text:
MA Climate Czar Says the Quiet Part out Loud in Private Meeting: We Must 'Break Your Will'
By Kira Davis | 6:30 PM on February 05, 2021
AP Photo/J. Scott Applewhite
The progressive crowd has been saying the quiet part out loud quite a bit lately.
Time Magazine released an article on Thursday extolling the praises of a shadowy cabal of industry higher-ups who conspired to manipulate the election and oust Donald Trump.
Wat https://t.co/GiKXiWGduD pic.twitter.com/h0Z9yrPETf
— Jack Posobiec 🇺🇸 (@JackPosobiec) February 5, 2021
The article shocked a lot of people for its brazenness. Mere days earlier, conservative outlets — including our own — were subject to page removals, suspensions, and outright bans for even suggesting such a thing.
In yet another stunning "quiet part out loud" moment, a New England government official revealed the left's endgame in fighting the climate in an online meeting he assumed would remain private. Massachusetts Undersecretary for Climate Change David Ismay participated in a meeting with the Vermont Climate Council back in January, where he admitted that when it comes to the big climate "offenders" in their region, there are no bad guys left to break. Ismay went on to say that now the only ones left to "break" are the people.
I know one thing that we found in our analysis is that 60% of our emissions come from – as I have it started to say you and me, except you guys are in Vermont – 60% of our emissions come from residential heating and passenger vehicles. Let me say that again …60% of our emissions that need to be reduced come from you, the person on your street, the senior on fixed-income. Right now there is no bad guy left, at least in Massachusetts, to point the finger at and turn the screws on and no break their will so they stop emitting. That's you . We have to break your will.
If you are shocked that a public official would not only admit out loud that they happily broke the back of a job-producing industry in their state, but that they now need to break the back of the average American, you're not alone. Ismay himself seemed surprised at the words coming out of his mouth, and in a stunning admission told attendees that he knew that was not something he could say out loud in public.
I can't even say that publicly.
Herein lies the problem with climate policy specifically, and progressivism in general. Everyone is on board as long as the "big guys" are getting screwed. What the public at large does not know is that progressive government has no intention of stopping at the big guy. They know that small business and the middle class make up the majority of American life, currently. They know that any significant change to American life must be done on the backs of those people. This is the terrifying truth that they dare not utter out loud, because even they know they are advocating for more poverty, more struggle, and less prosperity for the people who pay their salaries.
This is the rub of every left-wing policy versus right-wing criticism. The left claims it is for "the people" and for justice, to even the playing field. When the right points out that it will be "the people" who will have to suffer more poverty and more oppression, they are labeled as liars or idiots.
Well, here is a government official saying the quiet part out loud. Here is a paid servant of the people admitting that the Right has been right all along. The endgame is complete capitulation and the oppression of the notions and desires of the voters. Poor people don't matter. Small business doesn't matter. Even as all these people are surely using walls, and insulation, and heat, and electricity, they simultaneously are plotting to make sure no one else has those privileges.
The issue isn't climate change. The issue is changing human nature and under our Constitution, no man has the right to force changes upon our free will. If people vote for heat it's because they like being warm in the winter. The will of the voter is intended to be the most powerful voice in the nation. As with the Time article, here we see unabashed, admitted proof that there is a concerted effort to circumvent the will of voters.
These people despise the existence of anyone outside their elitist bubbles. That's all you need to know.
Kira is an author, freelance writer and Editor-at-large for RedState. She has appeared on Fox News, OANN, The Blaze and The Dr. Phil Show. Kira is also a regular guest host at KABC radio in Los Angeles and occasionally fills in for The Dan Bongino Show. Her podcasts "Just Listen to Yourself" and The Kira Davis Show are heard by hundreds of thousands of listeners across the country and the globe. Kira lives in Southern California with her husband and two children. She is a dog person but has been known to tolerate cats from time to time.
Kira's new book, Drawling Lines: Why Conservatives Must Begin to Battle Fiercely In the Arena of Ideas launches January 25, 2023 and is now available for pre-order on Amazon.
Read more by Kira Davis
Tags: CLIMATE CHANGE DAVID ISMAY RULING THE UNWASHED MASSES


form a state chapter of CEA. Annual Board elections are held to date.
to be published to date.
three-credit course. Another course is offered in February 1989.
are continued annually to date.
Behind Bars as a highly effective education program.
Continuing Education Association's Leadership in Education Award.
Dr. Richard Shiver of UW-Oshkosh to offer a series of three one-credit courses.
mark 20 years of partnering to deliver certified vocational programs.
Oshkosh to offer a three-credit course.
April 1996 - Wisconsin hosts Region III & IV CEA Conference in Madison.
Literacy Liftoff conference in Houston.
held in 2000, 2001, and 2002.
June 1997 – Sherry (Settle) Zwicky receives Virginia Hart Award.
February 1998 – Marion Olson, OCI, celebrates 50 years as a correctional teacher.
April 1998 – Anita Wilcox selected Region III Teacher of the Year.
May 1999 – CEA holds Wisconsin State Correctional Education Conference.
October 2000 - CEA-W website is created.
published each year to date.
from the national LVA organization.
office to present workshops at the International CEA Conference in Portland, OR.
impact of education on recidivism is published.
sponsored by Teaching for Success.
March 2004 – CEA-W News Review celebrates its 100th issue.
training session in Manhattan Beach CA.
and Wisconsin at the International CEA Conference in Baltimore.
Simulation Game sponsored by Economics Wisconsin.
the Parenting Special Interest Group.
Technical College System. Co-sponsoring of the conference continues until 2012.
November 2004 - First issue of Parenting Connection newsletter is published.
Bi-monthly issues continue to be published to date.
November 2004 - Guide to Successful Parenting Programs in Corrections published.
Guide is updated in 2008.
Racine Manufacture and Commerce organization.
July 2005 - Parenting Special Interest Group approved to expand to national group.
Governor's Council on Financial Literacy.
May 2006 - Wisconsin hosts Region III & IV CEA Conference in Wisconsin Dells.
III and Wisconsin at the International CEA Conference in Anaheim.
Region III and Wisconsin at the International CEA Conference in Atlanta.
Conference is held in Wisconsin.
July 2007 - Peggy Meyers elected Region III Assistant Director.
March 2008 - CEA-W and Parenting SIG sponsor Effective Black Parenting Seminar.
Training Day. Another Jail Training Day was held in 2009.
the website to its current look.
the year at a ceremony in Washington DC.
Silent Auction is held at the Appleton Art Center in December 2009.
Region III and Wisconsin at the International CEA Conference in Madison.
May 2009 – Sharon Abel receives Governor's Financial Literacy Award.
July 2009 - Wisconsin hosts the 64th Annual National CEA Conference in Madison.
July 2009 – Jerry Bednarowski receives CEA's Lifetime Achievement Award.
May 2011 - Wisconsin hosts Region III & IV CEA Conference in Elkhart Lake.
Region III and Wisconsin at the International CEA Conference in St. Paul.
training session in Indianapolis with other NIC, CEA, and GEDTS representatives.
Success through Continuity and Educational Opportunities Grant for programming in La Crosse County Jail.
presents GES 2014 training to approximately 75 educators.
April 2013 – Margaret Done elected CEA Region III Director.
to over 300 participants at CEA-Wisconsin Training Days in Madison.
40 years of partnering to deliver certified vocational programs.
July 2013 – Peggy Meyers elected national CEA Vice President.
demonstrates effectiveness of correctional education programs.
Center, named Juvenile Detention Educators of the year.
for Educational Excellence in Alternative Settings' Blended Learning Initiative.
sweeps Stock Market Simulation competition sponsored by Economics Wisconsin.
CEA's Highly Qualified Correctional Educator Certificate.
May 2015 - Wisconsin hosts Region III & IV CEA Conference in Madison.
July 2015 – Peggy Meyers elected national CEA President-Elect.
exhibit at UW-Fox Valley and a Silent Auction at the Esther Annual Banquet.
Change for Expanding Fair Chance Opportunities at White House.
July 2016 – Peggy Meyers assumes office of national CEA President.
exhibit and Silent Auction at the Esther Annual Banquet.
April 2017 – Ray Schlesinger elected CEA Region III Treasurer.
Educational Association Conference in Canberra, Australia.
Education and Reentry Roundtable at Capitol in Washington DC.
March 2018 – Wisconsin hosts International CEA Leadership Forum in Madison.
– Peggy Kaiser named DAI Education Director.


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DIVREI TORAH ON PARSHAS DEVARIM
The Torah teaches people everything they need to know, including the life skills necessary to speak to other people. When Moshe Rabbeinu asks Hashem to forgive Klal Yisroel for making the Eigal, he says, Lomo Hashem Yechere Apecho B'amecho, Hashem, why are you getting angry at your nation. However, when Moshe Rabbeinu speaks to Klal Yisroel, he tells them, Atem Chatosem Chato'o Gedolo, you have done a terrible sin.
I know several people who will agree with the person to whom they're speaking, when they're mediating between two people, such as a husband and wife. While mediating between Hashem and Klal Yisroel, Moshe Rabbeinu did the opposite. He asked Hashem, and told Klal Yisroel, what they should change, and not what the other had to change. He tells Hashem that He shouldn't become upset, and Klal Yisroel that they did something wrong. This is how I understand this.
When I speak, individually, to people during a mediation session, I can choose to agree with each (as many others will do to get them "on their side") but, by agreeing, I'm telling them not to change, and that the other person is wrong. Telling one side of the mediation table that they're right, means that the other side is wrong. This confirms their right to be angry at the other person, and I haven't gained anything.
Instead, I'll explain to each party that I won't discuss what they believe the other person did wrong to him/her. I'll discuss what that person may have done wrong. Both sides need to adjust, and "you (the person I'm speaking to) must only focus on your contribution to the present issue."
To the Ribono Shel Olam, Moshe Rabbeinu invokes Zechus Avos, and other reasons why He should forgive Klal Yisroel. Nevertheless, Klal Yisroel has to know that they did something terrible.
If people would understand how to learn from the Torah to live successfully, they would "run" to the Torah much more quickly. Parents should transmit each part of all of the Torah's lessons to their children, and have them appreciate that the Torah is Darchei Noam, a sweet path.
The author can be contacted at shmuelgluck@areivim.com
The Sifri says that there are four reasons that Yakov, Moshe, Yehoshua, and Shmuel, didn't criticize Klal Yisroel until they were near their death. One of those reasons was to avoid being a Mochiach V'chozer U'mo'chi'ach, constantly repeating the same message, or, in English, what we call nagging.
Waiting until just prior to their death to "bring up" past deeds assumes that Klal Yisroel did Teshuva for past sins. If not, there would've been a Mitzvoh repeat the criticism as many times as necessary. However, if Klal Yisroel did Teshuva, why did Moshe Rabbeinu bring up the Aveiros that they did many years before?
I believe the explanation is the following. People can learn lessons on multiple levels. For instance, imagine a parent telling a five year old child not to call his brother stupid. A few minutes later, the parent hears the same child calling his brother dumb. When confronted by the parent, the child, sincerely, says, "You told me not to call him stupid but didn't say anything about not calling him dumb". That child learned the lesson from his parent in such a narrow manner that, although the specific lesson was learned, little was gained.
Klal Yisroel may have done immediate Teshuva for worshiping the Eigal, but that was of limited value. The broader message, not to be an Am K'shei Oreph, a stubborn nation, may have slipped past them. The Eigel was a one-time act. Being stubborn is a trait which, unless it's recognized as such, will stay with them for many generations. That's why criticism and self-reflection was required even after the Aveirah was acknowledged.
People must attempt to understand the entire scope of their error. If not, they can become a Kelev Shov El Ke'yo, like a dog that returns to the food it recently vomited, not realizing that it's the same food it has already tried to eat. They keep repeating mistakes, and claim ignorance, or worse, that life isn't fair. In reality, with thought, they should have learned from their mistakes a broader lesson.
In the beginning of the Parsha, Moshe Rabbeinu lists, B'remez, multiple mistakes that Klal Yisroel made during their forty years in the desert, delicately, not to offend them. For instance, V'chatezeiros, refers to the challenge from Korach, and Di Zohov, refers to the Eigel. Since Moshe Rabbeinu was speaking to the new generation, those people who didn't do any of those Aveiros, why did he have to mention them at all? If there was a need to mention them, why did it have to be done delicately?
Rav Moshe Feinstein, explains why it was necessary for men who saw a Soteh killed in the Har Habayis, to become Nizirim. They had done nothing wrong and, in addition, they saw how the Torah punishes a sin. Why did they have to distance themselves from the pleasures of wine?
Rav Moshe explains that people who experience thought changing events often need "reprogramming". Their view of the norm may have become distorted. For example, there are many Aveiros that people are comfortable in doing, since it's "what everyone does" and, while they accept that it is wrong, they accept it in others and, maybe, even in themselves. These people need to be deprogrammed, and then reprogrammed. Their attitude should be that no Aveiro is tolerable, even if it is commonly done.
There are also attitudes that people believe are Toradick, having seen them since they were young. Some people may believe (even if only subconsciously), that giving a lot of Tzedoko removes their responsibility to have good personal character; other people may believe that if they learn a lot of Torah, their decisions will be flawless. Even the best of people require reprogramming in some area.
When Moshe Rabbeinu spoke to Klal Yisroel, he was speaking to them, not because they did these Aveiros, but with an understanding that they shouldn't see those Aveiros as the "norm". Therefore he revisited the events of the past, but had to do it with sensitivity, because they had done nothing wrong.
People should think about which of the attitudes they have adopted were from unhealthy sources, and which of those they are "handing down" to their children.
If you enjoyed or benefited from these divrei torah please consider making a donation to Areivim
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Marketed by Nottingham Estate Agency - Sherwood.
Fantastic Location - Well positioned. three bedroom mid-terrace house located in a popular area of Sneinton, with a wealth of amenities on your doorstep and within walking distance of the City Centre. A perfect home for any first time buyer on Investor. Call now!


A female snowy owl arrived at Stillman in May 2014 after recovering from a wing injury she sustained at O'Hare Airport.
A female snowy owl enjoys a newly-constructed enclosure at Stillman Nature Center in South Barrington.
The past year has been a good one at Stillman Nature Center in South Barrington, particularly with the addition of a snowy owl.


Erika Girardi Archives - The Real Housewives | News. Dirt. Gossip.
Erika Girardi Answers If The Real Housewives Should Apologize To Lisa Vanderpump, Plus Says What She Thinks About Puppy Gate And Leaking Stories!
Erika Girardi Thinks the RHOBH Season 9 Reunion Will Be "Great" Says That She Thinks Lisa Vanderpump Will Show Up!
Amid Her Husband's $15 Million Dollar Lawsuit, Erika Girardi Says She Pays Her Own Bills!
RHOBH: Erika Girardi Opens Up About New Season And Reveals Her Dream Cast!
The RHOBH Cast Doesn't Think Lisa Vanderpump Will Show Up For the Season 9 Reunion!


apartment in historical center san gimignano, chianti, tuscany.
Apartment with double bed, with private entrance, bathroom and kitchen. Orthopedic mattress. Vaulted ceilings and beams, terracotta floors. Courtyard with tables and chairs for relaxing.
You can get the front door for loading and unloading luggages, free parking near the door of St. Matteo.
Bus stop 50 m, at the door san matteo.
Within walking distance of shops, bakery, bars, restaurants, chemist, newsagent, tobacconist, grocery, library, wine cellar and hairdresser.
we are in the full center of San Gimignano, in Via San Matteo, the main street, along the ancient Via Francigena. A few steps from Porta San Matteo, the bus to Florence or Siena or train station Poggibonsi.
we are a short walk from the main square of the city and countless architectural works, including the beautiful Romanesque cathedral. San Gimignano is situated in a strategic position to explore the surroundings and the main cities of art in Tuscany, such as Siena (34 km). Florence (49 km), Volterra (30 km), Pisa (90 km), Colle Val D'Elsa (10 km), Monteriggioni (20 km) and Montalcino (90 km), easily visited on a day trip.
Chianti Classico (30 km) with the ancient villages of Castellina in Chianti, Radda in Chianti, Gaiole in Chianti Greve in Chianti and the Crete Senesi (40 km) with Pienza, Montalcino, Montepulciano ..
Unique accommodations with great hosts.
Charming apartment in a walled fortress city. After a bit of searching for parking we really enjoyed our stay. Luigi and Marzia are great hosts. The property has been in the family for generations. It was nice to hear the history of the estate and explore this charming city. Clean well kept with free wifi. So many good restaurants within a short walk and a bakery nearby. Wish we had more time to spend there.
Hello Mitchell, thanks you so much for your words, we are really in the main street.
very helpfull for our guests. All the best for you.
for travellers: we send always at our guest email with itineary for enter inside the area traffic limited and arrive in front our door. When you arrive here we will give you informations for free parking with a map for find immediatly place.
Very unique and fun! A beautiful place.
I'm so glad that we stayed here. The host is very sweet and the apartment and patio were beautiful. It felt very authentic- not like a plain hotel at all. The only thing that we missed was A/C but even in July it wasn't a big deal. I highly recommend this spot.
Thank you so much for your positive feedback and kind words. We are pleased to know that your experience at our apartment has been nice and memorable and that the suggestions and information provided have been helpful for you to enjoy San Gimignano at its fullest. We hope to meet you again in the future, all the best you all!
We only stayed for a week but we packed a lot in due to the help and information provided by Marzia. Let her know what your interests are food, music, wine tours etc and Marzia was there with suggestions. So thanks Marzia.
The Piazza was a great historic place to stay and the location was ideal for bars, restaurants, shops & public transport with out worrying about noise etc. We traveled by pubic transport from Pisa airport and Marzia helped with our early return to Poggibonsi train station by arranging a car pick up.
Thank you for the lovely words! Yes, you can ask Marzia or the Staff any suggestions for your dinners, walks, tours and much more, we always provide all the information we have available, also because we think that it's very helpful and can come in handy to the guest. Hopefully we will be able to meet you again, it was a pleasure for us to host you! Take care and all the best to you all.
This place is centrally located on one of the main streets of this beautiful walled city. You can walk the entire town comfortably. The owner Pierluigi and his wife do everything they can to make your stay memorable and comfortable. We were in room 7 which is on the first floor and is fully equipped with everything needed to cook your own meals which is cost containing. There is a supermarket at the entrance to the town which you can walk to or ride the local mini buses for .75 €. Tickets on sale in Tobacco shop next door to apartment. We were there for a week and were able to also rent a car for about 90€ including gas, which is very expensive in Italy. With the car we drove to the Chianti region and were able to visit many small towns and had lunch at a small restaurant where we got the best meal we had in Italy. Gelato shops in the main square have the best gelato. Although weather was a bit chilly we thoroughly enjoyed our stay and want to thank Pierluigi for his hospitality. The trip to SanGi was by train from Florence to Poggibonsi where right outside the train station you catch a bus for a 20 minute ride to town. Bus tickets are purchase inside train station at Tobacco shop. You get off at San Mateo door which is literally steps from Pierluigi's beautiful building.
Would definitely recommend this lodging and hope to return!
my 3 friends and i were on vacation from Los Angeles,CA for 2 weeks traveling around italy and we stayed in this town for 3 days and was one of the best times we had in italy. very quiet and cozy at night when all the tousist go back to where they were staying. i would highly recommend staying here.
The palace is situated in the midst of Tuscany, in San Gimignano, a beautifully preserved medieval hill town, Placed strategically between Pisa, Florence, Siena, Lucca and Chianti, and It provides an ideal base for the exploration of Tuscany.
Palazzo Buonaccorsi, is a wonderful Historical House, dating from the thirteenth century and is located in the main street of the historic center of San Gimignano, inside the city walls. Step away from the most beautiful squares of the medieval town and its imposing towers.
The apartments and rooms are comfortable, furnished with antiques and tastefully selected.
The apartments have the entry into the courtyard of the palace, very quiet area.
This feeling of intimacy and ease, is further Top ENCOURAGED by the Italian Pierluigi of welcome, together with His wife Marzia, and the Their valuable informations.
Their are proud to continue this family tradition, opening the doors of this ancient historical residence and to offer Their guests a very pleasant stay under the medieval towers of San Gimignano.
Residenza d'Epoca Palazzo Buonaccorsi is a haven of solicitude and courtesy from the family Boldrini.


Sean H Goetz is a General Dentist (General Dentistry dentist) practicing in Houston, Texas. This dentist is listed on Dentist Network with a medical license speciality in General Dentistry.
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Investing in cryptocurrency is uniquely risky. Its value fluctuates unpredictably, your transactions aren't insured, and they're practically irreversible.
Just like it's important for people like you and me to understand crypto's risks before making our first purchase of bitcoin, it's infinitely more important for entrepreneurs to understand the complex inherent risks of starting a business in the cryptocurrency space.
If you're starting (or currently running) a cryptocurrency money services business (MSB) or money transmitter, do you know what your risk profile is? Do you know how vulnerable you are to money laundering and other financial crimes? If you operate a chain of cryptocurrency kiosks, do you know the unique risk profile of the city or cities they're located in? Do you have an anti-money laundering (AML) program, and other policies and practices to help mitigate that risk?
When it comes to cryptocurrency compliance, many business owners we talk to aren't exactly sure where to start. We always tell them the same thing.
Start with a risk assessment.
We're continuing our series of cryptocompliance 101 posts to help cryptocurrency business owners understand the regulatory landscape, its nuances, and what steps need to be taken to strengthen their compliance. Today's topic is extremely important to the ongoing compliance health of a crypto operation – the annual risk assessment.
Risk assessments are absolutely critical for cryptocurrency MSBs. It's often the first step in designing compliance procedures that protect your business from financial crime, and keep you in the good graces of federal and state regulators.
In short, it is one of the most important tools you can use to keep your cryptocurrency business not only compliant but viable for the long haul.
Other businesses in the financial sector perform risk assessments, but crypto MSBs are unique for a couple of reasons.
One is that there is often little guidance from federal and state regulators about how cryptos should operate. Without clear guidelines, crypto MSBs are in a tough spot; they are expected to develop compliance protocols that adhere to key pieces of legislation like the BSA or USA Patriot Act, yet figure out how to apply traditional finance compliance to a unique and emerging model.
This leads into the second way crypto MSBs are unique in the eyes of regulators. Generally speaking, regulators tend to view emerging technologies as posing a higher level of inherent risk. Crypto transactions are, after all, fast, anonymous, and irreversible. Though crypto transactions are undeniably secure thanks to blockchain technology, they're completely decentralized, meaning there's no federal insurance organ to appeal to if your digital funds are lost or stolen.
A risk assessment is a crypto MSB's way of playing ball with state and federal regulators, despite not having clear guidance on how they should operate. It is also essential operating intel that informs business owners of their risk profile — where their business is vulnerable — which enables entrepreneurs in the space to develop risk mitigation strategies and strong compliance procedures that protect their customers and their livelihood.
Bottom line, a risk assessment tells you, the business owner, what can go wrong with your business, how likely it is things can go wrong, and how much risk you're able to tolerate if you continue to operate.
Pursuant to U.S. legal and regulatory requirements, regular risk assessments are vital components of effective compliance.
That said, risk assessments are not explicitly required of financial institutions, including MSBs in the crypto space. However, operating without an understanding of your risk profile is kind of like driving at night without your headlights on.
Your business might be incredibly vulnerable to money launderers and terrorist financiers, and if you don't have robust protocols in place to identify and report suspicious activity, then you open yourself up to a myriad of problems — reputational damage, loss of business, fines, even jail time.
I can't emphasize this enough — the best way to know what kinds of procedures you need to put in place to protect your business is by performing a risk assessment.
In order to provide business owners with an overall understanding of the risk profile of their MSB with regard to money laundering and terrorist financing, risk assessments should focus on a few key areas.
An evaluation of the adequacy and appropriateness of the policies and controls established by the business in order to comply with regulations and mitigate risk.
Identification of significant risk gaps or weaknesses in the business.
Recommendations to help the business improve its compliance procedures.
A risk assessment should also make recommendations as it pertains to the trending direction of risk and, where appropriate, recommendations on where the business can strengthen controls to manage its risk.
A risk assessment analyzes two kinds of risk: inherent risk, and residual risk. It also analyzes the mitigating controls in place to help a business manage its vulnerabilities.
Inherent risk is the risk profile of your crypto MSB absent mitigating controls, or, how much risk you're exposed to if you do nothing about it.
Residual risk is how much risk remains after factoring in your mitigating controls, or, the amount of risk you have to tolerate regardless of what you have done about it.
Mitigating controls are things like your policies, AML program, protocols for reporting suspicious activity, and other practices that help you manage your risk profile and exercise good compliance.
To put it simply, a risk assessment is going to look at how risky your crypto MSB is before you do anything about it, what you can do about it, and then the risks you should still be aware of even if you do everything you can to protect yourself.
This might lead you to ask how a risk assessment calculates your risk profile in the first place.
A thorough risk assessment will look at things like your business strategy and operating model. If you run a bitcoin ATM that accepts cash, that will have an influence on your risk profile. If you accept in-person transactions, that will as well.
Your customers: If you're B2C or B2B, if your customers are U.S. citizens or not, your customers may pose a risk to your business.
Your services: Again, your operating model, and the risks that it exposes you to.
Your location: If you run your business in a big city, especially one that is designated a HIFCA or HIDTA, you will have a higher risk profile.
Your location also matters if you are in a state where specific regulatory guidance has been handed down to cryptos. If there are regulatory expectations in your state that you are not compliant with, it will increase your risk profile.
The key takeaway here is that a risk assessment will analyze your business across these dimensions: what you offer, who your customers are, and where you're operating. It will then tell you your risk profile and make some recommendations for lowering your risk.
How do I know if I need a risk assessment done?
If you are running a cryptocurrency exchange, a network of ATMs, or any business that could be considered an MSB or money transmitter, you should get a risk assessment done at least once a year, or any time significant changes have been made to your business (you expand into a new area, offer a new service, etc.).
Even if your business has been operating for months and has never had one done, it is an invaluable undertaking and should be done as soon as possible.
Otherwise, you could be an unwitting target for money launderers and terrorist financiers. If agencies like FinCEN or the IRS start tracing criminal transactions to you, and they find that you lack sufficient compliance to combat financial crime then you, too, could be held liable.
Treat it like your dentist or your annual physical and just get it done.
It is not advisable to try and perform a risk assessment on your own. You will need an objective and learned analysis from professionals who understand regulatory nuance, the unique operating model of crypto MSBs, and the profile of financial crime within the space.
Contact BitAML today for a free consultation. We'll help you schedule a risk assessment, and advise you on other strategies for strengthening cryptocurrency compliance and thus, your business. Fill out the form below and we'll be in contact soon!


BETHESDA, Md. (AP) — The suburban Maryland home of the late John Glenn has been sold for $1.3 million.
WTOP in Washington reported Saturday that the dwelling that belonged to the former astronaut and U.S. Senator from Ohio had been on the market for five months.
The Bethesda house sold at the end of August. It was custom built for John Glenn and his wife in the 1990s. It's said to have some of the best views in the area. It overlooks the 11th hole of a golf course.
Glenn became the first American to orbit the Earth in 1962. He served in the U.S. Senate from 1974 to 1999. He died at age 95 in 2016.
This story has been updated to correct the dateline to Bethesda, Md., not Bethesda, Va.


text:
Ward 2 Forum
Serving the Community together.
Report back on Responses received on Commonage articles – 2016-019
During our campaign to inform the Ward 2 community of the intent by TWKM to alienate a portion of the Commonage (Erf # 595), we have tried to separate the undoubted benefits of the fruit farming venture from what we believe to be the unnecessary and illegal sale of the land itself. The fruit farming venture can proceed independently by leasing the land. In fact, it is our considered opinion that the venture would be more viable under a lease arrangement.
We highlight below the responses as received in respect of the various and extensive comments submitted by the community in response to the series of articles published by the Ward 2 Forum on the subject. The topics and points raised have, for ease of reference, been categorised into separate headings:
Spraying of fruit trees with chemicals
Due to the proximity of the proposed fruit farming development to residential areas, sufferers of respiratory ailments such as hay fever and Asthma have expressed concern that spraying of the fruit trees may cause increased problems because of the closer proximity to Greyton, in particular when the wind is from the southeast.
The export-driven fruit industry is managed with a high level of monitoring and control. However, an EIA will have to examine the situation and if it considered that the negative impact of spraying on human health is significant, mitigation measures will have to be considered.
River pollution
The Sonderend River is known to have unacceptably high pollution levels at times, associated with the lack of municipal control of the effluent from both the Genadendal and Greyton sewage facilities. It is hoped that a joint venture between Ward 2 and TWKM will resolve this situation before it becomes too serious. The value of the farming businesses downstream from us is far too important to allow this to continue, but the measures needed for improvement are largely dependent on Government funding and the inclination from TWKM.
Loss of Renosterveld
Concern for Renosterveld areas in the Greyton Commonage has been expressed. Because it occurs in fertile clay-rich soils, the majority of the area has been transformed over the years to agriculture. Less than 2% of the original extent is now formerly conserved. Renowned for spring flower displays, it often has a high grass content, hence its value for grazing.
As part of the EIA, the quality of the Renosterveld areas will be assessed, together with a plan to mitigate further degradation, and possibly to conserve some areas. Cape-Nature and the Overberg Lowlands Conservation Trust will be asked to contribute to this process.
Various views have been taken of the number of employees required to operate a typical fruit farm. An important aspect of the project is the potential employment in particular of local workers. Hortgro, an organisation within the deciduous fruit industry, which is responsible for production, markets and transformation, publishes data for the industry; for example for 2014, the average number of employees per hectare was 1.17 for apple farms and 1.05 for pear farms. The figures are the total permanent equivalent, include seasonal workers. Dependents are said to average an additional 400%.
The financial and social benefits of using as much local labour as possible, which has been confirmed by the Consortium, are very evident in terms of minimising the possibility of having to build houses on the farm, and to provide municipal services.
It is not clear how the expectations of the Ward 2 community will match those of the Consortium.
It is understood in the fruit farming industry that extensive training and development of employees is a major requirement, so that, although local employees are preferred, it is not always possible to guarantee sufficient numbers when they are required.
For this project to be really successful, training and mentoring are considered prime requirements. Some local agricultural educational facility may be considered and discussed as part of the EIA.
This item should be considered an essential element in the PROPOSALS FOR THE PROJECT.
The original prospectus states that no Government funding of the project would be required, except for services of the Land Bank. Additional funds could be available from the Department of Agriculture.
Vigne Legacy – Greyton Commonage
It is clear from our research and documentation obtained from various sources that the Greyton Commonage was intended to be land for the use of all and that the land was never to be alienated. https://ward2forum.org/vigne-legacy-greyton-commonage-report-2016-015/#comment-28. It is the view of W2F that the veracity of the Vigne Legacy and intent is not in dispute and that the onus now remains with TWKM to prove the opposite.
Furthermore we are of the view that the Local Authority does not have the right?? to negotiate any alienation of the remainder of Erf 595.
Rural Development – Greyton Infrastructure
Concern was expressed by many about the current status quo in respect of the Greyton Infrastructure and in particular the road system that would have to cater for additional agricultural and large vehicular traffic, which will be utilising the R 406 through Greyton. This will be addressed in the EIA.
Availability of Water from the Breede-Gouritz Water Management Area (WMA)
It is a known fact that no "free" water is available in the Sonderend River, as all available water has already been allocated to existing farms in the Water Catchment Area. The only water still available would have to be "procured" from existing farms and transferred to the new proposed farming entity that is hoping to develop portion of Erf 595 as a fruit farm. The transfer of water rights, if there are any available, is done by the Dept of Water Affairs in conjunction with the WMA. However, if water is available and motivation good, this could potentially be negotiated between the relevant parties.
Flooding of the project area
The Engineering Report for the Greyton Commonage Spatial Framework Plan (June 2000) refers to the absence of flood line data for the Gobos and Sonderend Rivers in the area of the project. It was recommended that a detailed study should be carried out in order to identify areas suitable for the construction of habitable structures. It was also suggested that minor earth works may be necessary to control the routing of flood waters.
It was stated that agricultural, recreational and sporting activities could be carried out below the 1:100 flood lines, based on their understanding of the probable position of these flood lines.
The possible failure of the category 3 Theewaterskloof Dam was also considered. The inundated area would be expected to cover a wider area than the 1:100 flood lines, but the risk of such failure was stated to be far lower than the 1:100 return period – "it is in fact extremely low and unlikely".
Financial failure of registered owners of 'Newco'
Unfortunately the possible failure of the proposed new business has to be considered as it may lead to the sale of assets of the business, such as the land itself, the subsequent development of which could be against the interests and expectations of the community. This could not occur if the land ownership is retained by TWKM, and it is leased to the business.
This is an ADDITIONAL OBJECTION AGAINST ALIENATION OF THE PORTION OF ERF 595.
Alternative business partners
The proposals made by us originated in the reality of Ward 2, where the whole community must benefit from a significant opportunity such as this project. Farm 39 has sufficient 'spare' land suitable for fruit farming, also adequate water rights. Within this community and the Consortium there should be sufficient labour with the required experience and skills, coupled with training and mentoring, to minimise the need for workers from outside the local area.
Because of our understanding that the elements of a successful business were already available in the area, we have not looked at alternative business models or constituent elements. However, it must be up to all the parties concerned to discuss and negotiate the way forward. Their success will undoubtedly lead to other such ventures.
We will keep you informed.
Should you want to be placed on the Ward 2 Forum Database please email us at the following address mygreyton@ward2forum.org
Ward 2 Forum Team
Author Derek CrabtreePosted on March 30, 2016 Categories All categories, Land1 Comment on Report back on Responses received on Commonage articles – 2016-019
Greyton Commonage Objections (Part 1 of 2). Report 2016-018
The objection in Part 1 only applies to the alienation of the portion of Erf 595 on which the proposed fruit farm project is located. Part 2 proposes an alternative leasehold method of acquiring land for the same project.
Part 2 also identifies various aspects of the farming project itself, which are considered to enhance the benefits for the Consortium of Fruit Farmers, TWKM and the Ward 2 community.
PART 1: OBJECTION TO ALIENATION OF PART OF ERF 595
With reference to the Notice in the Theewaterskloof Gazette on 19 January 2016 for the proposed alienation of about 235 ha of Erf 595 in Greyton at R 4,329,850, and a subsequent Notice in the Gazette of 23 February 2016, extending the period for submission of comments and objections to 31 March 2016, we are hereby submitting an objection to the proposed alienation on the following grounds:
The price of the property
The proposed price of R 4.3 m is based on the valuation of vacant land with no consideration at all for its potential value if professionally marketed with its various features identified. Although still zoned 'Undetermined', which means no Primary or Consent Uses, once rezoned the potential uses of the property could include housing development, agriculture or resort development, representing considerably different land values. In fact, the valuation incorrectly states that the land is 'Authority' zoned. As Commonage, the land has considerable added value because of the grazing of horses and cattle, and recreational uses, enjoyed by the community for over 150 years.
There is no evidence that the longer term future value of this land has even been considered.
The proposed price of R 0.02 m per ha is unrealistically low compared with rateable values (July 2014) of other vacant land in the Greyton Commonage (R 0.05 – 0.08 m per ha). The rateable value of a further area (8,7 ha) of land within the urban edge, although zoned for residential use, but also vacant and without any services, is R 0.33 m per ha.
It seems that the lowest possible valuation of the land has been determined, based on a nominal cultivated 'field price' of R 45,000 per ha, discounted by 60% on the basis that the soil has not been cultivated and contains alien vegetation. However, the prospectus, when considering the financial benefits to TWKM, states that the business will apparently be worth R 150 m when it is mature, which is R 640,000 per ha. The difference between current cost and future business value of over 1400% must be questioned.
It is considered that the price for this property has been hugely under-valued, without any reasonable justification, and therefore does not comply with the requirements of Section 14 of the Municipal Finance Management Act (Act 56 of 2003) which states that:
The municipality has considered the fair market value for the asset, and the economic and community value to be received in exchange for the asset (section 14 (2)(b));
It is further considered that the unrealistic price represents the loss of a potentially highly valuable asset by TWKM, the whole municipal population and in particular the community of Ward 2.
The economic and community value received from the disposal
The disposal of the Commonage land itself is stated in the prospectus to create significant financial benefit for the municipality from Rates and services. However, the Rates payable are dependent on the annual valuation of the land so will take time to grow to the estimated annual potential of R 300,000 and even then will only account for a very small part of the TWKM Rates base.
The net value to TWKM of municipal services, although dependent on the scale of the development, would not be significant.
On the other hand, the provision of bulk municipal services, which would also vary depending on the scale of development, has not been assessed in terms of their availability and the cost of providing them. The prospectus does not include a clause specifying that the buyer of the property is responsible for the full costs of providing the services.
The above benefits are real, but are dependent on the farming business itself, independently of the land disposal. They would be the same if the land was leased at a realistic level instead of being sold off. Therefore they should not be considered to support the argument for sale of the land.
The transfer of ownership is considered to be unfair, inequitable and not competitive in terms of the Municipal Finance Management Act (section 14 (5)), thus making it illegal.
Public Participation Process
TWKM reported that they were in discussions with potential purchasers of this property in 2003, and had earmarked it for alienation for small holdings. There is no reference to this in the SDF of 2003-2005, and the project was abandoned. We requested the Municipal Manager on 3 February 2016 to provide access to Council resolutions relating to the rezoning of the property at that time, but have received nothing.
We have also requested the following information relating to the current proposal, but to no avail:
Minutes of the TWKM Council Meeting at which a vote on the project was taken;
Details of any restrictions in the Title Deeds for the property;
Details of any alternative projects that were assessed in comparison with the proposal.
We have been unfairly denied these documents in time to make meaningful comment on them before the deadline.
There is no record of any attempt by TWKM to communicate with any person who uses the Commonage for any legitimate reason, and there has been no offer of alternative land or financial compensation for these users. Further, there has been no attempt at all to determine the level of support from the residents of the community for the sale of the land.
This does not conform to the Promotion of Administrative Justice Act (No 3 of 2000), particularly section 3 which relates to the fairness of administrative action which materially and adversely affects the rights or legitimate expectations of any person.
Legality of the proposed alienation
4.1 PC.Doc.12/1997: Municipal Commonage policy and procedure:
There is no evidence that TWKM have consulted with the Dept of Land Affairs (DLA), to satisfy themselves that the proposed development will not result in the dispossession of people's rights (formal or informal) granted on or over the Greyton Commonage.
Local people who have rights to graze cattle or horses on the property have not been approached on the matter, and their situation has not been considered. No arrangements have been made for alternative land or financial compensation.
Where town development and urbanisation require Commonage to be sold, wide support from local residents must be obtained. There is not, and never has been, any municipal policy that maintains that this or any other portion of the Commonage is required for the development of Greyton.
The municipality may not alienate, dispose of or sell the Remainder of a Municipal Commonage property but must retain and utilise the said Remainder for public use, which is to ensure that such land is released to the needy local residents for agricultural purposes on a leasehold basis.
The Minister of Land Affairs approved the municipal commonage policy on 12 June 1997, emphasising the fact that municipal commonage is land, which has a public character, and that land needed by local poor residents for agricultural purposes should be made available on a leasehold basis for such purposes.
It is clear that the proposed alienation fails to comply with any of the 4 policy statements above that are the essence of the Government policy issued in 1997.
4.2 TWKM By-law:
According to the TWKM By-law, which was gazetted on 21 June 2015, municipal commonage means land owned by, or under control of, the municipality which has a zoning of 'undetermined' and which may be set aside for grazing or for such other purposes or use as may be deemed necessary by the municipality. There is no reference whatsoever to the possible sale or alienation of Commonage land.
Clearly, the proposed alienation does not comply with the above municipal By-law.
4.3 The Will of Herbert Vigne
It is absolutely clear that Herbert Vigne bequeathed the Commonage to the people of Greyton. Neither the Will, nor the intent, has ever been in dispute. It is considered that if there had been any intent to permit alienation of all or part of the Commonage, contrary to Herbert Vigne's Will, then some evidence would have been found. No such evidence has been found.
There is no known record of the removal of restrictions presumed to have been in the original Title Deeds when the 2 farms Kanon Berg and Boschmanskloof were separated out of Erf 595 to create the Greyton Nature Reserve on 13 May 1977.
Whatever may have actually happened to cast doubt on the validity of the Government policy in relation to Greyton's Commonage is shrouded in mystery. We are aware of only one legal opinion on the possibility of alienating part of the Greyton Commonage – done by Hannes Pretorious Attorneys of Hermanus, as part of the Greyton Commonage Spatial Framework.
There is much confusion in this document, and therefore in the conclusions drawn and recommendation made, that makes one very suspicious of its validity. For example, there is no mention of any record of the removal of restrictions presumed to have been in the original Title Deeds for Greyton and the 2 farms mentioned, but 'apparently' missing from the deeds for the remainder of Erf 595. We consider that if there had been any intent to permit alienation of all or part of the commonage, contrary to Herbert Vigne's Will, then some evidence would have been found.
Therefore, we submit that the onus must be on TWKM to prove beyond all doubt, that they can legally alienate any part of the Greyton commonage.
4.4 Conditions of tender
Although the following Conditions of tender imposed by TWKM are essential elements supporting the decision to go ahead with this project, it is considered that they cannot be enforced in law. If they are not fully complied with, they have no penalties or other forms of compensation attached and therefore are meaningless. The pertinent Conditions are that:
development of the land commences within 2 years of the date of registration of the property;
a minimum of 95 ha of land is developed with deciduous fruit trees;
a minimum of 150 work opportunities are created ;
80% of the workers must be from the Greyton/Genadendal/Riviersonderend area;
Should any of the above conditions fall significantly short of expectations, assuming of course that accurate monitoring of the conditions could be achieved, it is contended that the benefits from the proposed project for the municipality and the surrounding communities will also not be achieved.
This would lead to an unnecessary waste of municipal funds and a reduction of economic and community value from the project, which would be contrary to the requirements of Section 14 of the Municipal Finance Management Act (Act 56 of 2003).
Municipal Policy
Policies and guidelines, relevant to the Commonage, in municipal spatial planning frameworks since 1999, including the most recent SDF of 2012 are:
Conserve the natural resource base and its bio-diversity;
Promote sustainable economic development;
Ensure that the community have continued access for recreational purposes;
No subdivision or alienation of land is permitted;
The desirability of combining small scale farming activities in Greyton and Genadendal;
The introduction of farming activities in the Commonage;
The areas (dark green on the map) to be formally incorporated into the Greyton Nature Reserve in order to protect the ecological role of the Commonage within the context of the mountain catchment area, the river eco-systems and the Greyton Nature Reserve (in process).
The proposal to alienate a portion of Erf 595 is contrary to policies expressed in all the spatial planning framework documents since 1999.This is supported by the absence of any detailed management plan which must surely be a prerequisite to such an important change of policy as the alienation of the Commonage.
Should the Commonage land be alienated, the attraction of Greyton as a tourist destination and a desirable place to live, will be diminished. The Heritage value may also be reduced. The result will be an inevitable lowering of property values.
TWKM will also undoubtedly conclude that they can freely alienate additional portions of the Commonage, further contributing to the decline of Greyton, and further reducing local property values, which would be contrary to the municipal policies for sustainable growth in Tourism.
Environmental Impact not considered
Even though it was admitted that a significant part of the total project land value was not suitable for fruit farming (85 ha of total 235 ha), there is no commitment from the Consortium or condition in the prospectus either to clear and maintain the land free from alien vegetation particularly along the river corridor, or to identify and assess areas of land containing conservation-worthy Renosterveld. Both of these activities represent costs and potential future benefits that should be examined in the EIA, and any approval of the project may be conditional on satisfactory management of these activities.
There is no evidence that the financial implications of these environmental impacts have been considered in the valuation of the land.
Municipal Support for Alienation
The TWKM prospectus focuses on the 'sale of a portion of Erf 595 for BEE commercial farming', but fails to contemplate the separation of the project into 'alienation of the land' and formation of a BEE venture 'to promote investor friendly practices …… leading to increased employment and growth in rates base …' It is argued that the BEE venture itself is not dependent on alienation of the land, and could indeed have more financial and social benefits through the alternative of a leasehold agreement instead.
The municipality fails to consider this argument in the prospectus. A special Ward 2 Committee meeting on 5 October 2015 records that 'the committee noted and awaits the outcome of the project plan as presented'.
Clearly, neither document constitutes a vote of approval or agreement for the alienation of a portion of the Greyton Commonage.
Furthermore, TWKM failed to consider any alternatives to the proposed alienation, in particular a leasehold agreement.
We strongly object to the alienation of approximately 235 ha of a portion of Erf 595, being part of the Greyton Commonage, on the grounds stated above.
However, our objection only applies to the actual alienation itself, and not to the whole project. Therefore, if the project can be revised to accommodate a leasehold agreement, we offer our support conditional on a number of additional proposals in Part 2 that we believe would be beneficial to all the parties concerned.
Part 2 will be issued as a separate document.
PART 2: PROPOSALS FOR THE FRUIT FARMING PROJECT as per previous article.
Author Derek CrabtreePosted on March 30, 2016 Categories All categories, Land3 Comments on Greyton Commonage Objections (Part 1 of 2). Report 2016-018
Final Report and Recommendations on proposed Commonage Sell-off 2016-017
GREYTON COMMONAGE SELL-OFF [Report 7.3 of 7]
Herewith the last in the series of comments on the proposed alienation on the Portion of Erf 595 as envisaged by the Local Authority. What will follow hereafter is a Summary of the numerous comments as received from the Community in response to the articles as published by the W2F (Ward 2 Forum) team.
The full document as submitted to TWKM by the Ward 2 Forum Team will also be published for general information to the W2F database & on Social Media.
The following proposals are part of a larger concept that includes a considerable increase in the area of the Greyton Nature Reserve. The community of Farm 39 intends to register Bakenskop & potentially parts of Snyerskraalkoppe, to the West of Loerkop, as a Nature Reserve. This will eventually form part of the proposed Greyton/Genadendal Biosphere.
PROPOSALS FOR THE FRUIT FARMING PROJECT IN WARD 2
Click on the image for full size
The grounds for objection to the alienation of portion of Erf 595, the Greyton Commonage, are considered a reasonable basis to allow the main parties concerned – TWKM, Consortium, and the Ward 2 community to contemplate an alternative outcome for this joint venture. W2F proposes that the Consortium, their labourers and Farm 39 (Genadendal) enters into a joint venture whereby:
A new company is formed with the above parties as shareholders. The shareholders' contributions are illustrated in the accompanying graphic.
The major portion of the fruit farming, as envisaged, is not done on the proposed portion of Commonage, but on a 200ha portion of Farm 39, whilst a portion of the Commonage is retained for grazing, a biological corridor and current recreational activities. This arrangement will have much less impact on neighbouring Greyton and addresses most of the concerns noted from Greyton residents.
The Consortium leases a portion of the Commonage land for the farming of fruit, as envisaged;
TWKM retain ownership of the Greyton Commonage, and its intrinsic value, through a medium term leasehold arrangement for the land to be used;
Minimum infrastructure for the farm, no residential housing for workers;
Ward 2 acquires a new sustainable business, labour intensive, mostly local labour, who will have the added benefits of ownership through dividend-paying shares in the business;
Some of the Commonage to be managed for grazing, which could be improved by additional water availability from Farm 39;
Mutual agreement between the Consortium and Farm 39 for additional leased land and water rights for fruit farming on Farm 39, further ensuring employment of local labour;
The amenity value of most of the Commonage to be retained for the community (MTB biking, riding, walking etc);
Suitable remnant Renosterveld areas to be protected;
Facilitate & register a Biological corridor, connecting parts of the Nature Reserve and separating farmland from Greyton;
The areas Knietjieshoogte, Maermanskloof and Loerkop that were designated in 2000 and confirmed in the SDF (2012) to be formally incorporated into the Greyton Nature Reserve, and having recently been surveyed as such, must be proclaimed and finally gazetted by TWKM;
Clearance of Sonderend River of alien trees and protection of the river banks.
Energy-efficient tourism project along Sonderend River to be considered for the future;
The benefits for all the parties concerned are evident:
Seasonal labour problems are minimised;
Need for new housing and additional municipal services is minimised;
TWKM retains ownership of an asset of significantly higher value than the proposed sale price;
Additional opportunities for joint ventures between Farm 39 and the Consortium.
The aims and intent of the Government Commonage policy are met;
The Will of Herbert Vigne who created Greyton and its Commonage will be honoured;
Community approval is anticipated to be widespread;
Platform from which to launch similar projects throughout the Overberg.
This alternative is an intrinsic part of our objection to the original proposal and as such should be considered together with the objection. This is the preferred concept from Ward 2 Forum, which is subject to modification and agreement between all parties concerned. There could be significant changes resulting from the EIA and the public participation process, from input from TWKM, the Consortium and Breede-Gouritz Catchment Management Area and after detailed discussions with the Departments of Agriculture, Land Affairs & Water Affairs.
Should you wish submit an objection to the proposed Alienation of the Portion of Erf 595 by TWKM please note these have to be submitted to TWKM, by latest 31 March 2016:
Address your objection to:
The Municipal Manager (Stan Wallace)
Theewaterskloof Municipality,
6 Plein Street,
Caledon 7230.
The submission can be handed in at the Municipal office in Greyton (DS Botha Street) or via Email to stanwa@twk.org.za, please ensure that you CC the following when submitting via email:
Cc: records@twk.org.za
Cc: annettesw@twk.org.za
Author Derek CrabtreePosted on March 29, 2016 March 29, 2016 Categories All categories, Land2 Comments on Final Report and Recommendations on proposed Commonage Sell-off 2016-017
Report 2016-015 – Greyton Commonage Sell-off (7.2 of 7)
After discussions with the parties concerned, Ward 2 Forum considers that it is essential that TWKM is persuaded not to alienate part of Erf 595. Objection is based on legal, financial and social grounds. The proposed fruit farming project should be broadened to include additional features that should substantially increase the benefits for the Consortium, TWKM and the Ward 2 community.
As part of overall Social & Economic growth planned for the region, more emphasis needs to be placed on the longer term planning prior to any development taking place. We are of the view that sustainable economic and rural development cannot be left to the agricultural sector alone, as the participation of the private sector, business sectors and the community as a whole need to be part of the process going forward.
Whilst Agriculture is currently the biggest contributor to the regions GDP, other sectors such as Tourism need to step up to the plate as well. Agricultural growth will require infrastructural growth; currently the only viable route to "market" for the farms with their produce is through Greyton. With the huge expansion in fruit farming in our valley by existing fruit farms already in production and soon additional farms down the R406, will be come into production as well which will necessitate alternative transport routes to cater for the expected growth in traffic a by-pass may become vital for Greyton
It is with these critical issues that the Ward 2 Forum has engaged with all interested and affected parties to find workable solutions that would not hamper growth but rather sustain planned growth that would benefit all equally.
SUMMARY OF OBJECTION TO ALIENATION OF PART OF ERF 595, GREYTON
With reference to the Notice in the Theewaterskloof Gazette on 19 January 2016 for the proposed alienation of about 235 ha of Erf 595 in Greyton at R 4,329,850 an objection to the proposed alienation can be made on the following grounds:
The price of the property:
It is considered that the price for this property has been hugely undervalued at R4.3 m, without any reasonable justification, and therefore does not comply with the requirements of Section 14 of the Municipal Finance Management Act (Act 56 of 2003).
The proposed price of R 0.02 m per ha is much lower than the rateable values (July 2014) of other vacant land in the Greyton Commonage (R 0.05 m – 0.08 m per ha). The rateable value of a further area (8,7 ha) of Greyton, although zoned for residential use, but also vacant and without any services, is R 0.33 per ha.
Public Participation Process:
We have been denied relevant information on Title deed restrictions, servitudes, Minutes of relevant Council meetings, which should have been supplied timeously for us to be able to scrutinise them properly.
This is contrary to Government legislation and the Constitution of South Africa, and has prevented the community from having access to information which may be relevant to the legality of the alienation.
Compliance with Municipal Commonage policy and procedure (PC.Doc.12/1997):
Local people who have rights to graze cattle on the property have not been approached on the matter, and their situation has not been considered. No arrangements have been made for alternative land or financial compensation.
Where town development and urbanisation require Commonage to be sold, wide support from local residents must be obtained. There is not, and never has been, any municipal policy that proposes that this or any other portion of the Commonage is required for the development of Greyton.
It is clear that the proposed alienation fails to comply with any of these policy statements.
Compliance with TWKM By-law:
According to the TWKM By-law, gazetted on 21 June 2015, municipal commonage means land owned by, or under control of, the municipality which has a zoning of 'undetermined' and which may be set aside for grazing or for such other purposes or use as may be deemed necessary by the municipality. There is no reference whatsoever to the possible sale or alienation of commonage land.
Clearly, the proposed alienation does not comply with the TWKM By-law.
The Will of Herbert Vigne
Conditions of Tender
The following Conditions of tender imposed by TWKM cannot be enforced in law. If they are not fully complied with then the benefits from the project cannot be achieved, and as there are no penalties or other forms of compensation attached, they are therefore meaningless. The pertinent Conditions are that:
development of the land starts within 2 years of registration of the property;
a minimum of 95 ha of land be developed with deciduous fruit trees;
a minimum of 150 work opportunities to be employed;
80% of the workers must be from the Greyton/Genadendal/Riviersonderend area.
Failure to comply with the Conditions would lead to an unnecessary waste of municipal funds and a reduction of economic and community value from the project, which would be contrary to the requirements of Section 14 of the Municipal Finance Management Act (Act 56 of 2003).
The proposal to alienate a portion of Erf 595 is contrary to all the spatial planning framework documents since 1999. Specific policies and guidelines that are relevant include:
Ensure that the community have continued access for recreation purposes;
No subdivision or alienation of land;
The introduction of farming activities in the Commonage.
The absence of any policy that supports alienation of any portion of Erf 595 must be taken into account.
Should our objections fail and the Commonage land is alienated, the attraction of Greyton as a tourist destination and a desirable place to live, will be diminished. The Heritage value may also be reduced. The result will be an inevitable lowering of property values.
TWKM will also undoubtedly conclude that they can freely alienate additional portions of the Commonage, further contributing to the decline of Greyton, which would be contrary to the municipal policies for sustainable growth in Tourism.
The TWKM prospectus focuses on the 'sale of a portion of Erf 595 for BEE commercial farming', but fails to contemplate the separation of the project into 'alienation of the land' and formation of a BEE venture 'to promote investor friendly practices …… leading to increased employment and growth in rates base …' It is argued that the BEE venture itself is not dependent on alienation of the land, and could indeed have more associated benefits through a leasehold agreement instead.
Clearly, neither document constitutes a vote of agreement for the alienation of a portion of the Greyton Commonage.
Author Derek CrabtreePosted on March 25, 2016 March 25, 2016 Categories All categories, LandLeave a comment on Report 2016-015 – Greyton Commonage Sell-off (7.2 of 7)
Vigne Legacy – Greyton Commonage Report 2016-015
Ward 2 Forum Information Document
We thank you for the tremendous support & encouragement received during this Commonage Campaign
During the research done by the Greyton Heritage Museum on Greyton and surrounds, some incredible information has been found, the information gathered has only proven that substantial more time and energy needs to be spent on further research. As part of this ongoing research, contact has been made with previous residents of the village and families of original inhabitants of the area, the objective is to piece together as much of the information so that a proper history of our valley can be collated.
In a bid to get the information into the public domain, The Ward 2 Forum in conjunction with the Greyton Heritage Museum will publish all information through the website and the social media platforms. It is envisaged that a manuscript will eventually be produced for the print media and eventual final publication.
The map hereto attached was produced in 1839 and has been amended from time to time as development on the Weltevreden Estate (now known as Erf 595) took place. Interesting to note the river names then, and the route of the Genadendal – Riviersonderend road (now R 406).
Below are some extracts of the original 1854 "Conditions of Sale" document that was made available to us by Keith Radmore (great grandson of Herbert Vigne).
Extracts from Conditions of Sale of Erven in the projected Village of "GREYTON", situate on the Estate WELTEVREDEN, in the Division of Caledon, held on the 27th, and 28th days of November 1854.
To the said extent of Morgen as hereinbefore mentioned, so set apart to form and constitute the said Village, the Seller attaches and cedes, as Town Common, the remainder of land of his Estate Bosjesmanskloof, which Estate is in whole extent 1,866½ Morgen, or 3,733 Acres, as will be seen by the original Diagram thereof, dated the 5th day of February 1839, which shall remain for ever inalienably appropriated as such Town Common exclusively …….
The Pasturage on the said Town Common, shall be appropriated exclusively to the use of Proprietor of Erven, and the Occupants of Erven under the authority of Proprietors, and to the use of bona fide Travellers to and from the Village ……
Author Derek CrabtreePosted on March 24, 2016 March 24, 2016 Categories All categories, Land2 Comments on Vigne Legacy – Greyton Commonage Report 2016-015
For ease of reference and due to the length of the last report, we have subdivided 7 of 7 into 3 separate documents. Herewith the first of the 3 final sections.
There are 2 separate issues involved. Firstly, the question of whether any part of the Greyton Commonage should be sold, which would prevent TWKM or the community ever having any influence over future uses of the land. Secondly, there are alternative or additional uses for the Commonage, that are briefly discussed below.
Alienation of the 235 ha land area
Government policy only permits the alienation of municipal Commonage for development purposes that will not result in any loss of local people's formal and informal rights, and where there is substantial evidence that the development enjoys the wide support of local residents.
Alternative to alienation
The only alternative to outright purchase of the land is a renewable lease, possibly reverting to municipal ownership after say 50 years. It is considered that the leasehold cost should reflect the actual land areas used for agricultural purposes, thus allowing possible additional uses in the areas not suitable for intensive agriculture, for example conservation, recreation, specific community projects and tourist-related uses. Such a compromise seems to represent the spirit of Government policy on Commonages, but at the same time encourages viable and sustainable business ventures such as specialised farming. Furthermore, the future asset value of the land is retained for the benefit of the municipality and the community.
Alternative agricultural projects:
Intensive fruit farming in the Overberg, particularly in the Riviersonderend river valley, has expanded significantly during recent years, largely for the export market. To be viable, it is said that 100-150 ha minimum are needed, water is essential (up to 6000 m³ per hectare per annum) and labour, some of which is seasonal, must be suitable for training and mentoring. The soil requirements have been assessed and confirmed by the Department of Agriculture to be suitable. Yet to be done is a detailed plan for the preferred areas to be cultivated and the layout of infrastructure and services.
The grazing of cattle as practised on the Commonage now, where the land is partially degraded and water is very limited, is only just viable, and needs only limited labour. However, intensive dairy farming is possible throughout this area on land transformed totally to grassland, with adequate water, but labour requirements are also limited.
Pomology farming which is the preferred use for a significant part of the project land is established in the area as a viable business, but there is limited suitable land available, and water rights are often not obtainable. Labour requirements, both permanent and seasonal, are significantly higher. The successful training and mentoring of local persons could obviate the common process of migrant labour, thus removing the necessity of providing housing and additional municipal services, in an area already with a high rate of unemployment and very limited services.
Honeybush harvesting based on existing areas of natural growth could assist the expansion of the existing small-scale business in Genadendal.
Fynbos farming may be an alternative for the future with lower water needs and a hotter climate.
Domestic firewood management using a community woodlot would ensure sufficient firewood available for the whole community.
Other alternative activities:
Residential housing would probably not be viable because of the costs involved in providing full municipal services (maybe including tarring of part of the Riviersonderend road), the regular inundation and possible flash flooding from the Gobos and Sonderend rivers. Housing development would also not comply with municipal policy, and would be outside the urban edge.
Recreational activities could be considered in parts of the area not being farmed, including grazing for horses and donkeys, MTB biking, walking, horse riding, dog exercising, camping site, birding, picnics.
Tourism-related development might be considered for the longer term, particularly along the Sonderend River, possibly an energy-efficient, low density, high quality tourist lodge.
Biological corridor
The establishment of a biological corridor from north to south would connect the different segments of nature reserve and help to ensure the long-term viability whilst also serving as a buffer zone & green lung between the proposed commonage agricultural development and the residential areas of Greyton village.
No-Go alternative Activities now in the proposed project area include some of the above recreations and some local small farmers use the land for grazing. Alien vegetation has been partly cleared. Mature wood has been harvested. There is at least one sand pit. With the exception of bike trails, the area is not used much by tourists.
Letter to the Mayor re Adjusted Budget Expenditure
Click here to View the Letter
Author Derek CrabtreePosted on March 22, 2016 March 22, 2016 Categories All categories, Public Participation Process, Whats HappeningLeave a comment on Letter to the Mayor re Adjusted Budget Expenditure
Report 2016-013 – Greyton Commonage Sell-off (6 of 7)
Since 1999 there has been a consistent view on the possible future land uses for this part of Erf 595, which has been documented in various municipal planning reports.
The spatial development framework (SDF) is a fundamental part of longer term planning. It encourages consideration of potential spatial developments, and gives opportunities for open discussion between the community and the municipality.
The Greyton Commonage Spatial Framework Plan was compiled during 1999-2000 and contains broad guidelines and conservation/development proposals for the future use of the Commonage. The document shows that a broad public participation process was followed.
The following general goals were identified:
Protect and enhance Greyton's rural/country character;
Consider agricultural small holdings in area 6;
Promote sustainable economic development, especially tourism.
Policies and strategies for planning areas 4 and 5:
Assess opportunities for low intensity recreational use;
Rezone to Open Space III (LUPO), where the only use is Nature Reserve, as buffer zones;
No agriculture, except harvesting of natural resources;
No mining, quarrying, waste disposal facilities, public infrastructure;
No subdivision or alienation of land.
Policies and management guidelines for planning area 6:
Low intensity land uses only – agriculture, recreation and tourism;
Structures/buildings to conform strictly with architectural and aesthetic guidelines;
Flood line investigation necessary;
Detailed agricultural investigation before any development permitted.
SDF (2003-2005)
Policy was restated that no portion of publically owned agricultural land should be sold, or leased for more than 10 years (renewable). Two relevant Integrated Development Plan (IDP) projects were identified for investigation:
The Commonage Program that is controlled by the Dept of Land Affairs is responsible for assisting municipalities to develop conditions that enable poor residents to access existing Commonage. Clearly TWKM, in proposing to sell off a significant part of our Commonage having no plan to manage it or to consult the community in regard to appropriate and sustainable land uses and activities. There are grants available and training to assist small-scale farmers.
SDF (2012)
The policies and guidelines above were confirmed in the SDF (2012). It was also proposed that the areas (dark green on the map) be formally incorporated into the Greyton Nature Reserve in order to protect the ecological role of the Commonage within the context of the mountain catchment area, the river eco-systems and the Nature Reserve.
Agriculture was considered a potential land use for the proposed project in 1999-2000, subject to confirmation of adequate soil quality. During the last 15 years, fruit farming has expanded significantly, not least in the Sonderend river valley. The northern adjacent property is part of Zand Vlakte (Farm 136) an intensive dairy farm that has been totally transformed to grassland and crops.
We consider there is strong support for a mix of land uses in this area of the Commonage that would bring significant benefits to the communities of Ward 2 whilst also meeting the requirements of government policy and the expectations of Greyton residents.
Author Derek CrabtreePosted on March 21, 2016 March 21, 2016 Categories All categories, Land3 Comments on Report 2016-013 – Greyton Commonage Sell-off (6 of 7)
This article attempts to assess the value of the part of the Greyton Commonage that TWKM intends to sell. The prospectus says that no municipal general valuation could be obtained, and confirms that a fair market valuation must be used. The benefits to each party involved are outlined.
PROJECT VALUATION
RATEABLE VALUES AND PROJECT COST
The valuation of R 4,329,850 is stated to be the 'market-related price'. This was said at the open meeting on 3 March'16 and will be ring-fenced. The valuation of such a large area (235 ha) seems to be grossly under-estimated.
The Valuation roll of July 2014 has an entry for Erf 595 of R 8.34 m, although the Erf area is only shown as 14.2 ha (data for previous years shows similar figures). The area is obviously incorrect, but is the value thus also incorrect?
Other property valuations (July 2014) Per hectare
Large plot inside Greyton's urban edge, vacant, with no services R 3.5 m
House on large plot in Greyton R 1.6 – 4.6 m
Vacant erven (3) in Commonage5,0 – 8,5 ha, no services R 0.05 – 0.08 m
Erf 530 (8,7 ha) vacant, zoned residential, no services R 0.33 m
PROPOSED COST of part of Erf 595 (235 ha), vacant, no services, with access R 0.019 m
This valuation must be challenged.
BENEFITS FOR TWK MUNICIPALITY
The prospectus implies that municipal rates will be R 0.25 m per annum, based on the value of the farm. However, until the farm becomes fully operational, the rateable value will be nearer to the purchase price, producing under R 9000 rates per annum. The initial cost should therefore reflect this long term value, rather than the arbitrary value agreed by TWKM. The alienation would also remove any responsibility for TWKM to formulate any plan for the management of the land.
It has been assumed that all bulk services will be funded by the purchaser. This is not actually stated in the prospectus, and in any case has not been detailed.
Although TWKM state that they will benefit from the service charges, this may not be the case because some services, for example potable water, are already inadequate and will require considerable capital investment to provide in the future.
MINIMAL BENEFITS FOR WARD 2
The project as it is will certainly provide some business opportunities for Ward 2, but they would seem to be marginal, although any sustainable employment has to be a benefit. There is unlikely to be any positive effect on Tourism; if the traffic impact, dust and noise become significant, the effect will be harmful.
The TWKM prospectus claims that a capital investment of approximately R 80 m will be required to develop a viable business. There is no breakdown of this figure to indicate how much expenditure will be on land clearance and preparation, buildings and infrastructure, and equipment. Expectations of significant local business expenditure are not considered to be realistic.
LOSS OF BENEFITS FOR GREYTON
Development of this project will not benefit Greyton, other than by some additional albeit unquantifiable local employment. There will be environmental impacts, the permanent loss of some natural vegetation, the permanent loss of grazing land for small farmers, the loss of amenity value for those who bike, walk, ride horses, collect firewood etc. Intense agricultural activities will be much closer than before to the residential areas of Greyton.
BENEFITS FOR PROSPECTIVE CONSORTIUM
Acquisition of additional farmland at a very low cost;
Financially viable and sustainable business venture;
Additional BBBEE points score for all the participating farmers;
Please note that this series of articles is aimed at giving an unbiased view, based on the points of view expressed by all the relevant parties and the collection of information related to the alienation of the Greyton Commonage. The series will culminate in a final document that will incorporate a full & comprehensive proposal that should address the expectations of all involved but with the prime objective of ensuring we as a community foster Rural Development in a viable and sustainable manner that would benefit all.
Author Derek CrabtreePosted on March 18, 2016 Categories All categories, Land1 Comment on Report 2016-012 – Greyton Commonage Sell-off (5 of 7)
Is alienation of the Greyton Commonage legal and is it necessary? This question is central to the proposal for a fruit farm in Greyton.
THE COMMONAGE BELONGS TO THE COMMUNITY
It is absolutely clear that Herbert Vigne bequeathed the Commonage to the people of Greyton. Neither the Will, nor the intent, has ever been in dispute.
According to the TWKM By-law, which was gazetted on 21 June 2015, municipal commonage means land owned by, or under control of, the municipality which has a zoning of "undetermined" and which may be set aside for grazing or for such other purposes or use as may be deemed necessary by the municipality. There is no reference whatsoever to the possible sale or alienation of commonage land.
Whatever may have actually happened to cast doubt on the validity of the above policy in relation to Greyton's commonage is shrouded in mystery. We are aware of only one legal opinion on the possibility of alienating part of the Greyton Commonage – done by Hannes Pretorious Attorneys of Hermanus, as part of the Greyton Commonage Spatial Framework Plan. It is in Afrikaans, dated 22 November 1999 – prior to the creation of TWKM. Salient features of the document, translated, are:
The document was not translated into English which is the language of the rest of the Framework Plan;
No mention is made of the legality of Herbert Vigne's Will bequeathing the Commonage to the people of Greyton;
The farms Kanonberg and Boschmanskloof were registered under Act 15 of 1887 in the name of the Greyton municipality, and which has subsequently became the Greyton Nature Reserve;
Restrictive conditions have been removed from the Transfer Title Deed for Erf 595 (Commonage and Nature Reserve together);
In respect of the remaining portion of Erf 595, there appears to be no restrictions on transfer of the land;
There is much confusion in this document, and therefore in the conclusions drawn and recommendation made, that makes one very suspicious of its validity. For example, there is no mention of any record of the removal of restrictions presumed to have been in the original Title Deeds for Greyton and the 2 farms mentioned, but 'apparently' missing from the deeds for the remainder of Erf 595.
We consider that if there had been any intent to permit alienation of all or part of the commonage, contrary to Herbert Vigne's Will, then some evidence would have been found.
Therefore, we submit that the onus must be on TWKM to prove beyond all doubt, to the satisfaction of the community, that they can legally alienate any part of the Greyton commonage.
SUMMARY OF GOVERNMENT POLICY
PC.Doc.12/1997 Municipal Commonage: policy and procedure is relevant.
Where a portion of the properties, formerly known as Municipal Commonages, is to be utilised for development, the municipality must, in consultation with the Dept of Land Affairs (DLA), satisfy themselves beforehand that such development will not result in the dispossession of people's rights (formal or informal) granted on or over such commonage land. In the event that people's rights are affected, it is a prerequisite that other arrangements satisfactory to those people have been made.
Furthermore, the municipality may not alienate, dispose or sell the Remainder of such a Municipal Commonage property but must retain and utilise the said Remainder for public use, which is to ensure that such land is released to the needy local poor residents for agricultural purposes on a leasehold basis that fosterers and facilitates Rural Development.
The DLA will also actively discourage the selling of commonage, except where this is clearly required for town development and urbanisation which enjoys the wide support of local residents.
The reasons for distinguishing 'Commonage' land from other municipal land clearly relate to the actual or proposed use of the land – for needy local people. The primary uses of the Greyton Commonage have been the grazing of farm animals and recreational activities. Should this property be alienated then the existing rights of the local people would be removed.
It is pointed out that alternative BBBEE projects for fruit farming could be considered for the same area of land, but on a leasehold basis. Any decision must take into account the dominant and widespread view of the community. The future amenity value of this area of land, if alienated, will be lost to the community and the municipality will have given away a financial asset of significant value, far exceeding the proposed 'give away' price.
The proposed project should be reconsidered on the basis of the sustainable long term interests of the Ward 2 community and the municipality.
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