013041 Erf 1, Mfuleni Unlawful Infilling
TABLE OF AUTHORITIES WITH JURISDICTION OVER THE UNLAWFUL INFILLING: COMMENTED ON WASTE IMPACT
REPORT, REHABILITATION PLAN AND EMP, FEBRUARY – JUNE 2014
Organization/Dept/Erf & Address
Department of Environmental Affairs and Developmental Planning: Waste Directorate, Land Management:
c/o DEA&DP Development Facilitation Unit
Tammy Christie
11th Floor, 1 Dorp Street
Cape Town
8000
Tel: 021 483 2776
Fax: 021 483 8311
Email: [email protected]
Competent authority in terms of Section 24O:
DEA&DP: Section 24G Unit
Zaidah Toefy
5th Floor, Atterbury House
Riebeeck Street
Cape Town
Tel: 021 483 2701
Fax: 021 483 4033
E-mail: [email protected]
Department of Water Affairs
Thanduxolo Stimela
52 Voortrekker Road
Bellville
Tel: 021 941 6268 / 021 941 6000 / 073 475 9575 / 083 653 2465
Fax: 086 620 04568
Email: [email protected]
Department of Environmental Resource Management
City of Cape Town:
Organization/Dept/Erf & Address
Alexander Forbes
Stocks and Stocks Building
Ntlanze Road
Khayelitsha
Tel: 021 360 1124
Fax: 086 6248 526
alexander.forbes.capetown.gov.za
ECONOMIC ENVIRONMENTAL AND SPATIAL PLANNING
ENVIRONMENTAL RESOURCE MANAGEMENT
Alexander Forbes
Environmental Professional
T: 0213601124 F: 0866248624
E: [email protected]
2014-04-08
Sillito Environmental Consulting
Suite 105, Block B2, Tokai Village Centre
Vans Road, Tokai, 7966
Attention: Ms C McCreadie
RE: SUBMISSION OF WASTE IMPACT REPORT, REHABLITATION PLAN AND EMP: WETLAND
INFILLING AND REMOVAL OF INFILL ON PORTION 2 OF REMAINDER ERF 1, MFULENI (DEA&DP
Reference 10/2/2/1/IN10 of 2010)
Thank you for granting the Environmental and Heritage Management Branch the opportunity
to comment on the above mentioned document. Kindly find attached hereto the City’s
comments on this report, consisting of input from the following departments:
• Environmental and Heritage Management (E&HM)
• Solid Waste Management
It should be noted that previous comments from the Biodiversity Management Branch dated
16 September 2013 have already been incorporated and addressed in the document under
discussion.
A) Environmental and Heritage Branch comments
1. With reference to the section of the report entitled “Description of activity”, it is
mentioned that the infilling covered an area of between 400-500m². However, the
area that has been filled (or covered with fill material) is much larger, and it should be
correctly indicated as such in the report.
2. It is also mentioned under the section of the report entitled “Description of activity”
that about 90m² (or 3 truckloads) of fill material has remained on the site. Although the
applicant removed some of the rubble, most of the fill material has been spread over
a bigger area in and around the wetland. This information should be correctly
reflected in the report.
3. It should be noted that some of the removed material ended up on Portion 16, a
portion of Portion 13, of Stellenbosch Farm 653 (Cape Town Film Studios) after its
removal from Portion 2 of Remainder Erf 1, Mfuleni. This occurrence can be confirmed
by the City’s Solid Waste Law Enforcement officers as well as the General Manager of
the Cape Town Film Studios. The report should address this incident by prescribing that
the appointed ECO must ensure that all material to be removed in future should be
taken to a City of Cape Town licenced landfill site to prevent such an incident from
occurring again.
KHAYELITSHA MUNICIPAL BUILDING
I-OFISI KAMASIPALA E-KHAYELITSHA
STOCKS AND STOCKS, BLOCK E, NTLANZANE ROAD, KHAYELITSHA
KHAYELITSHA MUNISIPALE KANTOOR
www.capetown.gov.za
Making progress possible. Together.
2
4. With regards to the removal of clean fill material, such material should be disposed of
at a City of Cape Town licensed landfill site. Since no charge / tariff is applicable for
the disposal of clean material at these landfill sites, certificates for disposal will not be
issued. However, in order to provide proof that all material as removed from Portion 2
of Remainder Erf 1, Mfuleni, has indeed been taken to a licenced site, the applicant
must keep written record of the date, time, and vehicle registration number of each
truckload being disposed of at the City of Cape Town licensed landfill site. Such
written records must be submitted to the E&HM Branch after completion of the
rehabilitation activities so that these records can be verified against the records of
Solid Waste Management as kept at each of the City’s licensed landfill sites.
5. With reference to the section of the report entitled “Description of activity”, it is
mentioned that “the isolated fragments of asbestos observed at the site therefore
pose some risk to people using the area around the wetland and should be removed
in accordance with applicable regulations for handling and disposal”. It should be
noted that, no matter how big or small the quantity of Asbestos being found on site, it
should always be removed by a specialised contractor and disposed of in
accordance with the requirements relevant to the disposal of hazardous waste (i.e. at
the Vissershok landfill site in this case). A copy of the disposal certificate must be
submitted to the E&HM Branch after completion of the rehabilitation activities.
6. The E&HM Branch concurs with the requirement stipulated by DEADP’s Directorate:
Land Management that a post rehabilitation report must be drafted upon completion
of the rehabilitation activities. This report must also be submitted to the City’s E&HM
Branch.
7. The E&HM Branch further concurs with the requirement stipulated by DEADP’s
Directorate: Land Management that a site inspection must be arranged with all
relevant parties after the submission of the post rehabilitation report. The City’s E&HM
Branch must please form part of this meeting.
B) Solid Waste Management
Please refer to the attached correspondence from the City’s Solid Waste Management
Branch for their comments.
The comments above are based on the information received by this Branch. Should any
new information be forthcoming, the E&HM Branch reserves the right to review the
information and comment accordingly, if required.
Kind regards,
A Forbes
Environmental Management Section
Environmental and Heritage Management: Eastern Region
Environmental Resource Management Department
CITY OF CAPE TOWN
KHAYELITSHA MUNICIPAL BUILDING
I-OFISI KAMASIPALA E-KHAYELITSHA
STOCKS AND STOCKS, BLOCK E, NTLANZANE ROAD, KHAYELITSHA
KHAYELITSHA MUNISIPALE KANTOOR
www.capetown.gov.za
Making progress possible. Together.
global
From:
Sent:
To:
Cc:
Subject:
Attachments:
Colleen McCreadie
20 June 2014 02:33 PM
[email protected]
[email protected]
Erf 1, Mfuleni wetland infill: response to City comments of 04/03/2014
013041 Ross Mfuleni Final EMP June 2014-highlighted.pdf
Dear Alex We have finalised the Ross Erf 1 Mfuleni reports, incorporating authority feedback and making the necessary changes. In response to some of the matters raised by the City in a letter dated 04/03/2014: Point : We would like to clarify that Page 5, Section 4 of the Waste Impact Report refers to a volume of 400‐500m3 of fill; whereas Page 1, Section 1 of the report states that an area of +‐5400m2 was covered during the infill activity. Point 2: Myself and another colleague from SEC visited the site again in December 2013. We estimated together that up to three truckloads of fill remain at the site. Points 3 & 4: With respect to chain of custody of the fill material still to be removed, we have included the recommendations which we agreed on at the meeting of 15/05/14, in the EMP. For your records, please refer to the highlighted section of the Final EMP attached. Point 5: Condition 3.2.1 of the EMP addresses asbestos handling and disposal Points 6 & 7 requesting submission of a post‐rehabilitation audit report to the City E&HRM branch, and requesting a post‐rehabilitation site meeting, has been dealt with under Condition 4.1 (e) of the EMP. This section has been highlighted for your records. We have submitted the final reports yourself and to the DEA&DP for approval. Thank you Kind regards
Colleen McCreadie – Environmental
Consultant
"Environmental Solutions for a
Changing World" P: +27 (0) 21 712 5060
F: +27 (0) 21 712 5061
M: +27 (0) 83 695 1664
[email protected]
www.environmentalconsultants.co.za Suite 105, Block B2, Tokai Village Centre, Vans Road, Tokai,
Cape Town, 7966 1
global
From:
Sent:
To:
Subject:
Attachments:
Colleen McCreadie
20 June 2014 02:32 PM
'Marbe Coetzee'
Erf 1, Mfuleni wetland infill: response to DEA&DP comments of 03/03/2014
013041 Ross Mfuleni Final EMP June 2014-highlighted.pdf
Dear Marbe We have finalised the Ross Erf 1 Mfuleni reports, incorporating authority feedback and making the necessary changes. In response to some of the matters raised by the DEA&DP Land Management Region 1 in a letter dated 03/03/2014:
Points 4.2.3: With respect to chain of custody of the fill material and asbestos remnants still to be removed, we have included the recommendations which we agreed on at the meeting of 15/05/14, in the EMP. For your records, please refer to the highlighted section of the Final EMP attached. In addition, Condition 3.2.1 of the EMP addresses asbestos handling and disposal. Points 4.2.4 & 4.2.5 requesting submission of a post‐rehabilitation audit report to the DEA&DP Region 1, and requesting a post‐rehabilitation site meeting, has been dealt with under Condition 4.1 (e) of the EMP. This section has been highlighted for your records. We have submitted the final reports to yourself and to the City for approval. Thank you Kind regards
Colleen McCreadie – Environmental
Consultant
"Environmental Solutions for a
Changing World" P: +27 (0) 21 712 5060
F: +27 (0) 21 712 5061
M: +27 (0) 83 695 1664
[email protected]
www.environmentalconsultants.co.za Suite 105, Block B2, Tokai Village Centre, Vans Road, Tokai,
Cape Town, 7966 1
global
From:
Sent:
To:
Subject:
Attachments:
Colleen McCreadie
20 June 2014 02:31 PM
Muneeb Baderoon ([email protected])
Erf 1, Mfuleni wetland infill: response to DEA&DP comments of 27/02/2014
013041 Ross Mfuleni Final EMP June 2014-highlighted.pdf
Dear Muneeb We have finalised the Ross Erf 1 Mfuleni reports, incorporating authority feedback and making the necessary changes. In response to some of the matters raised by the DEA&DP Waste Directorate in a letter dated 27/02/2014: Point 2.1 relating to listed activities, this was discussed and clarified at the meeting held on 15/05/14. The minutes of the meeting reflect the following: “It was clarified that the handling and disposal of the remaining fill material (temporary storage; transportation; disposal to a registered landfill site) does not trigger any of the regulations in terms of the NEMWA: the waste does not require classification or assessment; the management of the remaining fill material does not require a Waste Licence; and there is not sufficient quantity of fill material remaining on the site to trigger the Norms and Standards for Storage of Waste”. Point 2.3: The Final EMP makes reference to the timing of the rehabilitation process. Please refer to Condition 3.2 (15) of the EMP attached, which has been highlighted for your ease of reference. We have submitted the final reports to yourself and to the City for approval. Thank you Kind regards
Colleen McCreadie – Environmental
Consultant
"Environmental Solutions for a
Changing World" P: +27 (0) 21 712 5060
F: +27 (0) 21 712 5061
M: +27 (0) 83 695 1664
[email protected]
www.environmentalconsultants.co.za Suite 105, Block B2, Tokai Village Centre, Vans Road, Tokai,
Cape Town, 7966 1