RAMPAC comments on the Table Bay district plan

6 th June, 2021 For  

Attention: [email protected]  


  1. As a grouping of planning, heritage and urban design professionals living in and with a community-based interest primarily in the Rosebank and Mowbray area our concerns also lie with those parts of the city that are integral to the broader environment around us – such as the mountain and theLiesbeekRiver. We have consequently taken an active interest in the unfolding processes regarding the future of the River Club site and its effect on the integrity of this riverine corridor and valley form. Our comment on the Table Bay District SDF refers solely to the River Club site.  


  1. This package of documents (Vol’s I-4) deserves to be commended on. An enormous amount of information is set out in a formidable series of layers in justification of the final spatial plan accompanied by the guidelines for reaching the objectives outlined.


  1. In demarcating the River Club site as an area for New Development, however, it is our view that the documentation lacks the required justification and fails to support such demarcation.


  1. In support of the above, reference is made to the Draft Table Bay District Baseline and Analysis Report : State of the Population and Environment DRAFT Version 1.1 (found in Vol I) which is dated 28 November 2019 – this being approximately fifteen months before the completion of the Vol II SDF document. The relevance of the above underlining lies with the fact that Section 3.4 of Vol I report documents the key spatial implications for the district plan in order to avoid or mitigate any potential negative impact on the natural and cultural environment; and enhance the opportunities associated with conservation of natural and cultural resources.


  1. The following further substantiates the lack of justification for the New Development demarcation of the site:

5.1 The Vol I report then emphasises :  

  • the need to conserve, maintain and enhance green corridors from the mountain through urban areas;
  • to protect and conserve existing natural river corridors;
  • to investigate and implement measures to reduce flooding along the Salt River system, particularly at the River Club and Paarden Eiland areas;
  • to prevent inappropriate land uses in identified flood prone areas; ROSEBANK & MOWBRAY PLANNING & ARCHITECTURAL COMMITTEE (RAMPAC) DulyauthorisedSubcommittee of the Rosebank Mowbray Civic Association (RMCA) Member of the Greater Cape Town Civic Alliance  
  • to ensure ecological buffers and biodiversity corridors are large enough (and connected) to provide the ecological requirements for the healthy functioning of rivers and wetlands and its associated biodiversity which will also serve to protect development from natural disasters like flooding.

5.2 The environmental management guidelines for flood-prone areas (Vol II, Table 2) states :  

  • Development is undesirable and at risk in the 1:50-year flood mark:
  • Undesirable activities in terms of NEMA should only beauthorisedunder exceptional circumstances, subject to compelling motivation (e.g. where there is an existing right)  
  • New development within the 1:100-year flood line should be subject to formal acknowledgement by the owner of flood risk, and is only permissible where there are existing rights. The entire River Club site lies within the floodplain and is subject to fairly regular flooding. It is questionable, therefore, whether the above term ‘where there is an existing right’ would apply to this site as it was acquired in the full knowledge that it fell within the floodplain, was (and still is) demarcated as Open Space in terms of the existing 2012 SDF which considered any activity which impedes the hydrological functioning and flooding of a river to be undesirable.

5.3 Returning to the above Vol I report, despite the fact that the cultural heritage portion makes no mention of the First Nation heritage linkages with the confluence area of the Black and Liesbeek Rivers and concentrates purely on the colonial history of the area, it nevertheless (Figure 3.1 on p48) indicates the entire Two Rivers Precinct as a Proposed Heritage Area. It is noted that Vol II, Fig 12 has carried this through so that the whole of the Two Rivers Precinct is shown as a Proposed Heritage Conservation area (which is strongly welcomed).  

5.4 The Vol II report refers to the need for further guidelines and refers to the Draft Two Rivers LSDF – recommending that its finalisation be prioritised (p 119).  


  1. All the above illustrates the fact that the documentation simply does not contain adequate justification for the River Club site to be earmarked for New Development – and points instead to the retention of its current demarcation as Open Space accompanied by the current guidelines for its future usage.


  1. We consequently object to the site’s demarcation as a New Development site justified solely by the MSDF’s policy frameworks relating to the economic and social needs of the City – without balancing them with the fundamental nature of the site and its environmental and heritage importance.


  1. The reality of the situation, however, is that environmental authorisation has already been granted by DEADP (in spite of the heritage concerns expressed by HWC), MPT has already approved of the rezoning and departures (together with a departure from the current SDF) to allow for an inappropriate form and scale of development which has now been approved by the City.


  1. Consequently, commenting on this matter (based on the available documentation) carries a feeling of futility as the events over the past number of years relating to this site have revealed, to us, what appears to be an unhealthy and undemocratic intent to secure an inappropriate and over-scaled development on a site that should be appropriately improved and cared for so that it can perform its function as an important natural metropolitan asset in commemoration of its past history. 


  1. We attach or comments on the Two Rivers Precinct Draft LSDF together with its accompanying comment on the River Club Draft Phase I report and request that they be taken into account in our above comments.


Kind Regards,  

Simon Birch  

Chairperson, RAMPAC 


 17th December, 2019  

For Attention: Cindy Postlethwayt [email protected]  

CC: [email protected] [email protected] COMMENT:  




In undertaking this study, strong reliance has been placed on the previous heritage studies undertaken for the area. As with these previous studies there is much which has been thoroughly researched and responsibly addressed. These documents are an important source of information relating to the area. The value of the current study has been considerably enhanced by the addition of the First Nation report.  

Our interest lies specifically with the lower reaches of the Liesbeek River Valley – being the River Club site. Other than general comments relating to the process and the overall study, our comments refer only to this site.  

Notwithstanding the thoroughness of this and the supplementary First Nation’s studies, we consider that the heritage importance of this shallow valley has not been recognised or adequately responded to in determining the heritage-related informants to the future usage of the area.  


1 The importance of the Lower Liesbeek River and its valley context  

  • In commenting on previous heritage studies relating to the River Club site, we have stressed that there has been a consistent failure of the heritage and other consultants to view the Liesbeek River in its broader (Peninsula) context and to appreciate its role as one of the major place-making landscapes along with the mountain and the coastline.  
  • There has, instead, been a narrow concentration purely on its river course and its immediate environment. Its place in the topography has been largely ignored.  
  • While the historic importance (both pre- and post-colonial) of the Liesbeek River and its environs has been responsibly acknowledged and addressed from the point of view of the First Nation connection to the site and the subsequent colonial settlement of the area, the heritage importance of the physical nature (valley) of the Liesbeek has been entirely overlooked.  
  • Notwithstanding the poorly defined topographic presence of the valley line (due to its natural low speed level of flow and exacerbated by extensive infill), it remains a valley – the landscape through which a river flows and floods. As such, it constitutes an important heritage resource in the landscape of the Peninsula which both environmentally and culturally should not be lost to more inappropriate usage. ROSEBANK & MOWBRAY PLANNING & ARCHITECTURAL COMMITTEE (RAMPAC) Duly authorised Subcommittee of the Rosebank Mowbray Civic Association (RMCA) Member of the Greater Cape Town Civic Alliance  
  • The manipulation of the site from the first colonial farming through to the infilling relating to its usage for sportsfields and to the subsequent River Club development has, in the minds and findings of all the consultant teams engaged with the site (seemingly together with the Provincial and City decision-makers), reached a stage of no turning back.  
  • What was a broad shallow valley riverine environment, was dramatically altered to become an elevated (but still floodable) flat plain accompanied by the canalisation of the river. The proposals now being the further lifting of the site out of the floodplain – this dramatic action to be mitigated by measures aimed at restoring the canalised stretch of river to the semblance of a meaningful riverine environment.  
  • While the change in character of this landscape to accommodate what was to become the River Club and its associated buildings was dramatic, it was (other than the visual imposition of the main building) not an overly large intrusion into the visual landscape of the broader area. The remnant of the shallow valley line still persists as an integral part of the full length of the Liesbeek River course.  
  • Notwithstanding the cautionary qualifications accompanying the notional depiction of the current proposals for development being indicated for the site (Fig 30, p47), the elevated ground level and extent of anticipated development will completely change the character of this site. Despite the restored riverine corridor, the still discernible form of a valley (however shallow) will be lost to urban infill.  
  • Apart from the huge environmental changes that would accompany urban infill, the visual perception (as seen from all surrounding higher-lying areas) of what is currently largely a green space (signifying the valley line) will be restricted to the river corridor. The valley as an integral part of the heritage landscape of the Peninsula will be lost.  
  • It is our opinion that the site should revert to public ownership and that its future usage should be subject to an exploratory process with the bottom line being that such usage should be appropriate to the character and context of the site. (Please refer to 6.0 below)  


2 Process  

  • Referring to Fig 3, we consider it to be of serious concern that the HIA has already (albeit at a supposed high-level) fed into and informed the draft LSDF proposals with regard to the spatial demarcation of land proposed for development in the absence of comments from I&AP’s and, critically, HWC’s interim comments.  
  • The heritage informants are a critical input into the LSDF and, in our opinion, require HWC ‘endorsement’ in order to give them validity.  
  • The fact that this study has also served as the basis for a high level HIA of the LSDF seems to procedurally confuse the matter. This is made more problematic as the I&AP comments are required to meet the same submission date  
  • Consequently, we find the relationship between the HIA and the LSDF to be extremely awkward. It lacks the re-assurance of visible impartiality and procedural correctness.  


3 Heritage –related informants to the LSDF  

  • While the repeated reference in the study to Heritage-related Development Informants (rather than the more conventional term of Design Informants) may be an innocent slip-up, it nevertheless creates the perception that this heritage study is overtly biased towards development.  
  • This perception is strengthened by the fact that the River Club site is currently designated for ‘open space purposes’ and we would have expected that the heritage-related informants should relate to any future usage of the site – not just development.  
  • We see the failure to recognise and acknowledge the valley line as an important tangible heritage resource to be a serious omission. The outline of the “Notional river corridor as area Page 3 of 4 to acknowledge and integrate First Nations” as indicated on Fig 30 (p47) is , in fact, a representation of the tangible valley heritage resource.  
  • To illustrate the problem of confusion in the process, we refer to the artists impression of the Composite LSDF overview (Fig 6.11, p113 of the LSDF document) and draw attention to the ‘notational’ depiction of development on the River Club site which clearly bears no resemblance to what would be anticipated by the terms “Develop with some caution” and “Develop with constraints” as indicated on Fig 30 (p47) – despite needing to be informed by them.  


4 Ownership of the land  

  • While acknowledging that this may not appear to be a heritage issue in terms of an analysis of identifying informants to future usage, we need to question the ownership of the land. The fact that State-owned land (earmarked for open space usage) was privatised is a matter that has yet to be adequately addressed.  
  • Its relevance to this study lies in the fact that (other than noting the issue of land ownership) we would expect the informants to future usage being determined solely on heritage grounds – with acknowledgement being taken of its designation in the existing District Plan and of its zoning.  
  • With regard to the River Club site, we strongly endorse the view expressed in the First Nations report referring to the custodianship (rather than the ownership) of the land – hence our views in 1.10 above..  


5 Spatial demarcation of areas for development (referring only to the River Club site)  

  • Referring to Fig 30 (p47), it could be argued that the terms ‘develop with some caution’ and ‘develop with constraints’ are not prescriptive but we consider that this would be shortsighted. Their spatial depiction on the plan (which carries through to the LSDF) is seen as a serious problem.  
  • We again refer to the concern that this HIA is being used as the high-level heritage informant to the LSDF without firstly taking into account the response from this public participation process and in the absence of the subsequent HWC’s interim comment.  
  • Our suggestion is that (certainly in respect of the River Club site) no spatial depiction of usage be indicated on the site plan. Instead, a notation could be inserted to the effect that all future usage should be informed by a list of appropriate indicators reflecting the historic importance of the site (both topographic and cultural) and, critically its physical relationship to the SAAO site.  


6 Possible way forward  

  • The study has emphasised the importance of the Vaarschedrift/River Club site with regard to the history of the First Nations group and, while the following statement (p58) applies to the overall study area, it has particular relevance to this site. “The associations of the site are historically, and in many respects currently, one of dispossession, exclusion, marginalisation and loss. Recognition and redress must be at the core of any heritage sensitive planning process.”  
  • We suggest that ‘recognition and redress’ apply equally as well to the loss of character of the lower reaches of the Liesbeek Valley.  
  • Referring to pp38-40 of the study, to quote : “Indigenising the Two Rivers landscape and transformation to a commemorative landscape, can be achieved by using land and space within the landscape … to give form, structure and functional expression to the intangible cultural heritage of the Khoi and San.”  


Various suggestions are then put forward to physically express this commemoration – these included a heritage centre, an open-air amphitheatre and other physical structures and spaces which would be spread as a matrix across the study area in acknowledgement of their presence and associations throughout the site. “The celebration of other aspects of intangible cultural significance of the area might, for example, include the following:  

  • Respect and protection of the wetland areas, not only for their ecological value but their heritage landscape value.
  • The recognition on the one hand of theLiesbeekRiver as being of outstanding significance in terms of the history of South Africa; and on the other, recognition of the Black River as being of strong local significance.  
  • Recognition of the crossing atVaarschedriftas being of outstanding cultural value in the precolonial history of pastoralism.  
  • Exploration of a detailed set of mechanisms at a site and precinct level tomemorialise, narrate and celebrate the history ofmarginalised and excluded groups …”  
  • It is not clear whether the above bullet point referring to “Exploration of a detailed set of mechanisms …” is the same as the condition contained in the study Recommendations (p63) that “The Western Cape Department of Transport and Public Works, HWC and the City of Cape Town engage with DCAS to agree on funding and initiating a proposal for the cultural heritage project for the entire Two Rivers site, to be undertaken before Precinct Planning for the first precinct is completed and in consultation with all relevant I&APs.”  
  • Whether the same or not, we would suggest that (however laudable the matrix of commemorative spaces/objects throughout the study area may be) the Vaarschedrift /River Club site is the most meaningful commemorative precinct and that the exploration/undertaking of the cultural heritage project should be focussed on this site – (subject to the agreement of the First Nations representatives). 
  • Any such project should include proposals for ensuring the long-term protection of the landscape character of the lower reaches of the Liesbeek Valley as an integral part of one of Cape Town’s prime landscape heritage resources.  
  • The effective undertaking of any such envisaged project would be totally dependent on the Provincial Government extending the provisional protection of the study area – but more particularly including the River Club site.  


Kind Regards,  

Simon Birch  

Chairperson, RAMPAC  

1 Warwick Street, Gardens, Cape Town 8001.

Tel 021 423 3241