Registration Number: 006 538 NPO – P.O. Box 709, Noordhoek, 7979, Cape Town – (021) 789 1751 – email: info@neag.org.za
Noordhoek Environmental Action Group
The District Manager Department: Planning and Building Development Management
City of Cape Town
comments_objections.northern@capetown.gov.za
20 May 2013
Dear Sir/Madam
APPLICATION FOR THE AMENDMENT OF THE CAPE TOWN SPATIAL DEVELOPMENT FRAMEWORK (A COMPONENT OF THE INTEGRATED DEVELOPMENT PLAN), REZONING, SUBDIVISION AND CONSENT USE: PORTION 18 OF CAPE FARM UITKAMP NO. 189, VISSERSHOK ROAD, DURBANVILLE – APPLICATION 146184 – Ref 18/6/4/32/1
The Noordhoek Environmental Action Group comment on the above mentioned application is as follows:
1. Amendment of the Urban Edge for Urban development:
Do not support the amendment of the Urban Edge because:
• We do not believe that the full implications of such amendment have been considered by the City. Surely the planning for Infrastructure requirements has been sized to cater for the area within the current defined urban edge.
• Effectively, allowing such amendment would imply that a future infrastructure shortfall to certain areas within the existing urban edge would be created.
• We are not convinced that the effect of this expansion of the Urban Edge on all necessary infrastructure to the area has been considered in an integrated fashion.
• Such amendment can create a precedent for further amendments to the Urban Edge in other areas without the necessary investigation of all planning and infrastructure issues.
• The Urban Edge has only recently been defined and is based on considerable work, inputs and insights of many professionals at great expense to the City. Surely these inputs are worth something and should not be dismissed and changed so easily, without their express comments relating to the effects of such amendment.
2. REZONING PORTION 18 FROM AGRICULTURE TO SUBDIVISIONAL AREA FOR MIXED USE DEVELOPMENT:
Do not support the rezoning because:
• As set out in 1 above, the services required for such development will imply that those developments within the urban edge will be negatively affected.
3. SUPPORT OF THE DURBANVILLE COMMUNITY FORUM (DCF) NEAG supports the case made by the DCF in all respects as:
• We believe that their objection to the proposed amendment has not been taken lightly and is the result of considerable inputs from knowledgeable and concerned members of that organisation.
• We understand from the information available that the facts relating to the agricultural soils on the farm in question have been mis-represented and are currently under dispute. If this is the case, the primary motivation for the proposed development is flawed. No further consideration of this amendment should be given until this dispute has been resolved fully.
• We understand from the information available that the facts relating to the extent and environmental issues relating to the Wetlands on the farm were not disclosed and this non-disclosure could hold significant bearing on the proposed amendment and zoning proposed. If this is the case, the proposed development planning is flawed in terms of our environmental legislation. No further consideration of this amendment should be given until this matter has been resolved fully after full disclosure of the facts.
• We understand from the information available that the proposed development potentially impacts on people’s rights in terms of Section 24 of the Constitution and that many objections have simply been ignored.
5. Process: We request to be listed as an Interested and affected Party and to be included in all future information dissemination and communications relating to this matter.
Yours faithfully
Secretary
On behalf of the NEAG Executive Committee
Noordhoek Environmental Action Group Executive Committee:
Cecil Whiteman (Chair)
Jon Lijnes (Secretary)
Rob Anderson
Glenn Ashton
Kathi Sales
William Liltved
Serge Raemakers
