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Proposed 6 Million Litre Mogale Water Reservoir

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The former Director of Mogale City Environmental directorate, Ms Snowy Mothiba was chiefly responsible for the planning of the six million litre Reservoir, which was approved in January 2006 by the Gauteng Department of Agriculture Conservation & Environment (GDACE) for development on top of a sensitive ridge in Rangeview extension 4. This site was authorized by GDACE (also a former employer of Ms. Mothiba) despite irregularities in the public participation procedure and widespread opposition from conservation groups and other interested and affected parties. This site is known as “Option 3.”

For inexplicable reasons Mogale City has consistently opposed proposals for the development of the reservoir at alternative sites, including an offer by Silverstar Casinos to accommodate the Reservoir on their property alongside the R28 highway. One of the options preferred by conservation groups is known as “Option 2” which is located in a disturbed area along the R28.
	Option 3 Mogales City's preffered site

Background to Mogale City’s application:

In 2005 Mogale City contracted consultants Strategic Environmental Focus (SEF) to undertake an investigation of potential sites for the development of a new water reservoir to supply the Muldersdrift Area. Despite the availability of numerous location options, SEF however concentrated their investigation on one site only, namely “Option 1,” located on a pristine ridge slope above Featherbrooke Estate, on land owned by the Walter Sisulu National Botanical Gardens (WSNBG).

Given the availability of more suitable options in relatively non-sensitive areas, the decision to target only one site was perplexing. Furthermore, as the primary stakeholders in the area, namely the Featherbrooke Homeowners Association and the WSNBG had not been automatically registered as Interested and Affected Parties (I&AP’s) by SEF (as required by law), the public participation process was later ordered to be redone.

In the second public participation process for this development application, only two additional options were tabled for discussion, namely “Option2,” located in a disturbed area along the R28 and “Option3,” located on top of a ridge within the WSNBG Nature Reserve, on stands that Mogale City claimed that they still owned. Most I&AP’s objected to Option 3, preferring Option2 as the more desirable alternative. Again the decision to limit the options to only two additional sites - ignoring the many better suited location alternatives in the study area - was inexplicable.

In the Final Scoping Report submitted by SEF to GDACE in December 2005, Option 3 was presented as the “most ecologically desirable option” - despite I&AP objections favouring Option 2. Minutes of public meetings containing details of I&AP opposition to Option 3 had strangely been omitted from the Report. Furthermore, SEF recommended Option 3 despite the fact that their own ecological specialists expressly advised against developing Option 3 on account of its ecological sensitivities and conservation importance.

In our view SEF had no reasonable basis for favouring Option 3, as no studies of any kind had been undertaken for the preferred alternative, namely Option2. We had argued that in the absence of proper comparative studies of all potential sites – not limited to the three supposedly under investigation - it was impossible for SEF to draw any reasonable conclusion in favour of Option 3.
It appeared that SEF had adopted this position under pressure from their client, Mogale City.

Based on the Final Scoping Report submitted by SEF, GDACE then issued a positive RoD in favour of Option3. Appeals from interested and affected parties, drawing attention to these irregularities and urging GDACE to review their decision, were all later dismissed without proper reason by the GDACE MEC in April 2006.

Option 2 wattle infested site >>

Efforts to find a reasonable solution:

In order to prevent what would have been an environmental catastrophe the Black Eagle Project Roodekrans (BEPR) was left with no alternative but to engage the services of legal advisers to try to encourage Mogale City to pursue development at the alternative locations.

In July 2006 – in an attempt to resolve this matter – Silverstar Casinos offered to make their property, located alongside the R28 highway, available to Mogale City as an alternative site (“Option 5”). A series of meetings was held between Silverstar (Mr. James Forbes) and Mogale City (Mr. Barry Friedman & Mr. Van Eck) in July and August 2006, culminating in an agreement for the development of the reservoir on the Casino property. This proposal was however apparently blocked by other officials in Mogale City, resulting in the immediate termination of this initiative.

In another effort to find a solution acceptable to all parties, an inter-governmental Task Team was established comprising SANBI (authorities for the WSNBG), GDACE and Mogale City. At its first meeting held in August 2006, it was agreed by all parties to carry out a detailed cost benefit analysis of the available options, focusing on the Casino (Option 5). It was further agreed that development of Option 3 would only be pursued as a last resort in the event that the alternatives proved unviable.

In violation of its own obligations in terms of the task team to work cooperatively with SANBI to complete these comparative studies, Mogale City announced in early 2007 that it was going ahead regardless of opposition with its plans to develop the reservoir at Option3. To date however the cost benefit analysis and comparative feasibility study has still not been completed.

The BEPR have reason to believe that the real reason behind Mogale City’s apparent opposition to these alternative solutions has a lot to do with the position of the Option 3 site in relation to the Roodekrans Ridge itself. The alternatives along the R28, namely Option 2 and Option 5 are all located on the north-facing slopes of Roodekrans Ridge, whereas Option 3 is located on the top of the Ridge. All these options are at a suitable elevation for gravity feeding 95% of the Muldersdrift area without the need for pressure boosters. Option 3 is the only option however that would allow water to be gravity fed southwards as well, towards areas south of the Roodekrans Ridge. The controversial development of the remaining phases of Sugarbush Estate cannot proceed as planned without a new water reservoir at Option3. Whereas the current water supply can meet existing demand, it cannot meet the anticipated future demand as a result of Sugarbush Estate. Supplying water to this area is not however part of the official terms of reference for the Mogale Water Reservoir project, which is to supply water to Mulderdrift – an area located exclusively to the north of the Roodekrans Ridge.

Any move on Mogale City’s part to proceed with Option 3 must be strongly opposed by interested and affected parties, including the affected Rangeview residents, on account of the following:

1. The ecological sensitivity of the Option 3 site and the irreparable damage that would be done to a pristine ridge area during the construction and operational phases of the reservoir and its associated pipeline, which will run down the northern slopes of the Roodekrans Ridge through the WSNBG. No impact assessment has been done on the associated pipeline upgrade and pressure reducing installations, which will require ongoing maintenance by Mogale City.

2. The presence of a geologically active fault-line traversing the Option 3 site, which Mogale City engineers failed to locate in preliminary geotechnical investigations carried out in 2005. This same fault line caused the partial collapse of the R28 in the 1970’s. Expert geologists have warned Mogale city not to interfere with this fault line due to its potential for shear zone failure northwards into the WSNBG and southwards into Rangeview. Although Mogale City engineers claim that the reservoir can be engineered accordingly, there is no guarantee whatsoever that the underground reservoir would be capable of withstanding movement in this fault line. Human lives and property, will therefore always be at risk

3. The undertakings of the inter-governmental task team to carry out a thorough cost benefit analysis of all available options. This process has still not been completed.

4. The fact that a verbal agreement was reached between Mogale City and the WSNBG in 1998 for the ownership of a total of 8 stands to be transferred from Mogale City to the WSNBG. These stands have been managed as part of the WSNBG for many years and comprise an important portion of the geological trail frequented by visitors to the gardens.

5. The fact that there appears to have been inadequate consultation with the affected residents of Rangeview extension 4. The applicant Mogale City was legally obliged to re-advertise the public participation process and register all neighbours to the Site (including those in adjacent properties in Rangeview Ext. 4) as interested and affected parties. This had not been done.

6. A total of approximately 10 000 trips will have to be made by heavy duty trucks to remove approximately 60 000 tons of rock from the Option 3 site. The impact of these vehicles over the anticipated 330day construction period, on the steep and narrow streets of Rangeview Ext. 4, and the resulting visual, dust and noise pollution - not to mention the impact of 18months of drilling and so-called “chemical blasting” to remove this rock from the steep slopes of this fault-line area – has still not been assessed. Apart from these direct impacts, the safety of the Rangeview residents and indeed the value of their properties would be severely compromised by the existence upslope of what could well prove to be a “ticking time bomb.”