a) SANRAL will demonstrate that the land claimed is incapable of being restored to the claimants.
b) The main points to be contained in our submission will be that (i) a road which carries a high volume of economically important traffic has been built on the properties at great cost and, (ii) further property has been acquired for future road widening and improvements at significant cost, which cannot be alienated without affecting our ability to carry increased traffic volumes in future.
c) SANRAL does not currently have an alternative plan and would have to start afresh with planning an entirely new route on another alignment.
d) It is impossible to estimate the costs of building an alternative route without first investigating the possible alternative alignments.