PORT ELIZABETH OFFICE
2 Lawrence Street, Central Hill, 6001, Port Elizabeth. PO Box 12444, Centrahil, 6006. Tel 041 585 9606 Fax to email 086 614 9701
Email peadmin@wessa.co.za www.wessa.org.za
10 July 2015
The Municipal Manager
City of Cape Town
P.O Box 16548
Vlaeberg 8018
ATT: Mr Kevin Sampson
Email: Kevin.Samson@capetown.gov.za
Dear Mr Kevin Sampson
COMMENTS ON APPLICATION FOR A COASTAL WATERS DISCHARGE PERMIT FOR HOUT BAY, CAMPS BAY AND
GREEN POINT SEWAGE SEA OUTFALLS
WESSA (the Wildlife and Environmental Society of South Africa) notes that in order to fulfil the provisions of Section
69 of the National Environmental Management: Integrated Coastal Management Act (ICMA: Act 24 of 2009), the
City of Cape Town (CoCT) is applying for coastal waters effluent discharge (DWS) permits for Hout Bay, Camps Bay
and Green Point Sea Outfalls. These new permits would legalise the three outfalls that are currently operating, but
whose DWS permits have lapsed. We note that the general public have been invited to submit comment on this
application. WESSA is deeply concerned about the continuing impact of the discharge of this effluent, particularly
its potential impacts on the CoCT’s Blue Flag status beaches.
A Blue Flag is an international award given to beaches that meet EXCELLENCE in the areas of safety, amenities,
cleanliness and environmental standards. The strict criteria of the programme are set by the international
coordinators of the Blue Flag campaign in Europe, the FEE (Foundation for Environmental Education). In South
Africa, the programme is managed by WESSA along with participating local authorities under the Department of
Environmental Affairs' CoastCare initiative. The CoCT has voluntarily participated in this programme and has had
Blue Flag status awarded to a number of its beaches for many years now. Their Blue Flag status has been a
powerful national and international tourism drawcard for the CoCT. The Western Cape is an important tourist
region in South Africa; the tourism industry accounts for 9.8% of the provincial GDP. According to the City of Cape
Town Report on the Economic Value of Tourism by Grant Thorton, 2009, 76% of all foreign tourists to the Western
Cape were visiting for holiday and leisure purposes. A review of webpages extolling Cape Town’s top attractions
elucidates that its beaches are consistently amongst those top attractions, particularly that of its Blue Flag status
beaches. The State of Cape Town 2014 Report indicates that achieving a higher future growth trajectory for Cape
Town will depend on the City’s ability to capitalise and grown the industries in which it has some comparative
advantages – namely tourism, amongst others. Clearly protecting the marine environment and the beaches of Cape
Town is of strategic economic importance.
As the Blue Flag National Operator in South Africa, WESSA is obliged to ensure that the Blue Flag programme has an
image of quality and environmental action that is respected and recognised; and that it only convers Blue Flag
status to beaches that meet standards of international EXCELLENCE in water quality (as opposed to only nationally
acceptable sea water quality standards). It is recommended that there should not be any discharge of industrial,
urban wastewater or sewage-related discharges into a Blue Flag area or immediate buffer zone/surrounding area;
and that no industrial, waste-water or sewage-related discharges should affect the beach area (BF Qualifying
Criterion 9). Criterion 13 requires that the participating local authority/beach operator must comply with all
regulations affecting the location and operation of the beach. The legislation may include regulations for land-use
planning, sewage/industrial waste effluent discharge, environmental health regulations, conservation plans,
operations licenses and permits, etc. Criterion 29 requires that emergency plans to cope with pollution risks must
be in place.
WESSA notes that the DWS permit application is for anticipated volumes of sewage to sea at Hout Bay of 11 300m3
a day, at Camps Bay 3 500m3 a day and at Green Point 35 900m3 a day. WESSA is concerned that:
1) the growth of the urban catchment areas that funnel into these outfalls are growing steadily and the marine
environment will not be able to continue to accept increasing volumes of sewage without leading to significant
marine pollution. If the recent aerial photographs taken by Jean Tresfon showing what are alleged to be
sewage plumes from these three outfalls and his anecdotal evidence that such sights are becoming far more
frequent; then this suggests that the tipping point for unacceptable marine pollution may already being
reached. It is not surprising that such effluent discharge rises to the surface from the seabed outfalls,
considering their temperature difference. This creates a public health danger from this surface effluent being
blown inshore. The numerous testimonials of water users in the areas around these outfalls noting smells,
floating sewage-related solids/wastes and that of infections resulting from this pollution is cause for alarm.
2) When these outfalls were commissioned in the decades previous, it could not be expected of the engineers to
anticipate the sheer number, complexity and toxicity of chemicals that are now readily disposed, both legally
and illegally, into these sewerage systems. The Precautionary Principle of NEMA advocates that the CoCT
reconsider the necessity of appropriately treating this sewage before discharging it to sea. The feminising and
fertility-reducing impacts of synthetic human female hormones (from contraceptive medication) circulating in
the recycled tap water of European cities, on human males and animal species, is well documented. This
cautions that we cannot take the disposal of waste chemicals into the environment lightly as they can have
compounding and unexpected harmful impacts.
3) The numerous testimonials of water users in the areas around these outfalls noting the presence of solid faeces
and other sanitary items normally found in sewage suggests that the current macerating devices and filters on
the sewerage systems are now insufficient for the task and need to be upgraded.
It is clear to WESSA that to simply continue the status quo operation of these three outfalls is to ignore the growing
evidence that these systems are no longer adequate, appropriate, that they are very likely to be incuring a growing
chemical pollution risk to the nearshore coastal environment and that they place at risk one of Cape Town’s key
economic drivers, being beach and marine leisure tourism. It must be considered that even the perception that
the coastal waters of Cape Town are becoming too polluted to safely access will have drastic impacts on foreign
and local tourism to the city. Durban experienced this in 2009 when reports of severe sewage contamination of its
central beaches just prior to the Easter holidays saw its beaches and hotel accommodation being deserted as badly
as the “Black December of 1957’ (when several shark attacks occurred). Durban hotel occupancy over 2009 and
2010 reportedly fell to averages of just 30%, with the economic shock resulting in severe criticism of the
Durban/Ethekwini political leadership.
We understand that there is very limited space for developing sewerage treatment infrastructure at these
discharge points, if the traditional pond treatment systems are considered. However there are examples around
the world of compact, new technology treatments systems that can treat the sewage to higher standards that what
is currently being released. The CoCT needs to conduct a thorough investigation into viable alternatives,
recognising that the expense of treating sewage and wastes is just as important as laying out other public
infrastructure to stimulate economic growth.
WESSA recommends that the CoCT cap developments that feed into these three existing systems, and instead
require future developments in these catchments areas to include their own sewage treatment systems as part of
their development or otherwise direct their sewage flow to other sewage treatment facilities that do have the
capacity to treat the sewage to safe, legal discharge standards. We also recommend that the CoCT, through its
Waste and Environmental Management functions, educate the public on appropriate disposal of dangerous
chemicals other than pouring them down drains; and along with that education, promote the development of
conveniently accessible receiving facilities for such chemicals for the public. Currently the WESSA Port Elizabeth
Office is assisting the Nelson Mandela Bay Municipality to develop an educational programme on responsible use
of toilets that are to be installed in communities that have previously not had access to sewage reticulation
systems.
WESSA encourages the City of Cape Town to reconsider its bid to simply continue to discharge inadequately treated
sewage from these three outfalls, because it is simply cheap and convenient to do so. The evidence is mounting
that the marine system is now struggling to adequately dilute this sewage and that this sewage is more frequently
causing a public health menace, which is of growing concern to the citizens of Cape Town. We believe that to
continue to implement the status quo is to jeopardise one the key economic drivers of Cape Town and its hard-won
Blue Flag status tourism beaches, and will place the city at a similar reputational and economic risk that Durban has
already experienced. Instead we urge the City of Cape Town to use this opportunity to create a world benchmark
sewage treatment system, which demonstrates leadership in meeting a city’s welfare and environmental
responsibilities.
Yours in sustainable development
Morgan Griffiths
Environmental Governance Programme Manager
Cellphone: 072 417-5793
Email: morgan@wessaep.co.za