Letter: To Mec Bredell on proposed WesCape development

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To: MEC Anton Bredell
Local Government, Environmental Affairs & Development Planning
Private Bag X9186
Cape Town, 8000

29 May 2013

Dear Minister Bredell

Amendment of the Cape Town Spatial Development Framework to extend the urban edge for the proposed WesCape development.

We understand that you are currently considering the application for amendment of the Cape Town urban edge to accommodate the WesCape development, which the Cape Town City Council has recommended to your office for approval. We argue here that the City Council’s support for this application is ill-considered, being in clear violation of Council’s own policies and plans. As such, we urge you to decline the application.

The Cape Town City Council adopted the Cape Town Spatial Development Framework (SDF) in May last year, after a long process of public participation, research and consultation. This process included your consideration and approval of the framework. It is our understanding that the SDF is a component of the Integrated Development Plan, in terms of the Municipal Systems Act 32 of 2000. We note that Section 35 of this act states:

(1) An integrated development plan adopted by the council of a municipality-

(a) is the principal strategic planning instrument which guides and informs all planning and development, and all decisions with regard to planning, management and development, in the municipality;

(b) binds the municipality in the exercise of its executive authority, except to the extent of any inconsistency between a municipality’s integrated development plan and national or provincial legislation, in which case such legislation prevails;

Although City Council has the power to amend certain aspects of the SDF, we believe that decisions in contravention of the current SDF not only present problems of inconsistent governance and disregard for civic process, but are also in conflict with the intentions of national legislation.

On 5 December 2012, the Cape Town City Council made a decision to support the WesCape application to amend the urban edge. As you will know, the WesCape proposal comprises over 3000 hectares of commercial, residential and industrial development, with a projected population of 800,000. The site lies over 10 km from the nearest existing built-up area, and has virtually no existing infrastructure in place. It is situated entirely outside the urban edge, which the SDF defined as the feasible and desirable limit for horizontal expansion of the Cape Town urban area over the next 15 years. Council’s support of this development contradicts the SDF in numerous ways, as follows.

The SDF sets out clear expectations of how alterations to the urban edge should be considered. According to the SDF, any such changes should be “City-led” and should not be encouraged “unless exceptional and unique circumstances exist”. The SDF holds that:

Reactive amendments to the Urban Edge, requiring bulk infrastructure investment not forming part of the City’s infrastructure investment plans cannot be approved without absolute clarity and approval of both the cost of installing the infrastructure and the impact of the development on the City’s operating costs. [emphasis added]

Council minutes show that this clarity was not obtained prior to approving the WesCape application.

Policy 16 of the SDF commits to “discourage major economic development… outside of established urban nodes” – the WesCape development is far removed from any existing urban node or development corridor.

Policy 24 of the SDF is to “direct urban growth away from hazardous areas” – the WesCape site lies inside the evacuation zone of Koeberg nuclear power station.

Policy 28 of the SDF commits to protecting agricultural land, including existing farmed areas – the WesCape site will occupy large areas of long-standing and currently utilised agricultural land.

And Policy 31 of the SDF is to “prevent urban development from intruding into the rural environment”.

These extracts show a jarring contradiction between Council’s undertakings in terms of the SDF, and its support for the WesCape application. We further note that Council’s disregard for the policies of the SDF, with their broad consultative basis, undermines an important mechanism of participatory democracy in Cape Town. The public participation process for the WesCape application, by contrast, received only five non-governmental comments, which indicates completely inadequate consultation when considering the scale of the proposed development.

We also note that the City’s own municipal officials submitted a report to Council’s Economic, Environment and Spatial Planning Portfolio Committee which concluded in no uncertain terms that support for the application should be refused. However, the Portfolio Committee instead recommended that the application be supported, and the application was subsequently approved.

Approving an amendment of the urban edge under these circumstances would grant Provincial recognition to a decision-making process that has disregarded key mechanisms of public participation, ignored expert opinion, and contravened Council’s own policies and plans. Such decisions cannot be reconciled with good governance. We therefore urge you to decline the WesCape application.

Kyle Mason-Jones
For and behalf of the Greater Cape Town Civic Alliance

1 comment to Letter: To Mec Bredell on proposed WesCape development

  • Craig Sharland

    It now makes perfect sense why the Department of Water Affairs is targeting small farmers in and around Atlantis with regard to water extraction from the adequate water supply from the Atlantis Aquifer , all unregistered boreholes are shut down and any new applications are rejected. This has stopped growth and the desperately needed jobs to this area, in my case two farms that had the potential of employing 40 staff (effecting a possible 400 people) financially has been put on hold for this reason.

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