Swartland Forum (SF) Response to Malmesbury Aviation Estate (MAE)
Final Scoping Report (12th June 2009)
1 . ABSENCE OF SCOPING FOR ANY AREA BEYOND TAKE OFF AND LANDING CIRCUIT
There is no mention of what happens to aircraft after they have taken off or before they land. The proposed site of the runway results in flight movements reaching or getting close to Malmesbury. The Final Scoping Report (FSR) estimates a `good chance’ of between 40 and 80 flight movements on both weekdays and weekends, and `technically’ up to 120 on flying event days. This translates into large numbers of craft continually in the skies above the area (and the region as a whole) with consequences in terms of noise, visual impact and safety.
We consider this to be a crucial omission in the process thus far as it limits the public in its understanding of the MAE and how it will influence them as interested and concerned parties. This information was repeatedly requested in the Swartland Forum response to the Draft Scoping Report.
We are unhappy that all noise, visual and safety studies are done within a four km radius of the runway and that there is no undertaking to expand this to include nearby settlements of Abbotsdale and Malmesbury, the Paardeberg and areas south of the location of the proposed MAE. This is exacerbated by the fact that that there are no accurate distances to Malmesbury, Abbotsdale, Tierfontein or other areas and settlements. It should be noted that the SF did request this information in its response to the draft scoping report. The public participation process itself has left Malmesbury (and other affected areas) overwhelmingly ignorant of the proposed MAE Finally, we need to know how flight movements associated with the proposed MAE will negotiate the various exclusion areas in and around Cape Town and Malmesbury.
2 NOISE IMPACT OF FLYING AIRCRAFT
The proposed MAE impact zone remains 4 km radius from the proposed airfield in the Draft Scoping Report (DSR). We expect Dr van Niekerk’s `comprehensive’ noise impact assessment in the EIA (Environmental Impact Assessment) phase to be expanded to at least a 12 km radius (as the crow flies) which will include affected nearby settlements, farms, affected farms with guest houses and other tourist activities as well as nature reserves. As we’ve pointed out earlier, planes do not disappear into thin air after take off and vice versa, and recreational aircraft, such as gyrocopters, helicopters and micro lights go on making approximately the same levels of take off noise for the duration of their total flight. Col. Moore’s Scoping study Pg 16 (taken from the developer's scoping document) states that a safe final approach on a visual glide path is approximately 9.3kms from the airfield at 1593 feet (485m) – this would be right over Malmesbury. `Forcing the air crew to shorten (such a distance) or cut the approach distance will impact on safety and is not accepted as a solution.’ `It is here where the community will have a problem with both noise and safety’.
It is of great concern that the SF took issue with the noise impact study of the Draft Scoping Report (DSR) and specifically requested `detailed, specific and extensive noise impact,’ to include nine categories one of which is all flight paths, holding zones, take off and landing flight pattern over the region and these in relation to ground locations,’ These have been totally ignored in the Final Scoping Report (FSR). It is also to be noted that there is a disparity between the main body of work in the Draft Scoping Report and the conclusions of the noise specialist. The SF in their response to the Draft Scoping Report (DSR) pointed this out especially in reference to addendum 13.This was ignored by the Environmetal Practicioner and the SF again pointed it out in the Final Scoping Report (FSR) . The conclusion not mentioned in the Final Scoping Report reads:
''At this time it is clear that the proposed Malmesbury Aviation Estate will have a permanent, negative impact on the local community. ''
This is misleading to the lay person reading the main body of the report.
3. SAFETY
Mist/Fog
Bird Strike
As with mist, bird strike cannot be accurately assessed without clear indication of proposed air movements and accurate distances. Similarly despite a request for a year-long ornithological study to assess bird strike, there is no indication that this will occur at Environmental Impact Assessment (EIA).
Safety near Town of Malmesbury and Environs
We expect that at the EIA stage, all air movements and distances as well as an analysis of accident conditions to be supplied. The scoping report states that due to the 8km distance from Malmesbury, the proposed MAE poses no safety threat to the town. Yet Col Moore’s Scoping study (part of the soping report)states that a safe final approach on a visual glide path is approximately 9.3kms from the airfield at 1593 feet (485m) - which places the appoach path right over Malmesbury. `Forcing the air crew to shorten (such a distance) or cut the approach distance will impact on safety and is not accepted as a solution' he states this very clearly. Col Moore further states that `since the airfield circuit pattern is approximately 2kms short of the town perimeter’. Therfore should an aircraft crash within this area, in the height of summer with a typical South Easter blowing, the resultant fire would threaten Malmesbury before fire services could be mobilized.
Crossing over the R302 We are told that the flight paths will not cross over the R302 in order not to distract drivers on the road. We find it difficult to understand how aircraft are going to leave or return to the proposed MAE without doing so, and further, we note that the proposed vertical circuit view (refer aerial map of property and site figure 2) clearly crosses the R302 at the northern approach point.
Air Pollution
We expect an air quality assessment based on the collection of data existing at facilities that are similar in nature and scale including aircraft movements and not just landing and take off paths. Further that the assessment spans annual climatic conditions. Yet we are told in a specialist report that the potential air quality impacts associated with the construction and operation of the proposed MAE by Brett Williams of Safetech are `not based on a collection of data at existing facilities that are similar in nature’ and `has not addressed the cruise mode of flight as the concern is with ground affected emissions around the airport.’ In figure 3 of the Final Scoping Report – Malmesbury annual wind rose 2008, section 6 Safetech report, shows clearly the prevailing winds to be South – South West for the majority of the year. This means air borne pollutants will be blown towards Malmesbury, (not to mention fire should there be an accident close to Malmesbury. Further we note the limitations given by Brett Williams on the basis of topography and climate, together with unknown air movements. With regard to the first of these it is stated that since `under very stable atmospheric conditions it is possible that the pollutants will not disperse readily in the valley formed by the topography to the east and west of the site. We have requested a careful year-long study under all climatic conditions but see no evidence that this will be done at EIA stage.
4. VISUAL IMPACT OF FLYING PLANES
As with noise the visual impact that must be assessed is of high numbers of aircraft in the skies. We are told that I&APs refer to `the visual impact of high numbers of planes in our quiet country skies ….”. The response offered by CLES to this is that:
Visual impacts were scoped. Refer Col. Moore report Addendum 14. He recommends three activity alternatives to be assessed by specialists in the EIA phase. A visual Impact Assessment will be conducted in the EIA phase to assess the scope of these concerns " (underlining added). It remains entirely ambiguous as to whether `these concerns’ refer to the visual impact of planes flying in the wider region as requested by SF, or simply planes taking off and landing for the three alternatives offered by Col Moore.5. NO ALTERNATIVE LOCATION GIVEN
This is a large project with significant implications beyond the immediate site of development. These implications include wider Civil Aviation and Provincial concerns. Under such circumstances it is reasonable to expect a study of alternative locations. To state that this is the only location that fulfils the criteria, is not acceptable. The need and desirability for the proposed MAE, as stated in the FSR, merely hints at but does not provide concrete evidence or justification to lead the reader to the conclusion that a need exists. One of the key requirements of a scoping report is to establish beyond doubt that the expressed need does in fact exist. Only once it has been established that a need really does exist, should an integrated planning approach involving environmental, aviation and municipal authorities plus a broad cross-section of the affected communities and conservation bodies take place. All of the key issues in this response document need to be addressed in this planning phase.
6. LEGAL & LEGISLATIVE SPATIAL PLANNING
CLES addresses all SF concerns with regard to use of Golf Estate Legislation simply in terms of the advice of a letter from the DEA:DP (11 July 2008). While we understand that DEA:DP has suggested the use of this legislation for land use application, we object to this on the grounds that it is being put forward as a fait accompli obviating any need to justify the use of this legislation. SF has serious concerns at the leapfrogging of the urban edge by the proposed MAE application.7 Interested & Affected Parties (I&APs)
The fact that comments from people not living in the area are considered irrelevant is problematic as the area has a viable tourist industry and regular visitors typically come from outside of the area from as far as Gauteng and the Eastern Cape. These visitors will therefore be directly affected by the MAE as many of them have explicitly stated. The list of Issues and Concerns from Registered and Affected Parties on pg 46 of the FSR does not reflect the range of concerns tabled in the responses to I&APs released by CLES with the notification of the FSR.
8. DEVELOPMENT EAST OF THE R302
The application made to Malmesbury Municipality for re-zoning of farmland includes an area east of the R302. However in the public meeting of 19th March 2008, as well as when specifically asked about development on that side of the R302, and were told that no development was intended. We require explanation for this.
A summary of issues not addressed by the Final Scoping Report follows below:
SUMMARY OF ISSUES NOT ADRESSED
The following is a list of issues that were tabled by the Swartland Forum for the Draft Scoping Report that have not been addressed in the Final Scoping Report, or the table of responses from Interested and Affected Parties comments which was included with the notice of availability of the Final Scoping Report.
1. Air movement not given
2. Explicit request for clarification of exact distances from site to Malmesbury and environs not given.
3. Addendum 13 concludes about noise: ‘At this time it is clear that the proposed Malmesbury Aviation estate will have a permanent, negative impact on the local community. This is not addressed see main document
4. Rationale for the Development i.e. section 9 in SF response to DSR does not explain how market needs have been identified.
5. Request for alternative locations not given.
6. Request for indication of who will buy the proposed MAE houses. This is not dealt with.
7. How the proposed MAE is similar to Golf estates.8. Noise assessment beyond the 4 km radius of the proposed MAE study area not addressed.
9. Bird strike study over a year not guaranteed as asked for.
10. Year long mist/fog study not guaranteed for EIA as requested.
11. The fact that the mist/fog rises quickly has not been dealt with.
12. Air pollution with regard to topography, climate and air movements.
13. Concern with regard to bias not addressed to our satisfaction.
14. Safety for Malmesbury not addressed to our satisfaction.15. Visual impact issues not addressed to our satisfaction.
