Maintenance Process halted

A consultation process began with Ndlambe Municipality around the 18th of November 2023 when Ndlambe correctly engaged in moving sand to give the Howson family access to their property after the storms and tidal surges experienced during the last quarter of 2023. These high seas had altered the flow of the estuary by moving the channel more than 100 m eastward. This trend has continued and moved by as much as 8 m during the year. This has meant a substantial volume of sand moving upriver since it has now to erode a sandbank of up to 6 m high and 100 meters long.

Fanie Fouche informed us mid-year that the MMP was halted by Dedeat until August 2025 when it would come up for review anyway. (The Deputy Director of Community Protection undertook to provide the official document to us on at least three occasions but has not done so yet.)
Nothing more was heard about the matter, and we were under the impression that the matter was settled. We accepted that we would be consulted when there was a need to do so.

We were therefore surprised when during October Mrs. Carol Liquorice was overheard publicly speaking about Robert Rose’s plan being approved and that they could start to move the dune.
In shock with the news, we contacted Ndlambe’s Director and Deputy Director. At first, they were not able to confirm if it was a fact or not.

The meeting between EC and Ndlambe on 12th November

After repeated attempts were made, a meeting was held with the Ndlambe Directorate and Warren Lange during which we were told the plan was approved and was going ahead. It was a big surprise since no consultation with us had taken place and we would not have been aware of the situation if Carol had not been overheard.

We commented at the meeting once again why the Ndlambe plan was not a viable option. It was pointed out to Ndlambe that:

• In the long run, what in fact would happen was that a permanent wall/dune would be artificially erected which would stop all the natural movement of sand flowing naturally westward. The incoming sand would then accumulate on the riverside (western).
• There is no Estuary Management Plan as legally required against which this intended plan can be measured.

Meeting held on Friday the 29th of November.

The meeting was called by the Municipal Manager with representatives from our organizations as well as Mr. Robert Rose and Ted Avis from CES.

When we enquired why the latter two participants were invited, as individuals, to share their personal agendas when the MMP was only to safeguard Municipal property, we were told by the Municipal Manager that it was not a KSDNA plan but a Ndlambe plan and that KSDNA was going to pay for the implementation of the project for a period of three years.

We learned for the first time that there was a new proposal on the table. As none of our team had seen this proposal, we requested that it to be sent to us. Jeremy Ridl asked for the “method statement” that was referred to. Warren Lange undertook to provide this and sent three documents prepared by CES:

• A Construction Environmental Management Program dated June 2022, which is informed by the original MMP dated 2019 and the rehabilitation plan commissioned by KSNDA in April 2020 (known as Robert Rose’s plan);
• A Maintenance Management Plan Construction Method Statement prepared in December 2021 and revised in June 2022;
• A PowerPoint presentation for DEDEAT which is dated October 2023.

The fact that there was a plan being discussed was a great surprise as were told two or three months previously that Dedeat had written to Ndlambe informing them that the project was on hold until the five-year review in August next year. We have asked for a copy of the letter from Dedeat but as yet we have not seen it.

We understood from the meeting that the proposed work was going to be undertaken in accordance with updated plans that would take account of the changes in the Bushman’s River. We expected to see a recently compiled method statement. From the documents provided, what is proposed is the implementation of the plan that we have contested, and we were told had been shelved until August 2025.

Despite the Municipal Manager’s insistence at the meeting that the Municipality was implementing the Municipality’s plan and not Mr. Rose’s plan, the documents given to us show that Mr. Rose’s plan is indeed being implemented. We find this unacceptable.

We also, once again, requested an answer to our letter addressed to the Municipal Manager by Jeremy Ridl dated 29 October 2024 and we received an undertaking that an answer to the letter would be received.

Our Counter proposal

I requested during the meeting that I write a counter letter to the presentation made by CES to Ndlambe, the contents of which were unknown to us.

It is unacceptable to expect us to make a counter proposal whilst the document for approval by the council has already been drafted and is to be put before the next Council meeting for final approval within a few days as per the words of Mr Fouché. This supports our notion that we have been excluded from private discussions between Ndlambe and CES yet Warren Lange had strongly denied in our meeting on the 12th of November 2024, that there had been any official meeting between himself or Ndlambe with CES and that there had only been casual interactions.

Because we have been surprised to receive the CES presentation which included many alterations to the one we saw some years ago, we therefore request that we have more time to analyse the contents to be able to make more informed comments.

In the interim, we submit our immediate concerns.

We commented that the proposal by CES was not viable in the long term as it opposed nature and that a permanent dune wall was going to be built that would stop all future sand movement eastwards. The incoming sand would then accumulate on the riverside (western) and ultimately close the river without considerable annual budget being spent.

Should this happen it will destroy the natural environment as well as the economy and livelihood of thousands of people.

Who do we represent?

We are a combined community organisation, represented by:

• Estuary Care representing sustainable nature and estuarine health,
• The two ratepayers’ associations representing the homeowners from both sides of the estuary; and
• Kenton Boesmans Chamber of Business and Tourism, with a mandate to promote tourism and investment in the area, ensuring we remain the Barefoot Capital and a premier holiday destination,

We are justified in making comment on issues that will affect not only the present generation but for generations for the next 100 years and beyond.

Some future costs to Ndlambe Municipality if the CES plan is followed:

• It would be remiss of us to not highlight the fact that the municipality would be committing to spend far in excess of a R1mil PA, at today’s cost, using Ratepayer’s money to maintain a system that will continue to fight the forces of nature. After the initial three year period the cost will be carried by Ndlambe in ad infinitum.
• There is misrepresentation in that the CES report makes no mention that an EIA would be required to distribute the sand at Middle Beach. That area does not fall within the authority of the current MMP. There is a very high probability that this permission will not be given. No start can be made on any segment of this proposal until a working plan is submitted and permission granted for every action intended.
• The sand will be deposited on a pristine beach between two highly prized blue flag beaches. The question is; Has the full extent of the depositing 6000m3 been assessed? Will it affect fishing and or the launching of recreational fishing boats?
• Within the estuary: It would be criminal if we did not warm the Municipality of the hard fact that if the proposal is carried out, it will add many thousands of cubic meters of sand to continue to accumulate up-river to the point when this jewel of the South African coast could become a blind river. This will be due to sea surges that are becoming regular occurrences, which will continue to scour the east bank of the river and deposit the sand up the river.
• No consultation has been entered into with Lands’ End property owner of the possibility of turning their one-car wide, current cul-de-sac into a two-way haul road.
• Has CES or Ndlambe been permitted to make a road through a pristine wooded valley with protected milkwood trees and within a proclaimed nature reserve?
• Have property owners along the alternate Westbourne Road route been consulted?
• Has anyone considered the effect on residents with heavy haul trucks passing their houses every few minutes? They would surely seek relief through the courts.
• Has anyone considered that young children use the roads of Kenton to walk to the beach? These are questions the public will be asking Ndlambe and not KSDNA or CES.
• Have civil engineers given the municipality any idea what the lifespan of the roads will be with 2000 passes of trucks every year?
• Holidaymakers will not enjoy the noise, dust and disturbance of machinery operating at the mouth of Bushmans River Beach for 3 to 4 months a year.
• Nor will they enjoy the bulldozer that will be constantly leveling the offloaded sand on the most used beach in Kenton.
• Has anyone considered the noise pollution of noisy loaders loading noisy dump trucks within meters of the Bushman’s water’s edge?
• These dump trucks would then have to haul their load up a steep incline over the dune and deposit it at a staging station 6m from in front of front-row residential homes.
• At this dusty staging station, a second bigger and noisier loader would then have to load this sand onto bigger trucks.
• A thousand loads of sand with heavily laden trucks passing over public roads every year will entail incalculable costs to Ndlambe, year after year, forever.
• While CES claim only 3000 m3 of sand will need to be removed annually is exactly half of my calculations taken as an average over a 30-year period. This is minute compared to the quantity PRDW estimated in their scientific study submitted on Page 5 of Kenton-on-Sea Dune Encroachment Study (S2001-39 R0 2015-10-30X7.docx PRDW) and depicted in the picture below. This is taken from their 2015 report to Robert Rose.

In answer to the proclaimed Objectives of the CES report:

• Wind-blown sand/dust: No cognizance is taken of the nuisance value of sand and dust being distributed with trucks driving through town or where sand is being loaded and offloaded on the beach. No consideration is taken for all other folks.

The ludicrous claim that vegetation would improve access to the river and beach and improve recreational amenities: See the picture below of what this area looked like in September 2014 when it was previously vegetated to gauge the value of that statement.

• Never has a sandy beach been improved by adding shade nets and branches, either as a recreational area or has the beach been visually improved.
• The residents of Boesmansriviermond and Kenton on sea will oppose this aspect at all costs. To have shade nets and machinery right in front of their most used recreation area, turning it into another industrial-type area as is the Amatola water plant. This could severely impact the tourism value and property values in Boesmansriviermond.
• The proposal will not give better access to the beach.
• There is no shortage of vegetated dune ecosystems to attract wildlife.
• Improved amenities; Holidaymakers come to the sea to enjoy sandy beaches and water.
• We have been informed that no watering of plants will be allowed yet the slides state the vegetation will be watered. Mr. Rose’s borehole water, drilled earlier this year, cannot be used legally.
• The introduction of no-go areas is not acceptable on a public beach.
• There are no guarantees that Ndlambe will remove the accumulating sand forever, and neither will Mr. Rose provide such guarantees.

A final request to Ndlambe:

We request that the CES proposal not be taken to the council for approval until such time as full consultation is concluded. We ask that you and the Directors consider the cost to Ndlambe Municipality and to the public at large if you implement the CES proposal.

We do not seek the legal route, but you leave us no option if you disregard this request.

Co-signed by KOSRA BRRAG, Chamber of Business and Tourism and Estuary Care Forum