I hereby submit a formal objection
I hereby submit a formal objection to the proposed rezoning and subdivision of Erf 563, Grabouw.
While I am not opposed to a development on the site, I find the current proposal inconsistent with Theewaterskloof Municipality's Spatial Development Plan (SDP) and other fundamental planning considerations. My objections are as follows:
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Non-Compliance with the Theewaterskloof Municipality’s Spatial Development Plan
1.1. The Theewaterskloof Municipality’s approved SDP incorporated an alternative development design, which the community supported and approved. The current proposal deviates from this approved framework without due process.
1.2. The proposed density of the development does not meet the SDP’s recommendations for sustainable urban growth.
1.3. The Applicant failed to formally request deviations from the SDP, as required for non-aligned proposals. The Theewaterskloof Municipality should have assessed and approved these Deviations before considering this application.
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Procedural and Governance Concerns
2.1. The Ward Committee had requested modifications and additional information when deviations from the original layout and past Council decisions were being considered. However, the Council proceeded contrary to the community's wishes.
2.2. Law Enforcement, Building Control, and Town Planning failed to act against unauthorised construction activities on the site, raising concerns about future enforcement and oversight of the development.
2.3. The Theewaterskloof Municipality has not demonstrated financial stability, and the project's feasibility is uncertain given the financial constraints.
2.4. The NEMA Authorisation, which was not supplied with the original documentation to the residence, clearly states that ALL Interested and Affected Parties should be formally advised of the authorisation within 14 days of the approval letter. The registered Interested and Affected Parties were not informed of the authorisation or our right to appeal the decision. (Reference: 16/3/3/1E4/11/1030/24; NEAS Reference: WCP/EIA/0001445/2024; Addressed to: WilfredSo@twk.gov.za )
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Site Suitability and Infrastructure Constraints
3.1. The proposed erven sizes are too small to ensure optimal land use and future expansion by property owners. Owners will lack adequate space for home extensions and on-site parking, leading to congestion and inadequate living conditions.
3.2. The Traffic Assessment assumes that future residents will not own cars, an unsustainable assumption that further highlights the impracticality of the development.
3.3. The construction of emergency plots commenced before the required Environmental Assessment was approved, violating environmental regulations and requiring a Section 24G application in terms of the National Environmental Management Act (NEMA). This raises serious concerns about compliance with legal frameworks.
3.4. The site contains large boulders, significantly increasing construction costs beyond what subsidies can cover. Given the municipality's financial limitations, it is unlikely that these additional costs will be absorbed without further strain on public funds.
3.5. The Theewaterskloof Municipality's recent financial statements indicate that citizens owe more than R143 million in unpaid municipal rates. The proposed low-cost development is unlikely to contribute meaningfully to municipal revenue, further exacerbating financial challenges.
3.6. Grabouw's existing sewerage system is already under significant strain. The proposed development will further burden the infrastructure, resulting in service delivery challenges. Evident of this is the Breede-Olifants Catchment Management Agency (BOCMA) conducting investigations into Grabouw's sewerage systems' non-compliance.
3.7. Over the past 15 years, the municipality has failed to facilitate the development of low-middle and middle-class housing in Grabouw at an appropriate scale. Instead, housing developments have placed undue financial strain on the Municipality, affecting its ability to provide sustainable infrastructure and services.
Conclusion
Given the significant deviations from the approved Spatial Development Plan, procedural concerns, and financial and infrastructural constraints, I strongly object to the approval of the rezoning and subdivision of Erf 563 in its current form. The Municipality should prioritise sustainable, community-supported, and fiscally responsible development in Grabouw.
I kindly request that my objections be recorded and considered in decision-making. I further request acknowledgement of receipt of this objection and updates on any subsequent hearings or decisions regarding the application.
I hereby formally request to be registered as an Interested and/or Affected Party (I&AP).
Yours sincerely,
Egrra is the authorized representative
info@egrra.co.za
2272 Celtis Laan
Grabouw
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