Posted on the 7th March 2013

 (We were not amused about the total lack of any mention of birds and birding and particularly birding tourism in the proposed Overberg District Municipality Spatial Development Framework.  We submitted a report to Rob Fryer of Whale Coast Conservation and he included this in their submission.  This submission is rather lengthy, but makes for very good and interesting reading. Important comments on birds and birding under 6.4 and 6.6. - Ed.)


Thanks to those members of the public who sent their input to us for incorporation into the WCC comment on the Overberg District Municipality Spatial Development Framework. It is gratifying to know that so many people would like to help to make this document as good as it can get. Below is the content of the comment that Whale Coast Conservation submitted to Simon Nicks of CNdV consultants.


Thank you for the presentation on 18th February to the Overstrand community of the draft Overberg District Municipal Spatial Development Framework; the local presentation was much appreciated and has stimulated local participation in the process. We are aware that a number of people who attended the presentation have made individual comment to you. Others have made comments to Whale Coast Conservation (WCC) and requested that we consolidate their contribution with our own comment, which is set out below for your attention.

The comments below will follow the headings in the PowerPoint rendition of the SDF dated 31 January 2013, it being presumed that there is a version with more descriptive text that will be available at some stage for further comment. This is important in order that the consistency and compliance of the Overberg District Municipal SDF (ODMSDF) with the Western Cape Provincial SDF (WCPSDF) can be tested. It is a major concern that the review of the ODMSDF is apparently running ahead of the review of the WCSPDF, which is not available even in draft form to refer to, and the WCC reserves its rights to submit further comment should it transpire that there are aspects of the ODMSDF that do not align with the WCPSDF when it is made available.

1. Vision

It is appreciated that an attempt has been made to express a vision that is specific to the Overberg. The proposed vision is, however, not very inspiring and isn’t easy to commit to memory. It doesn’t seem to bare any relationship to the challenges that the communities in the district face to adapt to changing circumstances and to transform towards a sustainable future. It seems a pity that broad public participation hasn’t been used to develop a vision that picks up identified needs for change and to put these into words to which the Overberg communities can relate. In the list of resources contained in the vision, the word “conservation” doesn’t seem to fit and could be replaced with “ecosystem services”.

It is proposed that the vision could be something like:

Valued provisioning, regulating and cultural ecosystem services are provided sustainably by the diverse mountain, rolling inland hills, coastal plains and sea, formed by the Riviersonderend and Langeberg mountain ranges, Ruens, Agulhas Plain, Kogelberg and Walker Bay and bounded by the Indian Ocean. These are managed by rural and urban communities that are committed to:

Support a healthy local economy based upon agriculture and tourism

Nurture compact, socially integrated urban communities;

Live within walking distance of the access points to essential daily activities;

Minimise the consumption of non-renewable resources;

Maximise the use of locally sourced goods and materials;

Use available public and non-motorised transport.

2. National Planning Commission

No comment

3. Principles

The principles are not addressing a very important aspect of the coastal towns in the Overstrand: that the towns are characterised by very low occupancy levels that will become increasingly unsustainable.

It is guesstimated that Hermanus, the main economic centre of the Overstrand, has an average occupancy of 40% and that other towns have even lower occupancy levels. This hampers the development of a functional local community, makes community-based convenience stores and amenities non-viable, skews infrastructural planning and weakens the economic development of the town. It horribly skews the average social gradient, leaving a large unemployed indigent population without opportunity for participation in the formal economy and social upliftment.

A new vision needs to be developed for restructuring the three main Overstrand towns (Kleinmond, Hermanus and Gansbaai) and their economies to encourage high levels of permanent residents and the development of more holiday accommodation to cater for short term visitors. The SDF should address this at the policy level.

Principles relating to the location and development of regional shopping malls should be included. The impact of regional shopping malls, which draw national chain stores into the area that marginalise local businesses, bring in goods and services from outside the area and syphon off profits for use in other areas, needs to be addressed.

Principles relating to the nature of transport routes and services between, into and through the main centres in the Overberg need to be more strongly represented in the SDF. The SDF needs to identify which government agencies have the jurisdiction for the different aspects of transportation planning and provide a summary of the plans for the Overberg District.

It will be very helpful if the depiction of the principles can be adapted to better suit coastal circumstances, in which the influence of narrow coastal plains between mountain and sea and complex topography, estuaries, wetlands and the seashore are important factors. For example the principles should include guidance on the development of urban settlements on steep gradients on mountain sides, principles relating to structures breaking sensitive skylines on mountain tops and against the horizon and on development along the coastal plains and particularly around estuaries. The principles should also address the management of treated effluent and storm water discharges into estuary and wetland areas.

Bioregional principles need to include guidance on the linkage between terrestrial and marine ecosystems, particularly where there are coastal wetland systems and estuaries. Although the SDF relates to terrestrial planning, this should not preclude including principles relating to the creation and management of marine reserve areas that are important to the communities living on the coast. The strong dependence of the Overberg community on tourism and the undeniable relationship between tourism in the region and recreational activities associated with the sea and estuaries should be covered in the principles. Principles relating to harbours for commercial and recreational fishing and to aquaculture farming should be included in the SDF.

4. Synthesis of Analysis

Map 4.1 needs to show important estuaries (Klein River Estuary, Bot River Estuary, Palmiet River Estuary, Uilkraals River Estuary, Onrus River Estuary). Refer to

Anecdotal evidence and the SDF vision cite agriculture and tourism as the two main drivers of the economy. 4.3 Main Contributors to GVA and 4.4 Main Contributors to Employment, however, don’t give any estimate for the contribution made by tourism. This is a serious shortcoming that needs to be addressed. The SDF needs to quantify the current and potential value of tourism and show how tourism growth is being planned for.

A study by Anchor Environmental attributes recreational fishing as being a major determinant of tourist activity and of residential property value in the Kogelberg Biosphere transitional towns. It is believed that these play an important role along the whole coastline. It would be valuable to quantify the contribution to the local economy of recreational fishing.

Avitourism is increasingly important and, given the international recognition of the Klein River Estuary to Hangklip coastal area, and six other areas in the Overberg, as an Important Bird Areas, the current and potential contribution of avitourism too should be quantified.

The contribution of aquaculture and commercial fishing to the local economy should be included in 4.3 and 4.4.

5. Broad Spatial Concept

The inclusion of the Voëlklip to Stanford coastal area into the “urban coast” spatial area is questioned; in fact the appropriateness of the designation of the Fisherhaven to Pearly Beach coastal area as “urban coast” needs to be challenged.

The Voëlklip to Stanford area is a highly sensitive mountain, estuarine and coastal dune system that should never be developed as an urban area. The Klein River Estuary ranks within the top five estuaries in South Africa in terms of its importance from a biodiversity and fish nursery area and the Kleinriviersberg mountain range should be protected as a highly conservation worthy area.

Similar comments apply to the Bot River Estuary, which ranks within the top ten important estuaries in South Africa. Importance also needs to be attached to the Uilkraals River and its estuary.

It needs to be noted that the coastal area from and including the Klein River Estuary through to the Kogelberg has been recognised internationally as an Important Bird Area and that an application is in process for the Bot River Estuary to be declared a RAMSAR wetland.

The Hemel en Aarde and Stanford valley areas should be seen as important riparian corridors to the sea, down the Onrus and Klein rivers respectively.

The SDF needs to propose development policies and strategies that protect the character of this “urban coast” from a further slide towards an ugly ribbon development, dominated by dual carriageway roads and multiple traffic light controlled intersections, lacking cycle tracks or imaginative design to create pleasing aesthetics, that will progressively weaken the Overstrand’s appeal as a tourism destination.

6. Spatial Development Framework

6.1 Spatial Planning Categories

Given the significance of estuaries in the Overberg, Core 2 should have estuaries added into the definition. The policy for setback line determination for estuaries should be given as the 5m above mean sea level contour line as established in the NEMA EIA regulations (NEMA Listing Notice 3: List of Activities and Competent Authorities Identified in Terms of Sections 24(2) and 24D for the Western Cape), which defines estuaries to include the “estuarine functional zone” as defined in the National Estuaries Layer, available from the South African National Biodiversity Institute’s BGIS website (

The policy for Urban Settlements should require consistency and compliance with the Western Cape Provincial SDF Settlement Restructuring: An Explanatory Manual (March 2009).

6.2 Bio-Regions

Tables: Characteristics of Bio-Regions

Kleinmond is shown as part of Map no.6 Urban Coastal Corridor when it should clearly be part of Map no.1 Kogelberg, where it is closely associated with the Palmiet River Estuary on the west and the Bot - Kleinmond river estuarine system on the east.

The Agulhas Plain is widely recognised as extending on the seaward side of the Kleinriveirsberg Mountain Range up to Voëlklip, taking in the Klein River Estuary (refer also to the attached letter from ELL Ivey).

Gansbaai and Pearly Beach, including the Uilkraals River Estuary should be included into the Wilderness Coastal Corridor, sharing common characteristics with Struisbaai, Agulhas, Arniston and Infanta.

Wave energy conversion should be added to the renewable energy potential. This should be associated with harbours where there is already disturbance of the shoreline.

6.2.1 Region 1: Kogelberg

A close linkage should be encouraged between Kleinmond and the other towns in the Hangklip region of the Kogelberg Biosphere Reserve. Kleinmond should be seen as the entry point into the KBR via the Palmiet River corridor. A marine reserve should be created between Kleinmond and the Bot River Estuary mouth.

The Lamloch Swamp area should be expropriated and incorporated into the Rooisand Nature Reserve.

6.2.2 Region 2: Theewaterskloof

No comment

6.2.3 Region 3: Riviersonderend Mountains

No comment

6.2.4 Region 4: The Ruens

No comment

6.2.5 Region 5: Agulhas Plains

Provision should be made for the use of treated sewage from the Stanford waste water treatment works for irrigation and not discharged into the Klein River Estuary.

Provision should be made for the R43 from Voëlklip to Pearly Beach to be upgraded to a high quality scenic route with a safe cycling track.

The route from the N2 through Caledon to Stanford should be recognised as the main access route from Cape Town to the towns east of Hermanus, obviating the need for a by-pass road around Hermanus through the Fernkloof Nature Reserve.

The policy CIP7 relating to the upgrading of the Caledon to Hermanus route through the Hemel en Aarde Valley is misplaced and should be stated under 6.2.6

6.2.6Region 6: Urban Coastal Corridor 5

As indicated above under the heading Tables: Characteristics of Bio-Regions, the demarcation of the Bio-Regions is not appropriate and what is included in the “Urban Coastal Corridor” needs to be reviewed and it is proposed that Region 6 should become “Greater Hermanus”. It is suggested that the western boundary of this Bio-Region should be Fisherhaven and the eastern boundary should be Voëlklip. The urban edge should be fixed at the current urban footprint at the eastern end of Voëlklip and at the western end of Fisherhaven and no further expansion should be allowed on the inland side of the R43 (i.e. no urban expansion towards the Onrus Mountain).

A new vision needs to be created for the Hermanus area that includes development of a commercial and light industrial centre at Hawston and reduces the private car traffic flow on the R43 into the centre of Hermanus. It is critically important that safe cycle lanes must be created along the R43 … it is not acceptable that provincial roads policy dictates that the R43 cannot have cycle lanes as this is in conflict with the provincial SDF!

A vision needs to be created, with implementation policies, for the development of three urban centres for the Overstrand (Kleinmond in the Kogelberg, greater Hermanus, Gansbaai). The vision needs to provide for these three centres to cater for the commercial and amenities needs of surrounding communities and to have strong public transport connectivity within and between them.

The vision and policies for greater Hermanus needs to be consistent with the Western Cape Provincial SDF Settlement Restructuring: An Explanatory Manual (March 2009).

The policy statement UCC2 concerning the proposed nuclear power station is misplaced and should properly be moved to 6.2.7 Region 7: Wilderness Coastal Corridor. The proposed site, Bantamsklip, is situated in a pristine wilderness area on Groot Hagelkraal, a national heritage site, flanked by the Pearly Beach and Soetfontein nature reserves and in close proximity to the Quoin Point Nature Reserve and the Agulhas National Park.

The SDF should contain an overlay that shows the infrastructural requirements for the construction village that will be required to house up to 10 000 construction workers and their families for the 10 year construction phase of the project and provide policy guidelines for how the influx of people will be dealt with in the short and long term.

6.2.7 Region 7: Wilderness Coastal Corridor

Policies need to include the management and sustainable tourist exploitation Dyer Island Complex, which is under the administration of Cape Nature.

As mentioned above, Gansbaai should be viewed as an important urban centre within the Wilderness Coastal Corridor and the consequences on this area of the proposed Bantamsklip nuclear power station need to be thoroughly dealt with.

6.2.8 Region 8: Langeberg

No comment

6.2.9 Region 9: Route 62

No comment

6.3 Settlement Hierarchy

No comment

6.4 Main Tourism Destinations

There are a number of serious omissions in the Overstrand area including:

o Avitourism: Internationally Important Birding Area (Hangklip – Klein River Estuary)

o Betty’s Bay: Harold Porter Gardens; Stoney Point Penguin Reserve; recreational fishing

o Kleinmond: Harbour Road; Blue Flag Beach; recreational fishing; Kogelberg Biosphere Reserve; Rooisand Reserve

o Bot River Estuary: sailing; recreational fishing; bird watching

o Hawston: Blue Flag Beach; recreational fishing

o Onrus: Art

o Hemel en Aarde Valley: wine route

o Hermanus: Fernkloof Nature Reserve; Cliff Path; Blue Flag Beach; Saturday markets; Village Square; restaurants; Old harbour; Whale Museum, whale crier and whale watching; adventure sports

o Klein River Estuary: sailing; recreational fishing; bird watching

o Stanford: Art; Wandelpad; River Cruises; Stanford Valley beer, wine, cheese tasting;

o Gansbaai: De Kelders; Walker Bay Nature Reserve

o Kleinbaai: Great white shark watching and cage diving; Dyer Island Complex (penguins, seals, birds)

o Baardskeedersboss: Art route

6.5 Land Reform

No comment

6.6 Major Projects

Transport: The development of an integrated transport strategy and implementation plan that pulls together all the government departments and municipal players that have fractured jurisdictional responsibilities and provides meaningful opportunity for civil society involvement is a high priority. Please refer to the attached letter from the Hermanus Ratepayers Association (HRA) and the associated Overberg District Municipal Mobility Strategy Concepts Volume 1 report: Towards an Integrated Public Transport Network.

WCC supports the recommendation contained in the HRA letter that an Overstrand Transportation Integration Forum needs to be set up to address the chaotic state of transport planning in the area.

Birding Route: Refer to the attached Letter from Birdlife Overberg and to the report prepared by Anchor Environmental for the DTI: Avitourism in South Africa, Opportunities and Recommendations (November 2009). Cognisance needs to be given to the seven Important Bird Areas listed in the Birdlife Overberg letter and to opportunity to embark on a project to develop the avitourism industry in the Overberg.

High School in Kleinmond: Provision should be made for a high school to be opened in Kleinmond.

6.7 Recommendations for Local Municipalities

6.7.1 Theewaterskloof

No comment

6.7.2 Cape Agulhas

No comment

6.7.3 Overstrand

Consolidate cadastral units making up individual municipal nature reserves, zone them as public open space zone 1 and have them proclaimed as nature reserves in terms of NEMA: Protected Areas Act No.57 of 2003 (as amended) to ensure their continued existence in perpetuity.

6.7.4 Swellendam

No comment


o BirdLife Overberg: Birding in the Overberg

o Hermanus Ratepayers Association: Transport Planning

o The DTI: Avitourism in South Africa

o Overberg District Municipality: Transport Network



CARIN MALAN (posted: 2013-03-07)
Dear Rob & Anton, Thank you for all your time, effort and dedication preparing and commeting on this important report.