URBAN EDGE
GUIDELINES MANUAL
FOR THE
CITY OF CAPE TOWN
CITY OF CAPE TOWN
ISIXEKO SASEKAPA
STAD KAAPSTAD
October 2004
MLH Architects and Planners in association with Piet Louw Architects, Urban Designer, Planner
URBAN EDGE GUIDELINES MANUAL
TABLE OF CONTENTS
Page
Page
CHAPTER 1: INTRODUCTION
1
List of Figures
1.1
1.2
1.3
1.4
1
1
2
2
1.
2.
3a.
3b.
3c.
3d.
3e.
3f.
3g.
3h.
3i.
3j.
3k.
4.
5.
6.
Background
Development Applications Adjacent to the Urban Edge
Purpose of the Urban Edge Guidelines Manual
How to use the Guidelines Manual
CHAPTER 2: ASSUMPTIONS
4
2.1
2.2
2.3
2.4
4
4
4
5
Legitimacy of Previous Documentation
Terminology
Mechanism to Assist Decision-Making
Transparency
CHAPTER 3: NORMATIVE POSITION
6
3.1
3.2
7
8
The Urban Edge Line and the Built Edge Concept
The Built Edge Concept Applied
Working Method
Context
The Urban Footprint and Protected Areas
The Urban Edge
Prominent Landform and Character Areas
Valuable Soils
Hydrology: Above and Below Ground Water Resources
Aquatic Ecological Resources
Terrestrial Significance
Protected Areas and Core Flora Conservation Sites
Green Structure
Landmark Elements and Special Places
Scenic Routes and Significant Public Views
Composite Resources and Character Contributing Elements
The Built Edge Concept
The Built Edge Concept Applied
CHAPTER 4: DECISION-SUPPORT SYSTEM
17
List of Annexures
4.1
4.2
4.3
4.4
17
18
26
47
1.
2.
3.
4.
5.
6.
Overview of Process
Sensitivity Analysis: Compatibility with Normative Principles
Detailed Evaluation by Planner
Decision by Local Authority
CHAPTER 5: THE WAY FORWARD
48
REFERENCES
49
Procedure
Peninsula Urban Edge Form
Melkbosstrand Urban Edge Form
Northern Urban Edge Form
Helderberg Urban Edge Form
Veldfire Related Planning Guidelines
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10
11
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12
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CHAPTER 1: INTRODUCTION
1.1
BACKGROUND
The need to manage growth and development pressures within the Cape
Metropolitan Area was identified as part of the spatial restructuring strategy
of the Metropolitan Spatial Development Framework (MSDF).
“Local planning authorities, coordinated by the Cape
Metropolitan Council and the Winelands District Council,
should demarcate, in detail, urban edges surrounding all
urban settlements throughout the Cape Metropolitan
Region including Cape Town, Atlantis, Paarl /Wellington,
Stellenbosch and Somerset West/Strand” (MSDF
Technical Report: Policy 24; 1996).
The creation of the Urban Edge was identified as a mechanism to protect
significant environments and resources and contain urban sprawl, in order
to rationalise service delivery through managing growth and densification.
The subsequent adoption of the MSDF and the policies contained therein
endorsed the need for an Urban Edge that defines an outer limit to urban
development.
Towards the end of 1997, the Cape Metropolitan Council (CMC) appointed
three consultants to prepare edge studies for distinct sections of the
metropolitan area: Peninsula, Northern and Helderberg. The Urban Edge
was drafted based on a contextual analysis of the area and the synthesis
of the following edge informants:
•
•
•
•
•
•
•
•
•
Geophysical environment
Biophysical and ecological environment
River and wetlands systems
Infrastructure location and capacity
Land use and related patterns
Demographic and population profiles and trends
Legal, planning and land ownership situation
Socio-cultural and historic environment
Visual resource analysis.
Extensive consultation was undertaken in order to reach agreement on the
alignment of the Urban Edge Line and input received from interested and
affected parties on the proposed boundary was used to amend and refine
the proposed Urban Edge Line. On the basis of an agreed Urban Edge,
supportive policies and strategies were drafted in order to manage the
Urban Edge and immediate surrounds on a sustainable basis. However, in
the case of the Peninsula Urban Edge, due to the complex nature of
the area detailed management zones and associated area specific
management guidelines were not identified. The Urban Edge Studies also
identified the need for a more localised approach to the sustainable
management of the Urban Edge Line and the zone immediately adjacent.
The Urban Edge Studies were adopted as policy by the City of Cape Town
on 29 August 2001 and subsequently submitted to the Provincial
Government of the Western Cape for approval as Structure Plans in terms
of Section 4(6) of the Land Use Planning Ordinance. However, due to
wider structure planning issues, the City of Cape Town Urban Edge
Structure Plan approval has not been granted to date.
In addition, following the veldfires of 2000, the Ukuvuka campaign was
launched. In April 2001, the Ukuvuka Natural Interface Study, Phase 1
report was completed which was followed by the appointment of
consultants to undertake the Phase 2 work. The Phase 2 work comprised
two studies, Stormwater Management on Slopes Adjacent to Natural Areas
(completed in 2003) and Veldfire Related Planning Guidelines. The
Veldfire Related Planning Guidelines document was completed in April
2004 and clearly has a close relationship with the Urban Edge Guidelines
Manual. The Veldfire Related Planning Guidelines document is contained
in Annexure 6 of this document.
1.2
DEVELOPMENT APPLICATIONS ADJACENT TO THE URBAN
EDGE
Most of the development applications received by the local authority are
straightforward and the decision-making in that regard intuitive. However,
there are a fraction of applications received that are controversial and
require careful consideration. Undoubtedly, the greatest pressure for
development occurs in the management zone adjacent to the Urban Edge.
These applications are therefore often difficult and controversial, with
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arguments both for and against the proposed development equally
convincing. As a result, the decision-making process associated with the
assessment of such development applications needs to deal with the
complexity within the local context.
Development applications are often necessarily motivated on the basis of
interpretation of applicable policy documentation. However, the
metropolitan-wide policy documents often use all-encompassing principles,
summed up in catch-phrase jargon (e.g. densification), which can be
twisted and used to substantiate any manner of development application –
whether suitable or not. It then becomes extremely difficult to assess what
constitutes “good” versus “bad” development since the broad principles
have been shown to support the proposed development application.
Although the overarching principles apply at a metropolitan scale, these
need to be contextually interpreted and applied to the specific local
situation. For example, although exercise is universally accepted to be
good for human health, too much exercise, or exercise in certain
circumstances (e.g. during illness) may in fact be harmful and destructive.
Thus, although a generally accepted principle, it cannot be applied as a
prescriptive standard for each individual in their unique situation.
As a result of the inherent ambiguity in interpretation of the metropolitanwide principles, the amendment of the Urban Edge is often used in support
of the specific development application. However, as indicated above, it is
critically important that each application is evaluated on its own merits and
in terms of the specific local context. Within the framework provided by the
policy documents, the assessment in terms of the local context should be
first and foremost. The amendment or refinement of the Urban Edge, if at
all, should be incidental to and as a consequence of the assessment of the
specific development application.
The previous Studies, referred to above, defined the Urban Edge boundary
and to some extent, the management zone on either side thereof. Due to
the vast area transected by the Urban Edge (in excess of 300km), the
Edge was based on a macro assessment of issues, but defined at a micro
scale along cadastral boundaries. The guidelines are therefore focussed
on translating the macro-principles as contained in the Urban Edge Studies
into a micro-level context where they can be applied to the assessment of
development applications adjacent to the Urban Edge. Thus, the Urban
Edge Guidelines Manual uses the accepted and adopted Urban Edge
boundary as a starting point, but provides the framework within which
decisions regarding local development applications can be made.
It is recognised that in hindsight, some sections of the existing Urban Edge
may seem illogical. It is important to stress that it is NOT the purpose of
the guidelines manual to revisit or redefine the accepted Urban Edge.
Rather, the guidelines manual operates within the context of the current
documentation and provides a decision-support system for use at a local
level which serves to achieve a level of consistency in decision-making
throughout the Unicity.
Similarly, the purpose of this research and documentation is NOT to
produce a comprehensive analysis of the micro-scale conditions
associated with each erf along the Urban Edge. Such refinement will be
the result of the future assessment of individual development applications
where the micro-specific conditions may adjust the Urban Edge – either
restricting or increasing the line around the urban area. For instance,
cadastral boundaries do not always respect topographic constraints such
as steep slopes that, in reality, may redefine the effective Urban Edge in
terms of a particular application.
1.4
1.3
HOW TO USE THE GUIDELINES MANUAL
PURPOSE OF THE URBAN EDGE GUIDELINES MANUAL
The need for guidelines supporting the Urban Edge Studies was identified
by Local Authority officials who are faced with the assessment of
development applications adjacent to the Urban Edge. The purpose of the
manual is therefore the provision of a decision-making framework that
allows the planning officials to review, evaluate and approve or reject
various development applications.
The Guidelines Manual is intended for officials within the Local Authority
who review and assess development applications adjacent to the Urban
Edge. It is intended to assist with difficult applications in order to ensure
that all the necessary elements have been covered in the assessment, and
that there is consistency in decision making.
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It is recognised that the bureaucratic procedures associated with the
assessment of development applications may change over time. However,
instead of focusing on providing an additional procedure for the officials,
the Guidelines Manual provides a decision-making support system that
sets out the thought process that the planner should consider, irrespective
of the bureaucratic procedure that is stipulated at the time.
In this regard, the planner needs to be familiar with the normative position
that underpins the Guidelines Manual (Chapter 3) (The normative position
being the accepted standard and position to which we all subscribe). The
normative position then provides the point of reference for the more
detailed evaluation that focuses on the specific local context of the site in
question.
The decision-support system is explained in Chapter 4 and Annexure 1. It
comprises a two-fold evaluation: a sensitivity analysis in terms of the
normative position, followed by a more detailed evaluation in terms of the
specific context and characteristics of the site.
The Guidelines Manual is also intended to assist the applicant with the
submission of applications. As such, the Guidelines Manual provides the
normative position against which all applications will be tested through the
sensitivity analysis. Secondly, the Guidelines Manual contains Urban Edge
forms (Annexure 2 – 5) which provide detailed step by step guidance, and
which can be completed by the applicant in addition to the motivation
report. These forms indicate the policy and legal documents that should be
considered by the applicant prior to submission, thereby ensuring that the
applicant has made reference to all the necessary secondary
documentation.
It is important to understand that the requirement for the applicant to
complete the relevant form is entirely at the discretion of the Local
Authority, and will be largely dependent on the nature and location of the
property in question as well as the nature of the proposal.
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CHAPTER 2: ASSUMPTIONS
At the outset it is necessary to record the assumptions that underpin the
rationale behind the Guidelines Manual and therefore guide the structuring
thereof in order to provide a useful tool for the assessment of development
applications adjacent to the Urban Edge. These assumptions or points of
departure are discussed in the sections below.
2.1
LEGITIMACY OF PREVIOUS DOCUMENTATION
The Guidelines Manual accepts the rationale and theoretical bases as
contained in the preceding documentation adopted as policy by the City of
Cape Town. Therefore, the principles of development and spatial
guidelines as contained in Metropolitan Spatial Development Framework
and the points of departure and terminology of the Urban Edge Studies are
accepted. Similarly, the Urban Edge as determined by the edge informants
and an extensive public participation process, and subsequently adopted
as policy provides a fix for the purpose of the Guidelines Manual.
However, since the Urban Edge was prepared at a metropolitan-scale and
based on cadastral boundaries, it is recognised that there is scope to
refine the Urban Edge through an interpolation process based on
assessment of individual applications in their specific local context. In this
regard, the Urban Edge is considered a starting point for the purposes of
the Guidelines Manual, but is not immovable as a result of development
applications. The Urban Edge may or may not be refined based on the
specific local context and nature of the development application. As the
Urban Edge is refined through the various applications, so the arguments
and principles underpinning the definition of the Urban Edge line are tested
and become stronger. The defence of the modified Urban Edge in future
applications therefore becomes easier.
2.2
TERMINOLOGY
The Urban Edge Studies defined the notion of an Urban Edge, Urban
Reserve and Management Zones. The interpretation of this terminology is
accepted and used in the Guidelines Manual. However, none of the
previous documentation has defined what constitutes urban or rural
development, primarily because of the complexities associated therewith.
Urban development cannot be simply defined based on land use or the
nature of the built form. It can be argued that the unique context
determines whether development is considered to be urban or not.
The context includes the specific local environment, site size and scale of
development, vegetation, surrounding land uses and nature of built form,
which is why “urban development” is difficult to define in a single sentence.
The definition of “rural development” suffers from similar complexities.
Therefore, the distinction between urban characteristics and rural
characteristics cannot be neatly made. Rather, rural and urban form the
two ends of a continuum. Some developments display clearly urban
characteristics and other clearly rural characteristics and should therefore
be inside and outside the Urban Edge respectively. Other developments,
on the other hand, display both urban and rural characteristics, which
makes it critical to examine the developed footprint and the specific context
within which the development falls.
It can be argued that the definition of whether an activity or development is
urban or not is incidental to the evaluation of the specific development
application. Since each application is unique, it should therefore be
assessed firstly within its specific context to determine whether the
proposed development is appropriate or not. It is only once this decision
has been made, that the debate can be entered into about whether the
Urban Edge line needs to be adjusted in a refined alignment as a
consequence.
2.3
MECHANISM TO ASSIST DECISION-MAKING
The Guidelines Manual is not intended to provide a blueprint for assessing
development applications on the Urban Edge because in many instances,
the answers are not simple. As indicated above, the unique context
specific to each application needs to be understood. The purpose of the
Guidelines Manual, therefore, is to provide a tool that will assist the
decision-making process associated with the assessment of development
applications adjacent to the Urban Edge, and should be read in
conjunction with the respective area–specific Urban Edge Report (2001),
and in the case of the Peninsula, also the Peninsula Management Zone
Report.
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The decision support framework assumes that the local authority officials
who are responsible for assessing the applications are familiar with and
have an intimate working knowledge of the relevant planning policies
applicable to the local area. The officials are therefore well placed to
assess whether the interpretation and application of the macro-scale
policy, as motivated by the applicant, is realistic, and through a series of
prompt questions to evaluate the overall implications of the development
proposal and to formulate suitable conditions should the application be
approved.
2.4
TRANSPARENCY
To the extent that LUPO and the Environmental Conservation Act requires,
the decision-making process is transparent. On the basis of this, and that
the Guidelines Manual is aimed at the larger and the more controversial
edge related land use applications, the manual should be publicly available
to ensure that applications are sufficiently and correctly motivated. If the
criteria and considerations used to evaluate the development applications
are public knowledge, the application process can be shortened since at
the outset the applicant can provide sufficient and adequate information.
The local authority officials can therefore quickly review the information
provided on the appropriate form (See Annexures 2-5) to ensure that it is
adequate and that the applicable documentation has been consulted and
referenced.
Sustainable development requires co-ordination between developers and
officials – not only in terms of submission of applications, but also ongoing
management of development and the resultant Urban Edge boundary
requires a cooperative working relationship between the public and private
sectors.
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CHAPTER 3: NORMATIVE POSITION
A normative position underpins the Urban Edge Guidelines. It is necessary
to understand this position as it establishes the premises and principles
upon which the decision-support system (as detailed in Annexure 1) is
developed.
Any normative position is value-laden. It presents what ought to be, and it
represents the generally acknowledged and accepted position of the
majority.
Previous Urban Edge studies cite McHarg, Mumford, Norberg-Schultz and
Lynch as visionaries who contributed to the rationale for managing the
outward growth of a city. This is based on the premise that the natural
environment is recognised as important. This provides the basis for the
formulation of the normative position that will be used to support the
Guidelines Manual.
The Urban Edge, as established in the previous studies and defined
according to select cadastral boundaries and contour levels is accepted as
the starting point for the Guidelines Manual. However, the Urban Edge,
and the Guidelines both may be refined over time, based on the piecemeal
assessment of individual applications and a monitoring of the effects of
those decisions. Of concern regarding the current alignment of the Urban
Edge is that often neither the natural environment (e.g. water, fauna, etc)
nor the visual environment (e.g. public views, scenic drives) necessarily
coincide with cadastral boundaries or contour levels. The process by
which development applications are reviewed should provide an
opportunity to clarify and consolidate the built edge of the city, in a variety
of forms, and to let the natural or unbuilt condition be the positive, and the
primary informant for such decision-making.
The guidelines in this manual place a strong emphasis on the natural
informants dictating the resultant form of development. In this regard,
ecological and visual continuities can be achieved and enhanced. The
resultant built form can then be used to define the Edge, not necessarily
coinciding with the current Urban Edge, but providing a refinement thereto.
The normative position promotes the fundamental principles and values
upon which guidelines are framed. These are: the need to acknowledge
and promote the unique and different environmental and built character
and qualities of Cape Town and the need to create sustainability.
The guidelines draw on these principles and apply them to the assessment
of individual development applications. By its very nature, decision-making
regarding the development applications is reactive rather than pro-active.
However, it is still necessary to ensure that the resultant urban form serves
the greater public good. In this regard, it is also critical to ensure that the
cumulative effect of the incremental growth and development does not
negatively impact on either the uniqueness of the metropole or the
sustainability thereof. It should, in fact, enhance and promote uniqueness,
while contributing to the definition of the built edge through an appropriate
built form.
In order to practically apply thes e principles to the decision-making
framework, a balanced approach to development needs to be adopted. In
other words, it is important to recognise that sustainable living requires a
balanced and harmonious interaction of the following four components or
environments:
•
•
•
•
Biophysical – living organisms and associated life support systems
(air, water, soil, etc) which provides the basis to our existence.
Social – people living together such that there is a peaceful coexistence
Economic – jobs and money which fuel development
Institutional – power, policy and decision-making which expresses
itself in democracy
The determination of the Urban Edge was seen as a mechanism to
manage growth and development pressures within Cape Town by
protecting significant environments and resources and containing urban
sprawl in order to rationalise service delivery through managing growth
and densification.
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.
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Fig 1 sets out the working method that has been adopted in order to unfold
and graphically illustrate the individual informants and combinations
thereof.
Fig 2 sketches the broader context of the Metropolitan Area of the City of
Cape Town to illustrate the relationships between the dominant natural
elements, the City of Cape Town Boundary, the Urban Edge, the main
national routes to and from the City and the urban footprint or built-up area
with the distribution of urban centres.
The main point illustrated in Fig 3a relates to the informal nature and
general looseness of the edge of the current urban built-up footprint that is
outward orientated. However, the establishment of protected areas has
created a first layer of constraint to urban expansion.
Fig 3b. identifies the Urban Edge line which follows cadastral boundaries.
The subsequent sequence of figures(3c-h), all informants in their own right,
contribute to the totality of the Green Structure (Fig 3i). The individual
layers of informants are:
•
•
•
•
•
•
Fig 3c
Fig 3d
Fig 3e
Fig 3f
Fig 3g
Fig 3h
Prominent Landform and Character Areas
Valuable soils
Hydrology: Above and Below Ground Water Resources
Aquatic Ecological Resources
Terrestrial Significance
Protected Areas and Core Flora Conservation Sites
More design orientated informants are illustrated on Fig 3j namely
Landmark Elements and Special Places, and on Fig 3k which shows
Scenic Routes and Significant Public Views.
Figures 3i, 3j and 3k combine to form Fig. 4 reflecting the Composite
Resources and Character Contributing Elements.
The natural informants provide the starting point for the unique qualities of
Cape Town. It is the combination of prominent landform, soils, aspect and
water (both surface and groundwater) that shape the landscape and create
conditions for particular micro-climates and the establishment of various
species of flora and the supporting fauna. Over time, however,
modifications were introduced to the natural landscape, which have
resulted in scenic routes and views, a specific pattern of agriculture, and a
unique cultural and historical landscape. The combinations and
interrelationships of these informants create the character and uniqueness
of Cape Town at a macro-scale.
It is therefore these criteria and informants from both the natural and
modified landscapes that need to underpin and guide the decision-making
process.
3.1
THE URBAN EDGE LINE AND THE BUILT EDGE CONCEPT
The opportunity exists, and it is argued that it is absolutely paramount, to
clarify and consolidate the built edge of the city. This can occur in a variety
of forms, however the overarching intention should be the establishment
and creation of a clearly defined edge which recognises the informants and
their contributions to the totality of the “green” system. The objective is to
work towards a situation where the natural condition is the positive end
state.
To achieve this end, it is important to know where not to develop and
where to promote continuities to the maximum degree possible to ensure
common agreements about regionally significant linkages (linking coast to
coast, coast to mountain zones), ecological corridors and public viewing
experiences.
Furthermore, the edge should be made in a strong coherent way, using
built form through the gradual piece-meal refinement of the edge,
effectively finishing-off the built-up area in the form of a Built Edge Line.
This line does not necessarily follow the Urban Edge, although it could
coincide with it (as occurs along much of the Peninsula Urban Edge in the
City Bowl and along the Atlantic Seaboard). In many instances, the Built
Edge Line will fall inside the currently defined Urban Edge line. From a
legibility point of view, this approach should clarify where the city (built-up
area) stops and starts using the Built Edge as the device to create a clear
edge, and through this defining the extent of the natural domain.
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The unbuilt zone between the future Built Edge Line and the current Urban
Edge can accommodate and include public open space, ecological and
river corridors, private open space, playing fields, agricultural activities and
uses, rural elements such as treed avenues, vineyards, orchards, fields
homesteads and farmsteads, and rural activities associated with the
cultivation of the land.
3.2
THE BUILT EDGE CONCEPT APPLIED
The concept discussed above is applied to the metropolitan context in
Fig 6. It is an illustration at the level of principle and intent. Built form is
used in a variety of ways to create a clear, defined edge.
At the junction of the built edge line, and national and scenic routes,
“gateways” and sense of arrival-type spaces should be created.
The built edge should, to the maximum degree possible, be aligned to
enable scenic routes to experience a feeling of openness and greenness.
In addition, the built edge should not present the rear and/or sides of
developments onto scenic routes, rather fronts with public access routes
and associated landscaping.
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CHAPTER 4: DECISION-SUPPORT SYSTEM
4.1
OVERVIEW OF PROCESS
A detailed review of the decision support system, together with the
responsibilities of both the applicant and the Local authority in this regard,
is provided in Annexure 1.
Irrespective of the bureaucratic paper-trail required in the assessment of
development applications, which will undoubtedly change over time, the
officials from the local authority are required to assess development
applications and provide recommendations to politicians who make the
final decision.
The decision-support system presented in the Guidelines Manual read
together with the specific Veldfire Related Planning Guidelines (see
Annexure 6) is intended to assist the officials (particularly the planners) in
making decisions regarding development applications adjacent to the
Urban Edge and to provide consistency in this decision making throughout
the Unicity.
This document is intended to assist the planner to undertake a sensitivity
analysis of the application, focussing specifically on where the site is in
relation to the Urban Edge. The sensitivity analysis is based on the
application of the principles embodied in the normative position. Through a
series of prompt questions and suggestions, the planner can quickly
ascertain the extent to which the development application contributes
towards or threatens the uniqueness of the area and the ongoing
sustainability thereof. In terms of the heightened sensitivity, the planner is
then well placed to evaluate the development application in more detail, in
terms of the specific characteristics of the site and the proposed built form.
A further set of prompts and comments is provided for the detailed
evaluation. With the background of the sensitivity analysis, the planner
evaluates the application with specific reference to how the applicant has
applied the relevant policy and legislative documentation in the motivation
of the proposed development. The detailed evaluation should occur in two
parts: The first to determine whether the application is consistent with
existing policy, and the second part to determine whether the proposed
built form responds adequately to the specific characteristics applicable to
the site. On the basis of an overall evaluation for each section, the planner
is then well placed to provide a recommendation from a planning
perspective.
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4.2
SENSITIVITY ANALYSIS: COMPATIBILITY WITH NORMATIVE
PRINCIPLES
On receipt of the completed application, the planner for the area can first
conduct a sensitivity analysis in the context of the normative position to
indicate the nature of the Urban Edge environment within which the
application is based, and the associated issues that will require careful
consideration.
At a fundamental level, the proposed development should comply with
principles encompassing the normative position. In order to assist the
planner to assess whether this is indeed the case, the following prompt
questions and suggestions for a preliminary evaluation have been
compiled.
In this section, the considerations relating to the normative principles focus
specifically on where the site is located in relation to the informants that
contribute to the quality and character of the Cape Metropole and
contribute to the sustainability thereof. It is critical that these fundamental
principles are adhered to, regardless of the type of development proposed.
A more detailed evaluation relating specifically to the proposed
development occurs at a later stage (section 4.3) and focuses on the
characteristics of the site and the anticipated built form response. In
addition, this detailed evaluation must take into account the Veldfire
Related Planning Guidelines contained in Annexure 6 of this document.
Therefore, the sensitivity analysis is not intended to provide absolute
answers to whether the development should be permitted or not, but rather
to heighten the awareness of the planner to the sensitive issues as
emerging from the normative position that should be borne in mind when
undetaking the detailed evaluation.
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CONSIDERATIONS
A. GENERAL CONSIDERATIONS
A1 To what extent is the proposed
development desirable from a public
benefit and desirability perspective?
COMMENTS / SUGGESTIONS
•
While it is important that development
is socially responsible and stimulates
equitable economic development, it
should also be environmentally sound.
It can be expected that the personal
economic gain from the proposed
development will be argued in terms of
the benefits to society as a whole (e.g.
increase in employment opportunities,
increased rates for the local authority).
The benefit of the proposed
development to the broader public
should be quantified (direct, indirect,
recurrent and cumulative benefits)
wherever possible in order to measure
the public benefit against the
anticipated costs.
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CONSIDERATIONS
A2 To what extent does the proposed
developed impose additional costs to
Council and society?
•
COMMENTS / SUGGESTIONS
While it is important that development is
socially responsible and stimulates
equitable economic development, it should
also be environmentally sound. The
various costs (although often not
expressible in monetary terms) need to be
assessed in this regard. However, the
direct costs associated with the provision of
infrastructural services, and the indirect
costs incurred through the enforcement of
conditions needs to be examined. In
addition, the opportunity cost to society
also needs to be evaluated (e.g. loss of
land with high agricultural potential,
additional impact on infrastructural
services). These issues and the initial,
recurrent and cumulative effect thereof
should be weighed against the purported
benefits of the proposed development.
Additional conditions (financial or
infrastructural) may need to be imposed
should the costs justify it.
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CONSIDERATIONS
A3 To what extent does the public comment
received support the proposed
development?
A4 To what extent do the comments from
other departments support the proposed
development?
•
•
COMMENTS / SUGGESTIONS
The planner is responsible for making the
overall decision with regard to the
application for the proposed development.
However, since sustainability requires
accountability, participation and
transparency, the public comments need to
be recognised, and where valid, feasible
and enforceable conditions should be
stipulated, particularly those that protect
the broader public interest, rather than
localised self interest.
The planner is responsible for making the
overall decision with regard to the
application for the proposed development.
However, since sustainability requires
accountability, participation and
transparency, the comments from other
departments need to be recognised, and
feasible and enforceable conditions should
be prescribed. In particular, special
consideration should be given to the legal
requirements in terms of the Environmental
Conservation Act and the Heritage
Resources Act.
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CONSIDERATIONS
A5 To what extent is the site visually exposed?
To what extent is the site located in a
hazardous position from a veldfire
perspective.
•
•
•
COMMENTS/SUGGESTIONS
Special care needs to be taken when sites are
located on high elevational ground, ridgelines or on
ground with slopes greater than 9° since it is likely to
be visually sensitive. In this regard, it is important to
determine the areas from where it can be viewed (of
topography and aspect). Particular attention should
be given to sites where development may impact on
the silhouette of the skyline and/or the ridgeline, and
where visible from gateways to the city, recognised
metropolitan viewpoints of public significance and
scenic routes.
9° is an internationally recognised convention.
Development on slopes of 9° or steeper is likely to
have a visual impact.
Note Annexure 6, Section 8.1 and Figure 7.
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CONSIDERATIONS
A6 To what extent can the site contribute to
the continuity and sustainability of aquatic
and terrestrial ecological corridors?
•
•
A7 To what extent is the site located in
proximity to protected or productive land?
•
•
COMMENTS/SUGGESTIONS
Consideration needs to be given to the proximity of
the site to the coast and/or stream or aquifer
networks. Coastal erosion, rising water levels and
floodlines should be taken into account. In addition,
the nature of the fauna and flora on the site (in terms
of sensitivity and rarity) should guide the permissible
development. It is critical that sensitive and rare
biomes are not isolated, but that they form part of a
wider network where natural migration is not
inhibited.
Where applicable, ensure the principles of the “Asset
Protection Zone” and “Final Modification” as
contained in Annexure 6 are adopted.
Development adjacent to high potential agricultural
soils or protected natural environments (formal or
informal) should be sensitively approached. As far as
possible, good agricultural land should be retained
for such use and therefore developments adjacent
thereto should be compatible with agricultural land
use. Similarly, land use in close proximity to
protected environments should support, enhance and
possibly expand the inherent uniqueness thereof.
Where applicable, ensure the principles of the “Asset
Protection Zone” and “Final Modification” as
contained in Annexure 6 are adopted.
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CONSIDERATIONS
A8 To what extent is the site located along a
scenic route, in the vicinity of landmark
features, near gateways or adjacent to
prominent public viewpoints?
A9 To what extent is the site located in
proximity to special places or significant
elements?
•
•
COMMENTS/SUGGESTIONS
Views onto the site from scenic routes and prominent
public view points are to be considered. It is essential
that sites that are implicated in this regard are
sensitively designed, with particular attention given to
issues such as building grain, building massing, roof
silhouette, boundary details and foreground.
Special places and elements such as neks (e.g.
Constantia Nek, Kloofnek), tree avenues of stature,
and places of historical, heritage and public
significance, and where these contribute to the
‘cultural landscape’, define the character and
uniqueness of an area. The urban design for the site
should therefore respond accordingly, recognising
and celebrating the uniqueness encapsulated in the
place-making elements.
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CONSIDERATIONS
A10 To what extent is the site in close proximity
to green structures (e.g. MOSS, zones or
areas with extensive tree canopies)?
To what extend is the green structure a
potential veldfire hazard?
•
•
•
•
COMMENTS/SUGGESTIONS
When a site is adjacent to a “green corridor”, it is
important that the development responds
appropriately, and where possible, contributes
towards and expands the green structure. Particular
attention in this regard should be given to
landscaping and the nature and location of the built
footprint.
Apply the veldfire related planning guidelines if
necessary (Annexure 6).
The overall intention is to maximise the open space,
as either public or private open space, and to
concentrate the built footprint and its impact.
Apply the veldfire related planning guidelines if
necessary (Annexure 6).
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4.3
DETAILED EVALUATION BY PLANNER
The type of application (rezoning, subdivision etc.) and sensitivity analysis
provide the backdrop to the more detailed evaluation presented below. In
particular, the sensitivity analysis should indicate to the planner the issues
that require special attention when considering the characteristics of the
specific site and the proposed built form response, including the response
of the application to the Veldfire Related Planning Guidelines. (Annexure
6).
In order to synthesise the arguments presented in the supporting
motivation and assist with the decision-making process, the detailed
evaluation is comprised of prompt questions (considerations) and
suggestions.
The sections are arranged in the same format as the Urban Edge form
(See Annexures 2-5) that should be completed by the applicant. However,
in order to assist the planner with the integration of the information
presented, a limited number of overarching questions with supporting
comments are provided for each section.
It is not possible to anticipate and provide a definitive answer for every
type of situation that may arise. Therefore, the questioning technique
applied in the considerations column is formulated to stimulate the thought
process or further discussion. Similarly, the illustrations are included to
support the comments or suggestions and as such, indicate generic
situations, the principles of which will need to be applied to the specific
circumstances pertaining to the development application in question.
It is anticipated that the responses to the considerations and suggestions
will enable the planner to formulate an opinion on whether the proposed
development should be approved, and if so, the conditions that should
accompany the final decision.
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CONSIDERATIONS
B. PLANNING POLICY
B1 To what extent does the development
application support or contradict the vision
and fundamental planning principles as
set out in this document including those
set out in the “Veldfire related planning
guidelines” (Annexure 6).?
COMMENTS / SUGGESTIONS
•
•
B2 To what extent is the development
application appropriate in its context.
•
•
If the proposed development cannot
endorse the vision and any of the
fundamental planning principles as
contained in the Structure Plan or Spatial
Development Framework, then, at the most
basic level, the application should NOT be
supported.
If the development is in conflict with the
veldfire related planning guidelines
(Annexure 6) it should not be supported.
The development application and
anticipated built form should be assessed
in terms of the impact on the identity of the
local areas as defined by the modified and
natural landscapes and the various
interrelationships that exist, with specific
reference to scenic routes and gateways.
If the development is in conflict with the
veldfire related planning guidelines
(Annexure 6) it should not be supported.
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CONSIDERATIONS
B3 To what extent does the development
application process support or contradict
the veldfire related planning guidelines
(Annexure 6) and the area-specific
planning principles that deal with
economic, social, biophysical and
institutional sustainability?
•
•
COMMENTS / SUGGESTIONS
Development applications must take into
account veldfire hazard if applicable.
It is critical that development applications
are sustainable and can prove this in both
a local and area-wide context, considering
all aspects of sustainability.
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CONSIDERATIONS
C. URBAN EDGE GUIDELINES
C1 To what extent does the Urban Edge need
to be amended to accommodate the
proposed development (e.g. proposed
development outside the Urban Edge is
considered to be urban)?
To what extent should the veldfire related
planning guidelines (Annexure 6) apply?
COMMENTS / SUGGESTIONS
•
Applications that alter the Urban Edge
require special scrutiny to justify such
amendment. Follow through the evaluation
to determine whether this modification can
be justified.
The current cadastrally based urban edge
may exhibit anomalous situations. Where
applications outside the edge are
approved, this should only be done where
major concessions to the natural
environment can be made, including inter
alia, the completion of ecological corridors
and open space systems. The nature of the
built form in such instances must reflect the
logic of the decision to amend the edge
and must comply with the other applicable
considerations in this document.
•
Development within the cadastrally
determined edge, that occurs in a situation
which could be regarded as anomalous,
should only be favourably considered
where the nature of the development
emphasises the natural state through, for
example, landscaping and open space
provision and the density of the proposed
development. Care should be taken to
ensure that the other applicable
considerations in this document are
addressed.
Where necessary, require the application
of the veldfire related planning guidelines
(Annexure 6).
•
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CONSIDERATIONS
C2 To what extent does the development
application support or contradict the
policies as contained in the Urban Edge
report?
•
COMMENTS / SUGGESTIONS
If any of the policies are contradicted, then
the motivation or mitigating circumstances
should be fully explained. Should the
argument suffice, the proposed
development could be permitted subject to
relevant conditions.
C3 To what extent does the development
application support or contradict the
management guidelines as contained in
the Urban Edge report for the relevant
section of the Urban Edge?
•
If any of the management guidelines are
contradicted, then the motivation or
mitigating circumstances should be fully
explained. Should the argument suffice, the
proposed development could be permitted
subject to relevant conditions.
C4 To what extent does the development
application take into account the Veldfire
related planning guidelines (Annexure6).
•
If the proposed development is at risk from
veldfires or could be a potential source of
veldfires, the guidelines as set out in
Annexure 6 should be enforced.
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CONSIDERATIONS
D. SURROUNDING ZONING AND LAND USE
D1 To what extent does the zoning define the
character of the area in terms of permitted
land use, minimum erf size, coverage,
floor area ratio, building lines, height, etc.?
D2 What restrictions are placed on the density
of development by the surrounding
zoning?
COMMENTS / SUGGESTIONS
•
•
Development applications that serve to
enhance or reinforce the existing or
established character of the surrounding
area (as defined by permitted land use,
minimum erf size, coverage, floor area
ratio, building lines, height, etc. resulting in
a particular grain and density of the
surrounding built footprint) should be
supported to the extent that the resultant
character is deemed to be appropriate. In
instances where the proposed zoning
permits significantly different rights to the
surrounding zoning, the development
application will need careful assessment
and convincing motivation. The unique
character of a precinct should be
celebrated and managed. However, care
should also be taken to ensure that
undesirable encroachment is not permitted.
The density of development can
contributes towards the character of an
area. The proposed development should
not exceed the density of the surrounding
area unless this is demonstrated and
agreed to be a positive contribution
towards the character of the area. if not,
the proposal may be required to change to
a smaller scale of development such that
the overall density of the immediate
surrounds is not substantially increased
thereby compromising the uniqueness of
the precinct.
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CONSIDERATIONS
D3 To what extent has the surrounding zoning
changed in the past year? Five years?
Ten years?
D4 To what extent has the surrounding land
use changed in the past year? Five years?
Ten years?
•
•
COMMENTS / SUGGESTIONS
Rezoning legally entrenches changed land
use rights. Changes in zonings (particularly
in recent months or years) reflect a change
in market forces that will probably be used
to argue the inevitability of the proposed
development and will be used as a
precedent for future development
applications. In order to be forward looking,
care therefore needs to be taken to ensure
that an unnecessary precedent is not set
especially since zoning entrenches specific
land use rights.
Changes in land uses (particularly in recent
months or years) reflect a change in
market forces. This will probably be used to
argue the inevitability of the proposed
development and will be used as a
precedent for future development
applications. Sustainability requires
environmental responsibility that is
balanced with development that is both
socially just and economically feasible.
However, the land use also needs to be
examined in terms of rights granted by the
applicable zoning scheme.
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CONSIDERATIONS
E. PROPOSED ZONING AND LAND USE
E1 To what extent are the land use
restrictions of the proposed zoning
compatible with the land use restrictions
applicable to the surrounding area?
E2 To what extent do restrictions (if any) need
to be placed on the permissible land uses
within the proposed zoning?
COMMENTS / SUGGESTIONS
•
Compatibility of land use is important to
ensure that the uniqueness of character is
maintained. Particular attention should be
given to the potential of maximum
development within a specific zoning, and
the negative impact this could have on the
surrounds. Proposed zonings that are
substantially different from the surrounding
zoning or have the effect of increasing the
overall density of the area in an
undesirable manner (e.g. in terms of
permissible coverage) should only be
approved with caution.
•
Care must be taken in terms of permissible
and consent land uses granted within the
proposed zoning. In this regard, the
underlying informants that create the
natural and modified landscapes and
thereby define the character of the precinct
need to be clearly understood. Should
there be a particular land use (within the
proposed zoning) that is undesirable in
terms of the character of the area, then it
should be expressly excluded in terms of a
condition of approval. Similarly, restrictions
or amendments that define the scale of
development (e.g. setback, coverage,
height, etc) may need to be enforced.
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CONSIDERATIONS
E3 Based on an approved rezoning or
subdivision, how can an undesirable
ripple-effect be contained or managed?
•
COMMENTS / SUGGESTIONS
It is critical to ensure that the ecological
limits associated with the natural carrying
capacity are respected and upheld. In this
regard, the entire system (and the
respective linkages) needs to be examined
and the potential cumulative impact
assessed. The conditions and specifics of
a particular rezoning or subdivision
application need to be carefully stipulated
in order to prevent the setting of precedent
that encourages urban sprawl.
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CONSIDERATIONS
F. NATURAL ENVIRONMENT
F1 To what extent do the natural
characteristics of the site and the
immediate surrounds determine the
development potential of the site. (e.g.
flooding, geological instability, fire)?
COMMENTS / SUGGESTIONS
•
•
F2 To what extent do the natural
characteristics of the site and the
immediate surrounds influence the
surrounding community (e.g. flooding,
geological instability, fire), particularly in
the long-term?
•
•
The Local Authority is responsible for
ensuring short-term and long-term safety
issues are adequately addressed. In this
regard, it is important to ensure that the
ecological limits of the natural environment
are respected. If the anticipated impact on
safety is significant when viewing the entire
system in its context. The proposed
development can be rejected on these
grounds.
Veldfire related planning issues as set out
in Annexure 6 must be considered.
The Local Authority is responsible for
ensuring short-term and long-term safety
issues are adequately addressed. In this
regard, it is important to ensure that the
ecological limits of the natural environment
are respected. If the anticipated impact on
safety is significant when viewing the entire
system in its context, the proposed
development can be rejected on these
grounds.
Veldfire related planning issues as set out
in Annexure 6 must be considered.
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CONSIDERATIONS
F3 To what extent do the natural
characteristics of the site and the
immediate surrounds influence on the
long-term sustainability of the natural
environment (e.g. groundwater discharge,
impact on surface water runoff,
maintenance of ecological corridors etc.)?
•
•
COMMENTS / SUGGESTIONS
The Local Authority is responsible for
ensuring long-term sustainability issues,
including downstream and upstream
impacts are adequately addressed. In this
regard, it is important to ensure that the
ecological limits of the natural environment
are respected. Issues such as floodlines
and water levels (including the effect of sea
level rise and coastal erosion) should be
taken cognisance of. If the overall
anticipated impact is significant when
viewing the entire system in its context, the
proposed development can be rejected on
these grounds. It is critical that any
development respects the ecological limits
and displays concern for the long-term
future of the area and, where possible,
expands ecological corridors or protected
natural environments. Subdivision
applications that divide corridors or
protected natural environments should
therefore be carefully assessed.
Veldfire related planning issues as set out
in Annexure 6 must be considered.
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CONSIDERATIONS
F4 To what extent do the natural
characteristics of the site influence the
aesthetics or visual amenity/integrity of the
local surrounds (e.g. ridgelines or steep
slopes which have visual exposure, extent
of cut-and-fill required, well vegetated
area, protected natural environment)?
•
COMMENTS / SUGGESTIONS
As far as possible, the specific uniqueness
and character of the area should be
retained. Development applications should
take cognisance of the informants that
create the uniqueness and specify how the
negative impacts of the development on
the aesthetics will be mitigated. Special
attention should be given to the silhouette
of the skyline and/or ridgeline and the use
of roofing materials. Reflective roofs on
steep slopes should not be permitted and
orientation and extent of glazing carefully
considered. If reasonable, these
specifications should be included with the
conditions. It is essential that these
mitigation measures are both feasible and
enforceable. It is critical that any
development respects the ecological limits
and displays concern for the long-term
future of the area and, where possible,
expands ecological corridors or protected
natural environments. Subdivision
applications that divide corridors or
protected natural environments should
therefore be carefully assessed.
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CONSIDERATIONS
F5 To what extent does the development
application remove or protect any
threatened and endemic species: fauna
and flora?
F6 To what extent will the proposed
development rehabilitate the environment
or require the environment to be modified
in terms of the veldfire related planning
guidelines (Annexure 6)?
•
•
COMMENTS / SUGGESTIONS
Sensitive natural habitats that create a
particular character or uniqueness should
be protected and managed. Particular
attention should be given to protecting and
managing fauna and flora that is either rare
and/or sensitive. Development applications
should specify how the negative impacts of
the development in this regard will be
mitigated, and if reasonable, these
specifications should be included with the
conditions. It is essential that these
mitigation measures are both feasible and
enforceable.
A commitment to rehabilitation, including
the application of the asset protection zone
and fuel modification principles if
necessary, indicates accountability and a
concern for the future. Development
applications should specify the
rehabilitation and veldfire related measures
that will be applied in the specific
development, and if reasonable, these
specifications should be included with the
conditions. It is critical that the measures
are both feasible and enforceable.
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CONSIDERATIONS
F7 To what extent does the proposed
development remove land of high and
medium agricultural potential from use for
agricultural purposes?
•
COMMENTS / SUGGESTIONS
It is important to respect the limited
availability of the earth’s natural resources,
including soil suited for agricultural
production. While land not classified as
being of significant agricultural value is
frequently perceived as being suitable for
urban development, this should not be
seen as justification for the fragmentation
of rural landscapes and urban sprawl. The
permanent removal of high and medium
potential land from agricultural production
should not be encouraged. The subdivision
of good quality agricultural land into nonviable farming units may remove it from
agricultural production, and this should
therefore be carefully examined.
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CONSIDERATIONS
G. BUILT ENVIRONMENT
G1 To what extent is the character of the area
informed by the “grain” of the built form?
Does this reflect a historical or cultural
architectural theme?
G2 To what extent does the scale, style,
orientation, height and position of the
proposed development on the site impact
on the visual aesthetics of the immediate
surrounds (i.e. impact on neighbours)?
COMMENTS / SUGGESTIONS
•
The character of an area is reflected in the
manner in which built form has responded
to the natural and modified landscapes.
Development applications that respect and
acknowledge the historical or cultural
character of the local architecture and
significant elements of the local landscape
should be encouraged.
•
Scale, style, orientation, height and
position of the proposed development on
the site contribute towards the character of
the immediate surrounds. Consideration
should also be given to the need for and
duration of lighting on the site. In instances
of subdivision where no particular built form
is proposed, these issues still need to be
considered in terms of permissible
development and entrenched in conditions
of approval.
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CONSIDERATIONS
G3 To what extent does the scale, style,
orientation, height and position of the
proposed development on the site impact
on the visual aesthetics of the local
surrounds (i.e. impact on surrounding
community, as viewed from local access
road or main road)?
•
COMMENTS / SUGGESTIONS
Issues relating to proposed built form
(scale and style), height, setback,
orientation and positioning on the site may
need to be addressed should the proposed
development impact on the character or
uniqueness of an area when viewed from a
local access or main road. Consideration
should also be given to the need for and
duration of lighting on the site. Although a
specific built form may not be articulated
for subdivision applications, these issues
still need to be evaluated. The addressing
of such issues should be included in
conditions associated with the approval. In
particular, scale and building design should
be appropriate in sensitive and scenic
settings.
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CONSIDERATIONS
G4 To what extent does the scale, style,
orientation, height and position of the
proposed development on the site impact
on the visual aesthetics of the metropole
(i.e. impact as viewed from a national road
or scenic route)?
•
COMMENTS / SUGGESTIONS
Developments which negatively impact on
the character of the region should not be
permitted, particularly if visible from a
national road or scenic route. In this
regard, developments in close proximity to
scenic routes and gateways should be
carefully scrutinized. Consideration should
also be given to the need for and duration
of lighting on the site, particularly from a
regional perspective. However, given an
appropriate scale of development, with
issues such as style, landscaping,
boundary treatment, orientation, height and
position on the site adequately addressed,
developments of regional significance may
be approved under certain circumstances,
particularly if infrastructure associated with
the provision of bulk utility services is
required for the sustainability of the
surrounding population. Although a specific
built form may not be articulated for
subdivision applications, these issues still
need to be evaluated in terms of
permissible development.
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CONSIDERATIONS
G5 To what extent does the proposed
development involve removal of
vegetation, and over what period can reestablishment be anticipated?
Is the removal and proposed
reestablishment of vegetation consistent
with the veldfire related planning
guidelines as set out in Annexure 6?
G6 To what extent does the internal road
network support the maintenance of the
Urban Edge and provide clear Edge
definition?
To what extent is the internal road network
compliant with the requirements of the
veldfire related planning guidelines as set
out in Annexure 6?
•
•
COMMENTS / SUGGESTIONS
While it is important that development is
socially responsible and stimulates
equitable economic development, it should
also be environmentally sound. If the
proposed development requires the
removal of established vegetation, special
consideration should be given to
rehabilitating the area with mature, hardy
(preferably indigenous) plants suited to the
local micro-climate such that the visual
aesthetics of the area are restored in the
shortest possible time. Such requirements
may need to form part of the conditions of
approval. Special attention should be given
to the protection of established avenues,
clumps and groupings of trees and the
maintenance and extension of tree
canopies.
Any development adjacent to the urban
edge should indicate a concern for the
future. In this regard, the integrity of the
Urban Edge should be maintained, and
internal road network should be carefully
examined in this regard to ensure that
sprawl and incremental growth is not
encouraged. The design of the road
network should reflect a concern for
policing of the edge, to provide access for
fire fighting purposes, to provide access for
maintenance purposes and to assist in
promoting a “public” front to the edge.
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URBAN EDGE GUIDELINES MANUAL
CONSIDERATIONS
G7To what extent do the boundary details (e.g.
walling, fencing etc.) and landscaping
complement or reinforce the overall
character and built form of the area?
•
COMMENTS / SUGGESTIONS
While the need for security is recognised,
attention should be given to boundary
details such that significant historical and
cultural features are integrated into the
surrounding area in a visually pleasing
manner. The landscaping should relate to
the surrounding area and enhance the
quality of the development. Rear or side
boundaries should as far as possible, not
face onto scenic routes. The nature,
material and finish of boundary fences
should be carefully considered so as not to
negatively impact visually e.g. precast
concrete fences should not be permitted
along defined scenic routes.
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URBAN EDGE GUIDELINES MANUAL
4.4
DECISION BY LOCAL AUTHORITY
On the basis of the sensitivity analysis and the detailed evaluation, the
planner should be well-placed to formulate a response to the development
application from the spatial planning perspective, with associated
conditions as deemed necessary.
Clearly, if the application is not compatible with the relevant planning
policy, and there are no extenuating or mitigating circumstances that
indicate otherwise, the development application should be rejected at a
fundamental level on these grounds.
Where the development application is compatible with the planning policy,
the response to the specific characteristics of the site, including the
response to the Veldfire Related Planning Guidelines, should be
scrutinized. Provided the development proposals are considered to be
consistent with the normative principles and appropriate to the
characteristics of the site, the development application should be
approved, with conditions emerging from the detailed evaluation. If the
development proposal or built form response is considered inappropriate
for the specific site, then the application should be referred back to the
applicant for the resubmission of a proposed built form that is considered
more appropriate for the site in question.
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URBAN EDGE GUIDELINES MANUAL
CHAPTER 5: THE WAY FORWARD
The Guidelines Manual provides the outline of a logical thought process
and decision-making framework. It was prepared and tested through a
public participation process and refined to produce a useable tool that will
primarily assist local authority planners to make decisions regarding
development applications outside the Urban Edge and inside the Urban
Edge (in the Management Zone). The Guidelines Manual is also intended
to provide consistency in decision-making regarding such applications
across the Unicity.
It is important to note that the decision-making process as defined in the
Guidelines Manual is not limited to applications adjacent to the Urban
Edge, but that the principles and thought process can be applied to the
evaluation of other applications, particularly those that reveal a high
degree of sensitivity in terms of the Sensitivity Analysis (i.e. close to scenic
route, MOSS, etc). However, the Guidelines Manual should not be seen as
a panacea to all development applications. The majority of applications
received are straight-forward and a “gut-feel” response is fairly accurate.
However, there are controversial applications that need to be responded
to, and the decision-support system within the Guidelines Manual is
developed to enable the local authority official to undertake a rigorous
analysis and evaluation in this regard. The Guidelines Manual will also be
a useful tool for new planners within the local authority, by providing
pointers to issues that need to be considered.
The usefulness of the Guidelines Manual to potential applicants should not
be underestimated. It can provide clear guidelines regarding the
information required by the local authority in assessing development
applications and the type of response that can be anticipated in relation to
various characteristics of the site and the proposed built form.
Over time, as the decision-making framework is applied to development
applications adjacent to the Urban Edge, so it can be anticipated that the
Urban Edge may be modified on a piece-meal basis, depending on the
type of development permitted on each site. Ultimately, as the Urban Edge
is rigorously tested and redefined, so it will become more distinctive and
defendable, ensuring that the unique Cape character is celebrated and
sustainability is promoted.
It is critical that the Guidelines Manual is read in conjunction with the area
specific Urban Edge reports (2001) and in the case of the Peninsula, also
the peninsula management zone report. These studies provide the context,
starting point and management guidelines applicable to specific sections of
the Urban Edge. Similarly, it is important that the local authority official is
familiar with the current planning policies applicable to his or her area of
responsibility.
As new policies are prepared and adopted, so the
application pro formas (included in Annexure 2 – 5) may need to be
amended. Regardless of these minor adjustments, it can be argued that
the thought process underpinning the decision-making framework should
remain relevant. It is the responsibility of the local authority planners to use
the tool provided in the Guidelines Manual to assist with and provide
consistency in decision-making.
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URBAN EDGE GUIDELINES MANUAL
REFERENCES
Cape Metropolitan Council (1996), Metropolitan Spatial Development
Framework, A Guide for Spatial Development in the Cape Metropolitan
Functional Region
deVilliers Brownlie Associates (2001) Review Guidelines for
Environmental Impact Assessment in the City of Cape Town, Prepared for
Cape Metropolitan Council Administration
MCA Urban and Environmental Planners cc (2000) Policy Guidelines for
Development within Helderberg Smallholding Areas, Prepared for
Helderberg Municipality
MCA Urban and Environmental Planners cc (2000) Policy Guidelines for
Development within Helderberg Rural Areas, Prepared for Helderberg
Municipality
MCA Urban and Environmental Planners cc (2001) Helderberg Urban
Edge Study, Prepared for Cape Metropolitan Council
Setplan and Praktiplan (2001) Rural Management Framework for the City
of Cape Town, Prepared for Cape Metropolitan Council Administration
VKE Consulting Engineers (Pty) Ltd (2000) Development Control
Guidelines in Flood Prone Areas, Prepared for Cape Metropolitan Council Catchment Management Department
VKE Engineers and Planners (2001) Peninsula Urban Edge Study : Draft
Urban Edge Report, Prepared for Cape Metropolitan Council
Administration
Gasson, Barrie (Research in Progress) UCT.
Enviromental Atlas of Metropolitan Cape Town:
Sandveld – Swartland Region
Setplan and Praktiplan (2001) Draft Rural Management Framework for
the City of Cape Town. Volume 1 : Findings and Recommendations.
Prepared for the Cape Metropolitan Council Administration
Ian L. McHarg (1967) Design with Nature
Setplan (2001) Melkbosstrand Urban Edge Study : Final Draft Urban Edge
Report, Prepared for Cape Metropolitan Council Administration
Setplan (2001) Northern Metro Urban Edge Study : Final Draft Urban
Edge Report, Prepared for Cape Metropolitan Council
Paul-Alan Johnson (1994) The Theory of Architecture : Concepts,
Themes and Practices
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ANNEXURE 1
DECISION SUPPORT SYSTEM
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DECISION SUPPORT SYSTEM
Applicant fills in form, motivating
the application in terms of relevant
policy and law.
Environmental evaluation
Cultural/historic evaluation/heritage
Visual/place evaluation
Submission of application
Engineering evaluation
Incomplete information
Relevant sections of Local
Authority review and verify
applicant’s interpretation of policy
and motivation.
Sufficient information to proceed with evaluation
Referred back to applicant for resubmission with amendments to proposed built form
APPLICATION REJECTED
Built form inappropriate in
terms of natural environment
and anticipated visual impact.
Built form appropriate in
terms of natural environment
and anticipated visual impact.
Planner evaluates application
using the prompt questions and
suggestions and department
comments
Sensitivity analysis based on
normative position to assess
location of site with regard to
structuring elements of metropole
which create uniqueness and
promote sustainability
Application is not compliant
with existing policy
Application is not compliant
with existing policy, but
extenuating circumstances
are well motivated
Application is compliant with
existing policy
Detailed evaluation of proposed
development in terms of specific
characteristics of the site
Incorporation of departmental
endorsements, comments and
conditions
APPLICATION APPROVED
WITH/OUT CONDITIONS
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RESPONSIBILITIES OF APPLICANT
reviewing completeness and adequacy of this component of the
application at the outset of the submission.
RESEARCH
Prior to submission of a development application, the applicant should do
the necessary homework; ascertaining what is permitted within the current
land use rights, and whether the proposed application can be
accommodated within the relevant policy parameters. The research is
essential since it forms a basis for the preparation of the motivation.
A step-by-step procedure is presented below that indicates how the pro
formas should be completed by the applicant:
1.
Select the appropriate pro forma for the relevant section of the
Urban Edge: Helderberg, Peninsula, Northern or Melkbosstrand
2.
Locate the property spatially – does it fall inside or outside the
approved urban edge?
What is the erf size?
What is the current zoning and land use?
3.
What is the type of application that has been submitted? This
needs to inform the motivation, assessment and evaluation.
4.
The summary information is recorded in the top right-hand corner
to enable easy tracking of the application should the pro forma at
any stage become detached from the motivation. The applicant
should fill in the property description (erf number) and the
applicants name and contact details (telephone number).
5.
The pro forma is divided into various sections, of which the
relevant policies and management guidelines need to be
considered by the applicant.
6.
The column entitled “criteria” lists those aspects that the
application should consider;
PREPARATION OF MOTIVATION
The applicant is responsible for motivating the proposed development and
associated change in or exercise of land use rights. The motivation should
clearly explain the current land use rights, how this differs from the
proposed rights and why the local authority should approve the application.
Specific issues of possible contention should be clearly dealt with at this
stage (e.g. traffic impact), with detailed investigations by relevant
professionals if necessary. The application should also be supported by
the various documents as stipulated by the local authority (e.g. title deeds,
conveyancer’s certificate, locality map, etc).
In addition, the local authority may require various summary forms to be
completed in support of the application and as a means to track the
application.
COMPLETION OF THE URBAN EDGE PRO FORMA
Pro formas pertaining to applications adjacent to the Urban Edge are
included in Annexures 1 – 4, depending on the relevant portion of the
Urban Edge. It is recommended that these sheets be completed by the
applicant (in addition to any other forms prescribed by the Local Authority)
since it provides a succinct summary of the information contained in the
motivation with respect to the Urban Edge and ensures that the applicant
has referred to the relevant policy and legislative documentation to
substantiate the application. It can be argued that if the application and
motivation is thorough, the information required by these pro formas
should be at the fingertips of the applicant. The presentation of the
information in this format therefore assists the local authority official in
•
Planning Policy: Overall planning policy (e.g. Urban Structure
Plan, Metropolitan Spatial Development Plan) obviously
applies. Other policies or studies (e.g. Spatial Development
Frameworks) applicable to the specific locality may also apply.
The Local Authority will inform the applicant which planning
policies need to be referred to.
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•
•
•
•
•
•
7.
Urban Edge guidelines: Generally one section of the Urban
Edge will apply, but two or more sections may need to be
considered when the application straddles two or more
segments of the Urban Edge.
Surrounding zoning and land use: Record the zonings of the
surrounding properties and current land use. Depending on
the context, the Local Authority may need to examine
properties beyond the immediate neighbours. – this remains at
the discretion of the Local Authority.
Proposed zoning and land use: Record the proposed zoning
and land use within that zoning.
Natural environment: Tick those characteristics or features that
apply to the site, and refer to the relevant legal and policy
documentation.
Built environment: Tick those characteristics or features that
apply to the site, and refer to the relevant legal and policy
documentation.
Other considerations: Tick those characteristics or features
that apply to the site, and refer to the relevant legal and policy
documentation.
The column entitled “Applicable legal and policy documentation”
contains the minimum documentation that should be referred to for
each criteria (row). In this regard, the applicable legal and policy
documentation needs to be considered or applied to the specific
application.
It is important to remember that the list of policies (as indicated on
the pro forma) is not exhaustive. As new policies are formulated
and adopted, these need to be integrated into the list and
appropriately referenced.
8.
When reviewing the legal and policy documentation, the applicant
should assess whether the documentation deals specifically with
or makes reference to issues such as minimum erf size,
restrictions on land use or built form, management guidelines, or
any other significant input which may affect the application. The
applicant should comment on what the policy says in this regard
and how it substantiates the application.
9.
The column entitled “Overall Evaluation” and the block entitled
“Decision/Recommendation” are for official use only. These
sections will be completed by the Local Authority Planner on
review of the information contained in the pro forma.
RESPONSIBILITIES OF LOCAL AUTHORITY PLANNER
INITIAL REVIEW BY LOCAL AUTHORITY
As indicated above, on receipt of the application, the local authority
undertakes an initial review to ensure adequacy of the submission for
detailed assessment and evaluation. In this regard, it is essential that the
officials have an intimate working knowledge of the various relevant policy
documents applicable to the site and can verify that these have been
considered and referenced in the preparation of the motivation.
The initial review by the Local Authority should also ensure that all the
necessary annexures and supporting documents are attached.
Applications that are incomplete will be referred back to the applicant, and
therefore, only applications that are deemed to have adequate information
for a more detailed assessment and evaluation will be accepted and
processed.
At this stage, the Local Authority will also decide which other departments
or sections (besides spatial planning) should review, comment on and if
necessary, approve (or reject) the development application. Copies will
then need to be issued to these departments for their internal evaluation. It
is important that the comments and conditions emerging from the other
departments or sections are collated and interpreted and where necessary,
incorporated into the final decision.
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ANNEXURE 2-5
URBAN EDGE FORMS
VELDFIRE RELATED PLANNING GUIDELINES
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ANNEXURE 6
NATURAL INTERFACE STUDY
VELDFIRE RELATED PLANNING GUIDELINES
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