N2 Wild Coast Toll Highway – Final Environmental Impact Report

Public Participation Process Report

1. INTRODUCTION
This report outlines the public consultation process undertaken for the Impact Assessment Phase
of the Environmental Impact Assessment (EIA) for the proposed N2 Wild Coast Toll Highway.
The proposed process for the public consultation for the Impact Assessment Phase of the EIA
was set out in the Plan of Study for EIA (see Appendix A, Volume 1: Main Report) which contains
the details set out below regarding the public participation that would be undertaken.

1.1 Summary of Public Consultation Contained in the Plan of Study for EIA
Public comment on the Draft EIR
The Draft EIR would be placed in public libraries and other public venues used earlier in the
process, and on CCA’s and SANRAL’s websites, in order to facilitate public review and
comment. An Executive Summary would be sent to all Interested and Affected Parties
(I&APs) on the project database. The publication of the Draft EIR would also be announced
in the media used earlier in the process. I&APs would be given an eight-week period within
which to submit comment on the report.
Compile Comments and Responses Report and Final EIR
Comments received on the Draft EIR would be collated in a Comments and Responses
Report. The Final EIR would then be compiled, with due consideration of comments received
and responses provided by the EIA project team and Applicant, and submitted to DEAT (and
the relevant provincial environmental authorities) for consideration and decision-making.
PUBLIC CONSULTATION PROCESS
It should be noted that a number of opportunities for public review would be provided during
this phase of the EIA process. These include the following:
 I&APs would be notified that the EIA process is commencing in accordance with an
approved PoS for EIA;
 Specialists would interact with relevant communities and other stakeholders, where
appropriate, in order to facilitate assessment of potential impacts;
 The Draft EIR would be released for an eight-week review and comment period;
 Hardcopies of the full Draft EIR would be made available at the same libraries and other
public venues used during the Scoping Study;
 Adverts would be placed in national, regional and local newspapers used during the
Scoping Study to announce the availability of the Draft EIR for review;
 An electronic copy of the full report would be made available on the websites
www.ccaenvironmental.co.za and www.nra.co.za;
 All registered I&APs would be notified by post of the availability of the Draft EIR for
review;
 I&APs would be notified of the submission of the Final EIR, DEAT’s RoD and the
statutory 30-day appeal period; and
 I&APs would be notified of the outcome of the Appeals period.
CONSULTATION WITH ENVIRONMENTAL AUTHORITIES
It is envisaged that the relevant environmental authorities would be consulted for input and
guidance and kept informed of the proposed project on an ongoing basis, and particularly at
the following stages:
 Submission and acceptance of the Plan of Study for EIA;
 Submission of the Draft EIR for review; and
 Submission of the Final EIR for consideration and decision-making, as appropriate.

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It is understood that DEAT would be the final decision-making authority, with the Eastern
Cape Department of Economic Affairs, Environment and Tourism and the KwaZulu-Natal
Department of Agriculture and Environmental Affairs being commenting authorities.
The National Department of Environmental Affairs and Tourism accepted the Final Scoping
Report and the Plan of Study for EIA on 22 May 2007 (see Appendix B, Volume 1: Main Report).
The acceptance letter states that the public participation process followed was adequate (referring
to the public participation undertaken for the Scoping Phase) and sets out the following conditions in
terms of the public participation for the Impact Assessment Phase:
The draft EIR must be made available at the public libraries and other public venues used
earlier in the EIA process, and on CCA's and SANRAL's websites, in order to facilitate public
review and comment. An executive summary must be sent to all interested and affected
parties on the project database. The publication of the draft EIR must also be announces in
the media used earlier in the process. Interested and affected parties must be given at least
45 days within in which to submit comment on the report.
The final EIR must be made available at the public libraries and other public venues used
earlier in the EIA process, and on CCA's and SANRAL's websites. An executive summary
must be sent to all interested and affected parties on the project database. The publication of
the final EIR must also be announced in the media used earlier in the process.

2. NOTIFICATION OF ACCEPTANCE OF FINAL SCOPING REPORT AND PLAN OF STUDY

FOR EIA
The National Department of Environmental Affairs and Tourism accepted the Final Scoping
Report and the Plan of Study for EIA on 22 May 2007. All I&APs on the project database (10 139)
were notified by letter of DEAT’s decision and informed that the Impact Assessment Phase of the
EIA would be commencing (see Appendix C, Volume 1: Main Report).

3. CORRESPONDENCE RECEIVED FROM ACCEPTANCE OF FSR TO RELEASE OF DEIR

Correspondence received from I&APs subsequent to the notification of acceptance of the Final
Scoping Report up until the start of the comment period on the Draft EIR is included in Appendix
C, Volume 1: Main Report of the Final EIR.

4. PUBLIC REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT REPORT

The Draft Environmental Impact Report (EIR) was made available for public review from Monday
10 November 2008 to Friday 9 January 2009. Following a number of requests from I&APs and a
directive from the Department of Environmental Affairs and Tourism the closure of the comment
period for the review of the Draft EIR was extended to Thursday 22 January 2009. The same
public libraries and public venues which were used for the review of the Draft Scoping Report
were again used for the placement of the Draft EIR, with the exception of Munster Public Library
which had since closed.

Copies of the Draft EIR were lodged in the following public libraries and venues for review:

Eastern Cape

East London Central Library Nyandeni Municipal Offices - Libode

Gonubie Library Port St Johns Library
Komga Library Lusikisiki Information Centre
Butterworth Public Library Ingquza Hill Municipal Offices (Lusikisiki)
Dutywa Public Library Flagstaff Information Centre
Mthatha Public Library Ingquza Hill Municipal Offices (Flagstaff)
Mhlonto Municipal Offices (Qumbu) Bizana Library
Tabankulu Library Matatiele Library
Umzimvubu Municipal Offices (Mount Ayliff)

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KwaZulu-Natal
Kokstad Library Cragieburn Library
Harding Public Library Scottburgh Memorial Library
Ezinqoleni Municipal Offices (Izingolweni) Park Rynie Library
Durban Central Reference Library Umzinto Library
Isipingo Civic Library Pennington Library
Isipingo Beach Library Hibberdene Library
Athlone Park Library Umtentweni Library
Amanzimtoti Library Port Shepstone Library
Kwamakhutha Library Uvongo Library
Kingsburgh Library Margate Library
Umkomaas Library Southbroom Library
Adams Mission Library Port Edward Library
The Draft EIR was also made available on the websites www.ccaenvironmental.co.za and
www.nra.co.za from 10 November 2008.

5. PUBLIC ANNOUNCEMENT OF THE AVAILABILITY OF THE DRAFT ENVIRONMENTAL

IMPACT REPORT AND DETAILS OF PUBLIC OPEN DAYS

Adverts (see Volume 5) announcing the availability of the Draft EIR and the libraries where it
could be viewed were placed in 22 national, regional and local newspapers as detailed below.
The same 17 newspapers that were used to advertise the availability of the Draft Scoping Report
were used once again, with the exception of those titles which had closed down in the intervening
period, and new titles in the study area were also added to the list. These adverts appeared in the
week preceding the start of the comment period. The adverts also gave details of the Public Open
Days and informed I&APs that copies of the executive summary to the Draft EIR were available in
English, Afrikaans, isiXhosa and isiZulu upon request from the consultants. The adverts also
indicated the duration and closing date for the comment period and provided contact details
where I&APs could submit comments on the report.
The advertisements appeared in the following newspapers:

 Daily Dispatch (Monday 3 November 2008)

 Die Burger (Monday 3 November 2008)
 East Griqualand Fever (Friday 7 November 2008)
 Ilanga (Thursday 6 November 2008)
 Isolezwe (Monday 3 November 2008)
 Isolomzi Fever (Friday 7 November 2008)
 Kokstad Advertiser (Thursday 6 November 2008)
 Mthatha Fever (Friday 7 November 2008)
 Natal Witness (Monday 3 November 2008)
 Pondo News (Friday 14 November 2008)
 South Coast Fever (Friday 7 November 2008)
 South Coast Herald (Friday 7 November 2008)
 South Coast Sun (Friday 7 November 2008)
 Sunday Sun (Sunday 2 November 2008)
 Sunday Times (Sunday 2 November 2008)
 Sunday Tribune (Sunday 2 November 2008)
 The Herald (Monday 3 November 2008)
 The Mercury (Monday 3 November 2008)
 The Rising Sun Merebank (Wednesday 5 November 2008)
 The Rising Sun South Coast (Tuesday 4 November 2008)
 Umafrika (Friday 7 November 2008)
 Uvo Lwethu (Friday 7 November 2008)

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Pre-recorded radio announcements in English, isiXhosa and isiZulu were also used to target
people in the rural areas of the Eastern Cape and KwaZulu-Natal who have limited access to
newspapers. These announcements provided the same information contained in the newspaper
adverts. Details of the radio stations which broadcast the announcements are provided below.

Imbokodo Community Radio covers the whole of the project area within KwaZulu-Natal,
extending from Durban to Port Edward along the coast and inland as far as Ixopo (see broadcast
area indicated in white on map 1 below). The pre-recorded announcement in isiZulu (1 min 30
sec) was broadcast 12 times daily on 4, 5 and 6 November 2008 between 6 am in the morning
and 8 pm in the evening.

Highway Radio broadcasts from Pinetown and covers the entire Durban metropolitan area,
extending south as far as Hibberdene and inland as far as Pietermaritzburg (see broadcast area
indicated in white on map 2 below). The pre-recorded announcement in English (1 min) was
broadcast 12 times daily on 4, 5 and 6 November 2008 between 6 am in the morning and 8 pm in
the evening.

Radio Sunny South covers the whole of the project area within KwaZulu-Natal, extending from
Tongaat to Port Edward along the coast and inland as far as Howick and Kokstad (see broadcast
area indicated in white on map 3 below). The pre-recorded announcement in isiZulu (1 min 30
sec) was broadcast 12 times daily on 4, 5 and 6 November 2008 between 6 am in the morning
and 8 pm in the evening.

Unitra Community Radio broadcasts from Mthatha and covers most of the project area in the
Eastern Cape, extending from Pondoland to Port Alfred along the coast and inland as far as
Mount Fletcher and Queenstown (see broadcast area indicated in white on map 4 below). The
pre-recorded announcement in isiXhosa (1 min 30 sec) was broadcast 12 times daily on 4, 5 and
6 November 2008 between 6 am in the morning and 8 pm in the evening.

Khanya Community Radio broadcasts from Butterworth and covers part of the project area in
the Eastern Cape, extending from Coffee Bay to East London along the coast and inland as far
as Stutterheim and Mthatha (see broadcast area indicated in white on map 5 below). The pre-
recorded announcement in isiXhosa (1 min 30 sec) was broadcast 12 times daily on 4, 5 and 6
November 2008 between 6 am in the morning and 8 pm in the evening.

Alfred Nzo Community Radio covers the eastern section of the project area within the Eastern
Cape, as well as the western section of KwaZulu-Natal, encompassing Mthatha, Libode and Port
St Johns to the east, Qumbu, Mount Frere, Mount Ayliff and Kokstad inland, and Ixopo, Harding
and Izingolweni to the west (see broadcast area indicated in white on map 6 below). The pre-
recorded announcement in isiXhosa (1 min 30 sec) was broadcast 12 times daily on 4, 5 and 6
November 2008 between 6 am in the morning and 8 pm in the evening.

Link FM broadcasts from East London and covers part of the project area in the Eastern Cape,
extending from East London to Lusikisiki along the coast and inland as far as Queenstown and
Elliot (see broadcast area indicated in white on map 7 below). The pre-recorded announcement in
English (1 min) was broadcast 12 times daily on 4, 5 and 6 November 2008 between 6 am in the
morning and 8 pm in the evening.

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Map 1: Broadcast coverage of Imbokodo Community Radio (shown in white)

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Map 2: Broadcast coverage of Highway Radio (shown in white)

Map 3: Broadcast coverage of Radio Sunny South (shown in white)

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Map 4: Broadcast coverage of Unitra Community Radio (shown in white)

Map 5: Broadcast coverage of Khanya Community Radio (shown in white)

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Map 6: Broadcast coverage of Alfred Nzo Community Radio (shown in white)

Map 7: Broadcast coverage of Link FM (shown in white)

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In the week preceding the start of the comment period 9 538 I&APs on the project database were
sent a cover letter outlining the same information contained in the newspaper advertisements
together with a copy of the executive summary to the Draft EIR (see Volume 5).
A full colour, glossy information brochure was also produced in English / isiXhosa and English /
isiZulu (see Volume 5). The Basic Information Brochure (BIB) provided information on the project,
EIA process, the availability of the Draft EIR and where it could be viewed, the Public Open Days,
the overall findings of the EIA and the way forward. It also contained a fold out map showing the
route of the proposed project and the location of the Public Open Day venues. A total of 10 000
brochures were produced in English / isiZulu and 25 000 in English / isiXhosa. The brochures
were distributed at voter registration stations throughout the study area on the weekend of 8 and
9 November 2008 and were also distributed to traditional leaders of Traditional Councils in
KwaZulu-Natal and Administrative Areas in the Eastern Cape.

6. NOTIFICATION OF EXTENSION TO COMMENT PERIOD

Following a number of requests from I&APs and a directive from the Department of
Environmental Affairs and Tourism the closure of the comment period for the review of the Draft
EIR was extended to Thursday 22 January 2009.
A letter was therefore distributed on 8 December 2008 to 10 005 I&APs on the project database
informing them of the extension to the comment period (see Volume 5).
Adverts informing the public of the extension to the comment period for review of the Draft EIR
(see Volume 5) were also placed in the following newspapers:
 Daily Dispatch (Thursday 18 December 2008)
 Die Burger (Thursday 18 December 2008)
 Ilanga (Thursday 18 December 2008)
 Rapport (Sunday 21 December 2008)
 Sunday Sun (Sunday 21 December 2008)
 Sunday Tribune (Sunday 21 December 2008)
 The Herald (Thursday 18 December 2008)
 The Mercury (Friday 19 December 2008)
 The Witness (Thursday 18 December 2008)
 Ulwesihlanu (Friday 19 December 2008)
 Uvo Lwethu Fever (Saturday 26 December 2008)

7. PUBLIC OPEN DAYS

7.1 Planning
Careful consideration was given to how the large quantity of information contained in the Draft
EIR could most usefully be presented to I&APs to enable them to provide input on the report. A
public meeting is a far from ideal format for presenting a large amount of technical information. A
Public Open Day is considered more suitable for presenting technical details such as the findings
from the 13 specialist studies contained in the Draft EIR. Public Open Days allow information on
different topics to be presented on posters using text and visual aids and the specialists can
attend to engage with participants. Public Open Days can also run for much longer than public
meetings and allow people to come in at a time which is convenient to them and spend as much
time as they wish perusing information and engaging with project team members.
While it should be noted that the EIA for the proposed N2 Wild Coast Toll Highway is being
conducted in terms of the Environment Conservation Act, 1989 (Act No. 73 of 1989) and the EIA
Regulations published in Government Notice R1183 of 5 September 1997 (as amended),
Guideline 4: Public Participation in support of the EIA Regulations issued in Government Gazette
No. 28854 of 19 May 2006 (in support of the NEMA EIA Regulations) has the following to say
about Public Open Days:

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Public meetings suffer from two distinct shortcomings. Firstly, they are not very effective in
conveying technical information about a project. This drawback is especially pronounced in the
case of previously disadvantaged communities. Secondly, they have the potential to engender
conflict among participants and to degenerate into "venting sessions" about long-standing
disputes unrelated to the project. In order to circumvent these difficulties, open days may be
held to provide l&APs with information about a proposed activity and to provide them with the
opportunity to submit comments.
The relevant specialists for the section of the proposed project covered by each Public Open Day
were present at the venues to explain or answer questions about their studies. Representatives
from SANRAL and the EIA consultant were also present at each Public Open Day.

7.2 Transport

The Public Open Days were held at central locations along the route and transport was provided
from outlying areas to the nearest Public Open Day venue. During the public review of the Draft
Scoping Report 13 public information sharing meetings were held at key centres along the route
and 124 additional meetings including focus group meetings and imbizos with rural communities
were held for people in smaller communities outside the main centres where the public meetings
were held. As it was not feasible to hold Public Open Days at all these venues it was decided to
provide transport from the outlying areas around the main centres so that people still had the
same opportunity to participate in the process as during the scoping phase.

Transport arrangements to bring people from the outlying areas to the Public Open Days were
made well in advance through the traditional authorities and/or ward councillors, and local taxis or
busses were used to transport people to the venues. The arrival of people from different areas
was staggered so that the venue was not overcrowded through too many people arriving at the
same time.

7.3 Dates and Venues of Public Open Days

Seventeen (17) Public Open Days were held from 10h00 in the morning until 17h00 in the
afternoon in rural areas, and until 19h30 in the evening in urban areas. The details of the Public
Open Days were as follows:

KwaZulu-Natal
Monday 17 November 10h00 to 19h30 Scottburgh Town Hall
Tuesday 18 November 10h00 to 19h30 Amanzimtoti Civic Centre
Thursday 11 December 10h00 to 19h30 Port Shepstone Town Hall

Eastern Cape:
Wednesday 19 November 10h00 to 17h00 Libode Town Hall
Thursday 20 November 10h00 to 19h30 Mthatha Town Hall
Friday 21 November 10h00 to 17h00 Nelson Mandela Museum - Qunu
Monday 24 November 10h00 to 17h00 Dutywa TRC Hall
Tuesday 25 November 10h00 to 17h00 Butterworth Town Hall
Wednesday 26 November 10h00 to 17h00 Komga Town Hall
Thursday 27 November 10h00 to 19h30 East London City Hall
Friday 28 November 10h00 to 17h00 Thombo Community Centre
Monday 1 December 10h00 to 17h00 Lusikisiki Teacher Training College
Tuesday 2 December 10h00 to 17h00 Mahaha Junior Secondary School
Wednesday 3 December 10h00 to 17h00 Baleni Clinic
Monday 8 December 10h00 to 19h30 Wild Coast Casino
Tuesday 9 December 10h00 to 17h00 Holy Cross Community Hall
Wednesday 10 December 10h00 to 17h00 Taleni Community Hall

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7.4 Presentation of Information and Facilitation

The information that was displayed at the Public Open Days was in the form of posters in both
English and the local language, either isiZulu or isiXhosa, depending on the location of the
meeting. These posters highlighted both the positive and negative potential impacts of the
proposed project and the recommended mitigation measures to reduce or eliminate negative
impacts. These posters contained visual images, where possible, to illustrate the information that
was being conveyed. Large photographs were also displayed depicting an example of a toll plaza
and a typical cross section of the proposed road in the “greenfield” sections. Maps showing
sections of the proposed route were also exhibited.

At the Public Open Days on the “greenfield” sections of the route 1:10 000 aerial photographs
were displayed which depicted the proposed route of the road and the alternatives that were
investigated, the proposed toll plaza positions, the proposed intersections with the local road
network, etc. These aerial photographs clearly showed the houses, schools, existing roads and
local landmarks which enabled local people to locate the proposed project in relation to their own
homes.

However, it was also understood that the information that was being displayed was highly
technical in nature and that many people who attended the Public Open Days would not be able
to understand and/or read the information without assistance. People from previously
disadvantaged backgrounds were therefore given the opportunity to be guided around the display
in groups by a facilitator who explained each poster and fielded questions in the mother tongue of
the participants. Informal meetings with a question and answer session were also arranged with
groups of people. As large groups of people from the same area would arrive together using the
public transport provided, sufficient numbers of people could participate in these ad hoc meetings
or be guided around the display by a facilitator. These interactions facilitated lively debate and
exchanges.

All participants were encouraged to write down their comments about the proposed project after
they had perused the display and finished engaging with the facilitators and members of the EIA
team. Members of the public participation team assisted those people who could not write or did
not want to write by recording their comments for them. Input from participants could be made on
the comments sheets that were available at the venues and either be deposited in a comments
box, or completed later and posted, faxed or emailed to the public participation consultant before
the close of the comment period.

It is considered that the Public Open Days, with the additional measures that were undertaken as
outlined above, were the most appropriate way of engaging with the large number of I&APs over
an extensive study area, from different cultural and educational backgrounds, in order to provide
them with a reasonable opportunity to learn about and comment on the Draft EIR.

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7.5 Attendance and Written Submissions at Public Open Days

Table 7.1 below shows the attendance at each of the Public Open Days and the number of
written submissions handed in at each venue.

Table 7.1: Attendance at Public Open Days and Number of Written Submissions
Completed

Public Open Day Attendance Written Comments

Scottburgh 185 102
Amanzimtoti 524 258
Libode 361 236
Mthatha 202 94
Qunu 70 30
Dutywa 160 79
Butterworth 144 95
Komga 102 25
East London 7 1
Thombo 198 126
Lusikisiki 262 191
Mahaha 208 172
Baleni 193 160
Wild Coast Casino 84 54
Holy Cross 136 106
Taleni 203 143
Port Shepstone 168 74
TOTAL 3 207 1 946

8. ANALYSIS OF WRITTEN COMMENTS RECEIVED ON THE DRAFT EIR

A total of 7 876 written comments were received during the comment period on the Draft EIR
which ran from 10 November 2008 to 22 January 2009. These comments are addressed in the
Comments and Responses Tables contained in Volume 5 (Comments Report) of the Final EIR.

A statistical analysis of the submissions was undertaken using random sampling and a sample
size of 371 (4,5% of the population) at a 95% confidence level. Random sampling was used
because, whilst this does not guarantee that every random sample perfectly represents the
population, most random samples will be close to the population most of the time (Neuman,
1
2006) . Based on this analysis the tables below were compiled to provide an overview of the
submissions made during the comment period.

It should be noted that the large number of comments received from KwaZulu-Natal was
influenced quite significantly by the efforts of the Upper South Coast Anti-Toll Alliance (USCATA).
USCATA was able to ensure that several thousand people declared their opposition to the tolling
of the N2 on the section between Umkomaas and Isipingo. The 1 502 courier submissions were
collected and then submitted by USCATA and were objection forms that had been distributed by
USCATA and completed by individuals. The vast majority of faxes and emails were also from
people who had completed standard objection forms prepared by USCATA (or other individuals
opposed to tolling) by simply inserting their name and address on the objection form that was
given or sent to them. While these submissions certainly highlight the overwhelming resistance to
the tolling of the existing N2 on the Upper South Coast, they distort the overall picture of the
comments on the Draft EIR as virtually none of these people were on the project database which

1
Neuman, W. L. Social Research Methods. Qualitative and Quantitative Approaches. Sixth Edition, Pearson Education Inc., 2006.

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stood at 9 538 prior to the commencement of the comment period on the Draft EIR. They had
therefore not received the executive summary to the Draft EIR, and had probably never seen the
Draft EIR itself, but simply completed forms objecting to the tolling of the N2 on the Upper South
Coast.

The analysis of issues raised was therefore restricted to original submissions and not duplicates
of other submissions with people’s contact details inserted on them. Even this analysis is
distorted as most of the original submissions were on standard objection forms or in response to
chain emails and therefore only raised the tolling of the N2 on the Upper South Coast and did not
deal with the substantive content of the Draft EIR.

The analysis of the medium used to submit comments (Table 8.1 below) shows that very few
people from the Eastern Cape sent in comments other than the comment forms which were
completed by people who attended the Public Open Days. This is not surprising as very few
people in the rural areas affected by the proposed project have access to faxes or email. In
KwaZulu-Natal where there is a strong and organised opposition to the tolling of the existing N2,
and where many people have access to email and faxes, there was a good response in terms of
registering opposition to the project as discussed above.

Table 8.1: Medium through which Comments were Received

Medium through which comments received Total KZN EC Other

Postal 396 384 8 4
Fax 2 641 2 626 4 11
Email 1 391 1 374 10 7
Courier 1 502 1 502
Comments Sheets completed at Public Open Days 1 946 434 1 512

As discussed above there were a large number of submissions which were duplicates of standard
objections that had simply had people’s contact details added to them. Table 8.2 below gives a
breakdown of the number of original and duplicate submissions. Approximately 45% of all
submissions from KwaZulu-Natal were duplicate submissions. The vast majority of original
submissions from KwaZulu-Natal were on standard objection forms or in response to chain emails
and were therefore only objections to tolling on the Upper South Coast.

Table 8.2: Number of Submissions and Original Submissions

Total number of submissions received 7 876

Number of identical submissions by different I&APs 2 848
Total number of original submissions 5 028
Number of original submissions from KZN 3 473
Number of original submissions from EC 1 534
Number of original submissions from other areas 21

Table 8.3 below compares the Eastern Cape with KwaZulu-Natal in terms of submissions
containing tolling or non-tolling issues. Not surprisingly, based on the discussion of the way
submissions were made from KwaZulu-Natal above, the majority (97.6%) of original submissions
from KwaZulu-Natal contained issues related to tolling. The issue of tolling is the major concern
for respondents from KwaZulu-Natal and covers the potential negative impacts on business,
commuters, air quality, safety on alternative routes, etc. Only 13.8% of submissions from
KwaZulu-Natal contained issues that were not related to tolling.

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In the Eastern Cape the situation is the exact opposite with 97.1% of submissions raising non-toll
related issues and only 8.5% of submissions raising tolling issues. In the Eastern Cape,
particularly in the Greenfield sections, there is strong support for the project as there is currently
very poor access to these areas.

Table 8.3: Number of Tolling and Non-Tolling Issues on Original Submissions

Issues Relating to Tolling Non-Tolling Issues

All original submissions 3 541 (70.4%) 1 992 (39.6%)
Original submissions from KZN 3 389 (97.6%) 481 (13.8%)
Original submissions from EC 131 (8.5%) 1 490 (97.1%)
Original submissions from other areas 21 (100%) 21 (100%)

Table 8.4 below shows the number of submissions containing the different categories of issues.
In KwaZulu-Natal the main issue categories related to tolling, the economic impact of tolling and
the impact on alternative routes. In the Eastern Cape the main issues indicated support for the
project and the job opportunities that would arise during construction, while concerns were raised
around access across the proposed road for people and cattle, fencing and its maintenance, and
issues of relocation and compensation.

Table 8.4: Category of Issues Raised on Original Submissions

Category of Issue All Original Original Original

Submissions Submissions KZN Submissions EC
EIA Process / Legal 84 (1.7%) 84 (2.4%) 0
Public Participation 85 (1.7%) 63 (1.8%) 22 (1.4%)
Specialist Studies 149 (3.0%) 84 (2.4%) 65 (4.3%)
Planning and Policy 42 (0.8%) 42 (1.2%) 0
Need / Motivation for 1 456 (29%) 251 (7.2%) 1 205 (78.6%)
Project
Scope of Work / 281 (5.6%) 84 (2.4%) 197 (12.9%)
Construction
Traffic and 188 (3.8%) 188 (5.4%) 0
Transportation
Impacts on 671 (13.4%) 649 (18.7%) 22 (1.4%)
Alternative Routes
Tolling 3 224 (64.4%) 3 180 (91.6%) 44 (2.9%)
Economic 2 841 (56.7%) 2 008 (57.8%) 833 (54.3%)
Social 303 (6.1%) 84 (2.4%) 219 (14.3%)
Biophysical 42 (0.8%) 42 (1.2%) 0

Table 8.5 below shows the most commonly raised issues on original submissions. In KwaZulu-
Natal the most commonly raised issues were opposition to tolling on the KwaZulu-Natal Upper
South Coast (86.7%), affordability of tolling for the poor (39.2%), the impact on commuters
working in the South Durban Basin (27.1%), and the perceived cross subsidisation whereby the
people on the Upper South Coast feel they would be paying for the construction of the road in the
Eastern Cape (18.1%).

In the Eastern Cape the two main issues raised were that the project must go ahead (77.1%) and
that job opportunities during construction must be given to local people (47.1%).

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Table 8.5: Specific Major or Most Recurring Issues Raised on Original Submissions

Specific Major Issues All Original Original Original

Submissions Submissions KZN Submissions EC
The project is needed 1 413 (28.2%) 230 (6.6%) 1 183 (77.1%)
Cross subsidisation 628 (12.5%) 628 (18.1%) 0
Against tolling on KZN 3 013 (60.2%) 3 013 (86.7%) 0
Upper South Coast
Affordability for the poor 1 360 (27.2%) 1 360 (39.2%) 0
of KZN
Impact on commuters 941 (18.8%) 941 (27.1%) 0
on KZN Upper South
Coast
Job opportunities during 849 (17%) 126 (3.6%) 723 (47.1%)
construction

9. AUTHORITY CONSULTATION AND LIAISON

A meeting was held with DEAT: Environmental Impact Evaluation on 19 June 2008 to discuss the
compilation of the Draft EIR and timeframes for the submission of the Final EIR, as well as the
public participation process for the review of the Draft EIR.

Following the closure of the comment period for review of the Draft EIR a meeting was held with
DEAT: Environmental Impact Evaluation, DEAT: Biodiversity Planning and DWAF: Forestry
Technical and Information Services on 24 March 2009 to discuss the development of a
biodiversity offset agreement.

A follow-up meeting with DEAT: Environmental Impact Evaluation was held on 18 May 2009 to
discuss outstanding issues regarding the compilation of the Final EIR.

A meeting was also held with SAHRA on 10 November 2009 to discuss SAHRA’s submissions on
the HIA and Draft EIR.

A total of 64 copies of the Draft EIR were distributed for review to key stakeholders and
authorities which included local and district municipalities, relevant provincial and national
government departments and government agencies. Registered letters were sent to all these
authorities prior to the release of the Draft EIR informing them that they would soon be receiving
copies of the report for review, and the reports were accompanied by a letter requesting comment
on the report within the review period which extended from 10 November 2008 to 22 January
2009. A letter reminding all the authorities to submit their comments by 22 January was emailed
or faxed on 17 January 2009. A final request for comments on the Draft EIR was sent out to all
authorities who had not yet submitted comments on 9 June 2009 (for copies of the reminder
letters to the authorities see Volume 5).

10. I&AP DATABASE

The I&AP database is continually updated as the project progresses. Each time information is
sent out new information is sourced for e-mails or letters that are returned and the database is
updated with where such information if available, or the I&AP is coded as uncontactable if no
further details can be obtained. The database is also updated with new requests for I&APs to be
placed on the database or if written submissions are received and the person making the
submission is not already on the database. Following the Public Open Days during the comment
period for review of the Draft EIR all attendance registers were checked and any attendees not
already on the database were captured. All written submissions received during and after the

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comment period for review of the Draft EIR were also checked against the database and any new
I&APs were entered onto the database.

At the time of acceptance of the Final Scoping Report in May 2007 there were 10 139 I&APs on
the database who received notification of DEAT’s acceptance of the report and the Plan of Study
for EIA. All returned emails and post from this notification were then processed and all the
uncontactable entries were coded and removed from the database. At the start of November
2008 when notification of the availability of the Draft EIR was undertaken there were 9 538 I&APs
on the database.

Table 9.1 below shows the composition of the stakeholder databases at the time of submission of
the Final EIR in December 2009. The main stakeholder database contained 16 851 I&APs and
there were also 152 stakeholders on the key stakeholder database comprising ward councillors
and municipal managers from wards and municipalities along the route of the proposed project
and organs of state. There was therefore a total of 17 003 I&APs on the database at submission
of the Final EIR in December 2009.

Table 10.1: Composition of I&AP Database on Submission of Final EIR in November 2009

Other
EC KZN Provinces / Total
Countries
Email 72 273 29 374
Fax 4 2 6
Postal 4 948 7 708 217 12 873
By Hand 3 419 179 3 598
Registered Mail – Key Stakeholders 98 47 7 152
Total 8 541 8 209 253 17 003

11. NOTIFICATION OF THE AVAILABILITY OF THE FINAL ENVIRONMENTAL IMPACT REPORT

Once the Final EIR has been submitted to the National Department of Environmental Affairs
(formerly the Department of Environmental Affairs and Tourism) for decision making the report
will be made available at the same libraries and public venues used for the distribution of the
Draft EIR and it will also be made available on the websites www.ccaenvironmental.co.za and
www.nra.co.za for information purposes.

All I&APs on the project database (currently totalling 17 003) will be informed in writing of the
submission and availability of the Final EIR and will be sent a copy of the executive summary to
the report (see Volume 5 for a list of all I&APs). The availability of the Final EIR will also be
advertised in the same newspapers used to advertise the availability of the Draft EIR.

12. NOTIFICATION OF THE RECORD OF DECISION AND APPEAL PROCESS

Once the National Department of Environmental Affairs issues the Record of Decision (RoD) on
the application for environmental authorisation for the proposed N2 Wild Coast Toll Highway, all
I&APs on the project database will be informed in writing of the RoD and the statutory appeal
procedure.

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