Thank You for Your Notification to Withdraw the Appeal to the Development of the New Science

Dear Eugene

Thank you for your notification to withdraw the appeal to the development of the new Science building. I am sure the senior management at UWC is hugely relieved to have the DEA&DP ROD rule in their favour, despite CapeNature's objection to the development. At the time I informed EnviroAfrica that I would not contest DEA&DP ROD since I knew the BAR to be hugely incomplete with respect to alternatives. There was virtually no material and no photos as prescribed on the form for these alternatives. Further, the BAR contained incorrect information with respect to the status of the ecosystem (degree of invasiveness, the high water table, confirmed by recent cores that I have taken, and being a seasonal wetland according to the McDonald botanical report and confirmed in the covering letter accompanying the BAR by EnviroAfrica). Finally there was consistent mis-representation of the I&AP’s response to the development. Considering that in response to an I&AP's question on the chance of successfully rescuing and replanting Sandpalin Fynbos on the "dogs-leg" to another area in the CFNR the consultants stated "Regrettably EnviroAfrica can neither comment on this nor state an example of where such an operation has been conducted". It seems that the only real mitigation offeredthrough the EIA process has an extremely remote chance of success, a situation confirmed by Dr Tony Rebelo an expert on Lowland Fynbos who stated that "I know of no studies that have translocated communities in Fynbos, let alone any that have been carefully documented. I dont think that it is possible without exorbitant costs". Personally I am in agreement with Dr Rebelo’s assessment of the situation and consequently see that the ROD has little value since it is likely to be as neglectful in its compliance as the EIA. My expertise, which was used to reconstruct our natural vegetation of the City of Cape Town in collaboration with Barrie Low the main author (which actually identified the dog’s leg as different to the rest of the campus vegetation), and was used to design the City of Cape Town'sBiodiversity Network Strategy. I was the original designer and implementer of the BGIS SANBI web map service* that is the decision support system used in the NEMA legislative procedure to identify vegetation status, but despite such expertise in biodiversity management I appear to be of no value to my employer, UWC who ignored my advice. Consequently I see little point in continuing to work at UWC and I am seeking employment elsewhere, however, I will attempt to suggest one last idea that might secure a meaningful outcome. UWC has stated in the press that it is "deeply committed to conservation" but it has also recorded and been asked to confirm that the CFNR is costing it R1.5 million rand per annum to manage. I suggest that the existing CFNR together with the agreed extension of 2.9115 ha be ceded either to the Provincial Government for management by Cape Nature (who have impressed me with their considered response on this issue), or to the City of Cape Town. This then provides a biodiversity offset to the proposed development that UWC wishes to pursue and sets a precedent of sufficient commitment that other landowners will take notice when considering the transformation of their critically endangered habitat. In other word it actually illustrates the biodiversity offset principle with a meaningful example. Since you have mentioned, "the CFNR is extremely well protected it is NOT “managed” properly since there is not disturbance regime" (I agree entirely with this assessment) it would mean that another threatened ecosystem could be properly managed by a competentconservation authority and they could set about removing the invasive woody species that our steadily appearing in the reserve. As an E&AP I would recommend that no further mitigation for the loss of the "dog's leg" is necessary and that UWC is free to develop any area of its revised estate boundary without any further consideration of protection of biodiversity, since there is now nothing of ecological value to conserve. This would mean that UWC could focus on its core activities of Education and Research with the freedom to expand when opportunities and needs arise. Further there would be no need to continue with the charade of planting indigenous species on campus and they are free to landscape the campus to their own tastes (possibly avoid planting kikuyu grass adjacent to the reserve). This would provide for a longer term protection of our national biodiversity and has secured a meaningful precedent for valuing conservation through a biodiversity offset process that is more in line with what DEA&DP recently presented at the Fynbos Forum. The Botanical Society could then engage with CapeNature in joint conservation ventures. Hopefully CapeNatureor the City of Cape Townwould see that this is actually an attractive option to achieve some of their mandates.

Cheers

Rich

*incidentally this is still hosted on my servers at UWC (although Mr Martin Cocks through IOI-SA now co-manages it and continues the development of the application)