Editor –

We act for the Harrismith Business Forum, an interested and affected party that has been involved in the environmental-impact assessment (EIA) process initiated by the South African National Roads Agency Limited (Sanral) for the proposed National Road 3 (N3) from Keeversfontein to Warden, in the Free State province, which is also referred to as the De Beers Pass.

The forum exercises its right to fair comment by responding to an article published in the online edition of Engineering News on March 8, entitled 'S Africa’s ‘R1bn a day’ infrastructure spend to be maintained”.

The forum would like to point out that Economic Development Minister Ebrahim Patel's briefing on the expansive development of infrastructure in South Africa at a recent Employment and Infrastructure Development Cluster event shows that he has an incorrect impression with respect to the
De Beers Pass (N3 Keeversfontein to Warden) project and the proposed N2 Wild Coast highway toll road project from East London to eThekwini.

First, the forum applauds the milestones cited by Patel but would like to clarify certain aspects raised by the Minister, specifically regarding the status of the proposed De Beers Pass (N3 Keeversfontein to Warden) project. Patel notes that Cabinet will fast-track at least 20 infrastructure projects and that his department ". . . has made good progress on establishing the technical specifications and engineering requirements, securing part-funding, approving environmental assessments and inviting contractors to bid for the projects . . .” The forum has been extensively involved in the EIA process for the Beers Pass ((N3 Keeversfontein to Warden) project. No environmental authorisation has been granted for the proposed development. The forum submitted comments on the draft EIA report in June 2015. The final EIA reports must still be made available for public comment.

In summary, the forum’s specialists concluded that the project is simply not economically viable. This is so because the consultants used by Sanral did not take all the costs into account when assessing the economic viability of the proposed road project. The socioeconomic impacts were also not properly assessed.

Sanral's own environmental specialists were concerned about and noted the significant environmental impacts of the project, even with mitigation. The construction of a duplicate national road next to an existing underused national road is even more implausible.

The Minister clearly laboured under the wrong impression with respect to the De Beers Pass project.

Secondly, the amaMpondo communities have also launched a legal challenge against the decision to grant environmental authorisation for the proposed N2 Wild Coast highway toll road project.

Patel also referred to this proposed project in his recent briefing. The N2 Wild Coast highway project would have a devastating impact on the amaMpondo communities and the unique and pristine biodiversity of the entire Wild Coast area.

Cullinan & Associates