to stress that no
grass, ornamental plants or trees are to be introduced to the landscaping of the building.
Parking areas are to be constructed using grassblocks (e.g. Loffelstein Grassblocks) to
allow water permeability and recharge of groundwater reserves. Irrigation is only to be
permitted during the establishment phase (3 years maximum) and that no fertilizers nor
organic material (other than chipped natural vegetation from UWC) is to be introduced
into the landscaping.
6) A natural habitats management and advisory committee needs to be established which
also overseas the CFNR management. The advisory committee should include
representatives from the City of Cape Town biodiversity management, Cape Nature and
the Botanical Society and will have the right to engage publicly on issues effecting or
impacting biodiversity on the campus.
7) In line with the Rector’s memoranda regarding the site of the Life Science Building,
and the suggested “Interpretation Centre for the Nature Reserve” this suggestion needs to
be actively supported by UWC management who are tasked to seek funding for its
establishment and that one of its focus areas is to advance “Reconciliation Ecology”
7) UWC is to actively engage in transforming it’s landscaping to use of locally
indigenous species and zero irrigation during the next 20 years with a target that such
landscaping covers two-thirds of the estate within this period. The University is to fund a
campus-wide Masterplan for indigenous landscaping which reduce its dependence on
municipal water and ground water supplies and thereby offset its cost.
8) UWC is to engage in establishing a permanent lectureship and administrative
assistance for its Environmental Awareness Techniques EAT programme and through the
engagement of the academic community to pursue the investigation for establishing an
Institute for Sustainable Studies (Ifss).
9) UWC needs to develop a policy and regulation framework to reduce its overall carbon
footprint and to increase opportunities for recycling and waste minimization over the next
20 years. Further all new buildings are to showcase techniques to reduce use of
resources such as water, electricity, sand/concrete etc and showcase some elements of
green engineering (e.g. reduced storm water runoff, increased insulation, pumped heat
exchange systems to avoid use of air-conditioning etc.)
10) UWC needs to develop a meaningful policy for addressing transport issues onto
campus and engage with public sector transport industries in seeking some solutions.