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Quick summary of FSM Comments, April-May 2019

• 30 April 2019 Comments on IDP
  Skip this part on a first reading. This was written at a time when the information about the budget line item was as yet unknown. The topics addressed are important for the coherence and effectiveness of the top four local-government legal instruments (IDP, MSDF, CITP and SEMF)
  • Ensure that the new 2019 MSDF (which differs strongly from the 2018 version) is properly reflected in the 2019 IDP
  • Make sure that the Comprehensive Integrated Transport Plan (CITP), which along with the MSDF and SEMF is one of the three key legal instruments under the IDP, is properly aligned (ie reflects the principles and directives) of the IDP and MSDF.


• 6 May 2019 Addendum Comments on Eastern Link Road and IDP
  These comments were written after it came to light on 2 May that the draft municipal budget (MTREF 2019-2022) contained a line item to start work on the Eastern Link Road even though this was not even mentioned in the MSDF. Of the complete draft 2019-2022 MTREF we refer in particular to Page 188 and Page 117. The FSM comments pertain to
  
  
  • the Eastern Link Road: Two small development proposals on Farm 372 smallholdings have led to three different road construction routes which are now being used to motivate the completion of road segment L3c between Wildebosch and Trumali Roads which would then form part of the Eastern Link Road. The comments set out in detail how a budget line item first presented to the public only on 2 May 2019 appeared under a different name in the MTREF budget itself but was altered to suit the opportunity of building the Wildebosch-Trumali part of the Eastern Link Road.
  • The provincial Department of Transport and Public Works (DTPW) has been acting beyond its powers in prescribing to Stellenbosch where and when to build nonprovincial roads. It has authority over provincial roads only. The DTPW letters of 5 April 2017 and 6 April 2017 are being used by Stellenbosch Municipality to motivate the construction of the Eastern Link Road, claiming they are required to do so.
  • The April/May 2019 IDP public participation process may be unlawful because the Ward 21 IDP public meeting was held only on 2 May 2019, while the deadline for comments had been set for 30 April. Five other IDP public meetings, those of Wards 3, 13, 1 and 16, were held on 29 April and 30 April (ie within a day of the closing of comments). An extension period for comments "granted" at the 2 May meeting was not provided to other wards.


• 8 May 2019 Comments on Urban Edge extension, Nature Area and Eastern Link Road
  These comments pertain to the draft Municipal Spatial Development Framework (MSDF) as well as update and extend the comments of 6 May pertaining to road building.
  • The MSDF is in general a very good document and FSM commends the planning department and consultants who drew it up. The Adam Tas Corridor initiative will go a long way towards fulfilling the needs for housing, densification, transport-friendly develoment and the underlying principles.
  • Brandwacht Urban Edge extension: However, the MSDF has at least one flaw which is in serious conflict with all the good principles and overall strategy. In Figure 28 of the MSDF, an extension of the Urban Edge was quietly inserted without commenting on these in the text itself. The yellow area south of Brandwacht suburb. The FSM comments briefly set out the background of this land and the reason why it should not be developed. See the comments and this section for details.
  • Paradyskloof Urban Edge extension: Even more serious is the second part of that proposed urban edge extension around the Paradyskloof waterworks. The 20 hectare area is a Critical Biodiversity Area (CBA) consisting of critically endangered renosterveld and a riverine ecosystem. The proposed extension would destroy both the renosterveld and the integrity of the upper Schuilplaats River valley south of the waterworks. The FSM comments sets out in detail the history and significance of this biodiversity area.
  • Eastern Link, general road-building and the bigger picture: In the last part of the comments, the comments analyse the emergence of a bigger picture of road-building in Stellenbosch, including the R44 "flying saucer" upgrades, the Eastern Link Road, the Western Link Road and its extension, the Western Bypass, and points out that this program is grounded not (as it should) in the IDP and MSDF but rather in the Roads Master Plan which has no legal status. In other words, the Stellenbosch road building programme ignores all the laws and even the MSDF itself.