This CAI paper compares the pros and cons of the newly approved construction of the N2 Wild Coast toll road, in South Africa’s Eastern Cape Province, and provides a discussion of its complications and implications. It has been suggested by a number of activists and environmental practitioners that the approval of the toll road has been dubious, with a dishonest and illegitimate Environmental Impact Report (EIR) process. Many of the problems with the initial EIR (commissioned in 2003), that have been exposed and discussed by appeals and public participants, have not been addressed in the more recent EIR (2008). Examples of these issues include the lack of significant alternatives to the proposed road, the lack of importance of the biologically diverse Pondoland Centre of Endemism (PCE) in the final decision, and proper consideration of the environmental impacts and formulation of appropriate mitigation measures.

The paper will discuss the social and ecological impacts of the construction of a major highway, the N2, through the Eastern Cape’s Wild Coast, and the controversy surrounding the environmental management issues relating to the approval of this project.

The proposed N2 Wild Coast toll road in facts and figures

The proposed coastal route of the 550 kilometre long N2 highway⁽²⁾ was recently approved after a decade of deliberations by the South African Government and public.⁽³⁾ This approval was given after the Record of Decision (ROD) for the Environmental Impact Assessment (EIA) for the new section of the N2 toll road was ‘overturned on the grounds of lack of independence of the environmental consultants’⁽⁴⁾ in 2004. The EIA process is governed by the National Environmental Management Act (NEMA) of 1998 and states that an EIA should report on the environmental impacts and mitigation measures for any proposed developments. The new route, which will run through the Wild Coast, was presented at the International Transport Investor Conference held in Cape Town in June 2011⁽⁵⁾. The project consists of an upgrade of the old N2 route from Durban to East London, with a new section which detours from Mthatha towards Port St. Johns on the R61. However, it redirects before the town of Port St. Johns which is expected to provide easier access to coastal areas.⁽⁶⁾ One of the aims of this project is to develop the Wild Coast’s tourism potential.⁽⁷⁾

The entire project is expected to cost in the order of ZAR 8 -10 billion⁽⁸⁾ (US$ 1.1 – 1.4 billion). It is anticipated that with this new route, the distance between East London and Durban will be shortened by 75km,⁽⁹⁾ assisted by the addition of nine new bridges.⁽¹⁰⁾ The project has been welcomed by Edna Molewa, the African National Congress’ (ANC’s) Minister of Water and Environmental Affairs, despite years of opposition from environmentalists, Non-Governmental Organisations (NGOs), local communities, and the KwaZulu-Natal Provincial Government.^(11)(12)

The pros and cons – gauging opportunity costs

The Wild Coast has historically been secluded from major developments and associated job creation. Subsequently, the area has been beleaguered by poverty and a lack of infrastructure,⁽¹³⁾ resulting in the area being one of the poorest in the Eastern Cape.⁽¹⁴⁾ The pervasive poverty and related problems facing the Wild Coast were the main factors driving the approval of the construction of the N2 highway, as one of the Government’s priority projects.⁽¹⁵⁾

The Wild Coast has great potential for economic development in the form of rural development initiatives and tourism-based approaches.⁽¹⁶⁾ The creation of this new road will increase accessibility to the area and thus increase job creation and improve livelihoods.⁽¹⁷⁾ It will also serve to increase connectivity and logistics between the Eastern Cape and KwaZulu-Natal regions.⁽¹⁸⁾ Moreover, the many coastal reserves, whose aims are to educate people and to conserve the natural environment, and serve as tourist attractions, will become more accessible.⁽¹⁹⁾ Overall, on the positive side, it is anticipated that the new N2 road will greatly benefit the surrounding communities in terms of job creation, infrastructure development and accessibility, which facilitates tourism and related economic opportunities.⁽²⁰⁾

However, the construction of the proposed new road is not without problems. A convenient detour that the toll road will take is expected to facilitate the proposed titanium mining enterprise in Pondoland,⁽²¹⁾ although the EIR failed to mention this as an important factor.⁽²²⁾ If the N2 road is constructed, it may likely lead to the commissioning of the titanium mining operation, or increased support for it. As such, the possibility of the setting-up of the mine could be seen as a considerable secondary impact of the construction of the new N2 toll road.

The Pondoland region is very valuable in terms of its biological diversity and endemism, and is also known around the world as the Pondoland Centre of Endemism (PCE).⁽²³⁾ Construction of the road will continue regardless of the fact that NEMA states that, ‘the State must respect, protect, promote and fulfil the social, economic and environmental rights of everyone’. The proposed mining ventures have been heavily opposed by the local communities and by tribal leaders in the area who have stated that they will continue to oppose this development.⁽²⁴⁾ If this mining project is implemented, there may be major displacement and relocation of local people with subsequent changes in social life, cultures and ancestral graves, not to mention the significant environmental impact.⁽²⁵⁾

One section of the proposed toll road will pass through mountainous areas with numerous ravines and, to accommodate this terrain, the construction of a further nine bridges has been proposed.^(26)(27) These bridges, as well as the rest of the new and upgraded roads, will be exceptionally expensive. To alleviate the costs to the Government, six toll gates have been proposed which will greatly increase the costs for road users, including vacationers and long-distance goods deliverers.^(28)(29) Durban’s daily commuters will also be affected by the tolls, with obvious implications.⁽³⁰⁾ There are also concerns about the tolls being used for profit by private companies.⁽³¹⁾

A further negative factor of the project is the inevitable loss of natural environment. The area proposed for construction has important biological diversity and the Wildlife and Environmental Society of South Africa (WESSA) have accused Molewa of not recognising or considering these highly relevant facts.⁽³²⁾ The road will pass through the pristine PCE, renowned for its aesthetic appeal and natural resources with, among others, secluded beaches, indigenous forests, and waterfalls.⁽³³⁾ The disregard for the social, economic and ecological value of pristine environments is not acceptable, especially in this situation where it appears very little precaution or mitigation measures have been considered. Maybe the whole appeal of these secluded areas is just that, their private and isolated nature, and the introduction of a major road network will surely decrease the aesthetic value of these pristine areas.

Environmental issues attached to the creation of roads, especially in pristine habitats, are extensive. As mentioned, the proposed N2 will pass through sections of the proposed Pondoland National Park.⁽³⁴⁾ An important issue here is habitat fragmentation. Many animals that are preyed on avoid open areas due to the increased chance of predation. The road construction will result in the division of habitat of certain populations because they are unwilling to cross roads.^(35)(36) However, there are some species that are attracted to roads or their adjacent vegetation. Snakes tend to gravitate towards roads in order to bask on the warm tar, while herbivores are attracted to feeding on the dense vegetation on roadsides. The dangers the road poses may lead to an increase in the mortality of such species.⁽³⁷⁾ Cumulative or secondary effects on animal populations are less obvious and may be present in the form of habitat destruction due to erosion or reduced river flow resulting in siltation, which in turn is caused by the construction of poorly planned bridges with enormous ecological implications. The Mzimvubu, the largest undeveloped estuary in South Africa,⁽³⁸⁾ will require the construction of a bridge if the proposed road is constructed. Mitigation of the above-discussed environmental issues, among others, did not receive adequate attention in the EIR.⁽³⁹⁾

As mentioned, the mountainous landscape of the area in which the N2 will pass will require the construction of nine new bridges.⁽⁴⁰⁾ Besides these bridges and roads being very expensive, they may also alter the water runoff patterns and cause large-scale erosion if proper preventative measures are not taken. This factor coupled with the simultaneous destruction of natural habitat to make way for the road, may create excessive erosion with subsequent negative effects on the environment and degradation of the land.⁽⁴¹⁾ For example, erosion may lead to storm water flow into water sources. Often, runoff from roads contains many unwanted pollutants such as heavy metals and by-products of combustion from motor vehicles, which will enter estuaries, rivers (with a possibility of contaminating groundwater), and eventually oceans, where marine and coastal ecosystems will be adversely affected.⁽⁴²⁾ Furthermore, estuaries along the Wild Coast are famous for their botanical diversity and importance. Previous bridge constructions suggest that bridges may restrict water flow and result in siltation, which has major implications for water flow regimes and subsequently for aquatic and marine organisms.⁽⁴³⁾

Controversy and complications

Molewa accepted the proposal to build the toll road in after dismissing 50 legal appeals against it.⁽⁴⁴⁾ According to Val Payn of the organisation Sustaining the Wild Coast (SWC), the EIA for the proposed road is flawed and the main objective of the construction of the road is for intercity linkages and not for the development of local communities.⁽⁴⁵⁾ Payn suggests that the EIA process for the new proposed N2 toll road has barely changed since its last overturned EIA in 2003. According to Payn, the main issues with the EIA is that it has double standards, does not take into account secondary or cumulative negative effects, although it mentions the secondary positive effects, has incompetent mitigation options and lacks adequate future policing in this regard, and it criticises the integrity of public participation in the process. Another important consideration is the biological significance of the Pondoland area, which is world-renowned for its endemism and diversity.⁽⁴⁶⁾ Payn postulates that this area simply cannot be developed because of its biological importance and thus, there can be no justification as to why the road should be built through it.⁽⁴⁷⁾ Therefore the proposed EIA did not conform to the National Environmental Management Act 107 0f 1998.⁽⁴⁸⁾

Lawyers and groups representing the communities that will be affected by the upgrade and construction of the new N2 suggest that Molewa approved this project without consulting the affected communities.⁽⁴⁹⁾ Cormac Cullinan, a lawyer representing the host community has said, “We are shocked by the decision, but not really surprised. Considering the political support this project had, it was just a matter of time before the road was approved.”⁽⁵⁰⁾ The ANC is not cooperating and resolving issues at hand and have suggested that environmental groups change their views on the project without offering alternatives,⁽⁵¹⁾ however, the rural communities are not backing down and will continue to fight this project.⁽⁵²⁾

Conclusion

Considering the discussion above, and the fact that the negative impacts outweigh the positive aspects of this project, a general conclusion at this point is that the planned construction of the N2 Wild Coast toll road is negative. The reasons for this include the argument that despite the fact that the process in which the EIR was undertaken was fundamentally flawed, it was still accepted by the Minister of Water and Environmental Affairs. Moreover, there appears to be an ulterior motive for the construction of this road, possibly in terms of profit from road-use tolls, or facilitating the much opposed titanium mining operation in the Pondoland area. The area proposed for the new road is valuable in terms of its pristine environments, high biological diversity and endemism, indigenous and social aspects, and cultural heritage. The implications for this area, if the correct mitigation measures are not taken, may be devastating. Although integrated environmental planning is considered a very effective method for planning, it will never yield positive results unless the process is performed honestly and precisely.

NOTES:

(1)Contact Wayne Brazier through Consultancy Africa Intelligence’s Enviro Africa Unit (enviro.africa@consultancyafrica.com).
(2)Mawande Jack, ‘Toll road opposed’, The New Age, 5 Aug 2011, http://www.thenewage.co.za.
(3)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(4)Val Payn, ‘Sustaining the Wild Coast: EIR commentary. N2 Wild Coast toll road proposal’, Sustaining the Wild Coast (SWC), 23 January 2009, http://swc.org.za.
(5)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(6)Fuad Fredericks, ‘Draft environmental impact report: Proposed N2 Wild Coast N2 highway’, October 2008, http://www.ccaenvironmental.co.za.
(7)Mawande Jack, ‘Toll road opposed’, The New Age, 5 Aug 2011, http://www.thenewage.co.za.
(8)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(9) Fuad Fredericks, ‘Draft environmental impact report: Proposed N2 Wild Coast N2 highway’, October 2008, http://www.ccaenvironmental.co.za.
(10)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(11)‘Wild coast will be costly’, IOL Business Report, 28 July 2011, http://www.iol.co.za.
(12)Hilary Venables, ‘Reports of Wild Coast toll road approval “abuse public trust”’, Wild Coast, 30 June 2009, http://www.wildcoast.co.za.
(13)‘ANC welcomes N2 toll road approval’, IOL Business Report, 1 August 2011, http://www.iol.co.za.
(14)Mawande Jack, ‘Toll road opposed’, The New Age, 5 August 2011, http://www.thenewage.co.za.
(15)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(16)Mawande Jack, ‘Toll road opposed’, The New Age, 5 Aug 2011, http://www.thenewage.co.za.
(17)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(18)Ibid.
(19)Ibid.
(20)Mawande Jack, ‘Toll road opposed’, The New Age, 5 August 2011, http://www.thenewage.co.za.
(21)Ibid.
(22)Val Payn, ‘Sustaining the Wild Coast: EIR commentary. N2 Wild Coast toll road proposal’, Sustaining the Wild Coast (SWC), 23 January 2009, http://swc.org.za.
(23)Fuad Fredericks, ‘Draft environmental impact report: Proposed N2 Wild Coast Toll highway’, October 2008, http://www.ccaenvironmental.co.za.
(24)Mawande Jack, ‘Toll road opposed’, The New Age, 5 August 2011, http://www.thenewage.co.za.
(25)Ibid.
(26)Eastern Cape Department of Transport, ‘South Africa: New roads for the Eastern Cape’, AllAfrica, 1 August 2011, http://allafrica.com.
(27)‘Wild Coast will be costly’, IOL Business Report, 28 July 2011, http://www.iol.co.za.
(28)Ibid.
(29)The Mercury, ‘Wild Coast toll road given OK’, IOL Property, 27 July 2011, http://www.iolproperty.co.za.
(30)Ibid.
(31)Val Payn, ‘Sustaining the Wild Coast: EIR commentary. N2 Wild Coast toll road proposal’, Sustaining the Wild Coast (SWC), 23 January 2009, http://swc.org.za.
(32)‘Wild Coast will be costly’, IOL Business Report, 28 July 2011, http://www.iol.co.za.
(33)Mawande Jack, ‘Toll road opposed’, The New Age, 5 August 2011, http://www.thenewage.co.za
(34)Fuad Fredericks, ‘Draft environmental impact report: Proposed N2 Wild Coast Toll highway’, October 2008, http://www.ccaenvironmental.co.za.
(35)Keller, I. and Largiader, C.R., 2003. Recent habitat fragmentation caused by major roads leads to reduction of gene flow and loss of genetic variability in ground bettles. Proceedings of the Royal Society of London B, 270(1513), pp.417-423.
(36)Vos, C.C. and Chardon, J.P., 1998. Effects of habitat fragmentation and road density on the distribution pattern of the moor frog Rana arvalis. Journal of Applied Ecology. 35(1): 44-56.
(37)Reed Noss, ‘The ecological effects of roads’, 29 June 1995, http://www.wildlandscpr.org.
(38)Stephen Mallory, ‘Mzimvubu to Keiskamma water management area’, Department of Water Affairs and Forestry, February 2005, http://www.dwaf.gov.za.
(39)Val Payn, ‘Sustaining the Wild Coast: EIR commentary. N2 Wild Coast toll road proposal’, Sustaining the Wild Coast (SWC), 23 January 2009, http://swc.org.za.
(40)Fuad Fredericks, ‘Draft environmental impact report: Proposed N2 Wild Coast Toll highway’, October 2008, http://www.ccaenvironmental.co.za.
(41)Krein, A. and Schorer, M., 2000. Road runoff pollution by polycyclic aromatic hydrocarbons and its contribution to river sediments. Water Research, 34(16), pp.4110-4115.
(42) Ibid.
(43)Ogbeibu, A.E. and Victor, R., 1989. The effect of road and bridge construction on the bank-root macrobenthic invertebrates of a southern Nigerian stream. Environmental Pollution, 56(2), pp.85-100.
(44)The Mercury, ‘Wild Coast toll road given OK’, IOL Property, 27 July 2011, http://www.iolproperty.co.za.
(45)Val Payn, ‘Sustaining the Wild Coast: EIR commentary. N2 Wild Coast toll road proposal’, Sustaining the Wild Coast (SWC), 23 January 2009, http://swc.org.za.
(46) Ibid.
(47)Ibid.
(48)Ibid.
(49)Mawande Jack, ‘Toll road opposed’, The New Age, 5 August 2011, http://www.thenewage.co.za.
(50)Ibid.
(51)‘ANC welcomes N2 toll road approval’, IOL Business Report, 1 August 2011, http://www.iol.co.za.
(52)Mawande Jack, ‘Toll road opposed’, The New Age, 5 August 2011, http://www.thenewage.co.za.

Written by Wayne Brazier ⁽¹⁾