Comments on the Draft Basic Assessment Report on the
Proposed Improvements to the R44 between Somerset West and Stellenbosch,
made available for public review and comment April/May 2014.

Introduction

A draft Basic Assessment report dealing with this project was made available for public review and comment earlier in the year. The process is being managed by CCA Environmental and the following appears on their web site which gives the current status of this project:

The Western Cape Government (WCG) Department of Transport and Public Works is proposing to improve road sections and intersections on the R44 between Somerset West and Stellenbosch. The R44 is a strategic link road between Somerset West and Stellenbosch. In order to maintain the integrity of the route, access needs to be managed accordingly as well as service and safety improvements need to be made. A Basic Assessment process is being undertaken to obtain Environmental Authorisation. A draft Basic Assessment Report (BAR) was compiled and made available for a public review and comment from 2 April 2014 to 30 May 2014. Based on comments received, a Revised Draft BAR is currently being compiled and will be issued in due course. For information purposes the original Draft BAR is still available for download below.

www.ccaenvironmental.co.za/sub-roads/improvements-to-r44-between-somerset-westand-stellenbosch

My Position

I was appointed by Stellenbosch Municipality in 1988 to undertake a Transportation Study. The study formed part of the Stellenbosch Structure Plan which was then in the course of preparation. The Stellenbosch Transportation Study Report was issued on July 1989.

The problems which were identified at that time and the proposals which were made on the ways in which these could be addressed are as relevant today as they were then. Very little has changed other than the continuing deterioration in both traffic operating conditions and ‘environmental quality.’ Stellenbosch is a far poorer place now than it was 25 years ago.

The history of Stellenbosch and its cultural and environmental significance are well-known; the importance of its setting in the Cape Winelands is an integral part of that significance. Both are unique. There is no other Stellenbosch; there are no other Cape Winelands. They are a national asset and there have to be adequate safeguards to ensure that their integrity is not compromised.

So, I am motivated not only by ‘academic arguments’ or ‘technical discussions’ on this or any other proposal but by a genuine affection and concern for the future of Stellenbosch. Any proposals which affect that future must be carefully considered and well-thought through. If that takes time then so be it. Any change which is made will be permanent and unalterable.

Whatever is proposed, whatever is considered, whatever is done must be shown to be in the best interests of Stellenbosch. The merits of any particular scheme of whatever type cannot be considered in isolation and discussed on the basis of its own, specific characteristics.

The Public Participation Process

Guidelines issued by the Department of Environmental Affairs in 2012 list the many benefits
of public participation. The primary function of the process is clearly to facilitate ‘information flow and feedback’ between the public and the applicant for environmental authorisation. However it uses such terms as “project, application, activity, decision’, treating a project as a single entity which can be considered in isolation based upon its own particular merits. This is its greatest weakness when considering a road such as the R44 which forms part of a complex road network and where its distributive effects have to be fully understood. It is irrelevant under which particular jurisdiction that specific road falls. It is the performance of the overall network which is important, not one specific link. Further it is unreasonable and unfair to place an inordinate amount of technical material before a lay public and expect an informed response. People are daunted by the sheer volume of material which has to be examined and deterred by its technical complexity. Amongst the benefits claimed of public participation is the opportunity it provides the public and the competent authority “to obtain clear, accurate and understandable information……” This is patently not the case with this project. Which is wrong.

The mechanism for ‘information flow and feedback’ is not from ’the public’, broadly defined, but from individuals – each I&AP and EAP. Any ‘dialogue’ which occurs is between the authority and each individual separately. There is no mechanism or indeed any encouragement for the various parties and practitioners to engage with each other and share views and opinions.

Appendix F: Public Participation Information of the Draft Basic Assessment Report contains lists of the names of people who attended meetings or submitted comments/ submissions at various stages of the engagement process. However no contact details were provided making it impossible for any dialogue to occur between people who have demonstrated their interest in the project. Had this been possible, such information exchange would have been both constructive and empowering. People would have learnt from each other and a greater understanding reached of what the project entailed, what its potential impact would be, both positive and negative, and what alternatives may exist. In this way the public would be better able to engage with the applicant for environmental authorisation from a far more knowledgeable and informed position.

The question has to be asked “what is the intention of public participation?” It is said to be important that people have the right to be informed about potential decisions which affect them and be afforded an opportunity to influence those decisions. It is said that it facilitates informed decision-making by the competent authority and may result in a better decision.
Central is ‘the decision’. It infers that the decision to proceed has been taken and is immutable. The only action available is to influence the decision, not to change the decision.
Fundamental questions about whether the project is actually necessary, whether there is not a better way of doing it or whether something entirely different should be considered are not asked. One may influence the decision but the ‘space’ does not exist to challenge it.

This is what I think

Do I accept this? No. For both Stellenbosch and the Cape Winelands the stakes are too high and the risks are too great. The debate is not about technical matters alone. The agenda cannot and should not be determined by road engineers alone.

I believe that it is essential that other views and opinions are taken into account, particularly those which ask the question “Isn’t there a better way of doing things?” This is my contribution. I hope will lead to a less-constrained public debate and discussion. How this will occur and what organisation or person may drive it I have no idea.

This document draws from others I have written and is not as ordered or well-structured as I would have liked. But I hope it will serve its purpose.

1 Problems with the data.

1.1 Incorrect Traffic Projections. There are many technical issues associated with the proposal, particularly those dealing with traffic in the main report and in the Economic Assessment appendix. These are not trite and superficial issues but basic and fundamental and call into question the ‘correctness’ of the various analyses and the validity of the conclusions.

For example, “Fig. 6.1 Average Daily Traffic between 1979 and 2013” is shown on page 28 of the Economic Specialist Study. The data has been incorrectly interpreted and growth has been stated as linear over this period which it isn’t. I think that the changes which have taken place over the past 25 years or so have been due to growth in population in the surrounding areas, the expansion of the Techno Park, investment in retail floor area in the CBD, growth in total employment and growth in student enrolment at the University. In other words, there has been cause and effect.

Consequently, as clearly demonstrated by the data, growth has not been linear but a ‘step function’ where growth in traffic correlates with periods of major investment in Stellenbosch. Furthermore it is stated that “The traffic figures have been extrapolated for the next 30 years at 4% annually in line with the Traffic Engineers design volumes.” This is ridiculous as it implies a doubling in traffic volumes every 18 years.

Traffic is a derived demand and doesn’t just ‘happen’. It is a ‘dependent variable’, responding to changes in two ‘independent variables’, in this instance ‘population’ and ‘employment’. If both grow by 4% per annum then indeed traffic flows will increase in proportion. If there has been no growth in either variable then traffic volumes will not increase.

The Economic Specialist undertook a Sensitivity Analysis to determine if changes in magnitude of any of the variables would make the project economically inefficient. It was stated that “Of these five variables, only the annual traffic growth and the cost of time could make the proposed intervention economically inefficient”. (Page ii of the Executive Summary of the Economic Specialist Study.) So, get the annual traffic growth seriously wrong as in this instance then the project becomes economically inefficient and should be rejected.

1.2 Where are the design volumes? Regrettably and somewhat surprisingly, no design
volumes are shown in the Main Report upon which the entire technical analysis hinges. However, it is clear that some sort of design volumes actually do exist as they are referenced in Table 6.2 Local Access Points and Additional Travel as shown on page 26 of the Economic Specialist Study. Kantey & Templer is acknowledged as the original source of the information contained in the Table which has been “supplemented with own (the Specialist’s) calculations” as was clearly thought necessary.

1.3 What is the ‘practical capacity’ of the route? It is far from clear how and to what this
growth rate of 4% per annum has been applied. In Section 6.2.10 Delays at Traffic
Signals entering Stellenbosch the following statement is made:-

One of the key criticisms of the proposed roundabouts is that while they would speed traffic up through the Annandale and Winery Road intersections, the time gains would be lost as the traffic builds up at the signalised intersections entering Stellenbosch. In other words, there would be no net gain in time to traffic driving in the direction of Stellenbosch in the morning. All gains at the
roundabouts would be lost at the traffic signals in the morning. This effect was included in the analysis by excluding the time gains for the mainline traffic driving from Somerset West to Stellenbosch. This is a conservative approach because it assumes that there are no time gains for the main traffic stream irrespective of the time of day or day of week. This assumption is varied in the sensitivity analysis.
All other traffic streams were included. There are, for example, vehicles leaving Stellenbosch in the morning, those entering Annandale from the East or West and vehicles travelling to Stellenbosch in the afternoon. This applies to the at-grade and grade separated roundabouts but not the traffic light
option at Winery Road.”

I can’t claim to understand what this means. I can only assume that for the analysis period, traffic on the R44 and at each local access points, including intersections with secondary roads, has been assumed to grow by 4% per annum. Stating that time gains for the main traffic stream have been ignored implies that despite the assumption being made that traffic will continue to grow at 4% per annum, time gains (as opposed to losses) will not have incurred. This is patently nonsense. Traffic growth of this magnitude, sustained for 30 years, would have overwhelmed the carrying capacity of
the R44 in any event, probably well before the end of a 10 year period, let alone 30 years.

The only traffic count information which is provided states that current traffic volumes on the R44 are 30 000vehs/day. With a total two-way volume of 30 000vehs/day, it is safe to assume that 15 000vehs/day enter Stellenbosch and 15 000vehs/day leave. I’d guess that the peak hour as a proportion of total daily flow would probably be about 12% which gives a peak hour flow in the morning peak period of 1 800 vehicles per hour. If one were to consider route capacity, recognising
that capacity restrictions would be imposed by various types of intersections along the route, particularly traffic signals, it would be reasonable to suggest a practical capacity of no more than about 1400 vehicles per hour on each of the two lanes. This gives a practical carrying capacity on this 2 lane carriageway of 2800vehs/hr. Using the growth rate of 4% per annum, if the peak hour volume was 1800 vehicles per hour, the ‘practical capacity’ of the route would be reached in 11 years. After that it
would not be possible to accommodate any more traffic. The road would be at the limit of its practical capacity. You’ll readily see that as this occurs well within the 30 year period upon which the consultant’s analysis is based, it invalidates their findings.

1.4 “You provide all the input data, I’ll do the economic analysis.” I fail to understand the
merits of modelling invalid traffic projections which are totally unrelated to reality.
Consequently the output from the analysis has no credibility. Throughout the Economic Analysis, the Economic Specialist has gone to great pains to distance himself from the traffic volumes with which he has had to work (and who could blame him?) He has made it quite clear that “The data provided by the applicant, the project engineers (Kantey & Templer), other specialists, affected land owners, municipal officials, residents and community representatives was assumed to be appropriately (approximately?) accurate……” In other words, whatever has been provided has been accepted at face value and the economic analysis has been based on those figures, whether they have been thought to be realistic by the Economic Specialist or not. It has been stated on page 8 of his report that “…SES has developed its own spread-sheet based software which, while following the HDM4 algorithms, is more flexible, transparent and the results are easier to convey to the lay person.”

Unfortunately the contents of the report do not support this contention. To take this matter any further and to try and figure out what has been going on, I need to see the design volumes and understand the assumptions on which they are based.

2 The Alternative

2.1 God bless America. The South African Geometric Design Standards are based on American practice. Their design philosophy is different to the European and its appropriateness is constantly called into question both in situations like this and indeed more generally. All too frequently the characteristics of the road design which results are at odds with the characteristics of the area through which the road passes. In other words, roads are imposed on the landscape but not integrated with it. It remains a ‘foreign’ element, at odds with the qualities of the area through which it passes. This can be ameliorated with varying degrees of success but it can never be resolved. Once it’s there – good, bad or indifferent – it’s there for all time. A good reason as any to get it right the first time.

The American ‘geometric design bible’ is the AASHTO Green Book, issued by the American Federal Highway Association. At the beginning there is a section which deals with ‘The Role of Functional Classification in the Design Process’. The key statement is “the first step in the design process is to define the function that the facility is to serve.” It goes on to state that “The flexibility available to a highway designer is considerably limited once a particular functional classification has been established.” So get that wrong then everything that follows is also wrong. You’ll recall that the consultants on this project have stated on more than one occasion the “The R44 is predominately a high speed mobility corridor…….” The question was not posed whether that is acceptable or desirable; it just ‘is’.

2.2 A 25 year old ambition. I have been involved with Stellenbosch since 1989 when I did the Stellenbosch Transport Study. Even then it was thought necessary to ‘de-tune’ the R44 to a ’lower-order facility’, making it more a rural road than a freeway. This would reduce its environmental impact and improve its operational performance. I never got around to doing that as there were other priorities at the time and I had better things to do than bang my head against an intractable PRE. But perhaps now is the right time.
2.3 Use at-grade roundabouts as the intersection control device at all intersections along the route. The primary consideration is intersection form, consistency and spacing.

Hypothetically, were appropriately designed and landscaped at-grade roundabouts provided at various intersections along the route, it would help to better define the nature of the route and would provide the operational consistency one required. All turning movements would be possible at each of these intersections, including traffic which would have to make a U-turn to reverse direction. With the current proposal only two roundabouts are to be provided which can accommodate these U-turns, at Winery Road and Annandale Road. This results in inordinately long additional travel distances, estimated at an additional 9000 veh.km. per day in year 1.

Will this result in any savings? The Cost Benefit Analysis compares the costs and benefits of 3 intersection forms – Signalised Intersection, At-Grade Roundabout and Grade-Separated Roundabout – at the two intersections which are the focus of the R44 report. The results are shown in Table 6-3 Results of the Cost Benefit Analysis which is on page 30 of Appendix 6: Economic Analysis. The cost of additional travel is the same for each of the three alternatives which, when discounted to NPV over the life of the project, amounts to about R280 million. This is overwhelmingly greater than the construction costs and land acquisition costs which, for the most costly grade-separated roundabouts option, amount to about R164 million, about 40% than the cost of additional travel.

I have problems with the initial capital costs and land acquisition costs which are given for the at-grade roundabout option (R35, 8million) and the grade-separated roundabout option (R163,9 million). The figures suggest that the cost of a gradeseparated roundabout is only about 4½ times the cost of an at-grade roundabout which I dispute, if only on the basis of common sense. (Elsewhere in the consultant’s report, the cost of the at-grade roundabouts are given as R22,7 million plus R20 million for pedestrian bridges thought necessary.)

I believe that if one were to “detune” the route making it a “lower-order facility” and ensure design consistency and improved operational performance, it might prove necessary to provide a total of 5 roundabouts along this section of the R44. Based on the costs which are shown in the report, their initial capital costs and their land acquisition costs would amount to about R90 million in total, a saving of some R74 million compared with the grade-separated option.

The NPV of the additional travel costs for each of the three options is given as R284,2 million. The current proposal provides two opportunities for U-turning on this section of road, at Annandale Road and at Winery Road. Were one to provide a total of five at-grade roundabouts, then there would be five opportunities for U-turning rather than two, clearly reducing the additional costs of travel which would be incurred. This would reduce the additional travel costs by 50% to 60%, a saving of between R140 million and R170 million.

3 What an opportunity!

3.1 Isn’t a by-pass necessary? You’ll remember that I spoke about the North/South Road and the East/West Road. They were first proposed in my 1989 report and if they were important then, they’re essential now (which I will deal with in a subsequent section of this document). Before going into them in any detail, it’s necessary to first deal with a number of related matters.

The first of these is the argument which has been advanced on numerous occasions that “the problem is the amount of through traffic and we need a bypass.” Not true. Through traffic is defined as ‘traffic which passes through an area without stopping’. Of course parents from outside Stellenbosch drop children off at school before going on to work/ business/ shopping or leisure. It could be something as innocuous as stopping to buy a newspaper or collect mail. Those aren’t through trips as they have a trip purpose within the area. Obviously there will be some traffic which passes through Stellenbosch without stopping but I’m sure the number is insignificant, hardly sufficient to justify a bypass.

If this needs to be confirmed, it’s a relatively easy matter to measure the amount of through traffic passing through an area. It’s called a ‘registration number matching routine’. It is necessary to record the registration numbers of a sample of vehicles entering and leaving an area based upon a predetermined number plate format and compare. With the technological advances which have taken place in recent years, there may well be some way of using automatic number plate recognition equipment as a means of collecting and analysing such information. The important point is that we don’t have to guess, we can measure. So, if it continues to be an issue, it is possible to provide a factual answer.

3.2 The importance of establishing a viable distribution hierarchy. I believe that
Stellenbosch already has a bypass which avoids traffic having to pass through Stellenbosch itself. It’s to the west of Stellenbosch and called Adam Tas, handling traffic between the R310/R44 in the south and west and the R304/R44/R310 in the north and east of Stellenbosch. The problem is that it functions not only as a regional distributor but also as a primary distributor as well as a district distributor. It is this ‘conflict in function’ which is one of the central issues which has to be addressed. It is important to understand the meaning and practical value of defining a distributional hierarchy. Any attempt at developing a functional classification for the Stellenbosch road network would quickly show where there are conflicts in function. The frequency and types of conflict are a measure of distress and one which every effort should be made to rectify.

3.3 The by-pass is to the west of Stellenbosch; Stellenbosch is to the east of the by-pass.
Generally speaking there is no way to access Stellenbosch from the west other than passing through the Adam Tas/Dorp Street intersection. From the south, discounting the Van Reede Road/Koch Road/ Suidwal Road link, there is no way to access Stellenbosch from the south without passing through the R44/Dorp Street intersection. And that needs sorting out.

3.4 How Stellenbosch has grown in the past twenty years! New suburbs have been created and growth has occurred in many existing suburbs. The population has increased from 104 000 in 1996 to 119 000 in 2001 reaching 156 000 by 2011. A small regional shopping centre of about 40 000 m² has been built in the historic core of Stellenbosch “comprising commercial, office, high-end retail, residential, leisure and medical facilities.” Employment, both formal and informal, has grown from 52 000 in 2001 to 66 000 in 2011, an increase of 27%, probably at least a half to two thirds of that being in the CBD. The number of students at Stellenbosch University has grown from 14 100 in 1990 to 27 000 in 2013 almost doubling in size; staff levels at the University grew by one-third since 2008.

The traffic problem has nothing to do with ‘removing through traffic’; it has everything to do with meeting the access needs of 50% more residents, serving a major increase in commercial floor space, an increase in employment of 25% and a doubling in student numbers.
.
3.5 But the road system has remained the same. Despite the magnitude and location of such growth, access arrangements have not changed and the road system remains unaltered, its main structural elements being in place by the later part of the 19th century. It is exhibiting all the symptoms of distress one would expect – growing levels of congestion characterised by an increase in queue lengths and unacceptable traffic delays. It is not necessary or desirable to increase road space provision in line with ‘growth’ but initially to make the best use of what road space is currently available. To do this it is necessary to restructure the road network, review the role and function of each link and rationalise traffic movement wherever possible.

The problems arise when a road is asked to handle a number of conflicting roles. For example, it may be asked to carry through traffic specific to its location, distribute traffic between specific places in the same general vicinity as well as to accommodate local traffic. It can be relatively straightforward to ‘bring order out of chaos’ if there is adequate capability on the road network to meet the demand for movement at each level of the distribution hierarchy, essentially defining regional, primary, district and local distributors and resolving conflicts in role and function wherever possible.

Where this cannot be achieved, it is necessary to increase overall capability by the provision of additional links to the network at the level of the distribution hierarchy required. Given the confused nature of the existing road network, it is necessary to provide additional access facilities from both the west and the south of Stellenbosch in the form of the proposed North/South Road which will be a primary distributor and the proposed East/West Road which will be a district distributor. This will allow for the role and function of Adam Tas to be reassessed as well as the functional efficiency of the entire road network reviewed in order to define a proper distribution hierarchy. While miracles are not possible, it will provide an opportunity for significantly improving the overall performance of the road network. Providing both the North/ South Road and the East/ West Road was important in 1989. With the growth which has occurred since then, in 2015, their provision is essential. Nothing will be achieved by just ‘tinkering around the edges’ – a road widening here, an intersection improvement there. That will achieve nothing. At issue is the necessity of reviewing the overall road network and resolving the glaring structural deficiencies which exist. That is the root cause of the traffic problems. Until that is done, conditions will continue to worsen.

3.6 Reviewing the feasibility of the two proposed roads. The need for the E-W road and
the N-S road was demonstrated in the 1989 Stellenbosch Transportation Study Report.
But much has changed since then. The proposed alignment of the N-S road remains feasible. Its function is to provide an additional route for traffic from the R44 seeking access to the central area and the university. It would start from a new intersection on the R44, possibly at the existing intersection to the Technopark, possibly somewhere else. At this level of debate, it is the concept which is important, not the detail. The N-S road terminates at an intersection with the E-W road.

The proposed alignment of the E-W road is no longer feasible. It is now blocked at its western end by development and there seems to be no way round it. But that does not negate the need for the E-W road and an alternative alignment must be sought further south. The intention of the E-W road is to enable access to be provided from it to existing internal roads which run north/ south. This will necessitate additional bridge crossings over the river and the realignment of certain existing internal roads. To use planning parlance, this increases the ‘permeability’ of Stellenbosch from the south.

Stellenbosch is approached by the R304 and the R44 from the north; the R44 from the south; the R310/M12 from the west and the R310 from the east, which come together to form one road, Adam Tas to the west of Stellenbosch. If considered in isolation and based solely on network considerations, combining such routes into a single facility was misguided. That the route is to the west of the Stellenbosch urban area and is the primary means of access for traffic approaching from all directions was ill-advised. It is never wise to place undue reliance on just one route. The result is clearly observable conflict in the various roles and functions which this section is expected to fulfil. There must be alternative routes.

The alignment of both roads link Provincial Main Roads, this time to the south and potentially to the east. It could be argued that the proposed N-S road and the proposed E-W road could be incorporated as part of the Provincial road network, joining the R44 and the R310/ M12 to the R304. Based on this line of reasoning, I believe that the proposed N-S road and E-W road could be strongly motivated.
3.7 How will this be funded? If handled correctly, the Province’s current proposal provides a magnificent opportunity to not only improve operating and safety considerations on the R44 but at the same time resolve these access problems and to provide the basis for an appropriate road distribution system for Stellenbosch. With savings of R74 million on capital items and R140 million to R170 million in the cost of additional travel, there is a lot of ‘savings’ to play with. It is certainly more than enough to build the North/South road and the East/West road which together would rectify the most glaring deficiency in the Stellenbosch road network. It would enable the movement system to be rationalised by providing better access to those activities which most need it – the CBD and Stellenbosch University.

The design of the East/West road would not happen in isolation but will be just one of the elements to be taken into account in upgrading and improving the environmental quality of the Eerste Rivier corridor, extending from the northern edge of Noordwal to the southern boundary of Suidwal. This will enable a significant though neglected feature of Stellenbosch to be integrated into the historic, environmental and cultural landscape of Stellenbosch of which it should rightfully form an important part.

The counter-proposal for the R44 has two distinct advantages which I don’t think can be disputed. Both the capital costs and the operating costs will be significantly reduced. In addition the nature of the route will change to something more appropriate to the environmental and aesthetic qualities of the area through which it passes. Those are essentially technical matters and are worthy of consideration. But the counter proposal goes much further than that, using the savings which are created to construct two additional roads, the provision of which are vital to resolve long-standing problems with traffic access and traffic movement in Stellenbosch. So, in a nut shell, for the same amount of money, greater benefits can be realised.

Lastly, there is one point which must be made forcibly and to which there should be no argument. This is the only time that there will be money of this magnitude potentially available. I doubt that an opportunity like this will ever come again. It is highly unlikely that such funds could ever be generated from municipal sources, particularly given other competing needs. The two roads are essential and this opportunity must be grasped in order to
secure the necessary funding.

If this opportunity is not seized now with both hands, it will never occur again. Stellenbosch will simply end up drowning in its own traffic.
Paul Mann. September 2015