Position Statement: Planning and Land Use Management

Position Statement -PLUM – Planning Land Use Management – GCTCA Sub-Committee

We believe that our prime function as a civic association is that of ‘watchdog’; to draw urgent attention to situations or applications which will lead to (now or later) unsustainable practices and situations where infrastructure and environment will be compromised.  This sort of thing will lead to unsustainable development which will inevitably compromise the community and the environment, but, by that time, it will be too late to do anything about it. The developer moves on to another project, having made his/her profits, and the community is left to shoulder the consequences.

So what do we do?

While realizing that developers play a valuable role in society in providing the engines for the development of cities and towns, we also realize that they do need to be curbed to a certain extent, particularly when the development is not sustainable, or when the necessary infrastructure is not available (or potentially available) or when the development is just not desirable and does not fit into the City’s Policies and/or the existing plans for the area.

There are some parts of the City that are ‘special areas’ due to theirunique circumstances, its physical restraints (like the difficulty of access), their natural attributes which have been acknowledged as worth conserving, including  their‘rural’ ambiance.

Currently many developers are virtually given carte blanche to do more or less what they want because they are perceived to be the providers of jobs and agents of city ‘densification’.  While jobs are obviously important to communities, job provision is not an appropriate reason to allow or dis-allow a proposed development.  The recent Council obsession with ‘densification at all costs’ stems from the reasonable realization by the Urban Edge studies that densification of cities is desirable in that it can help curb ‘urban sprawl’ into valuable farmlands and sensitive natural areas.  We understand this.  The Cape Town Spatial Development Framework (CTSDF) applied this principle sensibly, by advising that densification be first encouraged along the major arterial routes where infrastructure is available and the need to densify is greatest.

Some areas were never even considered as a target area, but developers were quick to pick up on the idea because they used it as justification for rezonings, departures, sub-divisions, etc. because the financial pickings are much greater here than on the Cape Flats, for example, where the need for development is much greater and more desirable.
The Council, on the other hand, should have been the appropriate ‘curb’, but the majority on the recent Spatial, Planning, Environment, Land Use Management committee (SPELUM) was so mesmerized by the idea of more and more rates to pay for their many schemes and salaries, that it seems they were only too happy to “pass all applications in the name of densification”.  They applied a “one scheme fits all” policy and ignored the essence of the local plans, development frameworks, policies, etc. as well as the desirability within the local context and whether the infrastructure had the potential to cope.

  • Natural scenic vistas must be protected and inappropriate development on mountainsides must be prevented by applying strict contour lines above which no development must occur.
  • The City must not apply short term solutions which are not sustainable, especially given that growth and subsequent shortages of natural resources are envisaged. (e.g. untreated outfall sewers = defaecating in our own nest + impacts on marine environment + impacts on future desalination, which might be a solution to shortages of water).
  • The city must apply an inclusive Public Participation Process whereby every person has the right to comment or object to any change of land use and be empowered through an informative notice to do so.

As a responsible Civic Alliance we need to be mindful of sustainable development and the fact that it is not in the public interest to further densify without thought of infrastructure in any significant way. We need, rather, to promote the provision of facilities for the existing population and we need to protect the environment and the sense of place that is so special to the many areas in the Cape Town Metropole.

We are also very aware that developers (and indeed some of the Council) repeatedly motivate densification in many areas by referring (incorrectly) to the CTSDF densification policy for the greater Cape Town as justification for obtaining rezonings and departures from regulations to support their development proposals.  We point out categorically that the Cape Town Spatial Development Framework (CTSDF) densification policy (laudable as it may be) was never intended for ‘special areas’ in Cape Town.

Many areas are already over-developed and do not have the capacity to extend infrastructure sufficiently to accommodate such densification which would also, in the end, degrade the environment and the ‘sense of place’.

Rather, the densification policy was specifically intended for areas along the major urban transport routes, areas where there are significant transport facilities (or potential for the provision of transport infrastructure) for serving the products of such densification.  Many of these areas are, in any case, not optimally developed and the communities along them (and to the sides of them) would benefit from such improvements to their areas.  We suspect that because these areas are generally not particularly affluent areas, developers are not so keen, as their profits would not be as great as they would be in more desirable areas.  We believe it is the responsibility of local government to encourage development into the areas where it is most needed, rather than where it will pay handsome profits to the developers at the expense of the community and the environment.

We further believe that the application of densification needs to be absolutely sensitive to the welfare needs of communities and not for it to be purely about economic benefits, numbers or bricks and mortar. The City has a moral, social and ethical responsibility to uphold, maintain, and expand Public Open Spaces (green lungs), given the increased need for these as a result of higher densities. The requirement for Public Open Space (POS) to be intrinsically woven into the densification policy is of paramount importance. Densification in the absence of consideration for the health and well-being of existing and future residents is morally and ethically contemptible and flies in the face of accepted and most basic urban planning norms. All existing Public Open Space needs to inviolable and as it forms part of responsible densification, much more new POS needs to be created.

The GCTCA is of the opinion that, amongst other things:

  • No residential developments should occur beyond the urban edge (except if they are in accordance with strict requirements- see separate heading on the Urban Edge, below) and immediately inside this edge (on the urban side) erven should be relatively larger and buildings sensitive to blending in with the natural mountain environment; the Urban Edge policies should be complied with.
  • Wetlands, rivers and streams, water courses, the beach and sand-dunes should be kept free of hard development, and the general and specific policies associated with such areas be complied with.
  • Conditions imposed in respect of previous subdivisions should not be readily overridden.
  • Title deeds should be respected and generally not changed unless the change is in the public interest and is not objected to by the community and the public in general. Zoning scheme regulations should generally be complied with and departures from them granted only with circumspection and if they are in the public interest.
  • Special Areas on the City’s Plans should be adhered to.
  • Commercial activity should generally be contained within areas set aside specifically for such activity, without being overtaken by residential usage (and vice versa), although a certain amount of mixed use is acceptable in commercial areas where the dominant use of each plot should be commercial (so as to contain commercial activity and prevent commercial creep into residential areas).
  • Residential areas, on the other hand, can absorb some commercial activity but only on a limited scale as specified by council policy, i.e. small scale self-employment, cottage industry style.
  • Established policies and regulations influencing development and conservation should be adhered to, and those who transgress these should be penalized.

All new developments and residences should be required to use water-saving and energy efficient technology, and existing establishments encouraged to adopt such measures.  Indigenous and water-wise gardening and the removal of invasive alien plants are encouraged.


Urban Edge

The metropolitan area of the City of Cape Town is experiencing urbanisation and urban growth that results in negative consequences to both the built and natural environment. The rural, scenic, and cultural character of many areas is being affected; valuable agricultural land is being transformed and production prospects lost; large settlements are being placed on and beyond the urban edges, placing unattainable demands on service provision; and development is taking place in the rural areas, where leapfrogging causes further pressure on the environment. These urban development trends in the Metro are not sustainable, since the cost of job losses in the agricultural and tourism sector, the cost of replacing agricultural resources, services infrastructure costs, the cost of traffic and public transport solutions, and the cost of the loss of biodiversity and conservation resources together with the concomitant impacts on tourism, which is closely linked to these resources, cannot be recouped from the undesirable development.

The GCTCA subscribes to the principles of urban edge protection and in this regard supports the purpose and function of an urban edge as defined in the Provincial Spatial Development Framework.

The purpose of an urban edge is to manage, direct and phase urban growth pro-actively and to protect environmental resources outside of the urban area.

The function of an urban edge is two-fold, namely :

  • It is a growth management tool, used to limit sprawl and the outward growth of urban areas, in favour of responsible densification and infill development, to ensure the more efficient use of superfluous resources and land within the urban area ; and
  • It is a conservation tool, used to exclude certain elements of the environment from the urban area, in order to protect or preserve it, or to discourage its development in the short and medium term, while the long term implications are uncertain.

The uniqueness of Cape Town is defined by the integration of and interrelationship between a number of informants or criteria, each exhibiting an inherent value. It should be noted that celebrating uniqueness does not equate to resisting change, but rather to ensuring that special places are protected and enhanced and new ones created.

Based on the fact that a large proportion of the characteristics that make Cape Town unique are to be found beyond the urban edge and in order to protect this uniqueness, all urban edges need to be held fast until acceptable densification has had time to take effect. Subsequently, any application for any amendment of the urban edge needs to be in line with the City’s previously identified growth corridors, and needs to undergo an extensive and separate Public Participation Process in order to gauge the impacts on:

  • Public desirability
  • The densification policy
  • Any prominent landforms (mountain slopes) and character of the area concerned
  • Valuable soils
  • Hydrology (surface and ground water features)
  • Ecological resources (aquatic and terrestrial)
  • Protected areas (conservation worthy sites)
  • High intensity / potential agricultural resources
  • Services infrastructure
  • Transport infrastructure
  • Developable land within the existing urban area
  • Precedent creation for future land use applications for development
  • Visual impact
  • Cultural / heritage resources
  • Ownership of land and existing land use rights
  • Urban agriculture and small scale farming.

Any application or planning initiative promoting an amendment of the urban edge which is not in line with the City’s previously identified growth corridors or which conflicts with the defined purpose of an urban edge, has negative impacts, or does not conform to the principles of sustainable urban growth, will not be supported.


Len Swimmer

1st September 2011

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