Mr P. Evard
Re:
Proposed rezoning, consolidation, site development plan approval and Council's
approval in terms of the Municipal Planning By-law: Erf 13707 and 13708
Constantia, Ladies Mile Road - application no. 70262385
Our group is comprised of
residents of a section of Constantia bordered by the following roads: Doordrift
Road, Spaanschemat River Road, Kendal Road and the M3. We take an active
interest in the entire Constantia community and city-wide affairs; we are
recognized as a civic organization by the City of Cape Town; our members liaise
with and have served on the Constantia Property Owners’ Association (now the
CRRA) of which many of us are also members; and we are represented on the Ward
62 Committee. As you can see, our area is immediately adjacent to erf 4724, of
which erven 13707 and 13708 form a part.
Firstly we do not contest that
it was just that restitution of this land was finally made to the Solomons
family and that they are entitled to develop their land. We do, however, object
to the inappropriateness of this application.
A. The application is unacceptable if read against the Southern
District Plan (SDP):
Application
is contrary to the general section of the SDP:
Refer to the SDP page 15.
The application does not “support(s)
broader city planning imperatives” - i.e. the CTSDF's preference for investment
along the Main Road/railway corridor;
it is not on an activity route
or street, nor on a development route; it does not support the City's declared
drive for residential densification;
it does not direct commercial
development “in or near to pockets of recently developed low income areas” (p.
40);
it does not “support … a mix of
residential types: (p 40);
it does not “enhance the unique
sense of place” of Constantia – it is positioned between two scenic routes and
close to two arrival points of Constantia, yet it is totally out of keeping
with Constantia;
it does not “enhance the value
of heritage resources and scenic routes”;
it is not “in keeping with the
special cultural landscape” of the area;
it is not a “limited
intensification of activity” (p 32), it is full-on, large-scale retail
development:
it is “compromising the
character(s) of (these) area(s)” (p 32);
it does not encourage and
support the development of a wider mix of residential options that provide for
single people, elderly people, young professionals, and lower paid
professionals such as teachers and nurses.” (pp 51–52);
it is not included in the areas
mentioned on p. 52 (h), which are supposed to “support mixed use intensification”
it does constitute a “challenge”
(p 34) in that it is “Inappropriate development pressure in identified cultural
heritage areas (e.g. Constantia …) ...”
it is not “locally appropriate
mixed use development” (p 57, point 7); in fact it is not 'mixed use', this
application is purely retail; furthermore it is not appropriate to an arrival
point in Constantia, nor to Constantia at all.
Application
is contrary to specific mentions of Constantia and of this site in the SDP (pp
122–125):
This application is contrary to
the Primary Spatial Development Objectives (p 123) viz:
a. To maintain and enhance the
unique sense of place and character of these valleys.
b. To maximise the productive,
recreational, and tourism opportunities of the open space system, particularly
in respect of the ‘greenway system’, viticulture and horticulture, and limiting
urban intrusion.
c. To not be a recognized as a
city growth area.
d. To accommodate a broader,
and more efficient /environmentally sustainable range of living experiences in
existing ‘village’ areas.
This application is contrary to
these Development Guidelines (p 123) viz:
3. The character of these urban
areas should in general not be subject to change. This includes the maintenance
of cultural landscapes, and residential quality and appearance. Consolidation
and enhancement of sense of place and character in certain areas is required.
(This application, situated on a scenic route, is at odds with the cultural
landscape and is far from residential in appearance or usage.)
4. The vision supports and encourages
bona fide, low impact, working from home practices. (This is full-on retail
usage, more properly belonging along Main Road or in a CBD area.)
5. No expansion in the extent
of existing commercial areas should be permitted and no further regional
shopping centres should be permitted. (The application is the start of doubling
the existing shopping provision, which is already more than adequate for
Constantia.)
6. In recognition of the need
for densification and also declining household sizes, densification, particularly
by means of small-scale, low impact subdivision and second dwellings, is
supported. (This application does not help densify residential accommodation.)
7. In the context of a growing
and rapidly changing city, and accommodating associated new demands and
requirements, limited accommodation of retirement villages and smaller ‘lock-up-and-go’
units/complexes should be considered. (This application misses a perfect
opportunity to fulfil this need.)
8. The inclusion of restitution
claimants, and also residential infill, including some inclusionary housing, on
identified strategic residential infill sites must respect sense of place,
scenic viewsheds (e.g. from scenic drives), character (including tree coverage
etc.), and environmentally sensitive areas, as well as integration with
surrounding residential areas ... (This application is not for residential
infill as the City prescribes, and its design does not respect sense of place,
nor scenic viewsheds.)
This application is contrary to
the specific guidelines given for this site Constantia Recycling/Land Claim
Site viz:
Future Use: Residential infill.
1. The most appropriate future
use of this area should be medium density housing.
Therefore we contend that the
zoning granted should be residential, not General Business 1.
B. The application is basically flawed – in that the
applicant claims that it constitutes 'mixed' usage (although even this is
contrary to City guidelines) – with no substantiation
The applicant posits a 'mixed usage'
(albeit contrary to City guidelines) – but this application is for 100% retail
development. There is no sign of residential usage at all, as is included in
the definition of 'mixed land use' in the Southern District Plan.
Instead of adhering to the land
use of 'residential infill', as listed in the SDP, the applicant claims that he
is returning to a certain 'mixed' usage that took place before his family's
forced removal. He refers to “agriculture, living, … shops and farm stalls …
and production” ( section 2.2.3 of the Motivation).
We contest that even 'mixed
usage' is unacceptable, and that 'residential infill' is appropriate for this
site. However this application in question is not even for mixed usage, it is
for 100% retail development.
The application itself admits
that it cannot speak for the other claimants to the rest of erf 4724 and their
intentions, thus the 'Conceptual Framework' drawing submitted is an artist's
impression only and no factual evidence is provided to prove that the other
claimants will not similarly seek full-on retail or commercial development. In
fact, a precedent will have been set and they might well do so. There is no
guarantee that the entire greater site will not end up as another business centre
like Claremont or the City CBD, totally out of keeping with the intentions of
planning for Constantia.
Further, even though no
substantiation is offered – and this application itself is for 100% retail usage
– there is no definition of what kind of 'mixed usage' is envisaged. On the
'Conceptual Framework', the large white blocks indicated could well indicate
other retail buildings, office buildings and the like.
C. Notwithstanding our contention that this application is inappropriate
as a whole, we hereby comment on particulars of the application as they appear
in the Motivation and its accompanying documents
2.4.2
– Visual Amenity.
It is not true that “... Erf
4724 has urban landscape qualities.” It does, in fact, stand against a backdrop
of the Constantiaberg Mountains and their green foothills, as well as the
heavily treed avenues of Constantia itself.
2.4.4
– Geotechnical Condition.
Point (ix) page 21 – this
contradicts the assertion that the basement and yard would actually be below
ground and thus not visible. After suggesting that deliveries would be
invisible and presumably inaudible, this point reveals the fact that the
designers are even at this early stage, considering “raising the basement and
yard levels”.
2.5
– Access.
Traffic: The volume generated
by the now-closed recycling site is in no way comparable to that that will
result from the proposed retail development and the effect that this will have
on the surrounding roads and residential fabric. Please refer to Appendix A for
our detailed comment.
3.1
– Conceptual Framework for erf 4724.
We note that the application
admits: “... this conceptual framework has not official status and is not
binding on any party ...” . We note the vagueness of key words like “flexibility”
and “an enabling public realm”. In fact no one can force the owners of the rest
of erf 4724 to respect any “identified heritage indicators” or to retain trees
or the like. These future owners might well look at this application, with its
tightly packed retail development, and themselves seek such maximum yield for
their space.
3.2.1
(ii) – Heritage and Urban Design Indicators.
The first paragraph cannot be
substantiated for reasons indicated above. In any event, long axil lines may be
well be a factor of the shape of the erven, not a deliberate heritage-evoking
choice. Landscaping cannot be enforced on other owners. In fact, the plans for
erven 13707 and 13708 themselves show very little greenery at all.
The application does not adhere
to the City's design parameters in many instance, e.g. “it does not contribute
positively ...” (more of this later during comment on the design and materials
for the shopping centre). This application does not “... contribute(s) to
improved quality of the public realm and public spaces (more later during
comment on the inappropriate design at a sensitive spot on a scenic route).
There is no proof that it will create “... safe and secure communities”. It does
not “ensure enclosure and positive interfaces onto the public realm” - and it
certainly does not “Respect and enhance the heritage, character and unique
identity of the city and its neighbourhoods”. It is a square, modern structure
clad in zinc roof and siding – inappropriately placed against the backdrop of
the Constantiaberg and at the start of a wine route.
(iii)
Topographical and Geotechnical Considerations
Discussion of ground levels and
the remark that the centre should be “visible by pedestrians” suggests that the
intention is to raise the base level of the centre, so that it will in fact be
higher than its declared two storeys above 'ground' level. This is emphasized
by the earlier mention that the basement might have to be raised. The design of
this centre is already not sensitive to any historic architecture or to the
semi-rural ambience – therefore making it even more obtrusive on such a visible
corner is highly undesirable.
(iv)
Road Access
Mention is made of a “landmark
double storey building on the south-western street edge”. The positioning of
this construction is insensitive, undermining any possible amelioration of the
impact of this project claimed by the aforementioned set-back of the main
building. As the architectural style is urban/industrial, this prominent positioning
on a scenic route is particularly unfortunate. No mention is made of additional
signage on this restaurant either in the text of the Motivation or in elevation
drawings. Already there are prominent Checkers signs all along the Ladies Mile
side. What can we expect right on this highly visible corner. We trust that
none of this signage will be illuminated.
3.2.2
Commercial Retail Centre Design
Point (i) expands on why retail
development is good for the developer/s, but provides no reason why it is good
for Constantia. Constantia is not earmarked for any more business/retail development.
The present shopping centre at Constantia Village was designed to be large
enough to serve the whole of Constantia when every declared erf was built upon.
Constantia is not designed as a development node, in fact the value of its
unspoilt greenery is of more tourism value than a retail structure better
suited to the Main Road precinct. The claim that “The building design is in
keeping with design ethos seen … at the top end of development ...” is not
supported by the zinc cladding, concrete flat roofs, grey sheeting, large
signage and unsympathetic architectural aesthetics. Moreover this structure is
almost twice as high as Constantia Village (at nearly 15 metres, according to
the Motivation document) which gives one an idea of the negative visual impact
it will have.
3.2.3
Visual Amenity
Point (i) refers to “landscape …
designed”. There is virtually no landscaping at all. There are 0 metre building
lines on the long sides of the proposed consolidation site. One new tree and a
few creepers on pergolas, as well as a few vertical lines of creeper are unable
to soften the square lines of this nearly 15-metre high construction.
Furthermore at least one existing tree will be removed and there is no
guarantee that the construction of basement parking will not disturb the roots
and compromise the other trees on the street side. There are no “major planting
elements”.
Point (iv) says that “Trees
will be planted on the embankment ...” however, as the embankment is below
ground level of the shopping centre, these will be inadequate to conceal a
square structure with zinc cladding – and, as large retail branding has been
indicated on this elevation, concealment is obviously not intended. Elsewhere
there is mention of planting Dietes
grandiflora. These plants are only about 600 mm high, so will be no use as
screening of a blatantly retail structure at a gateway arrival point.
3.2.4
Parking Provision
Point (iv) – again we question
whether this “open service yard” will in fact be “at basement level” and thus
concealed – as earlier in the application it is mentioned that a higher base
level for the centre will be chosen, and that the basement might not be below
ground level.
“Non-compliance” paragraph: the
waiver to enable the developer to put parking closer than 10 metres from a
street boundary should not be allowed. Where could it be more important to “enhance
amenity at street level” than at this point on a scenic route in Constantia?
Much is made of the supposed
enclosure of this site. Will there be fence or wall around it? What design and
materials will be involved? Will the berms on the boundary be retained, to
attempt to soften the impact of this development? They are also not mentioned.
3.3
Landscape Concept, Principles and Planting
Point (v) Existing Eucalyptus
Trees … will be retained, except where road widening dictates. This vague
statement is no guarantee. See our previous comments about the possibility of
the excavation of the basement damaging tree roots.
Point (vi) “... woodland and
vineyard ...” are not evoked by the high, square, modern building totally
filling its erf widthwise, with some small trellises and thin creepers on wires
up the side of the building.
3.4
Proposed Access, Public Transport and Non-motorised Transport
See our Appendix A.
Furthermore, re Point (ii)
Public Transport and point (iii) Non-motorised Transport - adding taxi embayments
as well as NMT cycle lanes may possibly damage tree root systems.
4.
Consistency with Municipality's Spatial Development Framework and Development
Management Scheme
First paragraph – site-specific
circumstances do not “justify departure from some of the provisions of the
Southern District Plan”. In fact, the circumstances of the site, i.e. its
position, removed from the Main Road corridor, on a scenic route, in an area
designated NOT for business development – demand that the SDF's requirement for
residential infill should be upheld, and retail/business development should not
be accepted.
4.1
Municipal Spatial Development Framework (2012)
Point 4.1 (i) Figure 14 of the
SDP says 'New Urban infill' AND this is further defined in the actual text on
page 125 specific to this piece of land, viz.
“Recycling / Land Claim Site
viz:
· Future Use: Residential
infill.
1. The most appropriate future
use of this area should be medium density housing.”
This application is not
consistent with the City's specific intention for this site.
We refer to points (a) to (f)
on page 38 of the Motivation. This application is not consistent with any of
these points: it is not appropriate; it does not respect the surrounding
environment; it does not provide more densified housing e.g. a retirement
village; it does not support a wider mix of residential options; its design and
function are not compatible with the surrounding development; its design and
function are not appropriate to the position on a scenic route in a green
valley with a wine route.
Point 4.1 (ii) claims that this
application will enhance heritage spaces, as it encompasses “the creation of
spaces or structures serving as memorials of the forced removals” - but it does
not. It is, in appearance and function, wholly retail. It cannot reply on
unknown applications to other parts of erf 4724 to provide enhancement and
memorialization. The application under question is for erven 13707 and 13708
only. Furthermore, although the claimants had long intended to develop a “mixed
use node” - we contend (a) this application is not for “mixed use” (it is
wholly retail) and (b) the City of Cape Town indicated “residential infill” for
erf 4724 a full six years after the “restitution settlement agreement”.
Point 4.1 (iii) – the
application does not follow the development guidelines for the Bishopscourt - Constantia
– Tokai Sub-District, as: it does bring about “... change ...” that does not
include “... the maintenance of cultural landscapes, residential quality and
appearance.” it does bring about further commercialization and retail
development, which is contrary to the intention of the “No expansion … should
be permitted” paragraph of the guidelines. It is not “residential infill” as
indicated in the guidelines; it does not respect a sense of place of a green,
historic valley, let alone those of an arrival point; it puts a retail
development with unsympathetic architecture and large branding on “scenic
viewsheds”.
The intention is expressed to “reinstate
Constantia's historic commercial hub” (sic), however it is a far stretch to
equate this proposed development with the former small produce shops and farm stalls
that themselves constituted a small part of the general agricultural activity.
In contrast, the “medium
density residential infill … the SDP's preferred land use” fulfils the City's desire
for residential densification and avoids the negative consequences of making
Constantia a business development node, which was never intended.
With reference to the last
paragraph in 4.1, we again repeat that what the Motivation implies will happen
on erven on the east side of the M3 does not any bearing on this application.
There is no proof of what will happen on any of the other land claimed.
4.2
Municipal Development Management Scheme (2015)
It is “ … desirable for the
Municipality to rezone the properties ...” but not desirable to make this zoning
General Business I. As mentioned earlier in this letter, General Business is
contrary to the Primary Spatial Development Objectives (p 123) of the SDP.
4.4
Site Specific Circumstances
Point (i) - in contrast,
business zoning will have serious impact on surrounding areas. Point (ii), it may
be a New Development Area, but it does not follow that this development should
be for business; while more densified residential development is a big driver
in the City's planning. Point (v) the City does not have a “responsibility to
facilitate … securing ...” land use rights for business development, in obvious
opposition to its requirements for development around development corridors and
near new low-cost housing.
5.
Desirability
5.1
Economic Impact
The economic empowerment of
certain land claimants does not trump wise spatial development planning. There
are plenty of sites where such business development should be sited, for the greater
good of the City population.
5.2
Social Impact
This is a subjective view of
social impact. No one denies the family the right to develop their land, but
developing it to the detriment of the surrounding areas will not contribute to
the “strengthening of Constantia's social fabric”. The “community” already has “access
to a new modern and convenient neighbourhood commercial retail centre”. There
is no evidence that this retail application would “celebrate and memorialise
the area's heritage”. It is for a wholly urban retail development with no link
to the Valley's historic architecture or visual appeal.
5.3
Capital Investment
Higher rates might accrue to
the City from a retail development, but spoiling Constantia with inappropriate
development will reduce revenue from tourism.
5.4
Compatibility with Surrounding Uses
This application will not
introduce “a network of hard and soft public open spaces” - it is for full-on retail
use only. There is also no evidence that it will “facilitate finalisation of
the Department of Land Affairs and Rural Development's sub-division plan for
the remainder of Erf 4724”. It is not sympathetic to its surrounding context,
which is all Single Residential. The increased traffic, noise and retail customers
it will draw into the area are not compatible with the intentions expressed for
Constantia in the SDP.
5.6
Impact on Safety, Health and Wellbeing of Surrounding Community
This application would bring
noise, insecurity and traffic congestion. Its 100% retail activity and unsympathetic
architecture and branding will not “contribute positively to Constantia's sense
of place”.
5.7 Impact on Existing Land Use
Rights
No mention is made of the land
use rights of anyone other than the claimants. Should this application be
granted, it would negatively skew the character of Constantia in the direction
of business development forever, to the detriment of other land owners and to
the detriment of the valuable tourist and recreational ambience of the area.
5.8
Impact on Heritage
This “development proposal” for
a retail shopping centre that we are given to consider, is not “respectful of …
heritage indicators”; it does not “Incorporate public spaces, places and routes
… of the past”. The paragraph itself admits that this 100% wall-to-wall retail
development is a “modern contemporary design” (concrete slabs, zinc siding
etc). It may “celebrate” the claimants' “new beginnings”, but it is not
appropriate for the area in question.
5.9
Impact on Biophysical Enviroment
Wall-to-wall concrete and
hard-surface parking area cannot be claimed to be an improvement to the present
condition of the two erven in question. They are almost completely green and
allow for absorption of rain and prevent flooding, unlike hard surfaces. Grassed
berms exist which will in all likelihood be removed. Trees will be endangered
by basement excavation and creation of a wide access (see comments on previous
pages).
5.10
Traffic Impacts, Parking, Access and Related Considerations
More traffic will be drawn into
the area – even late into the night, as many restaurants are contemplated.
Roads might have to be widened. The accommodation of the proposed NMT route is certainly
not guaranteed.
6.
Conclusion and Recommendations
6.1
Conclusion
The application may (i) comply
with the requirements of the City of Cape Town Municipal Planning By-Law in
that it goes about the application according to regulations (as far as the
public is permitted to ascertain); however –
(ii) The application certainly
does not comprise a reasonable and permissible deviation from the Municipality's
SDP (it is in fact contradictory both to the general tenets of the SDP, to
those of the Bishopscourt – Constantia – Tokai Sub-District, and to those for
this specific site); and –
(iii) it does not prove that it
is constitutes a desirable land use as per the criteria of section 99 of the
Municipal Planning By-Law – as our letter has already described the negative
influence it will have on e.g. · Economic impact · Social impact ·
Compatibility with surrounding uses · Impact on safety, health and wellbeing of
the surrounding community · Impact on heritage · Impact on the biophysical
environment · Traffic impacts, parking, access and the like.
In
summary, we respond to the five specific requests made in the application.
We object to rezoning to GB1,
as this would be unacceptable for reasons outlined above. The zoning should be
Single Residential or, at most, General Residential.
We have no objection to the
consolidation requested.
We object to the Site
Development Plan, for reasons outlined above.
We object to permitting parking
bays at ground level located closer than 10 metres from a street boundary, for
reasons of appearance on a sensitive scenic route – and because another lane
might well have to be added to Ladies Mile at that point. (See Appendix A.)
We object to deviations from
the Southern District Plan of the Spatial Development Framework.
Business development should not
be allowed for reasons outlined above. The site should be
residential.
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Our request to the City is that
it refuse this application for retail development. Allowing such totally
unbalanced, inappropriate development would be out of keeping with the City's
own overall guidelines, out of keeping with the specific intentions of
preserving Constantia's uniqueness, and out of keeping with encouraging investment
where it is actually needed (near the Main Road and railway line, and near
low-cost housing).
For the wrong reasons (not good
town-planning ones), Constantia would get another Claremont-like business
centre. Commercialization of the Constantia Valley would be to the detriment of
tourism, which is one of Cape Town's chief economic drivers, as well as to the
detriment of the recreation and enjoyment of its own citizens.
Increased traffic and
deliveries, noise, retail signage, urban glass and facebrick slabs and harsh
zinc siding – all are inappropriate and unwise and will resonate with
undesirable consequences for decades to come.
We request an interview when
this application comes up before the relevant tribunal.
Yours faithfully
M. WALDRON - CHAIRPERSON OF THE
COMMITTEE OF THE BARBAROSSA RESIDENTS' GROUP
Appendix A: Comments on Traffic
Impact Assessment for Checkers development, prepared by H.J. Diesveld, Pr Eng,
a member of the Barbarossa Residents’ Group
COMMENTS ON
TRAFFIC IMPACT ASSESSMENT
1. Disclaimer
I am a retired professional civil
engineer, but traffic engineering was not my speciality. My experience with traffic studies involved
the monitoring of traffic counts for traffic planning on urban and rural
Provincial roads in the Western Cape.
2. Traffic counts
The existing traffic was counted in July
2015, i.e. during winter school holidays. Because traffic during this period is
invariably less than normal, the Levels of Service (LOS) calculated in the study
are going to be lower than that calculated. This means that any measures to
improve traffic flow in future will be required sooner.
3. Signalisation
of Spaanschemat River and Kendal Roads Intersection
The LOS experienced at the right hand
turn from Kendal Road into Spaanschemat River Road was so low that
signalisation of the intersection was approved, despite the fact that the
distance to the existing signals at Ladies Mile is even less than the 375m
specified for an Intermediate Roadside Environment. This signalisation was
supposed to have been completed in the 2015/16 financial year. It should be
noted that because of the low LOS for this right hand turn, the traffic count
at this intersection is distorted because motorists are taking alternative
routes to avoid this bottleneck. Most of these “rat runners” will return to
this intersection once the signals are installed.
4. Increased
traffic forecast generated by the development.
The assumptions made for the traffic
generated by the development appear to be reasonable, resulting in an expected
500 vehicles/hour entering the development and the same amount leaving during
the expected peak time around midday on a Saturday. This is a fairly
substantial traffic volume, but only results in an increase of the order of
about 10% on the roads, but with an about 10% decrease in traffic on the
section of Spaanschemat River Road between Doordrift and Kendal roads. This
nett effect on traffic is less than that one would intuitively expect, but
reference to Annexure A will indicate the values and explanations.
5. Proposed
traffic circle
This appears to be a good solution to
cope with all the additional turning movements. One only hopes that the size of
the circle and the width of lanes will be adequate to cope with the generally poor
driving standards of South African motorists. One would hate to see the
“Foreshore Traffic Circle” option being repeated with multiple traffic signals
in the traffic circle.
6. Increased
traffic generated by the future development of the balance of erf 4724 (North
and South)
These erven are also the subject of Land
Claims and it would appear that no development proposal has been submitted to
date. They measure 4,9 hectare in extent compared to the 1,6 hectare area of
the ‘Checkers’ development under discussion. In the worst case scenario, if
these erven are also rezoned commercial, a very substantial increase in traffic
will be generated. No allowance of any sort for this traffic has been factored
into the LOS calculations, which means that any measures to improve traffic
flows will be required sooner. The possible additional left in/left out
intersections on Spaanschemat River Road and Ladies Mile, the full access to
Kendal road at the M3 on-ramp together the proposed servitude on the ‘Checkers”
development appear to be the only feasible access points for these erven.
7. Measures needed
now to ensure traffic flow improvements are possible in future
Because of the great uncertainty in the
magnitude of traffic increases that will occur due to items 2, 3 and 6 above,
conditions must be imposed on the “Checkers’ development to ensure that there
is sufficient flexibility available for remedial measures to take place to
counter unforeseen traffic increases. These conditions include the following:
a) Any consolidation and rezoning of
erven 13707 and 13708 must be conditional on a servitude for vehicular traffic
being registered to allow access from and to the remainders of erf 8724. This
is to ensure that these erven can make use of the traffic circle.
b) No relaxation of building lines or
departures to allow development of parking bays within 10 m of Ladies Mile
Street boundary should be approved. This is to ensure that additional lane/s can
be added to Ladies Mile if a low LOS requires signalisation of the Ladies Mile
/ M3 ramp intersection. Due to the extremely short, 90 m, distance between the
traffic circle and the M3 ramp intersection, additional lane/s will be required
to store traffic during the red phase.
