District Plans Have Your Say

Comments for the Draft Blaauwberg District Plan 2021 and its further drafts being volume 2 – 4. We have attached with the covering mail both our comments from 2021 and this document from 2022
Introduction
The City sets out the purpose of these documents as being to bring clarity and align with higher level policy. This they have blatantly failed to do. The writer/s seem to allow sections that are directly against current policy. If these sections are retained. This document will add to confusion and frustration we already see from and residents. This frustration will lead to conflict between objectors and the City. And will see long drawn out rezoning and planning procedure. Sadly this document has failed to meet its desired objective.

1. City Comment Public Participation Vol 4 Page 343
   a) In their response to our comment around public participation the City responds thus.
   ‘The public participation was lawful in terms of all legal requirements.
   Great effort has been made to have an authentic and inclusive public participation process. Multiple public meetings were held and transport offered to enable those without access to PCs or transport to be included. Documents were available to read at public libraries. Written comments were accepted at sub council offices. A second round of public participation on the reports is being undertaken between June 2022 – August 2022 to allow a further opportunity for comment.’
   b) What The City of Cape Town has failed to respond to is why important points such as Erf 1117, Erf 1674 Melbosstrand, Erf 38599 and the densification nodes were not part of the presentation given at public participation by City officials. These are important and major changes that needed to be brought to the public’s attention and the City failed to show these in a presentation during their public participation. It is pointless documenting the methods of participation if salient points are omitted either by design or error. The people need know the parts of the documents that will affect them.
   c) We note that the City admits that documents can be read at libraries. The same library service that is being cut by the City. These are large and onerous documents making their reading difficult and would take many days of reading.
   d) The comment Written comments were accepted at sub council offices. In this the City needs familiarize itself with the legislation and policies that protect the rights of vulnerable people. It expects people to get to an office that closes at around 15:00 to drop off a document. How then does the City expect people who do not have access to computer equipment to have access to transport. The city lacks empathy for the most vulnerable in our society and has refused to accept its responsibility to protect this section of society.
   e) The point of a public participation process is to listen to the comments and make changes to the plan presented. What the City has done is to attempt to justify its errors and non-compliance with policy by using comments. It has not listened to the comments and public outcry. What we see once again from the City of Cape Town is the appearance of a public participation process. The City is simply not responding to the wishes of the people of the area which is not in line with the City’s legal obligations and renders this entire public participation process futile.

2. Comment City Water & Sanitation Vol 4 Page 343
   The City make the comments.
   ‘The DSDF shows a long term vision for the area. The Implementation Plan set out the required actions to enable this vision, however there are numerous challenges to implementation of the plan which is regrettable.’
   a) What the City refers to as numerous challenges is experienced by the residents as raw sewage running down the streets where human beings are expected to live, work and play.
   b) I am sure that the residents of Joe Slovo and Dunoon after decades of enduring these inhumane living conditions will feel insulted that the City now have an Implementation plan to enable a vision.
   c) To describe as regrettable. People being forced to live with raw sewage running freely through their streets. Is totally unacceptable. It shows the total lack of empathy the City has for the most vulnerable in society. This situation is not ‘regrettable’. The situation it is against the constitutional rights of those residents who are forced to endure such living conditions. . It is noted that during the last lost decade of service delivery in terms of water & sanitation. The City of Cape Town staff members who are responsible for this competency have been paid in full. What is regrettable is that not one person has been accountable for this lack of service delivery.
   d) It also must be noted that the City has yet to make good on its promises to solve these and the many problems with water & sanitation. They simply allow more development which they are aware will worsen the problem.

3. District Nodes Marine Circle, Bayside, Parklands & Melkbosstrand
   a) In seeking to densify these areas that City is looking more to help developers profits than the residents and rate payers of the area. This is a clear case of short term panic rather than long term thinking on the part of the City. This proposal ignores huge sections of policy and will cost the City of Cape Town and therefor Rate payers more in the long term. The cost of these proposals will be seen in a MyCity bus service that will not be economically viable and will require rates to be used to fund this transport system. . This will see longer and more expensive travel to and from work. Which will increase the carbon foot print of the City as the City of Cape Town forces more and more people into private cars and longer journeys. These predictions can be found in the City of Cape Town’s own policies. Polices that predicts these outcome’s if we fail to develop towards the inner City.
   b) We give some background of previous planning decision. And the results of poor planning decisions that put the short term profit of developers above the long term public good.
   (i) Blaauwberg Road is considered an activity route. However The City of Cape Town in planning the Mycity bus lanes removed the space for slip roads to allow vehicles to stops and access shops. The City of Cape Town allowed a car parking in this route, The City of Cape Town has encouraged and passed residential only development in so doing failing to provide the space for economic opportunities that should come with an activity route. We see informal traders around Bayside shopping center.
   (ii) Parklands Main Road is again an activity route. Again the City of Cape Town allowed residential only from the circle at link road. In so doing not allowing the commercial space for businesses to open, the economy to grow and employment to grow. We now see informal traders on both sides of the road around this area.
   The City in allowing these short term decisions which consider developers profits over the long term public good. The City has missed the opportunity of encouraging mixed use development which would stimulate the economy and much needed jobs. The fact we have informal traders highlights the need for those traders to be at that point on an activity route would confirm what is needed is mixed use developments. Developments that provided the commercial space for these traders to be housed in a more formal setting. In both these areas policy should have been to encourage mixed use development. Similarly the City has allowed developers to build residential only. This seems to be a policy that Developers Know Best from the City. However TOD policy highlights that developers will build for their profits only. National legislation states that the City of Cape Town must act in the public good.
   This highlights that the City cannot be trusted and is not listening to residents. It is the public who to put up with these poor decision and lack of adherence to policy. The City has not checked policy against the actual lived experience, the conditions on the ground and the adherence to agreed policy. The City refused to learn from its mistakes and now seeks to add more misery to the daily lives of residents. As the City of Cape Town presents a ‘more of the same’ district plan proposal which adds more confusion than clarity.
   c) In attempting to justify the inclusion of these proposed district nodes the City makes the following statement:
   The confusion is noted and wording has been relooked for clarity. The 'Urban Node' designation is conceptual and must be applied contextually. The reference to 2km is part of general guidance for how far the node could be considered. The text explicitly states that it must be considered
   contextually and gives further suggestions on how to do so. Nodes do not need to be within the Urban Inner Core. The DSDF is a policy which describes a future development vision - it does not give or take away land use rights and so does not negate or conflict the title deed restrictions in the area. The proposed node was included in the maps and text of the draft SDF documents and presentations which were used in public participation. It is not a major shift in policy as suggested, as a node was present in the area in the 2012 District Plan.
   (i) The confusion that the City refers to is obviously in the mind of the writer and the City. We will agree that nodes were in the 2012 District plans but were smaller and around Bayside Shopping center, Boy De Goode and Maine Circle and were designed to bring mixed use development around a major shopping center and Blaauwberg Road. The nodes proposed in the 2022 draft are very different and would see densification across most of Table View and Parklands which does not align with City Policy. This is a major shift and I defy the City to engage with the public and justify their statement.
   (ii) We would agree with the City that nodes do not need to be within the Urban Inner Core. But densification or more specifically the support for densification by the City does have to be within the Urban Inner Core. In creating these nodes the City seeks to support a sustained program of densification that is outside the Urban Inner Core, away from major transport links, away from job opportunities, in areas that lack basic services and are not in the inner city. The proposed nodes should not be supported for densification.
   (iii) If we compare the Statements made by the City in terms of this draft and policy to the location of the proposed nodes. It is clear that the proposed nodes are not supported by the City of Cape Town’s own draft. It sees the City of Cape Town making short term decisions for the good of developers. Decisions that the rate payers will end up paying a heavy price for in the years to come.
   1.6 Decision support criteria Page 10
   Based on this principle, should the provisions of the integrated DSDF and EMF and any
   related lower order / local plan be deemed to be inconsistent with the MSDF, the MSDF will take precedence.
   Given that the proposed nodes are inconsistent with the MSDF in that the City is promoting densification in an area outside the Urban Inner Core. The inclusion of the proposed nodes creates conflict with the MSDF. This would cause confusion for town planners and residents. This would lead to conflict as residents attempt to fight each individual application. This leads to longer periods for development to start and adds costs to developers and the community.
   1.6 Decision support criteria Page 13
   By locating new land use opportunities where people are located, the Integrated DSDF and EMF proposes to create a greater mix of land uses locally. This is advantageous to the future resilience of local areas, for example during the COVID 19 pandemic office workers made use of more services close to their homes because they were required to work from home.
   The proposed nodes are predominantly single residential dwellings. There are not the people that the draft district plan refers to. There are not the services that the draft district plan refers to. Therefor the proposed nodes are not suited for densification.
   3.1.2.2 New Development Areas - Future Urban Development Page 47
   Access to public transport system (existing or planned): Medium to high levels of densification should be aligned with existing/proposed public transport routes. This is essential for housing development targeted at lower-income earners, who are unable to afford the costs of private transport. It should not be an overriding consideration for middle and upper-income townhouse/group housing. developments, as the residents are likely to make greater use of private transport.
   Land use integration: Preferably medium to high levels of densification should be located near places of employment, social services and community facilities.
   It is clear that the inclusion of the proposed nodes are not near transport routes. For the lower income developments. The Greater Table View Area is not close to employment, social services or community services. This is well documented in many City of Cape Town Documents.
   (iv) Proposed Nodes, City Policy
   Both the MSDF and the City’s TOD policy support densification but The Greater Table Area does not support these blanket densification nodes. This not a question of not in our back yard but is more a case of this being the totally wrong back yard. It seems that the City of Cape Town has abandoned their habit of cherry picking small sections of policy to justify undesirable development and now wants to ignore policy all together.
   • Densification should be supported within the Urban Inner Core
   • Densification should be supported towards the inner city
   • Densification should be close to work opportunities, close to major transport routes. Walking distance to be within 0.5Km’s
   • The use of private vehicles should be discouraged
   • The Mycity bus system is not financially viable. Densification should encourage the use of public transport which will only become financially sustainable if development encourages bi directional trips.
   • Major work opportunities are centered around the CBD, Epping and Bellville
   (v) The City’s claim of a possible station at the center of the Parklands node is rejected. There is a single railway line that might become a station. This proposed station and line have been proposed for decades. The responsible department can’t keep the current railways going how can we expect it to implement new lines within the time frame of this district plan. Until such time as there are credible and tangible plans for the railway to become functional we must assume that this area is not served by a railway . We must consider the peoples lived experience and the service delivery of the current rail system. By naming a road ‘Station Road’ will not make it a station we need dedicated, functioning public services for that.
   The proposed nodes are circular which would create a blanket of densification. The blanket nature of the proposal creates areas that are not near a major transport route. The proposed nodes simply do not satisfy the policy requirements for densification to be supported. They fail to make policy requirements as they are not consistent with the higher level MSDF document. In this case the MSDF document should take precedence. The inclusion of these nodes will only provide an inconsistency, confusion, conflict and longer application periods. As such the proposed nodes must be removed from the final draft.
   We would suggest further investigation into the proposed densification of the area. This should lead to further public participation. Public Participation where the City of Cape Town actually considers the wishes of the owners of the City of Cape Town. The Residents of the City of Cape Town. For the City of Cape Town to propose such major and wide reaching densification plans in a few lines of text, hidden towards the back of a draft plan is disingenuous. Plans that would impact the lives of the people of an entire suburb. Should be communicated in a way that people can understand.
   In suggesting these huge changes without tangible and believable plans to install the required improvements to transport, public services and water & sanitation is simply reckless.

4. High Level Densification Figure 21: Blaauwberg sub-district 3: Greater Table View Page 9

Area 1 Is an area next to a school and is subject to land use application Case ID 70494419 Erf 38251 which we understand has been withdrawn from the MPT schedule by the City. The inclusion of this area in the district plan as an area to be high density development is troublesome. This area is not within the development corridor of Blaauwberg Road nor is it within the Inner Urban Core. The inclusion of this ERF in the District Plan in our opinion is clear attempt to interfere with and preempt land use application 7049419. This must be removed from the draft district plan 2021.
Area 2 Is an area next to a school. It is not in the development corridor nor is it in the Urban Inner Core and thus its inclusion in this plan is not policy compliant. This must be removed from the draft district plan 2021.
By including these areas as high-density densification conflict with section 5.1.3 and introduces confusion not clarity. The inclusion of these areas in the district plan must be removed.
We stand by these comments. In particular Erf 38251 is subject to a land use application. In including this in the district plan the City is aware that the planners must consider the contents of the district plan in future applications. In including this plot in the district plan the City seeks to influence the outcome of an ongoing land use application.
We must ask why have these two areas been included for this special attention by the planning office? What is special about these two areas? Why not other areas ?
We ask for a full investigation into the inclusion of this section of the Draft Plan. Who drafted this section ? And what was the motivation in doing so?
5. DA 5: ERF 1117 (Large NDA east of Big Bay) Page 93 Section 4. 2021 Draft Reads
Redevelopment of the site should facilitate the provision of public facilities and enable a range of entry-level and subsidy housing opportunities.
However the 2022 draft page 9 reads
1.2.3.2 Site for Investigation
Further land has been identified specifically for investigation for publicly assisted housing projects. This is limited to publicly owned land and will be updated over time based on new information. This includes various portions of undeveloped or underutilised land. The areas where land has been identified for publicly assisted housing projects within the Blaauwberg District include:
• Erf 1117 along West Coast Road
• Erf 105391 Sanddrift Site
• Erf 1694 RE Melkbosstrand

This area does not lend itself to entry level and subsidy level housing.
a) This area in not within the Urban inner core.
b) The area is not near any work opportunities or any major transport links. Residents would need to use limited public transport to access work opportunities. These journeys would be longer journeys which is against TOD principles.
c) To develop entry level and subsidy level housing on the outskirts of the City away from work opportunities supports Apartheid type planning principles where poorer people are dumped on the outskirts of the City. Away from work opportunities and public services. They are forced to travel long distances to work and use a disproportionately high percentage of their income on travel. Therefor leaving the inner city for the well off residents of the City.
The City commented:
The principle of providing new housing opportunities near to job opportunities and other services, as proposed by the GTAF, is in alignment with the City's spatial planning principles. Developable land within the urban development edge is a scarce resource in Cape Town. Erf 1117 is a major opportunity due to its large size, road access and location within a developing area. The site has potential for great transport access due to it being bounded by the R27, and surrounded by the MyCiTi network. There are existing and planned industrial and commercial areas relatively close to the site. The vision and plans for the Sunningdale/Sandown/Rivergate area is for continued residential, commercial and industrial development within the urban development edge. This will bring with it more job and housing opportunities. Residents would travel a shorter and cheaper distance compared to other site options for subsidised housing opportunities. In the long term, the site will be on the northern edge of the West Coast development area, but not isolated from urban development. The vision for the site is for a mixed use development which will provide a range of housing, job and development opportunities. The guideline to include public facilities will also reduce residents need to travel to access public services. Please also note that 'subsidised housing' refers to a range of housing products (e.g.. social housing, FLISP-mortgages etc.) which caters for various household incomes from roughly R22 000 per month and less. An updated definition is included as the income brackets change from time to time due to changes in inflation and policy. The development guidelines include that both subsidised and market housing should aim to be provided. There is a fear that the City will plan an informal settlement – This is not the case, and any development on the site will need to follow the regular development application process e.g.. to rezone the site will also require public participation. For an idea of how this could look, the Conradie Hospital development is
an example. The development guidelines direct new development to be sensitive the surrounding area so that it is an integrated, inclusive and a vibrant addition to the area.
It is clear that the City of Cape Town has a plan to develop this area into a mix between inclusionary and low cost housing. It is also clear the City of Cape Town has investigated and decided on its decision. Why then suggest that investigation still need to take place. Again the City of Cape Town causes confusion and does not add clarity.
It must be noted that the proposed industrial area as mentioned would not be adequate to offer the employment opportunities required for this proposed development and for the densification proposed in other parts of the district plan
We would also state that the City if removing industrial land by allowing industrial land in Racing Park to be rezoned to residential. Not surprisingly The City of Cape Town fail to mention this in their response. The City of Cape Town’s comment around the limited opportunities does not hold up to policy. The MSDF states that the majority of work opportunities are within the CBD, Epping and Bellville. It is noted that the proposed MyCity bus routes will only take travelers to the CBD.
We map this proposal to policy
d) This site in not within the Urban inner core. It is on the very edge of the City and will require a massive investment to provide the infrastructure required. This is against policy which states that densification should only be supported where services currently exist.
e) The site is not near any work opportunities or any major transport links. Residents would need to use limited public transport to access work opportunities. These journeys would be longer journeys which is against TOD principles. Whilst the City makes the comment it is surrounded by the MyCity bus service. This service is limited.
f) To develop entry level and subsidy level housing on the outskirts of the City away from work opportunities supports Apartheid type planning principles where poorer people are forced to travel long distances to work and use a disproportionately high percentage of their income on travel.
We reject the City’s comments around the Conradie Hospital Development. There is little to compare. The Conradie Hospital Development is close to Epping and the CBD and therefore work opportunities. The site makes use of existing services. The Conradie Hospital Development represents a good densification project due to its location being within the Urban inner Core . To compare the Conradie development with the proposed ERF 1117 and attempt to justify a proposal that is does not hold up to policy scrutiny. To attempt to develop Erf 1117 in the way the City of Cape Town proposes both reckless and short sighted. Again we see the City of Cape Town attempting to make major changes to this area based on a few lines in the draft. This is a major proposal and will impact the lives of the people in the entire suburb. It would seem again the City of Cape Town has failed to consider the
For these reasons the City of Cape Town needs to rethink its proposals around Erf 1117. We would suggest that the City engages with local residents and community based organizations to determine what they would want to see in this area.
6. Erf 1694 Melkbosstrand
The comments and objections to Erf 1694 Melkbosstrand are much the same as to the proposals around Erf 1117. Erf 1694 is even further away from the City
a) We map this proposal to policy
(i) This site in not within the Urban inner core. It is on the very edge of the City and will require a massive investment to provide the infrastructure required. This is against policy which states that densification should only be supported where services currently exist.
(ii) The site is not near any work opportunities or any major transport links. Residents would need to use limited public transport to access work opportunities. These journeys would be longer journeys which is against TOD principles. Whilst the City makes the comment it is surrounded by the MyCity bus service. This service is limited.
(iii) To develop entry level and subsidy level housing on the outskirts of the City away from work opportunities supports Apartheid type planning principles where poorer people are forced to travel long distances to work and use a disproportionately high percentage of their income on travel.
The Proposal to develop Erf 1694 is again a short term decision on the part of the City of Cape Town. It represents a threat to the well being of local residents, the residents of the proposed development, it will encourage single directional trips which will threaten the financial security of the MyCity bus network and we will see people using private vehicles to travel to work, access services and schools. This will increase the Carbon footprint of the City. Again this is not a question of ‘not in my backyard’ it is the totally incorrect back yard.
We see the City of Cape Town proposing major changes to the Melkbosstand area using a few line of text which is totally insufficient for such a proposal. There is no tangible comments around the provisions of employment and services that this people who would be house in this development would need.
The City of Cape Town needs to engage with locals residents and community groups. And actually listern to the comments of these people and come up with a workable policy compliant proposal.

Conclusion
The City of Cape Town has presided of a lost decade of service delivery. It has failed to install waste water systems and treatment capacity that would allow the densification policies that it implemented. It is simple logic that if you are adding demand to waste water treatment plant and system that has a finite capacity. The system and treatment plant with that finite capacity will run out of capacity. In this case this has led to the total destruction of the Diep River, Milnerton Lagoon and the beaches around the area. And yet the City of Cape Town wants to continue this destruction by adding more and more developments to an already over capacity plant We have seen over the last decade planning application after planning application passed with supporting comments from Water & Sanitation officials aided and abetted by officials from the City of Cape Town Planning. These officials must have been aware of the capacity constraints of the Potsdam waste water treatment plant as it was agreed City Policy. And yet not one City of Cape Town official or political leader has been held to account. Whilst the City of Cape Town has agreed to upgrade the Potsdam Plant the sewer and stormwater drains are aging and no provision for their upgrade as been seen at the time of writing.
The City of Cape Town has failed to document that the upgrades to the Potsdam Plant have not been put out to tender with no tenders being agreed. The completion dates given by The City of Cape Town for the Potsdam Plant when considering the last lost decade of service delivery would seem to be unobtainable. We would suggest that most of the period covered by this draft will be without any increase capacity being made available and the Potsdam Plant. We would also document that the first of the proposed Private Waste Water Treatment Plants has been rejected by the City of Cape Town’s own Environmental Management Department. These private waste water treatment plants would see the privatization of Environmental Destruction which for the last ten years has been the unfortunate responsibility of the City of Cape Town.
The areas of most concerns are the blanket densification of much of the Greater Table View Area and the Melkbosstrand CBD as well as the proposals around Erf 1117 & Erf 1694. We see much of the same attitude from the same City of Cape Town officials who have presided over the last lost decade of service delivery. They have submitted proposals that seeks to develop in areas that suit the profits of the developers rather than adhere to agreed City of Cape Town policy and act within the public good. These areas are just not suited or policy compliant for these types of densification.
Whilst we are aware of the major population growth that the City of Cape Town must manage. The poor proposals presented by the City of Cape Town must be rejected. The City of Cape Town must better engage with the owners of the City of Cape Town being the residents. Whilst we agree that developers must be allowed to make a profit this must be made within the confines of the City of Cape Town acting within its policy and acting in the public good.
We would also comment that the proposals we have outlined has not achieved the main objective of this document. This document would see more confusion as the proposed document fails to align with higher level policy. Confusion leads to conflict as residents become objectors and land use application become more and more drawn out. . In this document the City of Cape Town seeks to make major changes to an area using a few lines of text hidden to the back of these drafts. This is plainly a disingenuous act designed to push through these changes to the detriment of the public good. We ask the City of Cape Town to meaningfully engage and listen to residents in the development of these areas.

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