PETITION AGAINST PROPOSED CLOSURE OF STREET, REZONING, CONSOLIDATION, SUBDIVISION, CONSENT USE AND DEPARTURE: ERVEN 21028 AND 21029, GEORGE AND PORTION OF LOCH LOMONDRY AVENUE, GEORGE, 6529
This petition creates an opportunity for concerned residents to express their views regarding the proposed high-density affordable housing development on erven 21028 and 21029 in King George Park, situated in Loch Lomondry Avenue between the King George Hotel and Die Bult Secondary School, and to make their concerns known to George Municipality.
- Printouts of the online petition's responses will be submitted to George Municipality on 5 December 2018.- Please complete the petition online by Tuesday, 4 December 2018.- This online petition is not affiliated with any political party.- Comments, questions or suggestions regarding this petition can be sent to email@example.com
The two erven in King George Park are situated in Loch Lomondry Avenue between the King George Hotel and Die Bult Secondary School.
According to the Memorandum (henceforth the 'Memorandum') that the Town and Regional Planners submitted to the Municipality (dated 30 August 2018):
"The proposed development aims at providing housing opportunities for the market between R425 000 and R445 000 for the town housing units. The development is therefore aimed at providing affordable housing also for the lower income group."
An application has been submitted to the Municipality to consolidate the two erven and rezone the consolidated erf to a subdivisional area "to be used as single residential (99 erven), town housing (86 erven), 3 business erven, a cell phone mast erf, a crèche, 11 public open space erven, public streets and parking."
The Memorandum also requested a "departure from the parking requirements for the town housing component of the development from the current 2 parking bays per unit plus 0.25 per unit for visitors to 1 parking bay per unit plus 0.25 per unit for visitors. In effect the departure would imply a reduction in the number of parking bays for the town housing component from 194 bays to 108 bays."
Lastly, the Memorandum requested "consent use to permit a cell phone mast on one of the proposed erven (proposed erf no 190)."
In terms of the deeds of transfer, Erf 21028 is 32 523 m², Erf 21029 is 8 577 m² and the relevant portion of Loch Lomondry Avenue is 4111 m². Total area of the application site is 45 211 m².
Despite the traffic congestion that this development will cause at nearby intersections, neither Power Group nor the Municipality is willing build any new roads. Furthermore, they have omitted the highly problematic intersection at Plattner Boulevard and York Street from the Traffic Impact Assessment (TIA) report entirely.
A similar and even larger development called 'Rooirivier Development' is also being planned. More details about both developments are provided below.
The 'Die Bult' (Highlands) area where this proposed development will be built is currently zoned General Residential Zone II (Group Housing), i.e. it allows for 35 units per hectare, whereas Loch Lomondry Avenue is zoned Transport Zone II. For the town housing component of the development, George Municipality intends to change this to 59 erven per hectare, resulting in high density town houses with an average unit size of 68m², i.e. the size of a double garage. The average density of the development for the total property will be 41 units per ha.
(It remains to be seen whether anyone would be willing to pay between R425 000 and R445 000 for a town house that is the size of a double garage.)
The height restriction of buildings is 6,5 m to the wall plate and 8,5 m to the pitch of the roof. The building lines applicable to the zoning are 5 m for the street boundary and 3 m in respect of the boundaries along the perimeter of the group housing site.
Street boundary walls will apparently be "low to create a friendly and welcoming feel in the streets with softer edges rather than solid high walls."
A total of ±188 units will be developed behind King George Hotel.
Other points mentioned in the Memorandum that the City and Town Planner submitted to George Municipality include:
WATER SUPPLY SYSTEM:
"Water reticulation exists within the adjacent neighborhoods to which the proposed development will connect. No upgrades to the water reticulation system is required to accommodate this development within the existing water distribution system."
"A normal gravity wastewater reticulation system exists in the adjacent neighborhood [referring to Dormehls Drift on the other side of the Camfersdrift River] to which the proposed development will drain. No upgrades to the existing bulk and sewage reticulation system is envisaged to accommodate this development."
"No bulk stormwater systems are required as the stormwater will be dispersed via several outlets into the existing stream situated towards the Eastern side of the proposed development."
In short, no upgrades will be made to the water supply system, the sewage system, or the stormwater system.
"Access to the proposed development will be provided via the existing circle south of the site. The circle can be accessed from the north via Loch Lomondry Avenue and from the south via King George Drive. This circle will be upgraded to allow waste disposal vehicles to access the development.
According to the developer, access to the property will therefore essentially remain unchanged, with almost no upgrades.
See the '3. TRAFFIC & ACCESS' section below for more details.
"In terms of the current parking requirement of the Integrated Zoning Scheme By-Law, namely 1 parking bay per single residential unit and 2 parking bays per town housing unit plus 0.25 bay per town housing unit for visitors, plus further requirements for business erven and the crèche, a total of 308 parking bays must be provided for this development."
However, according to the Memorandum:
"Application is made to depart from this requirement in respect of the town housing component... which in effect means that a total of 222 parking bays need to be provided for this development."
To have ±185 families (potentially 284 families if approved as submitted) in an area with only 222 parking bays will most likely lead to the use of the open space square as parking area. This will defeat the aim of this central open space. Approximately 185 families will have visitors that must also be accommodated. Defacing the open space square will have a negative impact on this development which will lead to further decay. Therefore, we are of the opinion that a minimum of 1.5 parking bays per dwelling must be provided, i.e. at least 278 parking bays. If the zoning remains as submitted, 2 bays per single residential dwelling unit must be provided on every property zoned as such and the Traffic Impact Assessment (TIA) needs to be amended accordingly.
This development isn't the main focus of this petition, although most concerns raised in this petition may also be applicable to the Rooirivier Development. As far as we know, the Municipality has not yet granted formal approval for this project.
1. Plattner Boulevard to York Street, and2. CJ Langenhoven street from Barkhuizen Drive via King George Hotel (Loch Lomondry Ave behind Rugby Stadium)
The current Traffic Impact Assessment for Village Ridge Estate will, at best, ONLY upgrade the following:
1. The Loch Lomondry Avenue/CJ Langenhoven Road intersection will be upgraded to a signalised intersection (with a slip lane).2. The Plattner Boulevard/Barkhuizen Drive intersection will be upgraded to a roundabout. Importantly, nothing is being planned to address the traffic congestion currently experienced at the Plattner Boulevard intersection with York Street, a key access route to the Checkers shopping center, Pizza Hut & Caltex, and a connection to the George CBD and George Airport.
Page 12 of the Traffic Impact Assessment (Revision 1, dated 7 August 2018) completed by Aurecom states the following:
"The TMH 17 [The South African Traffic Impact and Site Traffic Assessment Manual (TMH 17, Volume 1, 2013)] recommends a growth rate between 0% and 3% for low growth areas and a growth rate of 3-4% for average growth areas. An annual traffic growth rate of less than 0.5% has been observed along CJ Langenhoven Road between 2005 and 2018. For this reason, it was decided that a growth rate of 3% would be too high and overly conservative. There could be multiple reasons for the low growth rate: existing congestion levels during peak periods, the introduction of the Go George bus service, etc. Taking into consideration the historic growth rate, the surrounding area and the economic climate of George, an annual growth rate of 1.5% is considered to be more realistic."
It seems likely that Aurecom decided to include (one might argue, largely irrelevant) data from many years ago, as far back as 2005 (when annual traffic growth rates were undoubtedly much lower) in order to arrive at the very low and totally unrealistic average annual growth rate of 1.5%. They therefore underestimate the adverse impact that these developments would have on traffic in these areas. Residents living in the affected areas know full well that the annual increase in traffic far exceeds 1.5% per annum, especially during the last 3-5 years which witnessed a dramatic increase in the number of families who decided to migrate to George.
This petition is primarily to express public opinion regarding the proposed Village Ridge Estate, and secondly, to start assessing the public's sentiment's regarding the proposed Rooirivier Development. The public's concerns about traffic congestion is but one of many valid concerns raised by numerous residents.
Desirability of a land use application includes the following factors: the physical characteristics of the property, existing planning in the area, character of the area, the locality and accessibility of the property as well as the provision of services. Other important considerations are the economic or financial impact and the direct impact on surrounding properties.
Accessibility to the development area is not at an acceptable standard. The civil engineers for the development acknowledge that the traffic improvements proposed (e.g. traffic lights at CJ Langenhoven / Loch Lomond intersection is not a permanent solution. Access to the west through Victoria Street and / or Marthinus Street to reach York Street is therefore a critical requirement for the implementation of the proposed development. We cannot accept the proposed development if this linkage to the west is not implemented simultaneously.
A link to the west via e.g. Palgrave Street will also be critical to ensure sensible traffic flow in the area west of the CBD of George, if the proposed development of a portion of Erf 9354, George (Rooirivier Rif) is to commence. This development proposal for Erven 21028 and 21029, George cannot be considered in isolation – as the traffic study considers a much wider area, in the same way all other planning considerations must also consider a much wider area.
Comments provided in the pre-application consultation document state that the Victoria Street extension is not on the masterplan and that it was agreed that a Traffic Impact Assessment (TIA) must be submitted in respect of traffic and parking. Just because a link or road is not indicated on the Roads Masterplan does not mean it should not be provided. The planning for the George municipal area has indicated the possibility of creating access to Victoria Street for decades. The development of Erven 21028 and 21029, George cannot be supported without a direct link towards the east to York Street.
A link to west over the Camfersdrift River must be implemented simultaneously. It is an important municipal engineering service that cannot be ignored as determined by Section 42 of the Spatial Planning and Land Use Management Act (SPLUMA, 2013).
If the requirements mentioned in this petition are not addressed, the development will most likely have an adverse economic and financial impact on this area west of the CBD. This will then negatively impact on property values, which will in turn reduce the income of the Municipality in terms of rates and taxes. Should the proposed development of Erven 21028 and 21029 materialise, George Municipality's responsibilities in the area regarding the provision of services and maintenance will increase, which must be justified through rates and taxes.
Erven 21028 & 21029, George are zoned General Residential Zone II, i.e. group housing. The developer's proposal is to develop 99 single residential erven (Single Residential Zone I) and 86 town housing erven (General Residential Zone III). This gives a total of 185 dwelling units with a density of 41 dwelling units per hectare. The development area is 4.5211ha. If the two properties are to be developed in accordance with the present zoning at a density of 35 dwelling units per hectare as the zoning allows, Erf 21028 can accommodate ±114 group housing units and Erf 21029 ±30 group housing units.
Providing 99 erven zoned Single Residential Zone I gives each of these properties the primary land use right of a second dwelling unit, only building plans to indicate a change in use and services contributions will be required. This will increase the proposed 185 dwelling units in this development to 284 dwelling units. It seems that this was not assessed at all in the engineering report. No condition of approval will suffice to address this matter.
The 99 erven should not be zoned Single Residential Zone I. The zoning can remain General Residential Zone II – group housing. The number of units remain the same and the total density of 41 dwelling units per hectare.
It was stated in the pre-application consultation document that the proposed erf sizes are not in accordance with GAP/FLISP ('Finance Linked Individual Subsidy Programme') standards. We couldn’t find any detail on how this proposed development fits into the housing market and what the requirements/standards are for GAP/FLISP housing. Even if FLISP housing subsidies will be an option to a new home owner, it is concerning that if the home owner sells the property within eight years of benefiting from FLISP, there is a condition that the portion of the government subsidy is to be refunded by the seller. In addition, the seller needs to give government first preference to purchase the property or get approval from the department of human settlements to sell the house. We are not in favour of the possibility that future owners might be forced to sell back their properties to the government.
The pre-application consultation document also states that the proposal does not support the character of the area and that the social gradient is not addressed. To have single residential erven of between ±700m² and ±950m² bordering directly onto single residential erven of approximately 187m² does not make sense. This is also why no Single Residential Zone I erven should be allowed in this proposed development. On average 4 of the proposed single residential erven fits into one of the established single residential erven. If the properties are to be developed in accordance with its current zoning, the average erf size would be 285m². It would therefore have been more acceptable if the erven bordering onto the existing established erven was 285m² in extent or greater.
The National Environmental Management Act No. 107 of 1998 (NEMA for short) specifies several points that need to be adhered to prior to an Environmental Authorisation being granted:
Section 41 that deals with the Public Participation Process (during the EIA process). According to NEMA:
41. (2) The person conducting a public participation process must take into account any relevant guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of an application or proposed application which is subjected to public participation by -
(b) giving written notice, in any of the manners provided for in section 47D of the Act to -
(ii) owners, persons in control of, and occupiers of land adjacent to the site where the activity is or is to be undertaken [or] and to any alternative site where the activity is to be undertaken.
(6) When complying with this regulation, the person conducting the public participation process must ensure that -
(b) participation by potential or registered interested and affected parties is facilitated in such a manner that all potential or registered interested and affected parties are provided with a reasonable opportunity to comment on the application or proposed application.
Furthermore, as per the Water Act (Act 36 of 1998), the developer will also require a Water Use License for bridges as per regulation 21:(c) impeding or diverting the flow of water in a watercourse(i) altering the beds, banks, course or characteristics of a watercourse.
The above will be applicable for bridges, so the developer would need to ensure that they have a water use license in place.
Furthermore, because the development is within 500 meters of a wetland they would have needed to have:
1. A freshwater assessment completed2. A risk assessment completed
This will determine whether the applicant would need to apply for a GA, i.e. General Authorisation (water use), or if they would need to apply for a water use license.
To be fair to all surrounding property owners whose property values will be adversely affected by such developments, George Municipality should decrease these owners' property valuations, and as a consequence, also be satisfied with reduced property tax revenues should the Municipality decide to continue with one or more of the developments.
Studies at Stanford University have shown that new affordable housing projects in poorer neighbourhoods increased surrounding home prices and reduced crime, while new affordable housing projects in wealthier neighbourhoods drove down home prices. (Surely both existing and new home owners would presumably want to know that the values of their existing and new homes will appreciate, not depreciate, in value.)
For more details, see 'Who Wants Affordable Housing in their Backyard? An Equilibrium Analysis of Low Income Property Development' by Rebecca Diamond and Timothy James McQuade (July 2015 Working Paper No. 3329, Economics, Stanford University - http://bit.ly/affordablehousingresearch).
2. By participating in this petition, you grant permission for your responses to be submitted to George Municipality and/or Power Group (the developer).
3. All personally identifiable information will first be removed if the petition's results are ever made public. In the latter case, it will not be possible to trace back the responses to the respondent. Additionally, your responses will be combined with those of many others and summarised in a report to further protect your anonymity.