Save Erf 82176 Princess Vlei
Greater Cape Town Civic Alliance:
Princess Vlei is the most natural and ecologically and socially the most important of the wetlands that once covered most of the Cape Flats. It is under threat from a City of Cape Town plan to have a shopping centre built on its eastern shore, on the land between Princess Vlei and Prince George Drive. This is the last opportunity for the Cape Town public, and in particular the communities living around the vlei, to rescue this neglected jewel of public open space and to turn it into something of value for these communities.
Two public participation processes
There are two separate public consultation processes going on.
A)Extension of RoD
The Environmental Authorization (Record of Decision, RoD) for the proposed development of a shopping centre expired on 30 November 2009. The City of Cape Town applied to the Provincial Government to have the RoD extended and the Provincial Government asked the City to appoint a consultant to conduct public consultation (DEADP ref. no. E12/1/3/6-A5/398-0036/09) before a decision on the application is taken. If extension of the RoD is refused, the shopping centre cannot be built.
The first step is for each individual and association to Register with the consultant (Chand Environmental Consultants) as an Interested & Affected Party (I&AP) by sending the information listed in Appendix A or the Chand registration form to email or to fax 021-7623240 or post to PO Box 238, Plumstead 7801 by 18 October 2010. Chand will send documentation to each I&AP, hold an Open House on 14 October 2010, Princess Vlei Eco Centre and invite I&APs to submit letters to comment on the extension of the RoD.
B)Extension of rezoning
Rezoning of the land (Erf 82176) from Public Open Space to Commercial expired on 3 September 2010 and the developer (Insight Property Developers) applied to the City of Cape Town for extension of this rezoning. If the extension is refused, the shopping centre cannot be built. The City of Cape Town is conducting public consultation on the Application no. 191904 (enquiries Donald Suttle 021-7108266).
No registration is required and all individuals and associations may submit letters by 23 October objecting to the rezoning extension (see Appendix B) to the Regional Manager, Planning & Development Management, City of Cape Town by email to or by fax to 021-7108283 or by post to 3 Victoria Road, Plumstead 7800.
What are the options for Princess Vlei?
Shopping centre
Insight Property Development would like to build a shopping centre on Erf 82176. This option is incompatible with other options and is irreversible. We oppose it as we believe it would destroy both the ecosystem and the Princess Vlei cultural heritage site.
Restoration of the landscape and natural vegetation
The Cape Flats Wetlands Forum “Saving the Princess” project has demonstrated that restoration is feasible. This option is compatible with the restoration of both the lake and Crititically Endangered fynbos, with a botanic garden and with a heritage memorial park and sunset amphitheatre.
Restoration of the lake and Critically Endangered fynbos
Consultants in 2000 drew up for the South Peninsula Municipality a comprehensive plan for the restoration of Princess Vlei and its surroundings but the City of Cape Town ignored this option when it commissioned an EIA in 2002.
Historically this site was Cape Flats Sand Fynbos, now the most Critically Endangered vegetation type in South Africa, urgently requiring restoration.
Botanic garden
There is a need to establish a botanic garden on the Cape Flats to complement Kirstenbosch.
Memorial park and sunset amphitheatre
Volunteers have drawn up plans for a Khoe Heritage Memorial Park and sunset amphitheatre.
What issues are at stake?
Princess Vlei, development and jobs
“Development” means improvement, not necessarily more buildings. We all want improvement, more jobs and a better life on the Cape Flats. Part of that can include providing Public Open Space, public facilities and recreation, as well as conservation of assets like Princess Vlei.
Crime, prostitution and drugs
The 2004 Scoping Study stated that crime at Princess Vlei could not be controlled. We believe that statement needs re-examination.
The cost of maintaining Public Open Space
The 2004 Scoping Study portrayed the site as degraded, littered, of little environmental value without potential for rehabilitation. Public perceptions, the EIA, the RoD and the rezoning decision all assumed this was true, and that a shopping mall might offer at least some chance of controlling these threats.
In contrast, the success of the “Dressing the Princess” project has demonstrated that it is entirely possible for the City and local interests not only to maintain the site as public open space and conservation area but also to restore it to what it once was.
The Khoe Princess and her descendants
The Baseline Study, EIA, public participation, RoD and approval process entirely failed to take into account the cultural and historical importance of Princess Vlei.
According to stories told by Khoe herders, passed on by slaves and recounted by Jose Burman in Safe To The Sea (Human & Rousseau 1962) the vlei was named for a powerful Khoe Princess whose headquarters was on Constantiaberg in what is today called Elephant Eye cave, clearly visible from the vlei. She and her Gorachoqua people would bring their cattle down the Princess Kasteel Stream to the vlei, a site where initiation and other rituals were performed. While bathing there in 1510, she was abducted by sailors from the ship of Portuguese explorer Francesco d’Almeida, who in 1513 on a return visit also died in a skirmish at the Cape. According to local tradition, her tears formed Little Princess Vlei and one person drowns each year in Princess Vlei in retribution.
During the 500 years that followed, the Gorachoqua and their descendants suffered enslavement, disposession, deculturation, apartheid, forced removal and countless other injustices. Deprived of access to most of Cape Town’s recreational beaches and scenic sites, they nicknamed the northern shore of Princess Vlei “Claremont Beach” and the area around Little Princess Vlei “Galaland”. But although Princess Vlei remained a popular site for outdoor recreation, religious worship and baptism, it was poorly managed and badly neglected by the City, as for example when used on occasion to dump sand and rubble from roadworks on Prince George Drive and silt dredged from the lake.
Many Khoe decendants on the Cape Flats regard the cave, the vlei and the Princess Kasteel Stream to be their culturally and historically most valued sites in Cape Town. There is now growing local opposition to the shopping centre.
The “Dressing The Princess” investment
The “Dressing The Princess” project has not only succeeded in removing the weeds and alien trees and restoring fynbos to the site, it has also changed public perceptions. Through the modest efforts of schoolchildren and ordinary citizens with an inspiring leader, a degraded landscape has been transformed into a thing of great beauty. Whereas the 2002 public participation process attracted comments from only nine people, a recent petition against the shopping mall carried 1588 signatures. And the interest and opposition are growing.
Perhaps the greatest value of the “Dressing the Princess” project will be realized when some of those school learners who today are tasting involvement turn out as adults to be passionate environmentalists like Calvin Cochran.
Critically Endangered vegetation on the site
The vegetation on the site was formerly Cape Flats Sand Fynbos, which has disappeared from the Cape Flats. It is the most Critically Endangered vegetation in South Africa. Only very small patches occur elsewhere, and only on particular sandy acid soil. To restore this original vegetation would be of the most significant conservation value. Very little remains, if any, of this vegetation where the shopping centre is proposed, but the original soil is intact and it is likely seeds and bulbs could have survived.
The expert view is that Cape Flats Dune Fynbos can indeed be restored on Erf 82176 on the eastern shore of Princess Vlei. In terms of its own and national environmental policy, therefore, the City of Cape Town has a duty to restore and conserve this vegetation.
The 2008 Biodiversity Network study further concluded that the eastern shore of Princess Vlei forms an important linkage for ecological processes that support the larger natural open space area. Although the vegetation is in poor condition, it was identified as an “irreplaceable consolidation” area in support of the adjacent wetland and strandveld vegetation. The western and southern sections of Princess Vlei are also represented on the Biodiversity Network. “Their ecological integrity is tied into the continuance of erf 82176 as part of the Network.”
The City’s Environmental Resource Management Biodiversity Department has the duty to rehabilitate and conserve Erf 82176 because of South Africa’s undertaking to conserve and follow the stewardship principal to look after the Fynbos Kingdom, which is a World Heritage Site .The vegetation types listed for the Princess Vlei area do not meet national conservation quota requirements and so there is great incentive to rehabilitate wherever possible with this area being a key example.
Wetland conservation
Cape Town and South Africa have lost too many wetlands to be able to afford more degradation of these vital ecosystems. The Cape Flats was originally a mosaic of seasonally flooded wetlands of different sizes. Their hydrological and ecological functioning is still poorly understood. Most streams and wetlands have been built over, canalized and drastically changed over the years, usually in ill-advised and mostly unsuccessful attempts to control flooding of the Cape Flats. Seasonal flooding of residential areas occupied by poor people remains an enormous problem in Cape Town. The more urban development has taken place, the more valuable the remaining water bodies and their hydrological, ecological and recreational functions have become.
Recent flooding events highlight the need for wetland and natural open areas to absorb high levels of water run-off. Flooding risks are set to increase with expected future climate change. Conversely we also need wetlands to retain water during dry times.
Timeline of events to date
This is based on documents and minutes of the 8 April 2009 meeting of SPELUM (the City’s Spatial Planning, Environment & Land Use Management Committee) plus a City of Cape Town media release of 16 September 2009, files examined in the Provincial Government Department of Environmental Affairs and Development Planning (DEA&DP) and the City of Cape Town, as well as discussions with City and Provincial Government officials.
Princess Vlei is a 29ha lake between Grassy Park and Retreat. It and Little Princess Vlei are on about 75ha public land. The surrounding vegetation has been badly degraded and invaded by alien plants and Princess Vlei badly affected by urban activities. For twelve years the City of Cape Town has worked to get all the necessary authorizations to be able to sell a part of the shoreline to a developer for the construction of a large shopping centre. Almost the only remaining step is the actual sale.
In 1997 or earlier, the South Peninsula Municipality (SPM) “received an unsolicited proposal” from Insight Property Developers (Neville Thornton) to purchase a portion of Erf 82176 for the development of a regional shopping centre (and taxi rank). In May 1997 an in-house Development Suitability Study[1] (not yet seen) was completed by the SPM. In May 1999 the SPM Executive Committee passed a resolution to deal directly with Insight Property Developers but to invite comments and counter proposals, none of which were forthcoming apparently.
In September 2000 a Princess and Little Princess Vlei Restoration Project study (an environmental baseline study)[2] was completed for the SPM. This included specialist studies (Freshwater[3], Geohydrology[4], Fauna & Fauna[5],[6],[7]). These two remaining lakes and their surrounding vegetation have been greatly degraded as a result of urban development. “Healthy patches” of the degraded original terrestrial vegetation (“a mosaic of Dune Asteraceous Fynbos and Dune Thicket”) remained but were only superficially examined. The botanical study said the vegetation was “not worthwhile rehabilitating”. Princess Vlei in particular had been damaged by water level control, pollution, sediment accumulation and biodiversity loss. Comprehensive guidelines for its protection (including “non-negotiable” features such as a 50m buffer zone, conservation precincts with limited public access, ecological corridors and protected dunes) plus a 3-5 year programme for its rehabilitation are detailed, linked to an integrated programme of monitoring.
The Baseline Study included public participation but neither the Background Information Document (BID) nor the report mentioned a shopping centre option. Options were extremely broadly listed (conservation, sports, entertainment, recreation, retail, residential.
In November 2000 a related Princess Vlei Planning and Urban Design Framework[8] was completed for the SPM. Public participation revealed the importance of the area as a community and recreation resource, the need for a framework for conservation and appropriate development, and concerns around crime, security and pollution. The Insight Property Developers proposal was mentioned but not discussed. This report essentially confirmed the recommendations of the Baseline Study.
In May 2002 the SPA commissioned a heritage baseline study.
In 2002 the unicity took over the land and these commitments and the SPM became the SPA.
In July 2002 the City submitted an application for sale, rezoning, subdivision and amendment of the Cape Peninsula Urban Structure Plan in terms of section 35(3) of ECA, the Environmental Conservation Act (No. 73 of 1989) for Environmental Authorization in terms of the EIA Regulations (the Environmental Impact Assessment regulations GN Numbers 1182 & 1183, September 1992) for “the change of land use from [item 2(e)] nature conservation or zoned open space to any other land use”.
Erf 82176 is still owned by City Parks and the portion on which it is intended to build the shopping centre lies between Princess Vlei and Prince George Drive. It comprises a 3.2ha portion of some 8.3ha public open space surrounding Princess Vlei and Little Princess Vlei, sports fields and an Eco-centre between them. The Council resolved on 22 April 2002 that the portion be sold as unserviced land, as resolved by the SPM. In May 2002, the relevant City authority, then Executive Councillor for Economic Development and Tourism, approved that such a direct sale take place subject to, inter alia, a public participation process, the outcome of a rezoning and Environmental Impact Assessment (EIA) process and subject to agreement on conditions of sale and the purchase price.
This application took the form of a Plan for Study of Scoping[9]. In this, the consultant (Dudley E Janeke, Tshukudu Evironmental Services) declares his independence of the nominal proponent (the City of Cape Town), that he has no interest in downstream activities and that work from the City made up 2% of his work during the previous 12 months. There is no mention of Insight Property Developers, the actual developer, for whom he formerly worked. The Scoping Study was to compare environmental consequences of three option, a “no-go” option (maintain the wasteland status quo), “limited commercial development” (expand the fish market) and a 9000m2 shopping centre. However, there was no mention of any of the concerns or conservation objectives identified in the Baseline Study, nor of any of the next round of specialist studies the Baseline Study identified as needed. To illustrate the change in approach, the “non-negotiable” 50m buffer zone around the vlei had now become 30m. There was no mention of the rehabilitation plan developed during the Baseline Study.
Advertising of the sale and consideration of the response to such advertising is also required because the project involves the sale of public open space. Conditions of sale are to include payments by the developer of a Development Contribution for electricity and other services, and to a fund for the environmental management “of the whole vlei”.
In 2002, Insight submitted a composite land use application, required for rezoning. A Traffic Impact Assessment[10] and the EIA were carried out by the City. The Provincial Department of Environmental Affairs and Development Planning (DEA&DP) is the competent authority to grant or refuse rezoning applications that involve Public Open Space.
A Heritage Baseline Study report[11] was submitted in September 2002. It noted the site’s landscape, recreational and cultural potential. It also essentially confirmed the conservation objectives suggested in the Baseline Study.
The Draft Scoping Report was submitted in November 2002. This study considered only the relatively small number of fairly superficial concerns articulated by the small number of local I&APs involved. The rezoning application and developer’s intention to buy the land were also advertised in November 2002.