OBJECTION TO THE PROPOSED LAMLOCH DEVELOPMENTPosted on the 12th April 2019
OBJECTION: THE PROPOSED DEVELOPMENT OF A GAME FARM WITH TOURIST FACILITIES AND ASSOCIATED INFRASTRUCTURE ON THE REMAINDER OF THE FARM LAMLOCH NO. 892, CALEDON DISTRICT (Pre-Application DEA&DP Reference: 16/3/3/6/7/1/E2/18/1343/15)
Doug Jeffery Environmental Consultants
Western Cape Province
12 April 2019
Dear Ms Groenewald,
Find herewith my objection to this proposed development. I do so as the member responsible for conservation at BirdLife Overberg and immediate past Chairman of that organisation, as well as the Western Cape Birding Forum and past Council member of BirdLife South Africa. I am further largely responsible for the marketing of the Western Cape Province as a top bird-watching destination. Note that we have received numerous letters of support for this objection – details of this could be forwarded to you if so required.
1. INTRODUCTORY COMMENTS
We have taken note of the continued debates about this issue in the media and studied a variety of draft objections that had been forwarded to us. These issues raise several moral (and often emotional) issues and include objections to the introduction of the elephants, concern about the Rooisand horses, concern about the lack of transparency on the erection of electrified fences through the watercourse, as well as questions concerning hydrological and botanical impacts and the like. We wish not to comment on these even though we support several of these objections in principle. This objection will only focus on the lack of meaningful Environmental Impact Assessments on birds, birding and birding tourism as it seems as if this had been disregarded in the planning and development of the proposed game farm.
Note further that we have not received appropriate information on the consequences and resulting implications concerning the approval of this development in contradiction to sections (2)(4) (f) and (o) of the National Environmental Act, 1998. This act requires that the public be adequately informed and be given the opportunity to propose ways of mitigating and/or reducing possible negative impacts through workshops, meetings and consultation. We are concerned about the lack of transparency witnessed in this regard.
|The Rooisand horses behind the fence - Image taken earlier by Carin Malan|
|The horses should be allowed to move freely between the Botriver Estuary and the Kleinmond Estuary without being impeded by the Lamloch fence through the watercourse. Image by Anton|
2. THE IMPORTANCE OF THE SITE FROM A BIRDING PERSPECTIVE
From a birding perspective this site forms part of at least three significant internationally accepted conservation measures, treaties and/ or conventions: 1. The Bot-Kleinmond estuarine system Phase 1 was declared as a wetland of global importance in terms of the Ramsar convention, 2. It forms part of the Cape Whale Coast Important Bird and Biodiversity Area (SA 118) accepted by BirdLife International and 3. It falls within the boundaries of the Kogelberg Biosphere Reserve. Brief details of these are provided:
In 2017 the Bot-Kleinmond estuarine system Phase 1 was declared a wetland of global importance in terms of the Ramsar convention. We are proud of the fact that it is South Africa’s 23rd Ramsar site – it is important as a fish nursery, it is world-renowned for its water birds and migratory waders and plays an important role as a buffer zone of the Kogelberg biosphere. Phase 2 of the Ramsar application is still to be compiled and we need to question how the electrified fence will impact on the current Ramsar status, and how this was allowed in the first place. Whether this will negatively influence the ability of the authorities to achieve success with the Phase 2 application remains to be seen.
2.2 THE CAPE WHALE COAST BIRD AND BIODIVERSITY AREA (IBA SA118)
The comprehensively compiled overview of the significance of this IBA taken from the Important Bird and Biodiversity Directory published by BirdLife South Africa can be studied at this link:
Note that I was responsible for the initial application to BirdLife International to have this area declared as an IBA.
|Blue Cranes seen from the Rooisand hide - Image by Anton|
2.3 KOGELBERG BIOSPHERE RESERVE
The detailed description of the birds found in the Kogelberg Biosphere Reserve by the late Rob Martin and Jessie Walton is at this link:
REVIEW OF APPLICABLE INFORMATION ON BIRDS FOUND IN THE IBA THAT INCLUDES THE LAMLOCH SITE
3. SPECIES REGARDED AS IMPORTANT BIRD AND BIODIVERSITY AREA (IBA) TRIGGER SPECIES FOUND IN THE CAPE WHALE COAST IBA (SA 118).
These lists are included to indicate the significance and importance from a conservation perspective of so many species found in the area.
3.1 Globally threatened species are Bank Cormorant, Cape Cormorant, Crowned Cormorant, Cape Gannet, African Black Oystercatcher and African Penguin.
3.2 Regionally threatened species are Greater Flamingo, African Marsh Harrier, Great White Pelican and Caspian Tern.
3.3 Restricted-range and biome-restricted species that are common in the IBA include Cape Bulbul, Cape Spurfowl, Cape Sugarbird and Orange-breasted Sunbird, amongst others.
3.4 Species that meet the 1% or more congregatory population threshold are White-breasted Cormorant, Red-knobbed Coot, Yellow-billed Duck, Greater Flamingo, Black-necked Grebe, Great Crested Grebe, Hartlaub's Gull, Kelp Gull, Great White Pelican, Cape Shoveler, Caspian Tern, Sandwich Tern and Swift Tern.
3.5 Species that meet the 0.5% congregatory threshold are White-backed Duck, Southern Pochard, White-fronted Plover and Black-winged Stilt.
|Crowned & Cape Cormorants - Image by Carin Malan|
|White Pelicans - Image by Charles Naude|
4. AS FAR AS BIRDING TOURISM IS CONCERNED THE FOLLOWING SPECIES ARE ON RECORD IN THE TWO APPLICABLE PENTADS FROM THE SOUTH AFRICAN BIRD ATLAS PROJECT 2 (SABAP2) AND THE KOGELBERG BIOSPHERE RESERVE
The following lists have been compiled based on the records of the two pentads in question of the South African Bird Atlas Project (SABAP2) and the Kogelberg Biosphere Reserve list published by the late Rob Martin and Jessie Walton. The two pentads in question are 3420_1905 (Rooisand side) and 3420_1900 (Kleinmond side). Note should be taken of the fact that many domestic and international bird-watchers regularly visit the IBA in general and the Rooisand Nature Reserve in particular to view and photograph the many spectacular bird species found in the area. The endemic species specifically play a significant role in this regard.
4.1 The region supports all seven bird species that are endemic to Fynbos habitats: Hottentot Buttonquail, Cape Rock-jumper, Protea Seedeater, Cape Siskin, Cape Sugarbird, Orange-breasted Sunbird and Victorin’s Warbler. Two of these, the Cape Sugarbird and the Protea Seedeater (the latter found higher in the mountains) require mature fynbos for breeding, and have greatly declined in numbers in recent years possibly as a result of the veld being too frequently burnt and unsustainable tourism developments.
4.2 Along the coast the following endemic or near-endemic species associated with the Benguela current are on record: Bank Cormorant, Cape Cormorant, Crowned Cormorant, Cape Gannet, Hartlaub's Gull, Kelp Gull, African Black Oystercatcher and African Penguin.
These fifteen species form the backbone of marketing efforts to attract domestic and international bird-watchers to this region.
|Orange-breasted Sunbird - Image by Anton|
|Denham's Bustard on nest on the Lamloch property - Image by Carin Malan|
4.3 Other endemic species that are hugely sought-after by international birders are: Bokmakierie, Southern Boubou, Blue Crane, Cape Grassbird, Black Harrier, Cape Clapper Lark and Southern Tchagra.
Note should be taken of the fact that at least a further 23 endemic species are on record in the two pentads. The Denham’s Bustard is not endemic but remains very popular with visiting birders – there are records of them breeding on the Lamloch property.
4.4 The reed-beds along the fringes and the swamps of the estuaries often support an interesting array of birds such as Little Bittern, Baillon’s Crake, Black Crake, Purple Heron, African Marsh-Harrier, Greater Painted-Snipe, African Rail, African Reed-Warbler, Little Rush-Warbler, African Snipe, African Purple Swamphen and Lesser Swamp-Warbler. A fascinating aspect of the bird-life is the presence of three species of flufftails: Red-chested, Buff-spotted and Striped. They all frequent dense, almost impenetrable, vegetation and seldom venture into the open thus making their status difficult to assess. Having studied images taken of the fence on 11 April 2019 we realized that the stretches of vegetation cut open along the fence could make it difficult for these flufftails, and possibly other species, to move freely through these open spaces. This issue needs to be studied in-depth in the avian impact assessment study insisted on later.
4.5 The mud-flats of the estuaries attract migratory waders including Bar-tailed Godwit, Common Greenshank, Terek Sandpiper and Common Whimbrel. The area is world renowned for its summer migrants.
4.6 The open water sometimes holds Pied Avocet, Great Egret, Yellow-billed Egret, Black-necked Grebe, Great Crested Grebe, Great White Pelican, Greater Flamingo, Lesser Flamingo, African Spoonbill, White-backed Duck and Hottentot- and Red-billed Teals amongst many others.
4.7 Sought-after bird of prey: Booted Eagle, Lanner Falcon, Peregrine Falcon, African Marsh Harrier, Fiery-necked Nightjar, Western Osprey, Secretarybird and Black- and Rufous-chested Sparrowhawks.
4.8 Rare and vagrant species recorded in the area in the past that have often attracted huge numbers of birders: Blue-cheeked Bee-eater, Common Cuckoo, Eurasian Curlew, Goliath Heron, Brown-backed Honeybird, Lesser Black-backed Gull, Goliath Heron, European Honey-Buzzard, Sand Martin, African Openbill, Eurasian Golden Oriole, Western Osprey, Eurasian Oystercatcher, Little Ringed Plover, Common Swift, White Wagtail, Yellow Wagtail and Sedge Warbler. Those difficult to find warblers such as Garden Warbler, Icterine Warbler, Marsh Warbler and Willow Warbler have also been recorded.
Note should also be taken of historical breeding records of Horus Swift in the area, as well as a road kill of an African Wood Owl along the R44.
|Eurasian Curlew - Image by Carin Malan|
|Western Osprey - Image by Carin Malan|
The significance of these sightings is aptly illustrated with the recording of a Western Osprey, photographed by Carin Malan of BirdLife Overberg on the Lamloch Safari Park fence on 30 April 2017. This bird was previously recorded at Onezhskoe Lake in the Vologda region of Russia on 11 July 2015 – 10,593 km away!
5. THE BIRDING TOURISM PERSPECTIVE
Most the species mentioned play a significant role in the marketing of the Western Cape Province as a top bird-watching destination and many of these are of critical conservation significance. This is illustrated in the Cape Whale Coast birdfinder web pages that can be studied at this link:
6. CONCLUDING COMMENTS AND RECOMMENDATIONS
The potential detrimental effects that the proposed development might have on avian biodiversity had been neglected and essentially ignored in the application documents studied. This applies particularly to the erection of the electrified fence across the watercourse that connects the Bot River Estuary with the Kleinmond Estuary. Our partners at Whale Coast Conservation (WCC) argue that this is defined in the Integrated Coastal Management Act as “Coastal Public Property” and that it should not be fenced. The possible impacts of the tourist accommodation camp built on stilts over the water, and other infrastructure developments, as well as the impact of the elephants on avian biodiversity had also been ignored in this application. For these reasons the following recommendations are made:
A comprehensive avian impact assessment study on the proposed development needs to be undertaken by an independent and suitably qualified team of ornithological and birding tourism experts. Such a study should at least focus on the potential negative impacts mentioned, as well as avian conservation and birding tourism issues. The contribution that the proposed developers could make towards the protection of avian biodiversity, birding tourism and environmental education should also not be neglected.
We will object to and oppose this proposed development until such time as the issues raised herewith are addressed meaningfully.
Note that this objection, together with illustrating images will be posted on www.westerncapebirding.co.za
Dr Anton Odendal
Postal address: Box 256, Onrusrivier 7201
Mobile: 082 550 3347