development of a methodology for defining and adopting ... · defining and adopting coastal...

VOLUME 2: APPENDICES

DATE: 31 May 2010

Development of a Methodology for Defining and Adopting Coastal

Development Setback Lines.

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks For discussion For final comment

Final Deliverable

Date 1 April 2010 20 May 2010 31 May 2010

Prepared by G G Smith G G Smith G G Smith

Signature

Checked by C Soltau J S Schoonees J S Schoonees

Signature

Authorised by A van Tonder A van Tonder

Signature

Project number 208100E 208100E 208100E

File reference 11.2 11.2 11.2

WSP Africa Coastal Engineers (Pty) Ltd 2nd Floor Ou Kollege Building 35 Church Street Stellenbosch 7600 Tel: +27(0) 21 883 9260 Fax: +27(0) 21 883 3212 http://www.wspgroup.co.za Reg. No: 2007/001832/07

208100E Setback Line Methodology 10

Appendix A: Minutes of Meetings

Appendix B: Project Terms of Reference

Appendix C: The use of CBA Maps in the determination of setback lines.

Appendix D: Case Study Report – Milnerton

Appendix E: Case Study Report – Langebaan

Appendix G: Stakeholder Engagement Report (PPP)

208100E Setback Line Methodology

Appendix A: Minutes of Meetings

Minutes of Meeting Date of meeting : 11/12/2009

Location : Department of Environmental Affairs and Development Planning

Client : Department of Environmental Affairs and Development Planning

Project : Development And Testing Of A Methodology For Defining And Adopting Coastal


Subject : Coastal Setback Inception Meeting

Present :

DEADP-DFU: Gerhard Gerber (GG), Siyabonga Dlulisa (SD)

DEADP-Spatial Planning: Alexia Julia (AJ)

Saldanha Bay Municipality: John Smit (JS)

City of Cape Town: Darryl Colenbrander (DC)

WSP: Geoff Smith (GS), Frans van Eeden (FE)

No. SUBJECT Action

required by

Date

required by

1 Presentation

1.1 GS outlined the steps and methods to consider the study of a

setback line

1.2 The definition of the setback required for different reasons (e.g.

socio-economic, ecological, coastal processes, erosion,

development) need to be made clear.

2 Available literature, studies and developed methodologies

2.1 The City of Cape Town developed a Coastal Development Zone

methodology. (DC)

2.2 A study and decision making tool on Western Cape sea level

rise to be completed end of Jan. by CoCT. (DC)

2.3 The setback line methodology must incorporate the various acts

(NEMA, ICM) in its decision making tree. (DC)

2.4 All literature relating to the project to be made available (or

download links there to) is to be provided by CoCT the relevant

authorities and consulting team.

DC 18/12/2009

2.5 SD together with the Saldanha Bay Municipality (JS) to provide

the Consultant Team with the information on the work

undertaken in Saldanha Bay.

SD/JS 18/12/2009

2.6 SD to also provide the Consultant Team with all the available

information (terms of reference, contact details of service

provider, etc) in terms of the other Departmental Project in the

Bietou area in terms of Climate Change and coastal setbacks.

SD 18/12/2009

2.7 SD provide the Consultant Team with a copy of the Climate

Change Vulnerability Report (2005) as well as the Western

Cape Climate Change Strategy (2009).

SD 18/12/2009

3 Public Participation Process (PPP)

3.1 WSP are to refine and describe information on the public

participation and stakeholder engagement process proposed to

be followed during the development of the methodology.

4 Administration

The Consultant Team is responsible for keeping minutes (action

minutes) of the project meetings. The minutes will be distributed

to the Steering Committee shortly after each meeting with the

Steering Committee members asked to provide comments on

the minutes.

FE 14/12/2009

The Consultant Team to provide refined Project Schedule and

final Payment Schedule (with payments linked to specific

deliverables, project days and timeframes)

FE/GS 15/12/2009

The Consultant Team to provide refined information on the

public participation and stakeholder engagement process

proposed to be followed during the development of the

methodology.

FE/GS 15/12/2009

5 General

The project reports must not just provide the HOW in terms of

the proposed methodology for determining setbacks, but also

the WHY in terms of the reasons why the specific methodology

is being proposed.

Skills transfer is to happen throughout the project period.

6 Steering committee

While there are concerns regarding the size of the Steering

Committee, it is vital that the following project partners and key

stakeholders are represented on the Steering Committee:

Siyabonga Dlulisa (DEA&DP: DFU) [email protected] tel :

021 483 5579 Gerhard Gerber (DEA&DP: DFU)

[email protected] tel 021 483 2787 Paul Hardcastle

(DEA&DP: EIA) [email protected] tel: 021 483 5687

Marek Kedzieja or Alexia Julius (DEA&DP: Spatial Planning)

[email protected] tel: 021 483 4580 Carmen van Uys or

Nontsasa Tonjeni (DEA&DP: Coastal Management)

[email protected] tel: 021 483 2819 Gosiaan Isaacs or

Dennis Laidler (DEA&DP) (in terms of the other Deparmental

Project in Bitou) [email protected] tel: 021 483 3925 Gregg

Oelofse or Darryl Colenbrander (City of Cape Town)

[email protected] tel: 021 487 2133 John Smith

or Lindsey Gaffley (Saldanha Bay Municipality)

[email protected] tel: 022 701 7116 Dr Niel Malan

(DEA) [email protected] tel: 021 402 3021

1 representative of Northern Cape Wilna Oppel

[email protected] tel: 027 718 8800

1 representative of Eastern Cape Phumla Mzazi


1 representative of KZN Omar Parak


1 representative of Cape Nature Tierck


1 representative of CSIR

WSP will contact the representative from the CSIR and report

back to the Committee.

GS 14/12/2009

Steering committee members are to engage actively in the

participation of the project through comments and criticisms

within the given time frames.

7 Next scheduled meeting

The Steering Committee will meet every 2 weeks (unless

otherwise indicated by the Department).

The next meeting is to held during the latter half of January

2009 (possibly on 26 Jan 2009).

The proposed dates of all the meetings are to be put forward to

the Steering Committee as soon as possible.

APPROVAL OF MINUTES OF MEETING

Approval by DFU

By: ___________

Date:__________

Approved by WSP

By: Geoff Smith

Date: 14/12/2009






Subject : Coastal Setback Progress Meeting

Present :

See attached Attendance Register

No. SUBJECT Action

required by

Date

required by

1 Minutes of meeting held on 11/12/2009

Minutes accepted and approved that all actions required were

taken as indicated.

Apologies:

Omar Parak

John Smit

Andrew Mather

Alana Duffel-Canham will be the representative for Cape Nature

2. Presentation of progress of methodology

GS presented the proposed setback line methodology

Comments are requested from the steering committee present.

FvE requested that sites be finalised for the case studies that

would test the methodology. A site has been identified by DC

from the City of Cape Town. JS from Saldanha Bay needs to

identify a site for the Saldanha Bay

JS 29/01/2010

3. Comments from Committee regarding presentation

The case study test sites must try to incorporate features that

will be able to test the methodology comprehensively within

reason.

Alternative methods to beach survey (e.g. slope measurements

using aerial photograph stereoscopy) to be investigated as

beach topography is an important input parameter

The return period for the setback line must be defined and

established in relation to practical considerations (e.g. 1:50yr for

private developments, 1:20yr for parking lot) but limited to say 2

return periods.

The line must also be able to stand up in a court of law –

incorporate cadastral boundaries

Zoning maps are not compulsory for municipalities and would

probably only exist for built areas and probably not for rural

areas

The SDF (Strategic Development Framework – which is

available for all muncipalities) include rural areas in land use

Cape Nature did a lot of work on biodiversity zoning maps. The

maps are available for the Western Cape.

The methodology needs consider the ‘worst case’ where no

information exists on the site.

Previous studies on setback-lines, sea-level rises, EIA’s etc.

exist for areas around the coast.

Historical data is important especially when considering

dynamic features e.g. estuaries.

Assumptions at the start of a case study need to be clearly

stated

Mining rights to be considered

Setback Lines must be incorporated into municipalities’

development zoning

No national coastal committee exists. The methodology should

include input from regional/local coastal committees

Need input from an ICMA representative.

Development seaward of the setback line will be prohibited or

restricted (controlled)

Consider an interim “rule of thumb” setback – in KZN the 10 m

contour line was employed.

A 2 year period has been allowed for the establishment of

setback lines

4. Future actions

GS to incorporate comments from steering committee into

methodology

GS Ongoing

The schedule for the PPP for the project is as follows:

GROUP DATE VENUE TIME

SB Municipality 4 Feb SB

Municipality

10H00

–

13H00

Other

Authorities

5 Feb DEAD&DP 10H00

–

13H00

CT Municipality 5 Feb CT

Municipality

15h30

–

16h30

SB Public 10 Feb Langabaan

Town Hall

17H30

–

18H30

CT Public 11 Feb TBC 17H30

–

18H30

DEA&DP 11/16

Feb

DEA&DP 10H00

–

13H00


The next meeting will be held on 16 February 2010 at 10h00.

It is requested that conference facilities be made available for a

progress report from the PPP process from Danielle Michel

(WSP Environment & Energy).

6. Addendums sent with the minutes

The terms of reference of the project, the presentation (by GS)

and the attendance register are sent out with the minutes.


Approval by DFU

By: ___________

Date:__________

Approved by WSP

By: Geoff Smith

Date: 27/01/2010

WSP Environment & Energy Registered office: WSP House, Bryanston Place Office Park, 199 Bryanston Drive, Bryanston, Johannesburg, South Africa Registered number 1995/08790/07

MEETING NOTES

Job Title Western Cape Coastal Setback Lines

Project Number 91212D

Date 4 February 2010

Time 14:00 – 16:00

Venue Saldanha Bay Municipal Offices, Bree St, Langebaan

Subject Draft Methodology

Client DEA&DP

Present John Smit, Geoff Smith, Danielle Michel (DM)

Apologies

MATTERS ARISING ACTION

GS – Presentation (See attached) 1.

Funding:

� Municipalities don’t have the capacity in house.

� Where will funding come from?

� The municipality’s budget for next year is already being finalised (end of April 2010), and so budget for setback lines needs to be included into this if required to be funded by the local/District municipality.

2.

Setback line time scale:

� Two lines have been propose 1) a 20 year and 2) 50 year line

� If there are different lines, who is responsible/how do they interact?

� What will be the difference between the 20 and 50 year lines – especially when they are close together? Will there be any other lines e.g. 100 year?

- It has been generally accepted that two lines only may be proposed.

- It is not finalised as to how these would interact, perhaps 1) the 20 year for recreational/infrastructure and the 50 year line for building structures (as this is how long buildings are generally designed for)

Setback line:

� Surely there should only be one line to determine where development should start?

� How do you classify areas within it?

- Perhaps need to have data layer to the setback line, to determine the level of “no development” or management within each area.

� Could the management of areas within these lines be negotiated between the local authorities and the developer/proponent?

- No, but would have to be determined by DEA&DP

- Two lines – erosion setback line (no development) and development setback lines (managed development). I.e. maybe do something similar to the biodiversity mapping (CAPE Nature), provide management actions, and ratings for each area within the setback.

WSP Environment & Energy WSP House, 1 on Langford Langford Road Westville Durban 3629 Tel: +27(0) 31 240 8860 Fax: +27(0) 31 240 8861 http://www.wspenvironmental.co.za


3.

Revision of the methodology:

� The same methodology as developed in this initial process should be used to revise the setbacks at regular intervals.

� Municipalities are required to revise the urban edge every 5 years, as the Spatial Development Framework (SDF) is revised every 5 years

� Perhaps the municipalities will need to revise the setbacks at the same time – so the setback can inform planning and be incorporated into the SDF

4.

Methodology

� The setback line needs to be applies to the surface at that time it is established, as the site of the line may change in height/nature over the years (due to storms, dunes shifting, etc.)

5.

Data:

� Is there beach survey data for the study areas (Saldanha)?

- Not detailed data.

� WSP may need to contact Saldanha Port/other municipality reps for data.

� Saldanha Municipality/WSP will need to get permission from the Saldanha port to receive this (Nimi – Saldanha Port)

Data accuracy

- May need to take sample of the data (e.g. from a stereo scope) and measure it on the ground to check its accuracy

- There is a second option: Lidar. But this may be expensive, however it is very accurate and quick to obtain all the data for a region.

� At implementation the methodology should give two options: 1) quick and expensive (Lidar), and 2) cheap and slow (Stereo Scope)

- WSP is still establishing how long the stereo scope option will take, as we need to keep within the two year timeframe for implementation (otherwise this may not be an option).

� For Saldanha Bay WSP can use the 2005 SDF for the time being. After 23rd February 2010, the 2010 reviewed SDF will be available (GIS data available).

Aerial photos & Long term shoreline trends:

� Need to consider looking at additional aerial photos that are available to monitor long term trends.

� Saldanha municipality has taken their own These will be different from the council’s maps, as should have been taken in different years.

JS to give Saldanha Port contact details (Nimi) to GS JS to give SDF GIS data to GS

6.

Enforcement of setback lines:

� How are the setback lines going to be enforced? Will they afford more protection than Coastal Protection Zones? The Coastal protection zones don’t really help protection of the coast, especially from an enforcement perspective, as there is no legislation to back it up.

- Setback Lines will be enforceable from a national level, and through the NEMA EIA regulations, as EIA will be required for development within the setbacks.

7. Purpose

� The purpose of the methodology should be to prioritise which properties need to be moved/protected

- This is the next step after the setbacks are set – e.g. Shoreline management Plan/coastal management plans.


8. Biodiversity aspects:

- Should the biodiversity map and setbacks be the same/similar

� No, because the biodiversity map will not be revised, and the setback line will be revised.

� Having both data sets (biodiversity & setbacks) will result in two ‘reasons’ for no development

� Development in the high biodiversity areas should be controlled by the EIA process, rather than only the setbacks.

9. Heritage sites

� Western Cape Heritage needs to be involved

� Different importance levels also need to be considered – National, Local, and international

- Western Cape Heritage and South African Heritage Resource Agency will be consulted

Distribution: � Steering Committee

� Saldanha Municipality


MEETING NOTES




Time 10:00 – 12:00

Venue DEA&DO Offices, Dorp Street, Cape Town

Subject Draft methodology & Authority input discussions

Client DEA&DP

Present Geoff Smith (GS), Danielle Michel (DM)

Apologies None


� GS – Presentation (See attached)

1. Current legislation & management of coastal areas:

� How does the trigger of 100m (developed) and 1000m (undeveloped) (from high water mark) lines relate to the coastal development setbacks?

- Municipalities will need to draw up management plans specific to development areas.

- These management plans will lead back to the (NEMA EIA) listed activities and the need for EIAs to be conducted.

- These plans will provide the time frames and management objectives for the areas – which need to be considered within any EIA.

- Therefore local municipalities will be able to use 100m/1000m line, unless or until there is a setback line. The conservative of approach should be taken, in terms of looking at which line is a greater distance fro the shore, either the between 100m or setbacks, in order to prohibit development

- The coastal setback line doesn’t necessarily include the coastal protection zone.

- Need to be able to exclude certain EIAs, and the setbacks will assist with this, but having ‘no-go’ areas prohibiting development.




2. Inclusion of dynamic coastal environments:

� The act includes mapping of littoral zones, including areas such as mobile dune systems. In the Southern Cape, previously mobile dunes have been immobilised by development and the introduction of alien vegetation to stabilise the dunes. How do we include these types of issues into the setback lines?

� There are a number of grey areas in terms of managing coastal areas as a whole (e.g. dunes systems). Are these going to be completely included into the setback methodology?

� If setback lines area potentially variable (e.g. being revised and dependant on dynamic coastal processes), how do you enforce these lines?

� There is potential for a mismatch between real and mapped land cover, especially where with coastal process have not been mapped accurately.

� Surely one should use the most ‘sensitive’ or conservative line?

- This is dependant on what activities are provided for in the new EIA regulations. Whether it will be 100m (from high water mark) that will trigger an EIA, or if setback lines become the overriding line.

� Are estuaries going to be included in the methodology?

- Yes. It should include any area affected by tides

3. Roles and responsibilities - implementation

� How will this be handled?

- There will be a prioritisation of the setbacks by DEA&DP to fund

- There is however pressure to meet the two year deadline

- Setbacks will filter down to municipal by-laws and planning/zoning schemes.

- Local by laws can be used to manage areas inside setback lines.

4. Flood line timeframes:

� The National Water Act provides for the Dept. of Water Affairs to determine and manage the 100 year flood line for rivers.

� This is especially important in terms of the climate change (e.g. the 50 yr flood line may become the 100yr flood line)

- Until we get more accurate data and literature it is difficult to identify the specific or the best timeframes. The 50 year is a generally conservative approach (for estuaries).

- It is going to be difficult to incorporate all potential coastal aspects at estuary mouths.

5. High Water mark:

� The definition of the high water mark according to the ICMA

- Could have implications in terms of what is the ‘normal’ high water mark. E.g. 10 year storms could become regular.



6. Prioritising areas:

� Is there going to be a system to prioritise different areas that are more vulnerable

- Depends on the ICMA and how management of these areas.

- The methodology will have to speak to the most probable outcome, need to focus on more vulnerable areas.

- This methodology will have to be applied nationally

7. Local spatial planning

� How will the setbacks talk to the municipal town planning scheme?

- The municipalities have additional responsibilities

- The coastal protection zones will need a management plan, which will translate into the planning scheme.

- Does depend on the level of detail required and the timeframes

8. Data availability

Are the maps from cape nature to be used in the study only conservation or ecological?

- They are biodiversity orientated, and include Ecological processes

- They include the different management activities required within each area and priority areas in terms of ecosystems.

- Dr Steve Holding (PE – SANparks) is the biodiversity specialist who can provide insight into the development of biodiversity mapping

- In the Western Cape they have managed to close the gap between the biodiversity management and planning aspects.

� Ultimately the setbacks need to speak to the land use management objectives, e.g. rural development framework

� Spatial biodiversity plan (SANBI – biosphere management)

SNABI – Biosphere management information needs to be obtained

9. Consultation process:

� Have the two municipalities been consulted?

- Yes – Cape Town has presented their process of coastal protection - Meetings with both municipalities have been arranged

� Note:- Saldanha represents the local government through being represented on the steering committee

� Saldanha water quality group should be included

- Yes, they are registered, & will be attending the focus group meeting next week

� This is a national process, therefore needs to consult with as many people as possible, and get as much input as possible, as it will be applied throughout the country.

� Next steering committee meeting next week

� All I&APs will have the information regarding the methodology sent to them



10. Methodology:

� The methodology needs to be a working document

� It needs to capture the issues, describe how they were resolved, so these can be traced when the methodology goes through review, and the issues are not duplicated each time.

Distribution:

Steering Committee

All present (See attached)

DM


MEETING NOTES




Time 14:00 - 15:00

Venue Cape Town Municipal Offices, Wale Street

Subject Draft methodology presentation & Cape Town Municipality input

Client DEA&DP

Present Geoff Smith (GS) See attached attendance sheet

Apologies


GS Presentation (See attached) 1. Use of Setback lines:

� What is intended by this set back line?

- A development setback line is for any structure, not just buildings

- Within ICMA - the setback lines protect the coastal protection zone, and other coastal management lines.

- To restrict or prohibit development

� Does this not make the setbacks null-and void?

- The setback lines will reduce the number of activities applied for in terms of the NEMA listed activities in EIA regulations

� In Cape Town, the Coastal Protection Zone delineates the development setback line.

- Development needs to be managed within the setback line, and

- The phrasing of the definition of a Setback Line needs to be done very carefully.



2. Private Development Rights within the setback lines:

� What private rights do people have within the coastal area?

� What is the appropriate way forward?

� Will these properties be appropriated?

- A layered approach will be taken (i.e. prioritisation of areas)

- This will guide future development on terms of where is safe to develop

� It has been suggested that there be two lines: 1) erosion setback and 2) development setback line

� Cape Town would like to see a broad ban within the erosion setback line to limited recreational development

� And a setback line to manage development within coastal areas in general

- This is quite a complex approach

- May need to come down to a site specific assessment, this general approach will not provide the necessary detail throughout the coastline.

� One needs to look at the enabling conditions within the legislation. ICMA doesn’t give an out right ‘no development’ approach. The setback line will lead into the coastal management plan within each municipality.

� ICMA allows for EIAs to be done for any proposed development within the setback line areas. The authorising authority are not allowed to give a positive decision unless it meets the criteria set out in ICMA, but the MEC can over ride decision.

3. Time frames of setback lines: � What are the implications of the 1:50 year line for setbacks?

- It has been proposed that the setbacks be based on the processes that will occur within 50 years

- The line needs to be reviewed on a regular basis (e.g. every 5 years) to ensure that it utilised the most current data.

� In order to maintain the coastline, need to restrict development completely

- Perhaps look at both 50 and 100 year for sensitive (sandy) areas, and decide which one would be best on a site specific basis.

4. Coastal processes: � Need to ensure the beach profile is maintained. It is an important aspect of coastal

flooding.

- WSP is going to use and recommend the use of the ‘stereo scope’ methodology to provide the most accurate profile data for beaches.

� Wind direction is another crucial aspect, as this influences the impact of the wave and storm events on the coastline

� Barometric pressure also an important aspect.

5. Biodiversity aspects: � City’s biodiversity network (based on biodiversity targets, not management

objectives) could feed into the process.

- This needs to be ‘vegetation type’ based, not habitat driven, as the general habitat may differ from what is on the ground.


6. Social aspects: � Socio-political aspects/objectives also need to be included, from the local

municipality, so as to determine what final outcome in terms of the local areas

- The Spatial Development Framework (SDF) could provide this information

� One also needs to include intangible issues, such as sense of place, etc.

� Socio-economic development priorities will be determined through the focus group discussions when determining setbacks

- These focus groups must include the local planning managers, and possibly SDF consultants

7. Scale of data available:

� Issues related to the scale of mapping need to be considered. Such as the SDF may not be at right scale to encompass/inform the setback lines

� This is the same with biodiversity mapping, as these maps may not include small patches of vegetation that may be crucial to conservation or habitat protection

8. Implications for EIAs: � Will DEA&DP be able to able to make a decision on the EIAs within these setbacks?

- These decisions may have to go to the minister. Setbacks will be used to deter future development (high risk of not receiving approval, long time frames, etc)

- Local municipalities will need to pay for maintenance of these developments within the setbacks, so will also deter development form a municipal perspective.

9. Heritage aspects: � Heritage aspects will need to be included into the precautionary approach as there

are many undiscovered resources.

� Aesthetics – The Heritage Act also ensures that aesthetic impacts are considered, e.g. cultural landscape

10. Public participation process: � Setback lines should not go to the public for review during the development phase,

as it is always going to be split between developers and local conservation/community groups.

� If setback lines must be legally defensible, they must be scientific processes and not determined by the public.

- The reality is that there needs to be some public (political) participation.

� Before presenting to public the line should be determined, by scientific means, so that it is defendable.

� Development group will be a problem, but setbacks may be generally supported.

� A robust methodology (and PPP in this methodology development phase) will back up the implementation, and therefore make the implementation more robust.

11. Prioritising undeveloped/rural areas:

� Need to look at undeveloped sites as a priority

� Also need to prioritise areas:

� Where there are no coastal setback lines to protect the coast,

� Where there is threat of development, and under new rights.

� Especially farms up the west coast, where there are few boundaries, little management or protection.


12. Methodology development:

� A suggestion to apply the setback line retrospectively in an area where these has been past contention with development application, and see how the setback would change the outcome of those developments e.g. golf estates, etc.

� E.g. Big Bay beach – soggy beach. The Milnerton development is also an example

� One needs to identify the problem areas, and what are the long term implications and costs

� One also needs to include the legal context. For example:- if the municipality knows that an area may be eroded, but existing developments are allowed to stay – what would the legal implications, insurance implications, etc.

� Need to instil the ‘Greater Good’ ideal.

Distribution:

� Steering committee

� Al present (see attached)


MEETING NOTES




Time 17:30 – 19:00

Venue Langebaan Community Hall, Bree St, Langebaan

Subject Public stakeholder meeting

Client DEA&DP

Present Geoff Smith (GS), Danielle Michel (DM), John Smit, see attached

Apologies None


Presentation (See attached)

1. Study sites (Paradise beach & Leentjiesklip)

� Why are the two areas being considered in isolation? They should be considered in conjunction with each other and surrounding environment

- Only a 2km stretch of the coastline could be used as a study area for practical reasons. Therefore to include both of these important areas, two separate areas where identified.

- Dominant coastal processes will be considered

� Why were these sites chosen?

- They were chosen for their existing coastal characteristics (e.g. actively eroding), biodiversity, etc to test the criteria of the methodology

� For every few km there are different dynamics and situations. Two sites will not define all scenarios

- Yes, coast is very dynamic. So these are just test sites for the methodology. Incorporated as many aspects as possible into the test sites.

� Why are both sites on the lagoon?

- The other site in Cape Town (Milnerton – Diep River) is on the exposed sea

- Only a 2km study site could be used, and to incorporate both of these areas (Paradise beach & Leentjiesklip ), the study site was broken into two sections.

2. Information out of date:

� Aerial photos

- Yes, this is just an example. The most up to date data will be used.



3. Existing data:

� CSIR has compiled a report for Paradise beach

- Yes this information is being incorporated

Copy of report

4. Existing properties:

� What happens to existing properties that will fall within the setbacks

� Will you loose you rights?

� What are the implications for property owners?

- This will need to be answered by the DEA&DP

For discussion with DEADP

5. Conflicting legal jurisdiction:

� In some areas local municipal jurisdiction overlap with district municipal jurisdiction – different areas and by laws. How will the setbacks fall into existing legislation

- This will be uniform throughout the coast

6. Undeveloped areas:

� Will rural areas have a bigger setback?

- Yes – will take the nature of the area into consideration

7. Public Access

� Has public access been considered?

- Yes this has been taken into consideration

8. Accuracy of available data - erosion:

� How will the fact that both sites chosen are rapidly eroding sites affect the setbacks? For example – the setbacks done by the CSIR (1996?) – used information from last 50 years, and in last 30 years there has been accelerated erosion, therefore setback from that study are in the water now. These types of processes take a long time to manifest.

- Technology has changed, and more detailed and better information is available, which will assist in predicting these potential rapid changes

- Proposing setbacks be conservative and will be periodically revisited. How and when they will be revised is under discussion with DEA&DP

9. Impact of other coastal development/processes:

� Impact on these (study area) beaches from the Saldanha dredging has meant that the sand moves off the beaches and onto the sea floor. This is further dredged, leaving the calcrete sea floor exposed, and no sediment to build up beaches

- Yes, all aspects need to be considered


10. Data availability & predicting coastal processes

� Coastal engineering is a very new science, and therefore it has to catch up with other sciences. The first aerial photos were only in 1905.

� 1997 was the first really major problem started with a storm with long wave length, which caused significant erosion along this section of the coast. So the 1987 prediction was a bit off.

- GS was involved in intensive modelling of the area, and is aware that these anomalies have occurred, and processes can change rapidly.

� In order to get the most accurate data, aerial photography should be done twice a year needs to be done.

� There has been rapid acceleration of erosion on some beaches e.g. 150m of beach lost in last 105 years

� Need to monitor the monitoring of the beaches and the sedimentation of the bay

� Needs to be monitored with hi tech equipment twice a year to monitor precisely

� There are other low tech/cost solutions for data collection.

� The CSIR report for the Saldanha Port was limited to the immediate area (Salanha Harbour), and did not include other potentially affected areas (e.g. the rest of the bay/lagoon).

11. Management of Setbacks

� Where there is a large setback (>30m), they are unmanaged, and the community can’t manage them. Need to consider how these setback areas are managed.

� Perhaps, make them conservation areas, with public access

- Yes – they need to be a practical distance from the coast, with appropriate access & infrastructure.


12. Implementation of setbacks – Prioritising areas:

� How are the areas prioritised?

- Proposed development areas (under pressure)

- Rural and urban will both be included

� Could one apply to prioritise a specific area?

� How do you do this (e.g. if someone is currently building along the coast where it is inappropriate)

- We are in the process of discussing this with the DEA&DP.

� Is it possible that certain areas such as Saldanha will get setbacks before other areas such as Durban, or will it be implemented at the same time?

- Yes, this is very possible, as the Western Cape is the first province to initiate this process

- However, provincial and local governments will be working together on this, and needs to be implemented throughout the country within next 2 years.

� There needs to be a mechanism for setting of priority areas. This could be considered in conjunction with local interest/community groups in terms of which areas need to be looked at.

- Yes, this aspect will be considered in terms of the methodology

- However, it should be noted that the local municipalities will be implementing these setbacks, and therefore should be aware of local issues.

For discussion with DEADP For discussion with DEADP

13. Time frames:

� Timeframes for implementation are too short. It will not be affective to implement setbacks along the entire country’s coastline on two years.

- Yes, timeframes are short, but this is a starting point. Lines will be revised and data will be gathered in time.

- We need to distinguish between the two different processes – this is the methodology development and the implementation of the line will come after this phase (within the next two years)

14. Types of setbacks:

� Will there be a general setback lines, or will they be more specific to each area of the coast?

- Yes, they will take all local issues into account, in order to get site specific setback as far as possible

15. Biodiversity:

� Do you take marine life into account?

� SANBI maps are prioritised on the land based habitats/vegetation, not marine

- The line will be landward of the high water mark, and therefore be out of range of marine environment. However the biodiversity component is likely to include these aspects where the data is available.


16. � There is inconsistency between different ‘regimes’ within the local municipalities. E.g. the next council might not agree with the previous councils planning, and therefore nothing will be done.

- The idea is to incorporate the SDF with the setbacks so that they will guide future development

� How does one cost for this process and how do you align the two efficiently to get a good result?

- This will be dealt with at implementation

17. Global processes

� How do you incorporate global warming into the methodology? E.g. the change in nature of storms, their change in directions, intensity, etc.

- This is a difficult aspect to predict. We do have data from recent storm events that will inform this aspect.

- Aspects such as sea level rise will be considered, together with the impact it has on storm events.

- It is important that this aspect be included, and we will use the most up to date information/data.

� Is sea level rising?

- Yes. Andrew Mather’s study indicates that it is rising at roughly 3mm/yr in Durban, and roughly 1.5mm/yr in Cape Town

� This will put certain people and areas at risk

18. Position of line:

� Will the setback line be behind the primary dunes?

- Yes, in most instances – wind blown sand, erosion, sea level rise, and other aspects will be taken into consideration, and therefore sets at least the erosion setback behind primary dunes. With the other aspects, it may be moved further inland.

Distribution: � All registered I&APs � Steering committee

Forward presentation with notes for comment


MEETING NOTES




Time 17:30 – 19:00

Venue Pinelands Community Hall, St Stephens Road, Pinelands, CT

Subject Public stakeholder meeting

Client DEA&DP

Present Geoff Smith (GS), Danielle Michel (DM), see attached

Apologies


Presentation of Draft Methodology (GS) (See attached)

1. Impact of developments on coast:

� The methodology seems to focus on protecting developments from coastal processes. Also need to consider how developments impact on the coast. E.g. Overstrand - there are three estuaries that are polluted and can’t be used for swimming. Need to look at the reverse – how the environment /inland development impacts the coast. Need to look at setbacks for rivers and estuaries. Maybe this should be built into the biodiversity issue?

- Riverine setbacks are outside of the scope of the coastal setback lines project

- It is a management issue that needs to be considered (Dept. Water Affairs Issue)

- In terms of ICMA – this aspect is not covered.

� How does harbour infrastructure impact the surrounding areas? How does the methodology account for the nature of these disturbed areas? Especially fishing harbours. Breakwaters, etc will remove the impact of storm surge, etc.

- The methodology does cover these types of areas – especially in terms of flooding and sea level rise

- Harbours are different types of areas, as they are predominantly hard structures immediately along the coast line. The only concern would be if the development is too close and regular over topping occurs (during modelling).

� This will be an interesting outcome of the study, and could get some emotional reaction form the public.

- The methodology needs to include broad aspects, but not specifically harbour type areas.

- The criteria set out in the methodology (A to F) will deal with all aspects that may impact harbours.

- It will need to be determined when applying setbacks to a harbour whether the existing drainage can deal with the over topping and other aspects. These will have to be looked at carefully for implementation and management of harbours.



2. Test site:

� The choice of Milnerton does not represent the Cape Town areas, as it does not contain rocky beaches, cliffs, etc.

- The estuary (within Milnerton study site) is an important component of the criteria

- This site was identified by the local musicality in conjunction with the other site in Saldanha Bay.

- Milnerton has had intensive studies done on the area in the past, and therefore there is a lot of data available.

� Jeff Brandish (sp?) has done SLR study

� The two sites are not typical of Cape Town. The methodology may be flawed if not representative of the area

- The process is for the whole of the Western Cape, and therefore what has been selected is representative in terms of the criteria being developed for the methodology.

- What site would you consider?

� Need some rocky shores. E.g. Hout Bay is heavily developed, has a rocky coastline, with sandy beaches in between, dune fields, wind blown sand, etc so would make a good example.

- Rocky areas have been included in the Saldanha site, as well as development pressures, and wind blown sand. And in addition the study areas have a history of data available, which can be tested and used.

3. Sensitive areas:

� Will the setbacks stop development in sensitive areas, e.g. in wind blown sand areas?

- Yes, biodiversity and coastal processes are both considered within the methodology

- Apart from looking at existing developments, consideration of future developments is a priority

- We need to allow coastal processes to continue naturally, and therefore take this into consideration

� Will the outcome be to build up beaches where they have eroded?

- This is not part of this study, but these types of areas will be flagged

4. Local municipal obligations:

� What power is given to the municipalities to give the go ahead for developments within the setbacks?

- They are mandated to protect areas of high biodiversity and coastal processes.

- While the municipalities have coastal protection zones, all these processes have a consultative component, which should include all interested and affected parties.


5. Purpose

� What is the purpose of this current process (as given in presentation)?

- To establish a methodology for developing setbacks

- It is to protect biodiversity, ensure any new development is setback, and ensure that natural coastal processes can continue.

� How does this tie onto the (Cape Town) City’s process of establishing the coastal protection zone (CPZ), which will become a statutory guideline for coastal development – how do these interact – the CPZ process is quite far advanced?

� Within both sites chosen, there is very little pristine coast line remaining – are you going to preserve what’s left?

- We do rely on the biodiversity mapping, and the Saldanha site is a critical biodiversity. Therefore the data and the site visits will indicate which areas need to be preserved.

- We will proceed with the best methodology with as much up to date input.

6. Time scale of Setbacks:

� Tendency to make the time scales very short and human scale. One needs to be aware of the 100 year and 1000 year events, which could occur within our life time due to climate change. The methodology should therefore be very conservative, human impact has already occurred, especially in terms of SLR – could be surprised within the next centaury as to the real impact. Could you not provide a very conservative approach and set it far back so that anyone who wants to build within it would have to get approval?

- Development is going to occur. People will need to apply for approval within the setbacks. The line is going to vary from area to area, and sometimes be closer to the coast.

- Regarding data - The further ahead you plan, the harder it is to predict. There is so much uncertainty.

7. Local Communities:

� Macassar is a coastal community. We don’t see the coast as separate form us. There are two rivers running through the community. People are infilling and mining within the river areas (for fossils and sand). As a result the river will cut into the hinterland and cause major flooding and marshland, diseases, etc. Why can’t we do this study in the False Bay area – there is a strong environmental community, and a need to look at this site.

- There is a need to have a fixed safe development line to start with.

- Priority needs to be given to different areas that are under pressure such as this.

� The CSIR has determined setback lines for these two areas. They are meant to be revisited often, as processes change. This is a scientific process. The north Carolina was only successful wave modelling.

� Need to include local community forums in the process, to get the local perspective. This is currently not being done, and we have the local knowledge that could inform the setbacks.

8. Sea level rise model:

� What model Is being looked at for sea level rise?

- We perceive that the IPCC is the best option, however as they are a consensus body, they are quite slow, and therefore certain issues may have been left out or change by the time they produce information.

- Therefore need to look at IPCC and other additional available information to obtain the best modelling and data.


9. Development Approval:

� What is DEA&DP’s stance in terms of the setbacks – will they approve development or wait till setbacks are prescribed?

- Existing applications will continue with the usual process. The process once setbacks are implemented will be determined by DEA&DP.

10. Positioning of setbacks:

� The admiralty reserve tried to define an area of no development form the high water mark. But it is difficult to survey the high water mark. Need sot be observed on the ground. The setback will be more definable. But perhaps need to impose an admiralty along the coast to prevent development within setbacks. Might have to leave out the long term issues. And there may be an issue with predicting wave run-up.

- We would rely on a host of imperial data that is available for the sites, and site visits and ground truthing will provide a good indication of the high water mark and processes existing on the ground.

11. Management of coastal developments

� The old Dept. of Environmental Affairs and Tourism were proposing high rise tourism developments along the coast to provide jobs, and eco golf courses, etc. Our community organisations (Macassar) will oppose these types of developments. Seems to be contradictory in terms of environmental and tourism objectives.

- The city of Cape Town recognise the need to preserve coastal processes, but also need to meet the needs of the communities, such as coastal access, housing, jobs, etc.

- This line will prevent this type of development, especially as this methodology will have robust scientific backing.

- The setbacks will not give a ‘no-development’ completely. There are planning implications and these areas need to be managed properly.

12. Biodiversity:

� The biodiversity maps are terrestrial base. Also need to ensure the marine biodiversity aspects are included.

- Yes, has been recognised

- Next week there is a biodiversity focus group meeting, this will include marine biodiversity, but there may be gaps in the information.

13. Time frames

� Is the two years for the methodology?

- No for implementation of setbacks throughout the country.

14. Consultation

� Have you been consulting with the City? If so, with whom?

- Yes. We have consulted with the coastal department. They are on the steering committee, and we have consulted with the coastal and environmental departments as part of the participation phase.

- Darryl Colenbrander, Gregg Oloefse, etc

Distribution: � Al present

� Steering committee

Consolidate & circulate meeting minutes, & presentation.







Present :


No. SUBJECT Action

required by

Date

required by



taken as indicated.

Apologies:

Danie Lambrechts

Gerhard Gerber

Bronwyn Palmer

Andre Theron

Andrew Mather

2. Presentation of issues to be resolved

GS presented a presentation of issues that were raised during

the recent focus group meetings and PPP meetings held in

Langebaan and Cape Town.


3.1 Robustness of the method

The more robust the methodology the more expertise is

necessary in the evaluation of technical components.

May be parts of the methodology that can be evaluated on a

level that does not require professional/expert input/opinion

3.2 Return period of Setback line

A ‘different value’ approach was suggested (i.e. structures

under a monetary threshold would incur a 1:50 yr setback line

study while structures above monetary threshold, 1:100yr)

It was pointed out that the value of structures is relative and

might not be a good measure. Suggestion was made rather

base this on

• Building codes (intrinsic value)

• Physical description

• Level of how essential the infrastructure is

A suggestion of classifying high, medium and low risk coastal

areas was put forward but classifying the coast from a scientific

point of view is another study all together

Cape Nature pointed out that the absolute minimum they

recommend is 1:50yr

A 1:100 year period of consideration for setback was proposed

with reasons (refer to presentation) and no objections were

received

3.3 Revision period of setback line

At each site/area, key variables can be monitored (e.g. changes

in nearby harbour, new dams in rivers, etc.)

Be very conservative with setback line as a revision/detailed

study (with more information) can move the line seaward. More

difficult/impossible to move line landward after development.

Concerns over the number of lines emanating from the

methodology (erosion / bio-diversity / socio-economic/ heritage/

conservation)

For the line to obtain legal status, it needs to be gazetted by the

MEC and go through all the processes (PPP, etc.). The case

studies will not go through this whole process because of time

restraints.

Identification of sites that does not need a development setback

line (e.g. declared nature reserve). This does not forgo the fact

that an erosion setback line exists.

Definition of different setback lines needs to be made clear in

methodology.

Proposal was made for a method in which areas can have a

rapid assessment with a conservative line vs. detailed

assessment with a more ‘accurate’ scientific line.

It was pointed out that the methodology is not a black box where

input parameters will be used to produce a line but that sound

coastal judgement and other scientific expert opinions are also

part of the methodology. It is a decision making tool/process.

It is proposed that a legal expert/opinion is introduced to the

committee after the 1st draft of the methodology to assess legal

implications of the methodology

3.4 Mobile dunes

Site specific and need to be assessed relative to local

issues/conditions

Cognisance of a flooding setback vs. erosion setback must be

kept in mind

3.5 Estuaries

The tidal area of a river is part of the coastal protection zone

(which in some cases can be 50km upstream of the river)

The absolute minimum of 1:50yr setback line is recommended

but should be considered case by case

Estuaries need to be assessed with a proper independent

estuary study as they are all different

3.6 Funding for local setback line studies

The methodology is aimed at assessing larger units of coast

(not individual properties)

Need to discuss/define a reasonable unit of coastline to assess

(economies of scale). The implication is that studies could be

financed by developers but must cover such a unit of coastline.

Flag legal issues in terms of Sect 63 of ICMA

3.7 Public consultation

Public should participate on methodology ONLY, not on the

results of setback line studies

4. Future actions

GS to incorporate comments from steering committee into

methodology

GS Ongoing


The next meeting will be held on Tuesday 23 March 2010 at

10h00.


The presentation (by GS) and the attendance register are sent

out with the minutes.


Approval by DFU

By: ___________

Date:__________

Approved by WSP

By: Geoff Smith

Date: 26/02/2010


MEETING NOTES


Project Number 208100


Time 10:00 – 12:00

Venue SAHRA, 111 Harrison Street, Cape Town

Subject Heritage meeting

Client DEA&DP

Present

Geoff Smith - WSP Mariagratzia Galimberti - SAHRA Nick Wiltshire, Belinda Mutti – Heritage Western Cape Jim Hallinan – City of Cape Town

Apologies None


Presentation of Draft Methodology (GS) (See attached)

1. Coastal heritage includes: Buildings over 60 years old, Burials, Shell middens, Wrecks, Fish traps, cultural landscapes, Lighthouses,

2. Coastal heritage sites are most likely at the shoreline, tapering off landward. Highest priority within up to 200 m of the shoreline. The group would ideally like to see setback for heritage purposes up to this distance.

3. Nodal development rather than strip development is preferred (related to above)

4. Maps with identified heritage sites can be provided

5. Heritage buildings and their surroundings should be considered

6. Assessments/surveys should not be limited to parts of individual sites – these should cover neighbouring sites.

7. Heritage have maps indicating known heritage sites which can be provided.








Present :


No. SUBJECT Action

required by

Date

required by



taken as indicated.

Apologies:

Omar Parak

Zain Jumat

Neil Lamprecht

Andrew Mather

2. Presentation of Draft Methodology amendments

GS presented the amendments to the draft methodology that

included the assumptions adapted from previous issues,

defining ‘HOW’ the methodology was construed and

international best practise.

FvE presented slides on progress with the case studies

SR presented images of modelling options executed as an

exercise for the case studies


3.1 Legal issues

If the setback line is drawn through a development, government

may be held liable for consequent insurance cost increases or

other costs (.e.g. of protective measures). If the setback line is

drawn through a proposed development area, government may

be held liable for losses associated with undevelopable property

It was suggested that the final methodology draft be submitted

for legal opinion to see if any serious flags are raised. These

issues are to be discussed with the HoD at DEA&DP

3.2 Setback line implementation

Part of the decision making process in executing the line is the

hold, advance or retreat option.

Comment from W. Roets from George office should be

obtained.

The line/s to be gazetted will be the “management” development

setback line/s (which would have had input from all stake

holders). In future this line will have to be managed.

A slow retreat option (hold the line and retreat some time later)

is also possible.

3.3 Heritage

Heritage can only be decided on known heritage knowledge and

can not make provision for ‘potential’ heritage sites. Setback for

heritage would evolve from the participation/consultation

process

Line can be reviewed in the light of new information

It was pointed out that setback for fish traps and wrecks may not

be required if these are situated at the shoreline

3.4 Finalisation

An approximate cost per unit (length) is to be included for a

study

WSP

The sensitivity of the variables are to be discussed in the

scientific issues

River floods are not to be covered within this methodology

4. Future actions

GS to incorporate comments from steering committee, focus

groups and other external sources into methodology

GS Ongoing

5 Next scheduled meeting and dates of deliverables

The following important dates were agreed:

1 April 2010 – Submission of final drafts (methodology and

case studies) to steering committee

The steering committee are invited to comment on the draft

reports.

15 April 2010: Period for comments on reports close

29 April 2010 Presentation of final methodology report to

steering committee and final steering committee meeting.

Time and location to be advised





Approval by DFU

By: ___________

Date:__________

Approved by WSP

By: Geoff Smith

Date: 23/03/2010







Present :


No. SUBJECT Action

required by

Date

required by



taken as indicated.

Apologies:

Alana Duffel-Canham

Danielle Michel

Neil Lamprecht

Gregg Oelofse

2. Presentation of Draft Methodology amendments

GS addressed the primary comments to the methodology, the

amendments to the methodology and learning points from the

case studies in his presentation. An ‘Enabling study’ box has

been added to the flow chart, as well as an extra Erosion

setback flow chart to the report.


3.1 Erosion setback line

The concern was that two different specialists could determine

two different setback lines at one site. This is unlikely to happen

since the study will have to be reviewed by an independent

specialist. Also, the judgement which is referred to is scientific

judgement. The methodology will be revisited to try to ensure

the reproducibility/replicability of the line produced – avoiding

misuse of the methodology to place lines excessively close to

the ocean.

WSP

Terminology of “no Development line”: Some development

might take place seaward of the line. However it is understood

that this will require approval by the minister (and only

acceptable if it is overwhelmingly in the interest of the public,

according to ICMA.). Light infrastructure (e.g. wooden access

boardwalks across dunes) should be acceptable

It should be made clear that it is not necessarily true that the

sea won’t ever reach development landward of the line (e.g. a 1

in 200 year storm). To incorporate this concept in the report

WSP

A 1 in 100 year line will not necessarily hold for 100 years, but

rather until the science is updated (e.g. sea level rise numbers)

Definition of High water mark: in future modelling should be

done to determine the high water mark as necessary.

Monitoring of high risk areas are needed to determine whether

or not the line should be revised – to be highlighted in the report

WSP

Estuaries: According to the ICMA only permanently open

estuaries are included in the coastal setback line

Different setback lines for biodiversity, heritage, aesthetics etc

must be available at the stage where the EIA process is carried

out. These lines can be made available – include in report

WSP

Who will determine the line, and who will sign it off.

Intergovernmental discussion must take place

All sections of coast carries equal priority, may it be

undeveloped or already developed areas. Developed areas are

relevant because of re-development.

Change 1km on either side (for independently funded setback

study) to a minimum of 1km. The distance is to be authorized.

If anyone questions the position of the already determined

setback line, that person has to repeat the entire study done for

that section of coastline (e.g. the whole 100km stretch of

coastline)

4. The way forward:

The plan of action is now to finalise comments (in 2-3 days),

submit for final comment (from steering committee) and then

complete by end of May.





Approval by DFU

By: ___________

Date:__________

Approved by WSP

By: Geoff Smith

Date: 17/05/2010


Appendix B: Project Terms of Reference

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 1 of 10

TERMS OF REFERENCE

DEVELOPMENT FACILITATION UNIT (DFU):

DEVELOPMENT AND TESTING OF A METHODOLOGY FOR DEFINING AND ADOPTING COASTAL DEVELOPMENT SETBACK LINES.

1. BACKGROUND:

1.1. On 21 April 2006 the following activities were, inter alia, listed in GN No. R. 386 as activities that may not commence without environmental authorisation in terms of NEMA:

2. Construction or earth moving activities in the sea or within 100 metres inland of the high-water mark of the sea, in respect of –

(a) facilities for the storage of material and the maintenance of vessels; (b) fixed or floating jetties and slipways; (c) tidal pools; (d) embankments; (e) stabilising walls; (f) buildings; or (g) infrastructure.

3. The prevention of the free movement of sand, including erosion and accretion, by means of planting vegetation, placing synthetic material on dunes and exposed sand surfaces within a distance of 100 metres inland of the high-water mark of the sea.

5. The removal or damaging of indigenous vegetation of more than 10 square metres within a distance of 100 metres inland of the high-water mark of the sea.

6. The excavation, moving, removal, depositing or compacting of soil, sand, rock or rubble covering an area exceeding 10 square metres in the sea or within a distance of 100 metres inland of the high-water mark of the sea.

1.2. With coastal areas being sensitive, vulnerable, often highly dynamic and stressed ecosystems, coastal areas require specific attention in management and planning procedures, especially where the coastal areas are subject to significant human resource usage and development pressure. The listing of the above activities was therefore welcomed.

1.3. An unintended consequence of the listing of these activities and the broad threshold of “within a distance of 100 metres inland of the high-water mark of the sea” is, however, that many activities in non-sensitive already developed

�

Department of Environmental Affairs and Development Planning

Departement van Omgewingsake en Ontwikkelingsbeplanning

ISebe leMicimbi yeNdalo esiNgqongileyo noCwangciso loPhuhliso


coastal areas are also subjected to the required environmental impact assessment (“EIA”) process in order to obtain environmental authorisation. For example, a home owner in Clifton, in the second row of houses away from the sea, must follow the EIA process (that could take anything from 6 to 12 months) and obtain environmental authorisation if he wants to extend his driveway or garage.

1.4. A further unintended consequence of the listing of these activities are that Municipalities have to undertake an EIA process and obtain environmental authorisation when they want to undertake certain maintenance and infrastructure development work (e.g. erecting toilets – even if temporary) in coastal areas.

1.5. These unnecessary applications are resulting in municipal service delivery delays as well as taking up the Department’s environmental officers’ valuable time who must evaluate all of these applications.

1.6. After months of lobbying together with the other Provincial Departments, the National Department has agreed to amend these activities to provide for these activities to not be listed if the activity will “occur behind a development setback line as defined or adopted by the competent authority”. The following definition for “development setback” has been proposed: “a setback line as defined or adopted by the competent authority and where none has been defined or adopted it will be assumed that no setback line applies”.

1.7. The proposed amendments to the NEMA EIA Regulations, published on 13 February 2009, included these amendments and the abovementioned definition. The amended EIA Regulations are to be promulgated and come into effect before the end of 2009.

1.8. On 11 February 2009 the National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24 of 2008) (“ICMA”) was promulgated. The objects of the ICMA are:

1.8.1. to determine the coastal zone of the Republic;

1.8.2. to provide, within the framework of the National Environmental Management Act, for the co-ordinated and integrated management of the coastal zone by all spheres of government in accordance with the principles of co-operative governance;

1.8.3. to preserve, protect, extend and enhance the status of coastal public property as being held in trust by the State on behalf of all South Africans, including future generations;

1.8.4. to secure equitable access to the opportunities and benefits of coastal public properly; and

1.8.5. to give effect to the Republic's obligations in terms of international law regarding coastal management and the marine environment.

1.9. The ICMA also provides for the established of coastal set-back lines and defines “coastal set-back line” as “a line determined by an MEC in accordance with section 25 in order to demarcate an area within which development will be prohibited or controlled in order to achieve the objects of


this Act or coastal management objectives”. The procedures for establishing coastal set-back lines are set out in section 25 which states that:

1. An MEC must in regulations published in the Gazette— (a) establish or change coastal set-back lines—

(i) to protect coastal public property, private property and public safety;

(ii) to protect the coastal protection zone; (iii) to preserve the aesthetic values of the coastal zone;

or (iv) for any other reason consistent with the objectives of

this Act; and (b) prohibit or restrict the building, erection, alteration or

extension of structures that are wholly or partially seaward of that coastal set-back line.

2. Before making or amending the regulations referred to in subsection (1), the MEC must— (a) consult with any local municipality within whose area of

jurisdiction the coastal set-back line is, or will be, situated: and

(b) give interested and affected parties an opportunity to make representations in accordance with Part 5 of Chapter 6.

3. A local municipality within whose area of jurisdiction a coastal set-back line has been established must delineate the coastal set-back line on a map or maps that form part of its zoning scheme in order to enable the public to determine the position of the set-back line in relation to existing cadastral boundaries.

4. A coastal set-back line may be situated wholly or partially outside the coastal zone.

1.10. The ICMA highlights in sections 27 and 28 that in determining or adjusting the boundaries of coastal areas the following must, inter alia, be taken into account:

1.10.1. the dynamic nature of the shoreline;

1.10.2. the need to make appropriate allowance for the periodic natural movements in the high-water mark; and the erosion and accretion of the seashore;

1.10.3. the importance of ensuring the natural functioning of dynamic coastal processes and of extending the coastal boundaries to include the littoral active zone and sensitive coastal ecosystems, including coastal wetlands;

1.10.4. the potential effects of projected rises in sea-level;

1.10.5. the purpose for which a coastal area is to be established;

1.10.6. the importance for coastal management to incorporate land inland of the high-water mark that that should be maintained in, or restored to, a natural or semi-natural state;


1.10.7. the need to avoid risks posed by natural hazards to people, biodiversity, coastal public property and private property;

1.10.8. the potential for the number and severity of natural disasters to increase due to the effects of global climate change and other impacts on the environment, and the importance of taking preventive measures to address these threats; and

1.10.9. the importance of allowing for the movement of the position of the high water mark over time and of protecting the inland coastal boundary by demarcating a continuous strip of land adjacent to it.

1.11. Part 5 of Chapter 6 of the ICMA specifies the requirements for consultation and public participation and states:

53. (1) Before exercising a power, which this Act requires to be exercised in accordance with this section, the Minister, MEC, municipality or other person exercising that power must— (a) consult with all Ministers, MECs or municipalities whose

areas of responsibilities will be affected by the exercise of the powers in accordance with the principles of co-operative governance as set out in Chapter 3 of the Constitution;

(b) publish or broadcast his or her intention to do so in a manner that is reasonably likely to bring it to the attention of the public; and

(c) by notice in the Gazette— (i) invite members of the public to submit, within no less than

30 days of such notice, written representations or objections to the proposed exercise of power; and

(ii) contain sufficient information to enable members of the public to submit representations or objections.

1.12. While both the amended NEMA EIA Regulations and the ICMA allows for the pro-active determination of coastal development setback lines, coastal development setback lines must also at times be re-actively determined when considering development applications in terms of the NEMA EIA Regulations.

2. SCOPE OF WORK:

2.1. Based on the above, the DFU would like to appoint a service provider, or a consortium of service providers, to assist with the following:

2.1.1. the development of a methodology for defining and adopting

coastal development setback lines; and 2.1.2. in consultation with the City of Cape Town and the Saldanha Bay

Municipalities, testing the methodology in the Cape Town Metropolitan area and the Saldanha Bay Municipal area.

2.2. As part of the development of the methodology, interested and affected

parties must be consulted with.


3. REQUIREMENTS:

3.1. Copyright and intellectual property: • Any study reports or other material, graphic, software or otherwise,

prepared by the consultant for this project under this contract shall belong to and remain the property of the Department of Environmental Affairs and Development Planning (“the Department”).

• Any study reports or other material, graphic, software or otherwise, prepared by the consultant for this project under this contract are to be used or distributed only with the permission of the Department.

3.2. The quality and format of all products compiled during the process must suit

the needs of the Department and of the project in general, with all maps and spatial outputs to be produced according to the Department’s data and metadata standards, attached to this Terms of Reference as ‘Appendix A’.

3.3. Any individual bidders and the members of any bidding consortium must

furnish their track record of relevant expertise and experience in regard to the project. Potential service provider(s) must have relevant work experience within the development arena within the Western Cape Province and must have a demonstrated understanding of development management and coastal ecology and have competencies in environmental management.

3.4. Potential service providers are requested to submit their project proposals

which must include a detailed work breakdown structure of how the project would be tackled and include a detailed breakdown of finances needed for each area, and separated in financial terms at least between: • defining and adopting development setback lines along the coast in

terms of the NEMA EIA Regulations; • establishing coastal setback lines in terms of the ICMA; • testing the methodology in the Cape Town Metropolitan area; • testing the methodology in Saldanha Bay Municipal area; and • undertaking the required public participation.

3.5. The award of the bid will be made subject to the successful bidder entering

into a formal agreement with the Department. 3.6. The successful service provider will be responsible for undertaking all

administrative work with respect to the project. This will include preparations for meetings/workshops, facilitating, recording and distributing comments from meetings/workshops and incorporating comments made at meetings and workshops into working drafts of documents. The successful consultant will also be expected to distribute all documents to representatives of the Department’s Project Management Team and the Project Steering Committee.


4. THE DEPARTMENT PROJECT MANAGEMENT TEAM: Initial Meeting with Project Team to confirm the Scope of Work – After appointment, the consultant team will meet with the Department’s Project Management Team to:

• Confirm the scope of the project. • Agree upon time frames for the deliverables. • Agree on timeframes for regular meetings of the service provider with

the Departmental Project Management Team. • Agree on the composition of the Project Steering Committee. • Agree on the timeframes for regular meetings of the Project Steering

Committee. 5. PUBLIC PARTICIPATION AND STAKEHOLDER ENGAGEMENT:

As part of the project, the municipalities, other government departments and interested and affected parties must also be consulted with. A project steering committee will also be established.

6. DELIVERABLES:

6.1. A plan of work must be submitted to be approved by the Department. The plan is to include an outline of the various draft and final reports to be produced, the delivery dates and all planned meetings and workshops. Comment periods for draft documents are also to be specified. This must include a project schedule that clearly stipulate tasks and deliverables, linked to timeframes.

6.2. A schedule of payment indicating when in the project schedule payments is to

be made must also be included with the plan of work. 6.3 The documents and tasks as set out in the Scope of Work above. 6.4 Minutes of workshops, Steering Committee meetings and meetings held with

the Departmental Project Management Team.

6.5 An electronic copy of a popularised presentation of the findings for future use by the Department during capacity building initiatives.

6.6 Three hard copies, and two electronic copies (one in Microsoft Word and one

in Adobe PDF) of all the final documents.

6.7 All reports are to be bound under a Departmental cover page to be designed by the consultant for the project in accordance with the Department’s requirements.

6.8 The project must be completed by the end of February 2010. The successful

bidder must achieve this goal. Failure to meet all the final deliverables by the indicated deadlines will result in a deduction of a sum calculated on the delivered price of the delayed goods or unperformed services using the current prime rate for each day of delay. However, if circumstances outside of the control of the successful bidder should so require, the time-frame can be renegotiated.

6.9 Skills transfer to the Department’s staff during the undertaking of the project.


7. STAFFING:

A breakdown of the proposed consultancy team in terms of qualifications, expertise and experience, representivity (gender, race and disability) and contactable references must be provided. This will be one of the criteria used in appointing the successful candidate.

8. INPUTS FROM THE DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND

DEVELOPMENT PLANNING: 8.1. The Department will provide documentation and information available in the

Department.

8.2. The staff of the Department will make themselves available for the various agreed workshops, meetings and will review and comment on all draft documents as per the agreed schedules.

9. MEETINGS:

9.1. The successful consultancy team must make themselves available for fortnightly progress meetings with the Departmental Project Management Team. The need for these meetings will be reviewed on an ongoing basis.

9.2. Action based minutes of all meetings must be taken by the consultants and

circulated within 5 work days of the meeting to all relevant parties. 10. INVOICES:

10.1. A schedule of payment is to be included in the draft plan of work, and should be related to tangible outputs.

10.2. Invoices must indicate the contract number, the task and/or output and should include a short description of work done and referring to any relevant reports, and an indication of cost per hour.

10.3. Disbursements to be claimed in accordance with the abovementioned payment schedule, with original invoices submitted to the Department.

11. CRITERIA FOR EVALUATION OF PROPOSALS:

All bids received will be evaluated based on the following criteria: 11.1. Equity (20 points) 11.2. Cost (30 points) 11.3. Functionality (50 points):

Functionality will be evaluated based on the following: 11.3.1 Clarity in understanding the brief (8 points) 11.3.2 Clarity of the methodology/approach to be followed (6 points) 11.3.3 Experience and expertise to address all aspects of the project (20

points) 11.3.4 Clarity on the deliverables/products (8 points) 11.3.5 Project design and process control (8 points)


12. CONTENTS OF BID PROPOSAL: All bid proposals must include the following information: 12.1. Composition of Project Team

• Qualifications of team members. • Experience of team members related to the requirements of the project. • Expertise of team members related to the requirements of the project. • Representivity of the team in terms of gender, race and disability. • Contactable references for team members.

12.2. Understanding of the Department’s Terms of Reference (“TOR”) for the project.

12.3. Detailed proposed technical approach. 12.4. Detailed indication of timeframes required by consultancy team to deliver

specified products (Project Schedule). 12.5. Detailed proposed work breakdown structure including specific

responsibilities of consultancy team members (The plan of work is to include detailed tasks to be carried out, noting the appropriate level of expertise and the hourly rate to be charged).

12.6. Schedule of payment. 12.7. Detailed Cost breakdown of project proposal. 12.8. Limitations of consultancy team in meeting TOR. 12.9. An original SARS tax clearance certificate as well as a company registration

certificate.

13. GENERAL: For clarity on any of the aspects under this terms of reference please contact Mr Gerhard Gerber at tel: (021) 483 2787, cell: 083 2269127 or via e-mail at [email protected] . ��

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Department of Environmental Affairs & Development Planning Chief Directorate Development Planning Sub-Directorate Information Services 4 Leeuwen Street Private Bag X9086 Cape Town, 8000 Vector Mapping Data Standards: (Version: Jan 2006) Introduction The following serve as a guideline for the drawing up of contracts to provide GIS spatial data to the Department of Environmental Affairs and Development Planning Western Cape. This only covers vector data standards.

Software The ESRI suite of products is to be used – ArcView® 3.2 or ArcGIS® version 9.1 or subsequent releases. Projection and Datum All data should be supplied in shapefiles or geodatabase format. The recommended projection to be used is the Gauss Conform projection, centered on the closest odd meridian of longitude. Datum to be used is the Hartebeesthoek_94 (WGS84). Data can also be supplied, using geographical coordinates, in decimal degrees to 9 decimal places. Sizes/coverage of Datasets The coverage or/and sizes of datasets will be prescribed within the project proposal. This specific

coverage per project will be used as an indicator so as to determine the size and coverage as may be required per project.

Accuracy The positions of well-defined points/features are captured relative to the photo control so as to ensure the mean square error of all features checked does not exceed 10 meters. Many factors can impact upon the accuracy of a map. Any number of factors can cause error. Note that these sources can have a cumulative effect. E = f(f) + f(l) + f(c) + f(d) + f(a) + f(m) + f(p) + f(rms) + f(mp) + u where, f = flattening the round Earth onto a two-dimensional surface (transformation from spherical to planar geometry) l = accurately measuring location on Earth (correct projection and datum information) c = cartographic interpretation (correct interpretation of features) d = drafting error (accuracy in tracing of features and width of drafting pen) a = analog to digital conversion (digitizing board calibration) m = media stability (warping and stretching, folding, wrinkling of map)

p= digitizing processor error (accuracy of cursor placement) rms = Root Mean Square (registration accuracy of tics) mp = machine precision (coordinate rounding by computer in storing and transforming) u = additional unexplained sources error (Extracted from ArcInfo Help File, ESRI, 2001)


To minimize error, consider the causes of each error factor presented above. A certain level of error is unavoidable, but it is critical that both parties agree to all methodologies used, and that quality checking and ground control is carried out. Scale Map Scale One mm on map = A 0.5mm pencil line = 1:10 000 10m 5m 1:50 000 50m 25m 1:250 000 250m 125m The required scale will be specified and discuss with the data provider. The above table indicates the level of potential drawing/digitizing error at each common map-scale, which can be compounded with other errors as in the previous section. Base data used must be consistent and appropriate to the scale of operation. GPS A detailed set of GPS standards will be supplied on request as required. It is vital to use the appropriate instrument for the scale and accuracy of data required. In general the reliable accuracy of the hand-held units is between 5 and 30m. For most purposes a machine capable of sub-meter accuracy (differentially corrected either in real time or post-capture) should be specified. The operator should have proven experience at providing data for GIS use. Attribute data The attribute data to be provided will be prescribed in the project documentation. The data field specifications should be consistent and standardized throughout the whole project. Data quality (“clean” data) All intersecting lines must be processed in GIS to remove overshoots and undershoots, (dangling arcs), “bowties” and sliver polygons resulting from incorrect closing of polygons. This is also a common problem where importing from GPS data. Lines between adjacent polygons must be captured once only.(Adjacent polygons will share boundary lines) If data are to be used for specific application/models they may require specific ArcGIS attributes in terms of linear networks or topology. A detail description, regarding topology rules will be available on request. Base data Administrative boundaries, infrastructure and where possible, all other base data must be used from a reliable source. Where possible the source must also be the custodian of the base data, ensuring correctness, coverage and updates as may be required. Metadata This is\ a critical component of data supply which will be required by law. All matters related to spatial data must be in accordance with the Spatial Data Infrastructure Act 54 of 2003 as published in the Government Gazette 25973 of 4 February 2004. For any additional information contact: Mr. André van der Merwe (Assistant Director) Tel: (021) 483-3499 [email protected]


Appendix C: The use of CBA Maps in the determination of setback lines.

(ADAPTED FROM: THE BIODIVERSITY SECTOR PLAN FOR THE

SALDANHA BAY, BERGRIVIER, CEDERBERG AND MATZIKAMA MUNICIPALITIES

2009

Supporting land-use planning and decision making in

Critical Biodiversity Areas and Ecological Support Areas


HOW TO USE THE CBA MAPS Below are the steps to follow when using the CBA Map to inform decisions regarding land-use applications. STEP 1: Determine the biodiversity category of the property in question (i.e. the site) by consulting the CBA Map and the GIS data on the DVD;

• Does the proposed development fall within a Protected Area, Critical Biodiversity Area, Ecological Support Area, Other Natural Area or No Natural Remaining Area?

STEP 2: Consult other information provided to gain an overview of the biodiversity of the area and the Desired Management Objectives of the site.

• Determine detailed biodiversity information of the site (vegetation type, species of special concern etc) by referring to the biodiversity GIS data on the DVD. The layers include: vegetation type, aquatic feature type (wetland, estuary or river types), presence of special habitat or species of special concern, etc.

• Determine the Desired Management Objective and the recommended Spatial Planning Category (SPC) of the site by referring to Table 7 and 10 respectively.

STEP 3: Confirm the land-cover by cross-checking what you see on the ground against the land-cover map provided on the DVD.

• There is a mismatch between verification and land-cover category: It can happen that a site visit or photographic assessment reveals that the land-cover map has incorrectly depicted a “degraded, production or transformed” site as "natural or near-natural", in which case it may have categorised the site as a CBA or ESA in the CBA Map. This kind of error may arise owing to a change in land-cover subsequent to the mapping exercise or due to errors in classification. In such a case, the CBA Map is in dispute and although the map may still provide a good indication of the landscape context of the site, the continued processing of the land-use application should be processed in terms of its actual biodiversity attributes.

• There is a match between verification and land-cover category: If the site has been correctly classified in the land-cover map as near-natural, degraded, production or transformed land, the classification of the site in the CBA Map is appropriate, and the application must be processed accordingly. In very rare cases, certain degraded areas (i.e. infested with invasive alien plants) or production sites (i.e. ploughed agricultural land) have been categorised as CBAs or ESAs. This prioritisation may occur for a particular reason, e.g. the site forms a vital link in an ecological process area. The CBA or ESA status is a pointer that such an infested site should be cleared and restored or rehabilitated

g, and in the

case of production lands, no further hardening of the surface should be permitted. If, for example, former fields have not been cultivated for 10 years or more, and a new application for cultivation becomes necessary, the land’s CBA status – and, particularly, Desired Management Objective – needs to be taken into account by the authority processing the application.

STEP 4: Site Assessment:

• The next essential step should be a site assessment to ground truth and verify that the CBA Map and GIS input layers (vegetation type, presence of aquatic features, special habitats or species of special concerns, ecological process area, etc) used to develop the CBA Map have been correctly depicted, i.e. they are spatially accurate. Refer to Frequently Asked Questions in Section 5 when verifying the information on these maps. The physical site assessment should be conducted by a specialist consultant and, if possible, a CapeNature, DWEA and/or SANParks official. Available supporting tools include the Fynbos Forum Recommended Terms of Reference

1 for the Consideration of Biodiversity in

Environmental Assessment (for site screening and Basic Assessments) and DEADP’s Guidelines for Involving Biodiversity Specialists available at www.capegateway.gov.za. These aim to improve specialist input into EIAs and to promote the early consideration of potentially significant impacts in project planning and design. In addition to the above recommended Terms of Reference, the specialist should assess the site according to the biodiversity features present on the site which resulted in the site being selected as a CBA or ESA. These features or ‘criteria for selection’ can be established by interrogating the attribute table of the relevant shapefiles.

1 Recommended Terms of Reference for the consideration of biodiversity in environmental assessment and decision-making.

Botanical Society of SA Conservation Unit, Private Bag X10, CLAREMONT, 7735 * Tel: 27-21-799-8824 * Fax: 27-21-761-

5983 * Inquiries: [email protected] and available at www.botanicalsociety.org.za


STEP 5: Assess compatibility of proposed land-use with CBA category by referring to the guidelines offered in Table 8:

• If the proposed development falls within Critical Biodiversity Areas (aquatic features and their buffers as well as the terrestrial features) or Ecological Support Areas, refer to Table 8 below for guidance on which land-use activities should be encouraged or discouraged. If the proposed land-use activity is not listed in this table, or if the proposed development definition differs from that specified in Table 9, then assess the proposed land-use activity against the Desired Management Objective (Table 7) to determine the compatibility of the proposed land-use activity with that objective. It may also be important to understand why a site has been selected as a CBA as this may influence the assessment of the possible impacts. This can be determined by interrogating the attribute table of the relevant shapefile provided on the DVD.

• If the proposed development falls within a Protected Area, refer to the National Environmental Management: Protected Areas Act (NEM:PAA) and the relevant Protected Area Management Plan for guidance on appropriate land-use activities.

• If the proposed development falls within Other Natural Areas and No Natural Remaining Area, this means that, from a biodiversity perspective, these areas are favoured for sustainable development. Note that in Other Natural Areas a botanical survey would be necessary if Species of Conservation Concern may be present.

NOTE: Table 8 has been guided by (1) the Desired Management Objective (described above) of the land; and (2) the likely impact of various land- and resource-use activities on biodiversity. Refer to Table 9 for definitions of these land-use activities. These provide information from only one sector in the multi-sectoral process of spatial planning and land-use management. For further land-use policy recommendations, refer to the Provincial Spatial Development Framework Rural Land-use planning and Management Guidelines (in prep.) and the Western Cape Provincial SDF (2005). These guidelines seek to ensure that activities associated with land- and resource-use avert or minimise impacts on biodiversity, especially in Critical Biodiversity Areas and Ecological Support Areas. Land-use that maintains intact natural habitat and has very low impact on biodiversity is considered to be biodiversity-compatible (e.g. appropriately managed grazing by livestock or game, sustainable harvesting of natural products from the wild). In contrast, land-uses that result in the irreversible loss of natural habitat and have the highest impact on biodiversity are biodiversity-incompatible land-use activities (e.g. cultivation, afforestation, urban development and mining).


Appendix D: Case Study Report – Milnerton

Development of a Methodology for Defining and Adopting Coastal Development Setback Lines

MILNERTON CASE STUDY

31 May 2010


MILNERTON CASE STUDY

QM


Remarks Final Submission

Date 13/05/2010 31/05/2010

Prepared by F van Eeden,

S Roux,

I Du Plessis

F van Eeden,

S Roux,

I Du Plessis

Signature

Checked by N Weitz N Weitz

Signature

Authorised by G G Smith G G Smith

Signature

Project number 208100E 208100E

File reference /11.2 /11.2


Contents

1 Introduction 1

2 Preliminary work 2

3 No development/coastal processes setback study 6

4 Limited/controlled development setback study 16

5 Public participation 17

6 Conclusions and recommendations 18

7 References 18

208100E/11 1

1 Introduction As part of developing a methodology to determine development setback lines in the Western Cape,

the proposed methodology is tested by means of a case study. This report describes application of the

proposed methodology to determine development setback along a section of beach in Milnerton that

includes the Diep River mouth and a part of Woodbridge Island to the south of the Golf Club. Figure 1

shows the extent of the site.

The primary aim of this study is to determine the coastal process/no development setback line (as

described in the methodology report - WSP, 2010) for the site through the testing of the proposed

methodology. The secondary aim of the study is to determine the limited/controlled development

line (as described in WSP, 2010) if applicable or different from the coastal process/no development

line.

The coastal process/no development line is to be determined (WSP, 2010) taking into account:

• The potential effects (erosion, wave runup) of a 1:100 year storm;

• Erosion trends (if they occur) for a 100 year period;

• Sea-level rise applicable to the next 100 years;

• Wind-blown sand. This may be applicable to the dry beach and dune areas at Milnerton;

• Potential dune or cliff collapse. However, at Milnerton, no cliffs occur, and the dune is

relatively low and not subject to collapse that would warrant additional setback

• Erosion due to estuary mouth channel meander. Migration of the Diep River mouth at

Milnerton may pose a threat to coastal development. Therefore, the history of the Diep River

is taken into account.

The limited/controlled development is to be determined (WSP, 2010) taking into account:

• Biodiversity;

• Heritage sites;

• Other issues such as public access, aesthetics, and shading.

All depths and heights in this report refer to land-levelling datum (also called mean sea-level (MSL))

unless otherwise specified. All coordinates given or referred to are measured relative to World

Geodetic System, 1984 (WGS84) in the zone Lo 19 (named after the longitude of origin).

It must be noted that the case studies did not have the benefit of the enabling studies which ultimately

will provide the following:

• Reliable, up-to-date beach topography data;

• Nearshore wave data at the site;

• Water-level data;

• Storm erosion modelling coefficients and an efficient approach.

The best efforts were made to overcome these shortcomings. Available topography data was

accessed and computational models were run (e.g. to determine local wave conditions).

208100E/11 2

2 Preliminary work It is important to note that this case study is purposefully performed with a limited amount of data.

Although previous, detailed studies on the coastal processes at this site do exist, this was deliberately

ignored to test whether a reliable setback can be obtained with the minimum of information available,

such as will be the case in more remote parts of the Western Cape.

2.1 SITE VISIT

Site visits were conducted on 5 February 2010 and 11 February 2010. The following were observed:

• The site is characterised by a mainly sandy beach with an estuary at the mouth of the Diep River

located in the middle of the site. A culvert mouthing out on the beach is observed to the south of

the site. The culvert extends approximately up to the low water mark.

• A low frontal dune separates housing developments from the beach area. Access from the

developments to the beach is obtained through wooden walkways. In some places, sand bags

are placed at the base of the frontal dune. The frontal dune is vegetated and maintained by the

respective developments. Hard edge developments line the southern bank of the estuary mouth

and extend all the way upstream of the Diep River.

• To the north of the estuary mouth, a low, well maintained frontal dune separates the housing

developments from the beach. Attempts at dune rehabilitation are in progress throughout the site.

Wooden walkways give access to the beach from the developments.

2.2 DATA COLLECTION

2.2.1 General

Table 1outlines the data that was accessed for this project Table 1: Data collected for use in this case study.

Data Source Approximate cost

Offshore waves and wind

ftp://polar.ncep.noaa.gov/pub/history/waves No cost

Historical aerial photography

Chief Directorate for Surveys and Mapping (CDSM)

R 7-00 per contact print R75-00 per photo enlargement

Geo-referencing of historical photographs

Centre for Geographical Analysis R400 / photograph

Bio-diversity maps (GIS)

Cape Nature / SANBI No Cost

Sediment grain size distribution

Analysis of site samples by CSIR R285 / Sample

Spatial Development Framework

City of Cape Town No cost

Heritage maps Heritage Western Cape No cost

Survey data City of Cape Town No cost

Bathymetry Naval navigation charts R300 / chart

The historical photographs come at no cost electronically. The data base at CDSM can be freely accessed at their offices.

Details of key data items follows.

208100E/11 3

2.2.2 Aerial Photographs

Aerial photographs covering at least part of the study area and used in the analysis were available for

the years 1945 to 2008 (9 photographs covering 63 years). In order to compare the aerial

photographs, each photograph had to be converted to a common scale. All photographs were

corrected for photographic distortion using GIS (Geographic Information System) software.

The following aerial photographs of the study area were collected from the Chief Directorate of

Surveys and Mapping (Mowbray):

Table 2: Dates of historical photographs analysed.

Number Photograph

1 1945

2 1958

3 1968

4 1977

5 1983

6 1988

7 2001

8 2005

9 2008

2.2.3 Tides

The tide at the site is semi-diurnal; that is, usually there are two high tides and two low tides during

each day. The nearest site to Milnerton for which predictions are available is Cape Town. The

predicted tidal levels for Cape Town are:

Table 3: Tidal levels predicted at the site (from SAN, 2009)

Tide Tidal Level (m to MSL)

Highest astronomical tide 1.20

Mean high water spring 0.92

Mean high water neap 0.44

Mean level 0.16

Mean low water neap -0.13

Mean low water spring -0.58

Lowest astronomical tide -0.83

From this table it can be seen that the mean spring tidal range is 1.50 m while the neap tidal range is

0.57 m.

208100E/11 4

2.2.4 Wind

Wind velocity and direction hindcast time series data originating from the Wave Watch III hindcast

model were extracted, at a location approximately 90km offshore due west of Cape Town Harbour,

34⁰S 17.5⁰E. Almost twelve and a half years of wind data, reported at 3-hour intervals, were used to

analyse the wind climate. While local effects do occur on the coast, this data is deemed to be

adequate for estimating wind-blown sand, wind set-up and conduct wind-wave assessments.

The wind regime is dominated by south to south easterly winds (about 50 % in total) while the

opposing north westerly to west north westerly winds occur much less frequently (about 20 % in

total).

2.2.5 Waves

Signficant wave height, peak period and wave direction time series originating from the Wave Watch

III hindcast model were extracted at the same position as the wind data extraction.

2.2.6 Topographic Surveys

A detailed LIDAR topographical survey of the development site was provided by Geosense (Cape

Town). The contour plots for both the developed site and the beach are depicted in Figure 2.

In keeping with the assumption of limited data, previous/historical beach survey data were not

accessed. Selected cross sections of the beach, as derived from the aerial images, are shown in

Figure 3 (note that the scales are distorted in this figure). Figure 4 shows the locations of these

profiles on the beach. Profile 1 is located to the south, close to the culvert outfall while Profile 6 is

located at the north of the site.

The wetted beach (the beach area between the high and low water marks) generally has an average

slope of 1:32 (between -1 m and +1.5 m to MSL) across the whole site. The profiles to the north of the

site generally have steeper slopes (approximately between 1:18 and 1:24). Slopes flatten out from just

north of the estuary southwards, averaging a slope of 1:44.

From the data compiled from the topographical survey, the highest indicated point on the frontal dune

is +7.87m MSL north of the Diep Rivier mouth while a fairly average dune height of approximately

+3.0m MSL is maintained south of the Diep River mouth. A low crest height potentially renders a dune

susceptible to wave overtopping (see Section 3.4).

During storms, the frontal dunes at the site may be eroded. This erosion is expected to be limited in

some areas due to the core material being gabion structures in some places together with hard edges

present along the site. Sandy areas that are adjacent to hard edged structures along with lower lying

sand dunes might incur more erosion.

The amount of trampling and human induced erosion of the frontal dune (that cause irregular intervals

of erosion) play a vital role in the rate of erosion caused by wave action during storm events.

Most of the developed site is above between +3.0 m and +7.0 m above MSL (Figure 3).

2.2.7 Sand Grain Sizes

Sand samples were collected from the inter-tidal beach at various locations along the site during the

visits of 5 February 2010 and 11 February 2010. Figure 5 indicates the locations at which the samples

were taken.

208100E/11 5

The grain size distributions were determined by sieving.

Table 4 contains the results of the grain size distributions. These results show that the grain size

distribution along the site is fairly consistent with a median grain size (D50) of about 0.24 mm. This is

medium to fine sand according to the Wentworth scale.

Table 4: Sand grain size distributions as determined through sieve analysis.

Location D95 D90 D84 D75 D50 D25 D16 D10 D5 Mean Size

Milnerton 1 0.25 0.22 0.21 0.20 0.18 0.16 0.15 0.14 0.13 0.18

Milnerton 2 0.36 0.27 0.23 0.20 0.18 0.15 0.14 0.13 0.12 0.18

Milnerton 3 1.13 0.77 0.54 0.30 0.21 0.17 0.16 0.15 0.14 0.30

Milnerton 4 0.80 0.63 0.54 0.42 0.25 0.17 0.15 0.14 0.13 0.31

Milnerton 5 1.18 0.82 0.59 0.44 0.28 0.23 0.21 0.20 0.18 0.36

Milnerton 6 1.16 0.67 0.45 0.30 0.25 0.19 0.17 0.15 0.14 0.29

Milnerton 7 0.66 0.51 0.40 0.31 0.26 0.20 0.18 0.17 0.15 0.28

Milnerton 8 0.66 0.52 0.43 0.35 0.27 0.22 0.20 0.18 0.16 0.30

Milnerton 9 0.59 0.46 0.40 0.33 0.27 0.21 0.18 0.16 0.14 0.28

Milnerton 10 1.00 0.68 0.53 0.40 0.28 0.22 0.19 0.18 0.15 0.33

Di= grain size that exceeds i % by mass. For example, D25= 0.16 mm means that 25 % of the sand grains in the sample are finer than 0.16 mm.

2.3 ASSESS BOUNDARIES

From the assessment of boundaries during the site visit it was clear that there are no areas available

for new development at the site. The Spatial Development Framework (SDF) for Milnerton and the

Blaauwberg area confirms this and no indication is given of new or restructuring developments

planned for the site or surrounds.

The eastern bank of the Diep River is identified as a critical public link. Walkways have been installed

along the river leading to beach providing access to the south of the estuary mouth. The SDF also

identifies a coastal protection zone of which the whole site forms a part.

No information was available regarding cadastral boundaries or previous setback line studies

conducted on the site.

208100E/11 6

3 No development/coastal processes setback study 3.1 GENERAL OBSERVATIONS

Aerial photograph observations The aerial photographs were used to establish changes to and characteristics of the site. For example:

• The partial weir at the mouth of the Diep River (eastern section was demolished in 1940) can be

seen in the photographs up to 1983.

• No cultivated land is observed in any of the photographs.

• Urban sprawl is seen from 1958 onward with urban dwellings established along the eastern

banks of the Diep River. Plots are demarcated on Milnerton Island (seen on photograph of 1958)

but established dwellings are only seen in the photograph of 1988, apart from Zonnekus (a large

residential dwelling owned by the Graaf family and seen on the photograph of 1958).

• Industrial development to the south of the estuary mouth is seen from 1977 onwards and located

landward of the access road. Residential development (Lagoon Beach) is seen from 2001

onwards with present state of the development already seen in 2005.

• The photograph taken in 1945 shows no development to the south of the Diep River mouth

although an access road from the south (towards the north), with numerous informal paths

extending from the access roads toward the ocean, is seen. Upgrade to a dual lane road is seen

in the photograph of 1968.

• A clear hard surface road is seen along the beach, eventually curving landwards to join the main

access road in the photograph of 1945. This road is covered up (seemingly by the beach) in the

photographs from 1958 onwards, although the curve that extends landward is still clearly visible

up to 1977.

• Construction of the railway is seen in the photograph of 1977.

The aerial photographs were also analysed to determine the variation in the position of the high-water mark (see Section 3.2.2).

Estuary observations:

The mouth of the Diep River is a prominent feature of the site. The following historical issues are

highlighted (CSIR, 1988):

• A well documented flood history exists for the Diep River. The flood levels upstream are

dependent on whether the mouth of the river is open and flowing freely into the ocean. Flood

levels can reach up to +4.34m MSL.

• The Diep River mouth consists of a double spit, free to migrate along an unrestricted sandbank

about 250m in length but is limited by gabion structures and concrete walls to the north and

naturally high hummock dunes to the south.

• The beach slopes adjacent to the north and south of the mouth do not seem to vary much.

• The nett longshore sediment transport at the mouth of the Diep River is relatively small and

directed towards the north.

• The development on Woodbridge Island is situated above the 1:50 yr floodline and that the

estuary should be opened when water levels reach a certain level.

• A sand bar across the river mouth separates the river from the sea for much of the year. The

actual duration of closure of the mouth varies considerably throughout the year.

• A maximum tidal range of 0.26m was recorded for the estuary mouth.

208100E/11 7

3.2 EROSION SETBACK

3.2.1 Sea Level Rise

The surveyed beach profiles were used (as discussed in Section 2.2.6 in the sea level rise

assessments. As explained in the methodology (Section 5.2.2 of the Methodology Report) a sea level

rise of 1m was used.

Two methods are compared to establish the impact of sea level rise on the site:

1) The Bruun Rule

2) Average beach slope

Bruun Rule:

The Bruun formula (Bruun 1962) was used to investigate the effect of sea level rise. The Bruun rule is

schematically illustrated in Figure 6.

From the survey information, the lowest dune height of 3.28m was used as input. The distance

between the dune crest and the closure depth was estimated to be approximately 400m. The closure

depth was calculated to be 4.5m, using the Hallermeier equation (Birkemeier, 1985). According to the

Bruun formula the shoreline will retreat with 51m.

Average Beach Slope

A setback distance due to sea level rise was calculated relative to the average beach slope at

selected cross sections (see Section 2.2.6) assuming a sea level rise of 1m over 100 years.

Although the Bruun formula is not a proven method for this particular case and the second method

used is an oversimplification of the situation, both methods will be considered in evaluating a setback

distance due to sea level rise.

Considering the beach profiles at the six locations (Figure 4) and applying the sea level rise of 1 m to

the average beach slope, an average setback distance of 48m is calculated.

This setback distance was added on to the long and short term erosion trends calculated in

Section 3.2.2.

3.2.2 Long Term Shoreline Trend Analysis

In order to determine the long-term shoreline trends, shoreline variations must be identified and

quantified.

The shoreline variation was analysed at 6 cross-sections (lines) along the site (Figure 3). Shoreline

variation at each line was quantified by measuring the distance, roughly perpendicular, from a fixed

reference point to the high-water mark at the time that each aerial photograph was taken. The

locations of the cross-sections analysed and the respective high-water mark are illustrated in Figure 7.

The measured distances are listed in Table 6. If these distances, measured from the reference line,

are plotted against time, curves of the variation of the location of the high water mark over time are

obtained (shown in Figure 8). A positive slope of such a curve indicates accretion because the beach

becomes wider; that is, the distance increases over time. Similarly, a curve having a negative slope

208100E/11 8

depicts erosion. If the distances fluctuate around a mean value (a horizontal trend on average), it

indicates that the beach is dynamically stable.

From Figure 8 it can be seen that a clear erosion trend is present in the data (negative slope for all the

profiles extracted). In order to estimate a long term setback distance, the variation of the high water

mark should be looked at critically. Apparent changes in the rate of erosion/accretion (as shown in

Figure 9) may be due to the several harbour constructions that have been conducted over the years,

some of which involved dredging of sand from Table Bay. Alternatively, the condition of the high

water mark may reflect short-term changes in beach condition due to extended calm periods and/or

migration of transient sedimentary features (which cause localised erosion/accretion) along the

shoreline.

A long term erosion distance (over 100 years) was calculated for each profile based on the long term

trends (Table 5)

Table 5: Horizontal setback distance allowed for the long term erosion trend.

Ref_6 Ref_5 Ref_4 Ref_3 Ref_2 Ref_1

Allowance for 1:100 yr Erosion

44m 39m 27m 67m 58m 56m

3.2.3 Short Term Shoreline Trend Analysis

Two methods were investigated in this instance:

1) Analysing historical photographs, removing the long term trend from the data and statistically

analysing the variation of the high water mark relative to a reference line.

2) Using numerical modelling to determine short term erosion induced by storms, tides, etc.

1) Statistical short term analysis:

After removing the long term erosion trend from the measured data, the following parameters were

determined:

• Minimum: the minimum distance from the reference point to the high-water mark

• Maximum: the maximum distance from the reference point to the high-water mark

• Maximum difference: the difference between the minimum and maximum distances, that is, the

largest variation

• Mean: the average location of the high-water mark measured from the reference point

• Standard deviation: the standard deviation of the shoreline distances

• Short term erosion: the short term erosion distance measured landward from high water mark

• 1 in 100 yr eriosion: erosion distance after 100 years, measured landward from high water mark

• Average Beach slope: slope used to calculate distance allowed for sea-level rise

• Setback allowed for sea-level rise: distance calculated by assuming 1m vertical sea-level rise

together with average beach slope

• Total setback distance: summation of Short term erosion, 1 in 100 year erosion and Setback

allowed for sea-level rise

208100E/11 9

Table 6: Shoreline variation and statistical analysis of the variation of the high water mark over time.

Ref_6 Ref_5 Ref_4 Ref_3 Ref_2 Ref_1

1945 172 229 248 260

1958 173 158 175 210 233 235

1968 170 159 147 211 240 241

1977 174 171 160 212 247 259

1983 174 170 185 219 239 251

1988 186 175 174 239 257 258

2001 158 147 147 213 235 243

2005 177 176 190 221 246 253

2008 156 156 213 237 245

No. of points

7 8 9 9 9 9

Minimum 158 147 147 210 233 235

Maximum 186 176 190 239 257 260

Mean 173 164 167 219 242 249

Maximum difference

28 29 43 29 24 25

Standard deviation

8 10 16 10 8 9

Short term erosion (m)

35 43 66 41 32 38

1 in 100 yr erosion (m)

43 38 27 67 58 56

Average beach slope (-)

0.0564 0.0428 0.0298 0.0144 0.0211 0.0257

Setback allowed for sea level rise (m)

18.0 24.0 34.0 70.0 48.0 39.0

Total setback distance (m)

97 106 127 178 138 132

Figure 10 depicts the de-trended shoreline variation over time for the Milnerton site. A maximum

difference between the positions of any high-water mark (along a cross-section) of 43 m exists while

the standard deviation along the beach varies between 8 m and 16 m.

2) Numerical Modelling:

The approach outlined in section 5.2.4 of the Methodology report (WSP, 2010) was followed for

computing storm erosion using numerical modelling. The approach consists of wave transformation

from offshore to nearshore, numerical simulation of storm erosion and statistical analysis of the

shoreline retreat due to all storms to estimate the 1:100 year short term erosion setback distance.

Wave transformation and storm analysis

An analysis of waves at the project site required the transformation of offshore waves to a nearshore

location close to the project site. Thereafter, computed transformation coefficients were applied to the

208100E/11 10

entire selected offshore wave dataset (Wave Watch III) to derive the nearshore wave conditions.

These nearshore conditions were then analysed to determine storm input for cross shore modelling.

This process is described in detail below.

Wave Transformation Model Description

The third-generation wave generation and refraction model SWAN (Simulating WAves Nearshore)

was applied (Booij, et al, 1999). SWAN was run within the DELFT3D-WAVE environment (WL|Delft

Hydraulics, 2008), which provides a convenient interface for pre- and post-processing of the results.

The SWAN model is based on the discrete spectral action balance equation and is fully spectral (in all

directions and frequency), implying that short-crested random wave fields propagating simultaneously

from widely different sources can be accommodated, e.g. a swell with superimposed wind sea.

Model setup and results

Domain and bathymetry

Figure 11 illustrates the area represented in the model study. The entire domain extends 137 km

alongshore and with a maximum cross-shore distance of 52 km.

The model study consisted of a nested grid (3 grids) model setup: An outer model and two nested,

inner models. The outer model consisted of grid cells 500 m x 500 m in size throughout the domain

The location of the two nested models within the outer model has been outlined in Figure 11. The

model bathymetry (Figure 12), was created with data from South African Naval Chart SAN SC4.

The x-y coordinate system used in the model was based on the Lo 19 (Clarke 1880) coordinate

system. A linear transformation was applied to provide model coordinates (xmodel, ymodel) that are

positive and increase from south to north and from west to east. The transformation used was:

xmodel = 500 000 – yLo19

ymodel = 4 000 000 – xLo19

Design wave climate

The dataset obtained from Wave Watch III (WWIII) covered a twelve year period (1997 to 2009). In

order to transform the WWIII offshore wave dataset to the equivalent nearshore dataset, a matrix (or

lookup table) of offshore to nearshore wave combinations had to be created which had to be applied

to each individual offshore wave condition in the dataset. Therefore a set of schematic offshore wave

conditions was devised which encompassed a good representation of all possible offshore wave

conditions which may occur. This set of conditions included a unit wave height of 2 m and several

combinations of offshore wave periods and directions (Table 7) resulting in a total of 175 conditions.

The transformation process involved identifying those conditions within the schematic offshore input

waves which most closely resembled the WWIII offshore wave condition. Thereafter a linear

interpolation was conducted between the associated schematic nearshore output waves to determine

the nearshore wave condition that will result from the WWIII offshore wave.

This resulted in 36679 nearshore wave conditions at 3-hourly intervals, at the location marked ‘Wave

extraction location’ in Figure 12.

208100E/11 11

Table 7: Range of wave periods and directions used for schematic offshore input waves

Offshore schematic wave climate: Wave height = 2m

Peak period (Tp) bins Direction bins

4.17 145.00

6.67 160.00

7.69 175.00

8.33 190.00

9.09 205.00

10.00 220.00

10.53 235.00

11.77 250.00

12.50 265.00

13.30 280.00

14.30 295.00

16.67 310.00

22.22 325.00

Results

An example of nearshore wave patterns is illustrated in Figure 13. A relatively good understanding of

the local wave conditions, i.e. wave focussing, can easily be obtained just from visual assessment of

these plots. At Milnerton it is evident that slightly higher waves occur towards the north of the Diep

River mouth than towards the south. Wave roses for the offshore and transformed nearshore

conditions are shown in Figure 14.

The resulting 36679 nearshore wave conditions were used to identify storm events. The time series of

nearshore wave height were plotted and evaluated visually to identify storms. The storms were

chosen in such a way that an average of one to three storms per year are selected from the time

series (refer to CEM II-8-5 (USACE, 2002)). Thus, a total of 31 storms were identified. Most of these

storms occurred during winter (May to August).

Cross-shore transport modelling

The cross-shore sediment transport model SBEACH was used to predict beach erosion and

consequent shoreline retreat due to the identified nearshore storms. The following section describes

the model, the model setup and the results.

Cross-shore transport model

The SBEACH cross-shore transport/morphological model (Larson and Kraus, 1989) was chosen for

predicting beach profile variations as a result of storm processes. In a comprehensive review,

Schoonees and Theron (1995) found that this is one of the best models currently available. The

theoretical basis is accepted and the model has been extensively verified (Schoonees and Theron,

1995).

The SBEACH numerical model was developed to predict beach profile change resulting from cross-

shore sand transport, focusing on the main morphological features of bars and berms. Changes in the

beach profile are assumed to be produced by breaking waves; therefore, the cross-shore transport

rate is determined from the local wave, water-level, and beach profile properties, and the equation

describing the conservation of beach material is solved to compute profile change as a function of

time. In addition, it can simulate dune overwash.

208100E/11 12

Model setup

The primary input data required for modelling the effects of storms are:

• The initial beach profile;

• Median sand grain size; and

• Time series of the storm conditions including wave height, wave period, wave direction and water-

levels.

No pre- or post storm beach surveys could be obtained upon which to calibrate the model and

therefore, default model parameters were used.

Beach profile configuration

The results of the sediment analysis (Section 2.2.7) indicated that the median grain size for the

northern section of the site is slightly coarser than for the southern section which agrees with the

findings of Smith and Luger (2003). Hence, two profiles were used as input; a northern and southern

profile.

The pre-storm profiles were obtained by merging beach profile data from the surveys given by

GEOSENSE (depths are to Mean Sea Level) with SAN Chart bathymetric data. The two pre-storm

beach profiles were created by taking the average of the beach profiles north and south of Deep River

mouth.

Storm configuration

The 31 storm events previously determined included the time series of wave height, period and

direction (relative to shore normal). The water-levels were determined by using the tidal constituents

for the Port of Cape Town given by Rosenthal and Grant (1989). Note that the constituents given in

the South Africa Admiralty tables can also be used.

Storm surge due to barometric pressure was determined by evaluating atmospheric pressure data

over the 12 year period covered by the WWIII data period. This data was obtained freely from

Weather Underground (www.wunderground.com). A seasonal variation in average pressure was

observed with an average of 1020 hPa during winter time. The average drop in pressure during a

storm event was typically 10 hPa which resulted in a temporary rise in water level of 0.1 m.

Wind setup was estimated by taking a typical wind speed which occurs during storm events namely

15 m/s, with an estimated the fetch of 1000km which resulted in a value of 0.2m.

The values for the wind setup and barometric pressure effect were added to all water levels to account

for storm surge.

Results and discussion

An illustration of a typical output from the SBEACH model is shown in Figure 15. Recession of the 0m,

1m and 2m contour lines were assessed to determine general erosion setback. An extreme analysis

of the results was carried out to determine the 1 in 100 year storm erosion.

The 1 in 100 year storm erosion calculated for the southern profile for Milnerton was 33m. This value

agrees well with an average storm erosion of 20m with a maximum of 31m for a 1 in 43 year event

which occurred in May 1984 reported in CSIR (1988).

208100E/11 13

3.2.4 Estuary

The current calculated flood levels are employed as guidelines for setback required for the estuary.

The estuary is a highly dynamic zone with regards to ecology, river and catchment areas, coastal

processes, tidal range, etc. that warrants its own specialist study. Thus, the setback line for this study

will not consider the area around the mouth of the Diep River however the 1:50 year flood line will be

used as this is the limiting value for the current development (CSIR, 1998).

3.3 SETBACK CONSIDERING WINDBLOWN SAND

The dominant winds cause wind-blown sand transport from (i) the south south east and south east;

and (ii) the north west. This is evident from Figure 16 which illustrates the calculated potential sand

transport distribution. Note that the sand transport is expected to be considerably less than the

potential indicated, since the (1) beach is wet most of the time (either through tides and wave action or

rain) - the presence of moisture in the sand has the effect of binding the surface sand and increases

the wind velocity required to initiate sand transport, and (2) because the fetch length is very short.

(The fetch length is the horizontal distance (in the direction of the wind) over which a wind blows and

mobilising sand grains.)

According to Figure 16, at times (mostly in spring/summer) sand will be transported from inland

towards the shore (offshore winds) and at times (mostly in winter) sand will be transported from the

ocean towards the coast (onshore winds). The net aeolian sand transport direction will be from the

south eastern sector because:

(1) The occurrence of south-easterly winds are higher than for the opposing north west winds; and

(2) During winter when the north-easterly to north-westerly winds occur, the sand on the beach will be

damp more often than in summer (due to more storm wave action and rainfall)

Little of this wind-blown sand will reach any developments at the site because it will be trapped by the

frontal face of the dune and by the vegetation on the crest of the dune. Considering the dominant

directions of wind-blown sand transport, the limited evidence of mobile sand and the presence of

vegetation seaward of most of the developments, no setback distance was allowed for windblown

sand.

3.4 SETBACK FOR FLOODING

A time series of offshore waves was extracted from the hindcast data from the Wave Watch III model

data. The time series contains the significant wave height, wave direction and peak period at three

hourly intervals.

There are various factors that affect the water level. These include tides, barometric pressure effect,

wind set-up and wave set-up.

The tidal levels corresponding to each data point in the wave time series were obtained from

predictions using tidal constituents (Rosenthal and Grant, 1989).

The daily minimum barometric pressures were obtained from Weather Underground

(www.wunderground.com). This value was subtracted from the average barometric pressure

(1020hPa) and multiplied by 0.1m to obtain sea level rise due to barometric pressure effects. The

208100E/11 14

average drop in pressure during a storm event was typically 10hPa which resulted in a temporary rise

in water level of 0.1m.

The wind set-up was calculated using the software CRESS (Coastal and River Engineering Support

System. Available: http://www.kennisbank-waterbouw.nl/cress/index.htm. A fetch of 1000km and wind

speed of 15 m/s was assumed. The barometric pressure effects and the wind set-up were added to

the corresponding tidal level to find the water level corresponding to each data point in the wave time

series. Wave set-up was included in the run-up calculation and thus not added.

The wave run-up for each data point in the wave time series, using the corresponding water level, was

calculated using the equation by Nielsen and Hanslow (1991). A time series of wave run-up was thus

obtained. This wave run-up time series was analysed to determine the 1:100 year wave run-up

(Figure 17). The 1:100 year wave run-up elevation is calculated to be +4.48m MSL.

Wave overtopping was investigated since the run-up level is higher than that of the dune crest

(approximate +3.0m MSL). To calculate overtopping, the 1:100 year wave was calculated. The 1:100

year significant nearshore wave height is 5.34m and the corresponding peak period is 15.5s. The tide

was taken as +1.04m MSL (HAT). The water level was taken at +1.39m MSL. The components to the

water level are the same as mentioned above. The resulting overtopping, calculated using the

Overtopping Manual (Pullen et al., 2007), south of the Diep River mouth is 0.001ℓ/s/m. No overtopping

is expected north of the river mouth as the frontal dune is higher than +3.0m MSL.

According to the Overtopping Manual (Pullen et al, 2007), this amount of overtopping poses no threat

to development given the current topography.

No setback allowance was made for flooding.

3.5 TOTAL COASTAL PROCESSES/NO DEVELOPMENT SETBACK

From Section 7.5 of the methodology report, the setback for coastal processes is determined from the

maximum of the following:

• Setback for coastal erosion;

• Setback for windblown sand;

• Setback for flooding (wave runup, overtopping if applicable)

No setback was allowed for geotechnical or sediment issues (Section 3.3) and flooding (Section 3.4).

Thus the total setback (barring the fact that the site falls within the coastal protection zone) is

determined by the setback for coastal erosion.

A conservative estimate is given by the statistical analysis method determining the long term, and

short term erosion variation when compared to the results from the numerical modelling. From the

numerical modelling, the 1 in 100 year storm erosion calculated for the southern profile for Milnerton

was 33m (Section 3.2.3(2)) while the statistical analysis reported short term erosion values between

32m and 66m (Table 6).

Thus, the statistical results were used in the determination of the coordinates of the reported setback

line. The determined setback line includes the coastal erosion (long and short term) plus the setback

allowed for sea level rise.

The coordinates of the erosion setback line at the site at Milnerton are given in Table 8, while the

location thereof is depicted in Figure 18. It can be seen that the erosion setback line is situated

between the beach area and the Diep River and includes part of the residential development on

208100E/11 15

Woodbridge Island. On the southern side of the site the setback line is, on average, located

approximately 50m seaward of the main road.

Table 8: Coordinates of the development setback line for the site at Milnerton (Coordinate System:

Lo19, WGS84)

Y (m) X (m)

-47909.17 -3752150.65

-47869.43 -3752060.54

-47836.09 -3751985.24

-47797.01 -3751924.40

-47762.07 -3751870.01

-47703.76 -3751781.46

-47672.97 -3751738.03

-47619.67 -3751662.85

-47621.24 -3751423.50

-47570.88 -3751275.33

-47515.66 -3751112.87

-47475.00 -3750991.26

-47420.88 -3750804.44

-47398.55 -3750727.35

208100E/11 16

4 Limited/controlled development setback study

4.1 SETBACK FOR BIODIVERSITY

According to the SDF and Biodiveristy map, the Diep Rivier estuary itself is considered as a

Conservation Area, but no other Critical Biodiversity Areas (CBM’s) are defined within the site area.

However, the whole of the site falls within the coastal protection zone and is thus considered to be a

managed, regulated and restricted development zone.

4.2 SETBACK FOR HERITAGE

Documents pertaining to archaeological and paleontological surveys conducted in the area were

investigated to determine if any sites of heritage importance exist which should be considered during

determining the setback line.

SDF maps, see Section 2.3, mark locations of two provincial heritage sites. Which structures they are

is not immediately clear and it is thought that the locations coincide with firstly the old wood bridge

connecting to Woodbridge Island and secondly the Milnerton light house on Woodbridge Island.

Other information available states scatter of shell middens, mostly disturbed, particularly just south of

the levelled parking area (Avery, 1995). Much of the material is found within the primary dune, which

becomes exposed during erosion events (Avery, 1995).

Many fossils have been recovered in the mouth of the Milnerton Lagoon, of both terrestrial and marine

origin (Avery, 1995).

Evidence has been found of calcareous beach deposits, Last Interglacial shell deposits as well as

Early Stone Age artefacts. Exact locations of these finds were not available. Khoisan burial sites have

also been uncovered however the exact locations have not been provided (Avery, 1995). Abrahams

(1983), cited by ACRM (1998), mentioned four burial sites were recovered from the dunes and south

of the mouth.

Generally sites are described as disturbed by land reclamation and development. Most archaeological

and paleontological material discussed in the available documents is described to occur close to the

shoreline, in and around the dune system and slightly eastward.

Shipwrecks are numerous in the area but do occur further seaward (ACO, 1998). Debris and artefacts

washed up onshore and into the lagoon mouth are considered valuable.

As the heritage sites of interest are generally seaward of the no-development setback line, no need

for a limited/controlled development setback for heritage was deemed necessary.

4.3 SETBACK FOR OTHER ISSUES

At the study site, not setback (landward of the no development/coastal process setback established

above) is deemed necessary for public access, aesthetic features, shading by structures and/or

significant landscapes (as discussed in the methodology report – WSP, 2010)

208100E/11 17

4.4 TOTAL LIMITED/CONTROLLED DEVELOPMENT SETBACK

No setback allowance additional to that for coastal processes/no development is deemed necessary

for limited/controlled setback required for biodiversity, heritage and other issues. Thus the

limited/controlled development setback line is to be situated on the same line coastal processes/no

development setback line.

5 Public participation

In a formal setback line study, the above results would be published once comment has been

received and addressed where relevant by focus groups. This will not be done for this case study as

this study is mainly concerned with the testing of the proposed methodology.

208100E/11 18

6 Conclusions and recommendations

The frontal dunes adjacent to the site, act as a buffer against storm erosion due to wave and tidal

action. It is recommended that the crest height of frontal dune be maintained to the current levels of

between +3.0m and +7.0m MSL. Also, measures to increase stability of the frontal dunes can be

implemented to aid against storm erosion.

The volume of sand in the dune must not be reduced and the dune must be fenced (as already

implemented at certain frontal dunes) to prevent people from trampling the vegetation and

destabilising the frontal dune. The use of the provided wooden walkways across the frontal dune

should be enforced at access points and at regular intervals along the shoreline. Maintenance of the

frontal dune and footpaths are required.

The site is not dynamically stable and exhibits a long term erosion trend as described in Section 3.2

and shown in Figure 8.

Calibration data for the site does exist as previous studies report storm induced erosion values (e.g.

CSIR, 1989; Smith and Luger (2003)). These values would naturally be used to calibrate the

numerical models that in turn would increase the confidence in the model. These models would then

be a more accurate representation of the situation. However, in keeping with the assumption of limited

data, predicted storm erosion values are deemed to be reasonable and comparable with previous

measurements.

Development setback for biodiversity was not applicable since no critical biodiversity area (CBA) on

the Biodiversity maps is defined within that area. Also, development is restricted inside the coastal

protection zone (DEA&P, 2009) indicated on the SDF map. The establishment of the setback line

distance would thus be a trivial exercise since the identified zone stretches a sufficient distance

landward and exceeds the recommended current setback distances.

This study was conducted with deliberate disregard for appropriate setback line and related studies

previously conducted at the site (e.g. CSIR (1988) and Smith (2003)) in order to test the methodology

in the event that data is limited (such as will be the case for most sites). Reference to these studies

would obviously have been the departure point for the current study as these reports would contain

vital short term erosion data that can be used for numerical model calibration purposes. Also,

calculated shoreline trends and other coastal process trends could be compared and reported on. This

would, to a certain extent, increase the accuracy of the setback line.

The following learning points have surfaced during the application of the methodology to this case

study:

• Adequate survey data: good quality topographical beach and bathymetry survey data is

essential to a setback line study, but this is not readily available from municipalities. Data

that was accessed was problematic in terms of vertical datum.

• Numerical modelling: correct setup, input and interpretation of the model output data requires

modelling experience.

• Numerical modelling: Calibration of models would be ideal, although results from

uncalibrated models (which employ model coefficients from experience of similar sites)

provide sensible results;

• Storm erosion modelling: Selection of storm conditions can be automated but with

considerable effort. This was conducted manually in this study;

• Storm erosion modelling: results from the statistical approach in the methodology had a high

correlation coefficient and provided plausible results;

• Water levels: a time series of measured water levels, including tides and surge, is required

for cross shore transport modelling

208100E/11 19

• Bruun Rule: the Bruun rule should be applied with caution. The input parameters and output

should never be used in isolation, since answers could be over conservative.

• Aerial photographs: the long term erosion trends determined form the historical aerial

photographs agreed reasonably well with those given in previous studies derived from

surveys, confirming the validity of employing aerial images in the methodology.

208100E/11 20

7 References

ACO (1998) Initial heritage resources assessment of a portion of land at Milnerton Golf course. Prepared for Doug Jeffrey (Environmental Consultant) by the Archaeology Contracts Office of the University of Cape Town. ACRM (1998) Desk top archaeological study: Milnerton Lagoon Mouth to Dolphin Beach. Prepared for OVP Associates by Agency for Cultural Resource Management. Abrahams, G (1983) The report on human skeletal remains and associated artefacts from Milnerton Beach, Cape Province. south African Archaeological Bulletin 38: 33-35 Avery, G (1995) Archaeological and paleontological survey: Milnerton Lagoon Mouth (3318CD). Report prepared for Knight Hall Hendry & Associates. south African Museum. CSIR (1988), Estuaries of the Cape: Rietvlei (CW24) and Diep (CW25), CSIR Research Report 427, Stellenbosch, May 1988 CSIR (1990). Setback analysis for the Durban Bight and Glenashley Beach. CSIR Report EMA-C 90147, Stellenbosch. CSIR (2003). Shoreline stability and sedimentation in Saldanha Bay. CSIR Report ENV-S-C 2003-081, Stellenbosch. J.A.G Cooper, O.H. Pilkey (2004), Sea-level rise and shoreline retreat: time to abandon the Bruun Rule, Global and Planetary Change , Volume 43, Issues 3-4, November 2004, Pages 157-171. W.A. Birkemeier (1985), Field data on the seaward limit of profile change. American Society of Civil Engineers, Journal of Waterway, Port, Coastal and Ocean Engineering, Vol. 111, No. 3, May/June 1985, pp. 598-602. Bruun, P (1962). Sealevel Rise as a cause of shore erosion. J Waterw Harbors Bruun, P (1988). The Bruun rule of erosion by sea-level rise: a discussion on large-scale two- and three-dimensional usages. Journal of Coastal Research, Vol. 4, No. 4, 627-648. Charlottesville (Virginia), USA. CSIR (1999). The effect of proposed harbour extensions on the Milnerton shoreline. CSIR Report EMA-C 99065, Stellenbosch. Rossouw, J (1989). Design waves for the South African coastline. Ph D. thesis, University of Stellenbosch, Stellenbosch. SAN (2009). Tide Tables. South African Navy, Tokai. Schoonees, J S and Theron, A K (1993). Review of the field data base for longshore sediment transport. Coastal Engineering 19: 1-25. Schoonees, J S, Theron, A K and Bevis, D (2006). Shoreline accretion and sand transport at groynes inside the Port of Richards Bay. Coastal Engineering 53: 1045-1058. Solomon, S, Qin, D, Manning, M, Alley, R B, Berntsen, T, et al. (2007). Technical Summary. In: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S, Qin, D, Manning, M, Chen, Z, Marquis, M, Averyt, K B, Tignor, M and Miller, H L (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New york, NY, USA. Swart, D H (1986). Prediction of wind-driven transport rates. 20 Intern. Conf. on Coastal Eng., Taiwan. Vol.: 2: 1595 – 1611.

208100E/11 21

Theron, A K (2000). Recession line evaluations. CSIR Report ENV-S-I 2000-02, Stellenbosch. USACE (1984). Shore Protection Manual. Volume I, 4th Edition. U.S. Army Coastal Engineering Research Centre, Washington D.D. U.S. Army Corps of Engineers. (2002). Coastal Engineering Manual. Engineer Manual 1110-2-1100, U.S. Army Corps of Engineers, Washington, D.C.. Wiegel, R L (1964). Oceanographical engineering. Prentice-Hall, Inc. Englewood. Cliffs, Fluid Mechanics Series. 532 pp. P. Nielsen, D. Hanslow (1991). Wave runup distribution on natural beaches. Journal of Coastal Research 7. 1139-1152. Florida Pullen et al. (2007). EurOtop – Wave overtopping of sea defences and related structures: Assessment manual. Hamburg: Kuratorium fuer Forschung im Kuesteningenieurwesen. Rosenthal, G., Grant, S., 1989. Simplified tidal prediction for the South African coastline. South African Journal of Science 85, 104-107. Booij, N., Ris, R. C. and Holthuijsen, L. H. (1999), A third-generation wave model for coastal regions, Part I: Model description and validation, J. Geophys. Res. Vol. 104, C4, pp.7649-7666. Larson, M., and Kraus, N. C. (1989). “SBEACH: Numerical model for simulating storm-induced beach change; Report 1, Empirical foundation and model development,” Technical Report CERC-89-9, U.S. Army Engineer Waterways Experiment Station, Coastal Engineering Research Center, Vicksburg, MS. SCHOONEES, J.S. & THERON, A.K., 1995. Evaluation of 10 cross-shore sediment transport/morphological models. Coastal Engineering, 25, 1-41. Smith, G. and Luger, S. (2003) EIA Specialist Study on the Impacts of the Container Terminal. Expansion on Shoreline Stability. CSIR Report No. ENV-S-C 2003-087 Dept. of Environment Affairs and SSA Engineers and Environmental Consultants (2009). A user-friendly guide to the Integrated Coastal Management Act of South Africa. WPS (2010), Development of a Methodology for Defining and Adopting Coastal Development Setback Lines, WSP Report

Appendices, Figures & Tables


Figure 1: Location map of the study area and study site extent (indicated by the red line).

Figure 2: Contour map of the area under investigation.

Figure 3: Cross sections of beach profiles taken at six locations along the site.

Milnerton beach profiles

0

1

2

3

4

5

6

0 50 100 150 200 250 300

Cross Section (m)

He

igh

t a

bo

ve

MS

L (

m)

Prof_Line_6

Prof_Line_5

Prof_Line_4

Prof_Line_3

Prof_Line_2

Prof_Line_1

Figure 4: Yellow lines indicate where beach profiles were assessed with Profile 1 in the south and

Profile 6 in the north of the site.

Figure 5: Red lines indicate positions on the beach where sand samples were taken for sieve

analysis.

Figure 6: Graphical illustration of the Bruun rule.

Figure 7: The distance to the high water mark is measured relative to a fixed point (Reference line)

along six cross sections (Profile Line). The high water mark of every available historical photograph

is also shown

Figure 8: General trend of the variation of the high water mark over time.

100

120

140

160

180

200

220

240

260

280

300

1940 1950 1960 1970 1980 1990 2000 2010 2020

Dis

tan

ce

fro

m r

efe

ren

ce

lin

e (

m)

Year

General trend of highwater mark over time

Ref_6

Ref_5

Ref_4

Ref_3

Ref_2

Ref_1

Figure 9: Variations of the high water mark over time as measured relative to the reference line.

Figure 10: De-trended variations of the high water mark over time

Variations in highwater line over time

120

140

160

180

200

220

240

260

280

300

1940 1950 1960 1970 1980 1990 2000 2010 2020

Year

Dis

tan

ce

fro

m r

efe

ren

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lin

e (

m)

Ref_6

Ref_5

Ref_4

Ref_3

Ref_2

Ref_1


120

140

160

180

200

220

240

260

280

1940 1950 1960 1970 1980 1990 2000 2010 2020

Year

Dis

tance fro

m r

efe

rence lin

e (m

)

Ref_6

Ref_5

Ref_4

Ref_3

Ref_2

Ref_1

Figure 11: Model domain indicating outer and inner model gridsModel domain indicating outer and inner model grids.

Figure 12: Bathymetry and location of nearshore wave extraction point

wave extraction point.

Figure 13: Wave refraction patterns computed through SWAN modellingSWAN modelling (for typical conditions)

Figure 14: Wave roses for (left) offshore wave data (WAVE WATCH III) and (right) transformed nearshore wave data.

Figure 15: Initial and final storm profiles.

Figure 16: Potential aeolian sand transport rose for Milnerton.

Figure 17: Exponential distribution of wave runup probability exceedence.

Figure 18: The development setback line is indicated by the red line.


Appendix E: Case Study Report – Langebaan


LANGEBAAN CASE STUDY

31 May 2010

QM


Remarks Final Issue

Date 13/05/2010 31/05/2010

Prepared by F van Eeden,

S Roux,

I du Plessis

F van Eeden,

S Roux,

I du Plessis

Signature

Checked by N Weitz N Weitz

Signature

Authorised by G Smith G Smith

Signature

Project number 208100E 208100E

File reference /11 /11


Contents

1 Introduction 1

2 Preliminary work 2

3 No development/coastal processes setback study 7

4 Limited/controlled development setback study 19

5 Public participation 20

6 Conclusions and recommendations 21

7 References 22

208100E/11 1

1 Introduction

As part of developing a methodology to determine development setback lines in the Western

Cape, the proposed methodology is tested by means of a case study. This report describes

application of the proposed methodology to determine development setback lines at two

separate sections of beach in Langebaan: Leentjiesklip to the south and Paradise Beach in the

north of Langebaan. Figure 1 illustrates the extent and location of the two sites.

The primary aim of this study is to determine the coastal process/no development setback line

(as described in the methodology report - WSP, 2010) for the site through the testing of the

proposed methodology. The secondary aim of the study is to determine the limited/controlled

development line (as described in WSP, 2010) if applicable or different from the coastal

process/no development line.

The coastal process/no development line is to be determined (WSP, 2010) taking into

account:

• The potential effects (erosion, wave runup) of a 1:100 year storm;

• Erosion trends (if they occur) for a 100 year period;

• Sea-level rise applicable to the next 100 years;

• Wind-blown sand. This may be applicable to the dry beach and dune areas at Milnerton;

• Potential dune or cliff collapse. However, at Milnerton, no cliffs occur, and the dune is

relatively low and not subject to collapse that would warrant additional setback

• Erosion due to estuary mouth channel meander. Migration of the Diep River mouth at

Milnerton may pose a threat to coastal development. Therefore, the history of the Diep

River is taken into account.

The limited/controlled development is to be determined (WSP, 2010) taking into account:

• Biodiversity;

• Heritage sites;

• Other issues such as public access, aesthetics, and shading.

All depths and heights in this report refer to land-levelling datum (also called mean sea-level

(MSL)) unless otherwise specified. All coordinates given or referred to are measured relative to

World Geodetic System, 1984 (WGS84) in the zone Lo 19 (named after the longitude of origin).

It must be noted that the case studies did not have the benefit of the enabling studies which

ultimately will provide the following:

• Reliable, up-to-date beach topography data;

• Nearshore wave data at the site;

• Water-level data;

• Storm erosion modelling coefficients and an efficient approach.

The best efforts were made to overcome these shortcomings. Available topography data was

accessed and computational models were run (e.g. to determine local wave conditions).

208100E/11 2

2 Preliminary work

It is important to note that this case study is purposefully performed with a limited amount of data.

Although previous, detailed studies on the coastal processes at the sites do exist, this was

deliberately ignored to test whether a reliable setback can be obtained with the minimum of

information available, such as will be the case in more remote parts of the Western Cape.

2.1 SITE VISIT

A site visit to both sites was conducted on 10 February 2010. The following were observed:

Langebaan north – Paradise Beach

The Paradise Beach site (Figure 2) is mostly a sandy beach with a rocky headland in the south

(Lynch Point) which partially protects development from direct wave attack. The headland

consists primarily of solid rock and with limited boulders and loose rock. The beach area to the

north of Lynch Point is relatively steep sloped and has a fairly high frontal dune. The southern

part has a housing development fairly close to the high water mark. Development extends to the

north (up to 400m from the rocky headland) with development set back landwards from the dune

crest. The dune crest increases in height as it extends to the north.

Wooden walkways provide access to the beach although evidence of trampled pathways was

observed across the dunes. The frontal dune is sparsely vegetated on the seaward slope with

vegetation density increasing landward over the dune crest.

Frontal dune erosion is visible along the length of the site with temporary measures installed

mainly at the housing development. This was achieved through the placing of sand bags at the

base of the dune and constructing wooden barriers (see Figure 3) arranged along shore just

landward of the high water mark.

Langebaan south – Leentjiesklip

The site under investigation (Figure 4) is predominantly a sandy beach and is bound by rocky

promontories (a point of land projecting into the sea) to the north and the south of the site.

Situated within the Saldanha Bay area, the site is mostly sheltered by the headland south of the

entrance to Saldanha Bay (Postberg Nature Reserve Area) from direct deep ocean waves

propagating from the south south west to almost directly western sectors.

The site primarily comprises a flat, sandy beach backed by a relatively low vegetated frontal

dune with houses and a camping area set back behind the dune. The beach area is accessed

from the urban edge via wooden walkways. These walkways are not always adhered to and

trampled trails leading from the houses over the dunes are observed in several places. No

vehicular access or evidence of vehicles on the beach area was observed. The frontal dune

gradually rises in crest height towards the south where signs of dune/land erosion are clearly

visible.

208100E/11 3

2.2 DATA COLLECTION

2.2.1 General

Table 1 outlines the data accessed for this project

Table 1: Data collected for use in this case study.

Data Source Approximate cost

Offshore waves and wind

ftp://polar.ncep.noaa.gov/pub/history/waves No cost

Historical aerial photography

Chief Directorate for Surveys and Mapping (CDSM)

R 7-00 per contact print R75-00 per photo enlargement

Geo-referencing of historical photographs

Centre for Geographical Analysis R400 / photograph

Bio-diversity maps (GIS)

Cape Nature / SANBI No Cost

Sediment grain size distribution

Analysis of site samples by CSIR R285 / Sample

SDF Saldanha Bay Municipality No cost

Heritage maps Heritage Western Cape No cost

Survey data City of Cape Town No cost

Bathymetry Naval navigation charts R300 / chart

The historical photographs come at no cost electronically. The data base at CDSM can be freely accessed at their offices.

Details of key data items follows.

2.2.2 Aerial Photographs

Aerial photographs covering at least part of the study areas and used in the analysis were

available for the years 1938 to 2007 (6 photographs covering 69 years). In order to compare the

aerial photographs, the different photographs had to be converted to the same scale. All

photographs were corrected for photographic distortion using GIS (Geographic Information

System) software.

The following aerial photographs of the study area were collected from the Chief Directorate of Surveys and Mapping (Mowbray): Table 2: Dates of historical photographs analysed.

Number Photograph date

1 1938

2 1960

3 1977

4 1988

5 1989

6 2007

208100E/11 4

2.2.3 Tides

The tide at the site is semi-diurnal; that is, usually there are two high tides and two low tides

during each day. The nearest site to Langebaan for which predictions are available is Saldanha.

The predicted tidal levels for Saldanha are (SAN, 2009):

Table 3: Tidal levels predicted at the sites

Tide Level (m to MSL)

Highest astronomical tide 1.17

Mean high water springs 0.89

Mean high water neaps 0.41

Mean level 0.13

Mean low water neaps -0.17

Mean low water springs -0.63

Lowest astronomical tide -0.87

From this table it can be seen that the mean spring tidal range is 1.51 m while the neap tidal

range is 0.57 m.

2.2.4 Wind

Wind velocity and direction were measured at the ore jetty at Saldanha, which is approximately

7km north west of Langebaan. Almost eight years of wind data, measured at 20-minute intervals,

were used to establish the wind climate (Luger et al., 1998). The wind regime is dominated by

south westerly to south easterly winds (about 57 % in total) while the opposing north easterly to

north westerly winds occur much less frequently (about 24 % in total). Wind velocities are below

4 m/s for about 39 % of the time and above 10 m/s for approximately 13 % of the time (Luger et

al., 1998).

Langebaan is close enough to Saldanha for the wind characteristics to be regarded as

reasonably representative of the study sites. The recordings roughly cover about an 8-year

period, which provides a very good estimate of the medium-term wind climate.

2.2.5 Waves

The wave climate considered at the study site is discussed in Section 3.2.3(2) as part of the numerical modelling exercise.

2.2.6 Topographic Surveys

Topographic surveys of the development site were provided by Geosense (Cape Town). The

contour plots for both the development sites and beaches are depicted in Figure 2 and Figure 4.

Profiles of selected cross sections surveyed along the beach are given in Figure 5 and Figure 6.

Figure 7 and Figure 8 indicate the locations of these profiles (note the distorted scale of the

beach profiles in Figure 5 and Figure 6). At both sites Profile 1 is located in the south while

Profile 6 is located at the north of the site.

208100E/11 5

Paradise Beach

The wetted beach (the beach area between the high and low water marks) has an average slope

of 1:7.3 (between -1 m and +1.5 m to MSL). The complete profiles are generally fairly steep

(between 1:7 and 1:19). The profiles to the north of the site generally have steeper slopes

(approximately between 1:7 and 1:8). The slopes flatten out southwards, averaging a slope of

1:19.

From the data compiled from the topographical surveys, the highest point of the frontal dune is

+16.6m MSL to the north of the site. To the south (north of Lynch Point), the housing

development is located at the toe of the frontal dune (between the +1.0m and +2.0m contour).

Leentjiesklip

The wetted beach has an average slope of 1:11 (between -1 m and +1.5 m to MSL). The profiles

to the north of the site generally have a steeper slope (approximately between 1:8.6 and 1:10).

The beach slope flattens out from the middle of the site towards the south, averaging a slope of

1:13.

From the data compiled from the topographical survey, the highest point of the frontal dune is

approximately +4.0m MSL to the south of the site while an average dune height of between

+4.0m MSL (in the north) to +3.0m MSL (to the south) is maintained. A low crest height

potentially makes a dune susceptible to wave overtopping (see Section 3.4).

During storms, the dunes in these areas may be eroded. This erosion is expected to be limited in

some areas due to either a high, steep frontal dune (Paradise Beach) or a well vegetated frontal

dune with a fairly steep beach front (Leentjiesklip).

The amounts of trampling and human induced erosion of the frontal dunes (that cause irregular

intervals of erosion) play a vital role in the rate of erosion caused by wave action during storm

events.

2.2.7 Sand Grain Sizes

Sand samples were collected during the site visits of 10 February 2010 from the wetted beach at

various locations along the site. Figure 9 indicates the locations at which the samples were taken

along both sites. The grain size distributions were determined by sieving.

Table 4 contains the results of the grain size analysis. These results show that the grain size

distribution along Paradise Beach is fairly consistent with a median grain size (D50) of 0.59 mm.

This is coarse sand according to the Wentworth scale. The grain size distribution along

Leentjiesklip is also consistent with a median grain size (D50) of 0.63 mm. This is also classified

as coarse sand according to the Wentworth scale.

208100E/11 6

Table 4: Sand grain size distributions determined through sieve analysis.

Paradise Beach D95 D90 D84 D75 D50 D25 D16 D10 D5 Mean Size (mm)

A1 1.21 1.08 0.99 0.80 0.49 0.29 0.27 0.24 0.19 0.58

A2 1.04 0.92 0.79 0.65 0.30 0.22 0.19 0.17 0.15 0.43

A3 1.30 1.15 1.08 0.99 0.74 0.54 0.42 0.32 0.28 0.75

Leentjiesklip D95 D90 D84 D75 D50 D25 D16 D10 D5 Mean Size

(mm)

B1 1.17 1.09 1.03 0.90 0.63 0.36 0.29 0.26 0.20 0.65

B2 1.15 1.07 1.00 0.83 0.58 0.37 0.30 0.28 0.25 0.62

B3 1.15 1.08 1.02 0.86 0.55 0.30 0.27 0.23 0.15 0.61

Di = grain size that exceeds i % by mass. For example, D25= 0.54 mm means that 25 % of the sand grains in the sample are finer than 0.54 mm.

2.3 ASSESS BOUNDARIES

The Spatial Development Framework (SDF) for Langebaan demarcates the Leentjiesklip site as

zoned for ‘resort’. A caravan park/holiday resort is located landward at the beach. A residential

area flanks the site to the north and an area zoned as ‘open space’ occurs to the south. This

‘open space’ is indicated to be ‘environmentally sensitive tourism and public facilities’ and an

area of ‘protected sensitive vegetation’.

At the Paradise Beach area the SDF shows residential zoning surrounded by area for public

open spaces. This residential zoning includes the current established development at Paradise

Beach along with a residential zoning to the north of the site. The sites under investigation does

not show any area demarcated for future development.

208100E/11 7

3 No development/coastal processes setback study

3.1 GENERAL OBSERVATIONS

Aerial photograph observations The aerial photographs were used to establish characteristics of the site. For example at Leentjiesklip:

• No development was established at the site until the 1980’s although it is evident that

some development was happening at the time of the 1977 photograph due to the

presence of what appears to be a quarry site north east of the site.

• The photograph of 1988 shows the establishment of Leentjiesklip Park and the quarry site

area is reduced.

• Between 1977 and 1988 construction began of the Langebaan golf course. The image of

2007 shows the golf course fully developed with greens and the accompanying estate

houses and property.

• Development extended northwards over Leentjiesklip 2 and beyond between 1989 and

2007.

• The number and direction of paths/roads between 1938 and 1977 had increased and then

decreased, becoming more established between 1977 and 1988. By 1988 and 1989 some

of the roads were tarred, in particular Camp Street heading out of Langebaan was tarred

up to Leentjiesklip 2. By 2007 the main roads were tarred and secondary roads surfaced.

While at Paradise Beach the following were observed:

• No development is evident in the photograph of 1938 however some paths are visible.

• By 1960 a farmhouse and associated buildings was built just south of the project site.

Most of the paths still exist although a new path had been established running northwards

along Paradise Beach turning eastward approximately 250 m from Lynch Point.

• The photograph of 1977 shows increased clearing of vegetation between the farmhouse

complex and the beach. Besides the reduced visibility of certain paths, probably due to

vegetation encroachment, the area had undergone little change.

• Construction of Club Mykonos pleasure craft harbour began in 1987. Substantial

development of this area is evident in the photos of 1988 and 1989. No other significant

developments had occurred. All paths/roads were still dirt.

• By 2002 the harbour had been completed, the accompanying resort had been completed

and development had increased to the north and east of Lynch Point. Roads along

Paradise Beach, approximately 50 m from the shore had been tarred and houses had

been built between the road and the sea.

• Vegetation around the project site remained largely unspoilt until in 2002 where sections

of the upper beach reach further inland with little to no vegetative cover.

208100E/11 8

3.2 EROSION SETBACK

3.2.1 Sea level rise

The surveyed beach profiles were used (as discussed in Section 2.2.6) in the sea level rise

assessments. As explained in the methodology (Section 5.2.2 of the Methodology Report), a sea

level rise of 1m was used.

Two methods were compared to establish the impact of sea level rise on the site:

1. The Bruun Rule

2. Average beach slope

Bruun Rule:

The Bruun formula (Bruun 1962) was used to investigate the effect of sea level rise. The Bruun

rule is schematically illustrated in Figure 10.

According to the Bruun formula the shoreline will retreat with 20m and 23m landward at Paradise

Beach and Leentjiesklip respectively.

Average Beach Slope

A setback distance due to sea level rise was calculated relative to the average beach slope at

selected cross sections assuming a sea level rise of 1m over 100 years.

Considering the beach profiles at the five locations (Figure 7 and Figure 8) and applying the

average beach slope together with a sea level rise of 1m over 100 years, an average setback

distance of between 6.0m and 12.0m for both the sites under investigation.

Although the Bruun formula is not a proven method for this particular case and the second

method used is considered an oversimplification of the situation, both methods will be considered

in evaluating a setback distance due to sea level rise.

3.2.2 Long Term Shoreline Trend Analysis

In order to determine the long-term shoreline trends, shoreline variations must be identified and

quantified.

The shoreline variation was analysed at 5 cross-sections (lines) along each site. Shoreline

variation along each line was quantified by measuring the distance, roughly perpendicular, from a

fixed landward reference line to the high-water mark in each aerial photograph. The locations of

the cross-sections analysed and the respective high-water mark are illustrated in Figure 11. If

these distances measured from the reference line are plotted against time, curves of the variation

of the location of the high water mark over time are obtained. A positive slope of the curve

indicates accretion because the beach becomes wider; that is, the distance increases relative to

the reference line over time. Similarly, a curve with a negative slope depicts erosion. If the

distances fluctuate around a mean value (a horizontal trend on average), it indicates that the

beach is dynamically stable.

From Figure 12, it can be seen that a clear erosion trend at Paradise Beach is present in the data

(negative

slope) while a fairly stable beach is indicated by a constant slope at Leentjiesklip (shown in

Figure 13). Thus, no long term erosion distance was allowed for Leentjiesklip. However, a long

term erosion distance was calculated for Paradise Beach.

208100E/11 9

In order to estimate a long term setback distance for Paradise Beach (a distance that should be

added to the normal variation), the variation of the high water mark should be looked at critically.

Figure 14 shows a graph of the variation of the shoreline over time for Paradise Beach.

From Figure 14 an erosion trend is clear up to the late 1970’s followed by some stabilisation until

around 1990 where another erosion trend is evident. Many scenarios could contribute to a

sudden erosion trend over a certain period of time where after stabilisation could follow (e.g.

major anthropogenic changes in the immediate vicinity).

A long term erosion distance (over 100 years) was calculated for each of the 5 profiles based on

the long term trends. Table 5 reflects the calculated distances that will contribute to the setback

distance.

Table 5: Horizontal setback distance allowed for the long term erosion trend at Paradise Beach.

Ref_5 Ref_4 Ref_3 Ref_2 Ref_1

Allowance for 100 years of Erosion

56 59 66 91 262

3.2.3 Short Term Shoreline Trend Analysis

Two methods were investigated in this instance:

1. Analysing historical photographs, removing the long term trend (if it exists) from the data

and statistically analysing the variation of the high water mark relative to the reference line.

2. Using numerical modelling to determine short term erosion induced by storms, tides, etc.

1) Statistical short term analysis:

Paradise Beach

After removing the long term erosion trend from the measured data (shown in Figure 15), the

following parameters (Table 6) were determined:



• Maximum difference: the difference between the minimum and maximum distances, that

is, the largest variation



• Short term erosion: the short term erosion distance measured landward from high water

mark

• 1 in 100 yr eriosion: erosion distance after 100 years, measured landward from high

water mark


• Setback allowed for sea-level rise: distance calculated by assuming 1m vertical sea-level

rise together with average beach slope

• Total setback distance: summation of Short term erosion, 1 in 100 year erosion and

Setback allowed for sea-level rise

208100E/11 10

Table 6: Shoreline variation and statistical analysis of the variation of the high water mark over

time (de-trended data).

Ref_Line_5

(m) Ref_Line_4

(m) Ref_Line_3

(m) Ref_Line_2

(m) Ref_Line_1

(m)

1938 175 177 180 192 332

1960 166 164 166 167 311

1977 168 160 163 165 305

1988 179 176 180 323

2007 174 169 174 185 326

No. of points 4 5 5 5 5

Minimum 166 160 163 165 305

Maximum 175 179 180 192 332

Mean 171 170 172 178 319

Maximum difference

9 19 17 27 27

Standard deviation

4 8 7 11 11

Short term erosion (m)

19 34 30 48 47

1 in 100 yr erosion (m)

86 81 80 65 41

Average beach slope )

0.190 0.249 0.126 0.152 0.283

Setback allowed for sea level rise (m)

5.28 4.01 7.91 6.57 3.53

Total setback distance (m)

110 120 118 120 92

Figure 15 depicts the de-trended shoreline variation over time for the Paradise Beach site. The

maximum difference between the positions of any high-water mark (along a cross-section) of 27

m is observed while the standard deviation along the beach varies between 4 m and 11 m.

Leentjiesklip

A normal distribution was also assumed for the Leentjiesklip study area as the beach is deemed

dynamically stable, for which only limited data are available. The following parameters (Table 7)

were determined:



• Maximum difference: the difference between the minimum and maximum distances, that

is, the largest variation



• Short term erosion: the short term erosion distance measured landward from high water

mark


• Setback allowed for sea-level rise: distance calculated by assuming 1m vertical sea-level

rise together with average beach slope

• Total setback distance: summation of Short term erosion and Setback allowed for sea-

level rise

208100E/11 11

Table 7: Shoreline variation and statistical analysis of the variation of the high water mark over

time.

Ref_Line_5 (m)

Ref_Line_4 (m)

Ref_Line_3 (m)

Ref_Line_2 (m)

Ref_Line_1 (m)

1960 333 254 236 246 269

1977 349 277 234 231 256

1988 347 275 238 235 253

1989 341 265 237 229 248

2007 343 260 235 233 237

No. of points 5 5 5 5 5

Minimum 333 254 234 229 237

Maximum 349 277 238 246 269

Mean 343 266 236 235 252

Maximum difference

16 22 4 17 32

Standard deviation

6 10 1 7 12

Short term erosion (m) 26 40 6 28 49

Average beach slope ) 0.1722 0.0823 0.1121 0.136 0.1428

Setback allowed for sea level rise (m) 5.81 12.15 8.92 7.35 7.00

Total setback distance (m) 32 53 15 35 56

Figure 16 depicts the shoreline variation over time for the site at Leentjiesklip. Figure 16, together

with Table 7, suggest a dynamically stable beach (i.e. having a horizontal trend on average).

Minimal differences in position of the high-water mark exist between consecutive photographs,

with a maximum difference between the positions of any high-water mark (along a cross-section)

of 32m. The standard deviation along the beach varies between 1 m and 12 m.

2) Numerical Modelling:

The approach outlined in Section 5.2.4 of the Methodology report was followed for computing

storm erosion using numerical modelling. The approach consists of wave transformation from

offshore to nearshore, numerical simulation of storm erosion and statistical analysis of the

shoreline retreat due to all storms to estimate the 1:100 year erosion.

Wave transformation and storm analysis

An analysis of waves at the project site required the transformation of offshore waves to a

nearshore location close to the project site. Thereafter, computed transformation coefficients

were applied to the entire selected offshore wave dataset (Wave Watch III) to derive the

nearshore wave conditions. These nearshore conditions were then analysed to determine storm

input for cross shore modelling.

This process is described in detail below.

208100E/11 12

Wave Transformation Model Description

The third-generation wave generation and refraction model SWAN (Simulating WAves

Nearshore) was applied (Booij, et al, 1999). SWAN was run within the DELFT3D-WAVE

environment (WL|Delft Hydraulics, 2008), which provides a convenient interface for pre- and

post-processing of the results.

The SWAN model is based on the discrete spectral action balance equation and is fully spectral

(in all directions and frequency), implying that short-crested random wave fields propagating

simultaneously from widely different sources can be accommodated, e.g. a swell with

superimposed wind sea.

Model setup and results Domain and bathymetry

Figure 17 illustrates the area represented in the model study. The entire domain extends 40 km

alongshore and with a maximum cross-shore distance of 21 km.

The model study consisted of a nested grid (3 grids) model setup: An outer model and two

nested, inner models. The outer model consisted of grid cells 200 m x 200 m in size throughout

the domain The location of the two nested models within the outer model has been outlined in

Figure 17. The model bathymetry (Figure 18), was created with data from South African Naval

Chart SAN SC2.

The x-y coordinate system used in the model was based on UTM 33S coordinate system. A

linear transformation was applied to provide model coordinates (xmodel, ymodel) that are positive

and increase from south to north and from west to east. The transformation used was:

xmodel = xUTM33S -700 000

ymodel = yUTM33S -6 000 000

Design wave climate

The dataset obtained from Wave Watch III (WWIII) covered a twelve year period (1997 to 2009).

In order to transform the WWIII offshore wave dataset to the equivalent nearshore dataset, a

matrix of offshore to nearshore wave combinations had to be created which had to be applied to

each individual offshore wave condition in the dataset. Therefore a set of schematic offshore

wave conditions was devised which encompassed a good representation all possible offshore

wave conditions which may occur. The schematic waves were run with unit wave heights of 2 m

resulting in a total of 175 conditions (see Table 8).

208100E/11 13

Table 8: Range of wave periods and directions used for schematic offshore input waves

Offshore schematic wave climate: Wave height = 2m

Peak period (Tp) bins Direction bins

4.17 145.00

6.67 160.00

7.69 175.00

8.33 190.00

9.09 205.00

10.00 220.00

10.53 235.00

11.77 250.00

12.50 265.00

13.30 280.00

14.30 295.00

16.67 310.00

22.22 325.00

The transformation process involved identifying those conditions within the schematic offshore

input waves which most closely resembled the WWIII offshore wave condition. Thereafter a

linear interpolation was conducted between the associated schematic nearshore output waves to

determine the nearshore wave condition likely to result from the WWIII offshore wave.

This resulted in 36679 nearshore wave conditions at 3-hourly intervals, at the locations marked

‘Wave extraction location’ in Figure 18.

Results

An example of nearshore wave patterns is illustrated in Figure 19. A relatively good

understanding of the local wave conditions, e.g. wave focussing, can easily be obtained just from

visual assessment of these plots. Greater wave heights at Paradise Beach indicate higher wave

action than at the Leentjiesklip site. Wave roses for the offshore and transformed nearshore

conditions are shown in Figure 20.

The resulting 36679 nearshore wave conditions, transformed from the offshore WWIII dataset,

were used to identify storm events. The time series of wave nearshore wave height were plotted

and evaluated visually to identify storms. The storms were chosen in such a way that the number

would be between one to three times the number of years within the time series (refer to CEM II-

8-5 (USACE, 2002)). A total of 31 storms were identified. Most of these storms occurred during

winter (May to August).

Cross-shore Transport Modelling

The cross-shore sediment transport model SBEACH was used to predict beach erosion and

consequent shoreline retreat due to the identified nearshore storms. The following section

describes the model, the model setup and the results.

Cross-shore Transport Model Description

208100E/11 14

The SBEACH cross-shore transport/morphological model (Larson and Kraus, 1989) was chosen

for predicting beach profile variations as a result of storm processes. In a comprehensive review,

Schoonees and Theron (1995) found that this is one of the best models currently available. The

theoretical basis is accepted and the model has been extensively verified (Schoonees and

Theron, 1995).

The SBEACH numerical model was developed to predict beach profile change resulting from

cross-shore sand transport, focusing on the main morphologic features of bars and berms. Many

of the assumptions and relationships used in developing the model are founded on

measurements made during physical model tests. Changes in the beach profile are assumed to

be produced by breaking waves; therefore, the cross-shore transport rate is determined from the

local wave, water-level, and beach profile properties, and the equation describing the

conservation of beach material is solved to compute profile change as a function of time. In

addition, it can simulate dune overwash.

Model setup

Essentially, the input data required for modelling the effects of storms are:

• The initial beach profile,

• Median sand grain size and

• Time series of the storm conditions including wave height, wave period, wave direction

and water-levels.

No pre- or post storm beach surveys could be obtained and therefore, default model parameters

were used. Note that the amount of erosion is very sensitive to these parameters as well as the

grain size and water levels. Calibration data is thus absolutely crucial in setting up the model.

Beach profile configuration

The pre-storm profiles incorporated for the assessment were obtained upon which to calibrate

the model by merging beach profile data from the surveys given by GEOSENSE (depths are to

Mean Sea Level) with SAN Chart bathymetric data. Two pre-storm beach profiles were created

by taking the average of the beach at Leentjiesklip and Paradise Beach.

The results of the sediment analysis (Section 2.2.7) indicated that the median grain size for

Paradise Beach was finer towards the south. The finer grain size was therefore used to ensure a

conservative approach. At Leentjiesklip the grain size was found to be coarser (around 500µm).

Storm configuration

The 31 storm events previously determined included the time series of wave height, period and

direction (relative to shore normal). The water-levels were determined by using the tidal

constituents for the Port of Saldanha given by Rosenthal and Grant (1989). Note that the

constituents given in the South Africa Admiralty tables can also be used.

Storm surge due to barometric pressure was determined by evaluating atmospheric pressure

data over the 12 year period covered by the WWIII data period. This data was obtained freely

from Weather Underground (www.wunderground.com). A seasonal variation in average pressure

was observed with an average of 1020 hPa during winter time. The average drop in pressure

during a storm event was typically 10 hPa which resulted in a temporary rise in water level of 0.1

m.

Wind setup was estimated by taking a typical wind speed which occurs during storm events

namely 15 m/s, with an estimated the fetch of 1000 km which resulted in a value of 0.2 m.

208100E/11 15

The values for the wind setup and barometric pressure effect were added to all water levels to

account for storm surge.

Results and discussion

An illustration of a typical output from the SBEACH model is shown in Figure 21. Recession of

the 0m, 1m and 2m contour lines were assessed to determine general erosion setback. An

extreme analysis of the results was carried out to determine the 1 in 100 year storm erosion.

The Leentjiesklip Beach profile were found to be dynamically stable, thus no erosion took place

during storm events. The 1 in 100 year storm erosion calculated for Paradise Beach was 14.2m.

3.3 SETBACK CONSIDERING WINDBLOWN SAND

The dominant winds in the greater Langebaan area cause wind-blown sand transport towards (i)

the sector north to north west; and (ii) to a lesser extent south to south east. This means that,

along the Leentjiesklip site, sand will mainly be blown up and down along the beach. At Paradise

Beach, some sand will be transported into the sea and into the frontal dune due to the orientation

of the beach.

The net aeolian sand transport direction will be towards the above-mentioned northern sector

(north to north west) because:

(1) The occurrence of south easterly to south westerly winds being higher (about 57 %) than for the

opposing winds (approximately 24 %); and

(2) During winter, when the north easterly to north westerly wind occurs, the sand on the beach will

be damp more often than in summer due to increased rainfall. The presence of moisture in the

sand has the effect of binding the surface sand and increases the wind velocity required to

initiate sand transport. Little of this wind-blown sand will reach the are behind the frontal dune

because it will be trapped by the frontal face of the dune and by the vegetation on the crest of the

dune.

The aeolian sand transport at both the sites (blowing with the dominant wind directions) will be

low because residential development surrounding the sites, together with vegetation covering the

frontal dune, limits the availability of sand to be transported. Figure 22 and Figure 23 shows the

distribution of potential aeolian transport. assuming no development has taken place, for

Paradise Beach and Leentjiesklip respectively.

No setback distance was allowed for windblown sand as it was found that windblown sand does

not pose a major problem at the site.

3.4 SETBACK FOR FLOODING

A time series of offshore waves was extracted from the Wave Watch III data. The time series

contains the significant wave height, wave direction and peak period at three hourly intervals.

There are various factors that affect the water level. These include tides, barometric pressure

effect, wind set-up and wave set-up.

The tidal levels corresponding to each data point in the wave time series were obtained from

predictions using tidal constituents (Rosenthal and Grant, 1989).

The daily minimum barometric pressures were obtained from Weather Underground

(www.wunderground.com). This value was subtracted from the average barometric pressure

208100E/11 16

(1020 hPa) and multiplied by 0.1 m to obtain sea level rise due to barometric pressure effects.

The average drop in pressure during a storm event was typically 10 hPa which resulted in a

temporary rise in water level of 0.1 m.

The wave run-up for each data point in the wave time series, using the corresponding water

level, was calculated. The run-up at Leentjiesklip and Paradise Beach were calculated using the

equation for sandy beaches by Nielsen and Hanslow (1991). At Lynch Point van der Meer’s

equation (Pullen et al, 2007) was used. A time series of wave run-up was obtained. This wave

run-up time series was analysed to determine the 1:100 year wave run-up. The 1:100 year wave

run-up elevations are:

• Paradise Beach (North): +4.5m MSL

• Leentjiesklip (North): +5.1m MSL

• Lynch Point: +8.5m MSL

Wave overtopping was not investigated since the run-up level is lower than that of the dune crest

level for all three cases.

Therefore, no setback allowance was made for flooding.

208100E/11 17

3.5 TOTAL COASTAL PROCESS/NO DEVELOPMENT SETBACK

From Section 7.5 of the Methodology Report setback for coastal processes are determined from

the maximum of the following:

• Setback for coastal erosion;

• Setback for windblown sand;

• Setback for flooding (wave runup, overtopping if applicable)

No setback was allowed for geotechnical or sediment issues (Section 3.3), flooding (Section 3.4),

heritage, bio-diversity or any other issues. Thus the total setback is determined by the setback

for coastal erosion.

A conservative estimate is given by the statistical analysis method determining the long term and

short term erosion variation when compared to the results from the numerical modelling. Thus,

the statistical results were used in the determination of the coordinates of the reported setback

line. The determined setback line includes the coastal erosion (long and short term) plus the

setback allowed for sea level rise.

The coordinates of the erosion setback line at the site at Paradise Beach and Leentjiesklip are

given in Table 9 and Table 10, while the locations of each are depicted in Figure 24 and Figure

25 respectively.

Table 9: Coordinates of the development setback line for the site at Paradise Beach (Coordinate

System: Lo19, WGS84)

Y (m) X (m)

-89869.05 -3657223.82

-89860.53 -3657265.33

-89851.62 -3657308.76

-89844.80 -3657341.98

-89834.96 -3657378.63

-89823.76 -3657420.29

-89809.80 -3657472.40

-89803.69 -3657520.35

-89797.10 -3657572.07

-89789.07 -3657635.24

-89800.53 -3657664.48

-89819.85 -3657713.82

-89847.51 -3657784.42

-89886.50 -3657817.50

-89892.81 -3657823.09

208100E/11 18

Table 10: Coordinates of the development setback line for the site at Leentjiesklip (Coordinate

System: Lo19, WGS84)

Y (m) X (m)

-89476.90 -3660157.93

-89468.68 -3660197.58

-89458.41 -3660247.54

-89467.75 -3660298.03

-89480.20 -3660365.30

-89493.23 -3660435.52

-89517.01 -3660518.13

-89541.05 -3660601.65

-89561.21 -3660655.74

-89584.45 -3660718.09

-89612.11 -3660792.28

It can be seen that the erosion setback line for Paradise beach is situated well behind the first

line of seafront properties and behind the crest of the frontal dune. The erosion setback line for

Leentjiesklip is situated some distance behind the crest of the frontal dune.

208100E/11 19

4 Limited/controlled development setback study

4.1 SETBACK FOR BIODIVERSITY

Using the steps outlined by Cape nature and SANBI, the Critical Biodiversity maps were used to

assess the biodiversity status of the area.

It was found that the Paradise Beach site and the Leentjiesklip site falls within a zone deemed as

‘No Natural Remaining Area’. No Natural Remaining Area data represent all the areas with no

remaining natural vegetation which have not been recognized as Critical Biodiversity Areas

(aquatic or terrestrial), Ecological Support Areas (critical and other) or National Protected Areas.

These areas are considered irreversibly transformed as rehabilitation would be unfeasible.

Therefore no setback allowance for Biodiversity is required

4.2 SETBACK FOR HERITAGE

Documents pertaining to archaeological and paleontological surveys conducted in the area were

investigated to determine if any sites of heritage importance exist which should be considered

during determining the setback line.

Particular reference is made to a survey conducted in the area by Parkington and Poggenpoel

(1987), cited all documents consulted, during which over 40 archaeological sites were

discovered. Later excavations were only conducted on a limited number of these sites.

ACO (1992), in response to a request to locate and evaluate archaeological sites in an area just

north of Lynch Point, provided a sketch of the locations of 5 sites of archaeological importance.

All sites, but 1, were not deemed worthy of excavation and subsequently no protection or

disturbance mitigation required during construction. One site was also considered not worthy of

excavation but the concern for what may lay below was raised. Unfortunately the relative

geographic location of the sites discussed in this report is not provided.

The report also makes mention of the possibility of finding human burial sites, but did not specify

where.

ACO (1997) conducted a survey of Leentjiesklip 2. Two sites were excavated and combinations

of middens, shellfish and animal bone artefacts were found. However, excavation was halted due

to the depths reached. The report recommended that development should continue in the hope

that further material be discovered during construction excavations.

Similarly, ACRM (2002) conducted an archaeological survey for the proposed Langebaan

Country Estate further inland, just east of the town of Langebaan. Remains discovered and

investigated were not considered to be important, although fossils and more remains may be

uncovered during construction excavations.

As the heritage sites of interest are generally seaward of the no-development setback line, no

need for a limited/controlled development setback for heritage was deemed necessary.

4.3 SETBACK FOR OTHER ISSUES

At the study site, not setback (landward of the no development/coastal process setback

established above) is deemed necessary for public access, aesthetic features, shading by

structures and/or significant landscapes (as discussed in the methodology report – WSP, 2010).

208100E/11 20

5 Public participation

In a formal setback line study, the above results would be published once comment has been

received and addressed where relevant by focus groups. This will not be done for this case study

as this study is mainly concerned with the testing of the proposed methodology.

208100E/11 21

6 Conclusions and recommendations The frontal dunes adjacent to the sites, act as a buffer against storm erosion due to wave and

tidal action. It is recommended that the crest height of frontal dune be maintained to their current

levels. Also, measures to increase stability of the frontal dunes can be implemented to aid

against storm erosion. Any disturbance of the vegetation or any other human activities on a dune

could destabilise the dune slope (which may cause slumping of the steep dune face) and may

also cause additional wind-blown sand problems.

The volume of sand in the dune must not be reduced and the dune itself must be fenced to

prevent people from trampling the vegetation and destabilising the frontal dune. Using the

provided wooden walkways should be enforced at access points and at regular intervals along

the shoreline. Maintenance of the dune and footpaths are required.

The Paradise Beach site is not dynamically stable and exhibits a long term erosion trend as

described in section 3.2.2 while the Leentjiesklip site is deemed to be dynamically stable.

Calibration data for the site does not exist as previous studies reporting storm induced erosion

values could not be sourced. Data from previous studies that could be used to calibrate the

numerical models would increase the confidence. These models would then be a more accurate

representation of the situation.

Development setback for biodiversity was considered and it was found that both the sites are

zoned for residential and/or commercial purposes. Both the sites are also considered to be

‘irreversibly transformed’ as rehabilitation would be unfeasible.

Previous studies conducted at the site and surrounds would obviously have been the departure

point for the current study as these reports would contain vital short term erosion data that can

be used for numerical model calibration purposes. Also, calculated shoreline trends and other

coastal process trends could be compared and reported on. This would, to a certain extent,

increase the accuracy of the report.

The following learning points have surfaced during the application of the methodology to this

case study:

• Adequate survey data: good quality topographical beach and bathymetry survey data is

essential to a setback line study, but this is not readily available from municipalities. Data

that was accessed was problematic in terms of vertical datum.

• Numerical modelling: correct setup, input and interpretation of the model output data

requires modelling experience.

• Numerical modelling: Calibration of models would be ideal, although results from

uncalibrated models (which employ model coefficients from experience of similar sites)

provide sensible results;

• Storm erosion modelling: Selection of storm conditions can be automated but with

considerable effort. This was conducted manually in this study;

• Storm erosion modelling: results from the statistical approach in the methodology had a high

correlation coefficient and provided plausible results;

• Water levels: a time series of measured water levels, including tides and surge, is required

for cross shore transport modelling

• Bruun Rule: the Bruun rule should be applied with caution. The input parameters and output

should never be used in isolation, since answers could be over conservative.

• Aerial photographs: the long term erosion trends determined form the historical aerial

photographs agreed reasonably well with those given in previous studies derived from

surveys, confirming the validity of employing aerial images in the methodology.

208100E/11 22

7 References ACO (1997) Phase 2: Archaeological excavations at Leentjiesklip 2, Langebaan. Prepared for

Lagebaan Waterfront (Pty) Ltd by Archaeology Contracts Office of the University of Cape Town.

ACRM (2002) Phase 1: Archaeological impact assessment. Proposed development Langebaan

Country estate, Langebaan, Cape west Coast. Prepared for Enviroafrica by the Agency for

Cultural Resource Management.

Parkington, J.E. & Poggenpoel C. (1987) An archaeological survey of the Lynch Point

Leentjiesklip area. Unpublished report submitted to Club Mykonos. University of Cape Town:

Archaeology Contracts Office.

CSIR (1990). Setback analysis for the Durban Bight and Glenashley Beach. CSIR Report EMA-

C 90147, Stellenbosch.

CSIR (2003). Shoreline stability and sedimentation in Saldanha Bay. CSIR Report ENV-S-C

2003-081, Stellenbosch.

J.A.G Cooper, O.H. Pilkey (2004), Sea-level rise and shoreline retreat: time to abandon the

Bruun Rule, Global and Planetary Change , Volume 43, Issues 3-4, November 2004, Pages 157-

171.

W.A. Birkemeier (1985), Field data on the seaward limit of profile change. American Society of

Civil Engineers, Journal of Waterway, Port, Coastal and Ocean Engineering, Vol. 111, No. 3,

May/June 1985, pp. 598-602.

Bruun, P (1962). Sealevel Rise as a cause of shore erosion. J Waterw Harbors

Bruun, P (1988). The Bruun rule of erosion by sea-level rise: a discussion on large-scale two-

and three-dimensional usages. Journal of Coastal Research, Vol. 4, No. 4, 627-648.

Charlottesville (Virginia), USA.

Rossouw, J (1989). Design waves for the South African coastline. Ph D. thesis, University of

Stellenbosch, Stellenbosch.

SAN (2009). Tide Tables. South African Navy, Tokai.

Schoonees, J S and Theron, A K (1993). Review of the field data base for longshore sediment

transport. Coastal Engineering 19: 1-25.

Schoonees, J S, Theron, A K and Bevis, D (2006). Shoreline accretion and sand transport at

groynes inside the Port of Richards Bay. Coastal Engineering 53: 1045-1058.

Solomon, S, Qin, D, Manning, M, Alley, R B, Berntsen, T, et al. (2007). Technical Summary. In:

Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the

Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S, Qin,

D, Manning, M, Chen, Z, Marquis, M, Averyt, K B, Tignor, M and Miller, H L (eds.)]. Cambridge

University Press, Cambridge, United Kingdom and New york, NY, USA.

Swart, D H (1986). Prediction of wind-driven transport rates. 20 Intern. Conf. on Coastal Eng.,

Taiwan. Vol.: 2: 1595 – 1611.

208100E/11 23

Theron, A K (2000). Recession line evaluations. CSIR Report ENV-S-I 2000-02, Stellenbosch.

USACE (1984). Shore Protection Manual. Volume I, 4th Edition. U.S. Army Coastal Engineering

Research Centre, Washington D.D.

U.S. Army Corps of Engineers. (2002). Coastal Engineering Manual. Engineer Manual 1110-2-

1100, U.S. Army Corps of Engineers, Washington, D.C..

Wiegel, R L (1964). Oceanographical engineering. Prentice-Hall, Inc. Englewood. Cliffs, Fluid

Mechanics Series. 532 pp.

P. Nielsen, D. Hanslow (1991). Wave runup distribution on natural beaches. Journal of Coastal

Research 7. 1139-1152. Florida

Pullen et al. (2007). EurOtop – Wave overtopping of sea defences and related structures:

Assessment manual. Hamburg: Kuratorium fuer Forschung im Kuesteningenieurwesen.

Rosenthal, G., Grant, S., 1989. Simplified tidal prediction for the South African coastline. South

African Journal of Science 85, 104-107.

Booij, N., Ris, R. C. and Holthuijsen, L. H. (1999), A third-generation wave model for coastal

regions, Part I: Model description and validation, J. Geophys. Res. Vol. 104, C4, pp.7649-7666.

Larson, M., and Kraus, N. C. (1989). “SBEACH: Numerical model for simulating storm-induced

beach change; Report 1, Empirical foundation and model development,” Technical Report

CERC-89-9, U.S. Army Engineer Waterways Experiment Station, Coastal Engineering Research

Center, Vicksburg, MS.

SCHOONEES, J.S. & THERON, A.K., 1995. Evaluation of 10 cross-shore sediment

transport/morphological models. Coastal Engineering, 25, 1-41.

Dept. of Environment Affairs and SSA Engineers and Environmental Consultants (2009). A

user-friendly guide to the Integrated Coastal Management Act of South Africa.

Figure 1: Location of the sites and extent of the study areas (in red) for each site.

Figure 2: Contour map of the Paradise Beach site.

Figure 3: Wooden revetment at Paradise Beach

Figure 4: Contour map of the Leentjiesklip site.

Paradise Beach beach profile

0

2

4

6

8

10

12

14

16

18

0 20 40 60 80 100 120 140

Cross Section (m)

He

igh

t a

bo

ve

MS

L (

m)

Profile5_N

Profile4_N

Profile3_N

Profile2_N

Profile1_N

Figure 5: Cross sections of beach profiles taken at six locations along the site of Paradise Beach.

Leentjiesklip beach profiles

0

2

4

6

8

10

12

14

16

18

0 50 100 150 200

Cross Section (m)

He

igh

t a

bo

ve

MS

L (

m)

Profile5_S

Profile4_S

Profile3_S

Profile2_S

Profile1_S

Figure 6: Cross sections of beach profiles taken at six locations along the site of Leentjiesklip.

Figure 7: Red lines indicate where beach profiles were surveyed along Paradise Beach with Profile 1

in the south and Profile 5 in the north of the site.

Figure 8: Red lines indicate where beach profiles were surveyed along Leentjiesklip with Profile 1 in

the south and Profile 5 in the north of the site.

Figure 9: Red lines indicate positions on the beach where sand samples were taken for sieve analysis along A) Paradise Beach and B) Leentjiesklip.

Figure 10: Graphical illustration of the Bruun rule.

Figure 11: The distance to the high water mark measured relative to a fixed point (‘Reference line’) along five cross sections (‘Profile Line’). The high

water line determined from each historical photograph is also shown.

Figure 12: General trend of the variation in the high water mark over time for Paradise Beach

Figure 13: General trend of the variation in the high water mark over time for Leentjiesklip.

0

50

100

150

200

250

300

350

400

1920 1940 1960 1980 2000 2020

Dis

tan

ce f

rom

refe

ren

ce l

ine (

m)

Year


Ref_Line_5

Ref_Line_4

Ref_Line_3

Ref_Line_2

Ref_Line_1

200

220

240

260

280

300

320

340

360

1950 1960 1970 1980 1990 2000 2010

Dis

tan

ce f

rom

refe

ren

ce l

ine (

m)

Year


Ref_Line_5

Ref_Line_4

Ref_Line_3

Ref_Line_2

Ref_Line_1


100

120

140

160

180

200

220

240

1930 1940 1950 1960 1970 1980 1990 2000 2010 2020

Year

Dis

tan

ce

fro

m r

efe

ren

ce lin

e (m

)Ref_Line_5

Ref_Line_4

Ref_Line_3

Ref_Line_2

Ref_Line_1

Figure 14: Variation in the high water mark over time for Paradise Beach.


100

120

140

160

180

200

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Figure 15: Variation in high water mark over time for Paradise Beach after the long term erosion

trend has been removed.

Figure 16: Variation in high water mark over time for Leentjiesklip.

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Figure 17: Model domain indicating outer and inner model grids.

Figure 18: Bathymetry and location of nearshore wave extraction points.

Figure 19: Wave refraction patterns computed through SWAN modelling.

Figure 20: Wave roses of (top) offshore wave data (WAVE WATCH III) and nearshore conditions for(bottom left) Leentjiesklip and (bottom right) Paradise Beach.

Figure 21: Initial and final storm profiles for Paradise Beach.

Figure 22: Potential aeolian sand transport rose for Paradise Beach in Langebaan.

Figure 23: Potential aeolian sand transport rose for Leentjiesklip in Langebaan.

Figure 24: Development setback line for Paradise Beach

Figure 25: Development setback line for Leentjiesklip.


Appendix G: Stakeholder Engagement Report (PPP)

91212D

Draft PPP Report - WC Setback Lines

STAKEHOLDER ENGAGEMENT

FINAL REPORT

Western Cape Coastal Setback Line

Methodology

WSP Group Africa:

May 2010

STAKEHOLDER ENGAGEMENT

REPORT:

Western Cape Coastal Setback Line

Methodology

Group Africa: Coastal

QM



Remarks Draft Draft Final Final

Date March 2010 May 2010 May 2010

Prepared by Danielle Michel Danielle Michel Danielle Michel

Signature

Checked by Hilary

Konigkramer

Hilary

Konigkramer

Hilary

Konigkramer

Signature

Authorised by Danielle Michel Danielle Michel Danielle Michel

Signature

Project number 91212D

File reference ES /91212D_2010-05-20

Contents

1 Introduction 3

1.1 Legal context 3

1.2 Approach 3

2 Stakeholder Engagement: Methodology Development 5

2.1 introduction 5

2.2 Phased Stakeholder Engagement 5

3 Stakeholder Engagement: Implementation Phase 13

3.1 Introduction 13

3.2 Phase 1: Processs initiation 13

3.3 Phase 2: Focus Group Meetings 14

3.4 Phase 3: Circulation of Draft report and Public Meeting 14

3.5 Phase 4: Stakeholder Feedback 15

4 Conclusion 15

References 15

Table 1 Advertisement Publications 5

Table 2 Focus Groups 6

Table 3 Summary of key issues raised in focus group meetings 7

Table 4 Summary of key issues raised in general focus group meetings 9

Table 5 Summary of key issues raised in response to the draft report 11

Appendix A Advertisements 16

Appendix B Registered Stakeholder List 20

Appendix C Background Information Document 23

Appendix D Stakeholder Groups 28

Appendix E Notes from Focus Groups 30

Appendix F Issues & response Table - General I&APs 37

Appendix G Authorities & Steering Committee Comments on Draft Report 47

Appendix H Issues & Response Table – Draft Report 72

91212D Western Cape Coastal Setback Lines – stakeholder Engagement Report 3

1 Introduction

The stakeholder engagement process required to undertake activities under the National Environmental

Management: Integrated Coastal Management Act (24 of 2008) (ICMA) require engagement of interested and

affected parties, and the provision of the opportunity for these stakeholders to provide representations on the

process.

This report outlines the process that was followed in order to develop a comprehensive stakeholder engagement

process for the development of coastal setback lines. Section 2 details the process followed in the development

and testing of the methodology. Section 3 provides the proposed stakeholder engagement methodology for the

implementation coastal setback line methodology.

1.1 LEGAL CONTEXT

The ICMA requires that interested and affected parties are given an opportunity to make representations with

regard to the development of a coastal setback line. This basic stakeholder engagement approach provides for:

In addition, the responsible practitioner must ensure that the principles of co-operative governance are followed.

In terms of Chapter 3 (section 41) of the South African Constitution, these principles require that all spheres of

government, and all organs of state within each sphere, must co-operate with one another in mutual trust and

good faith. ICMA reiterates this notion in terms of the National Environmental Management Act (107 of 1998)

(NEMA), which states that:

2(4)(l) - There must be intergovernmental co-ordination and harmonisation of policies, legislation and actions

relating to the environment.

In addition, transparency is highlighted as a key principle of NEMA. Section 2 (4) (k) states that:-

“Decisions must be taken in an open and transparent manner, and access to information must be provided

in accordance with the law.”

Co-operative governance and transparency are key aspects of stakeholder engagement which should be carried throughout the process.

1.2 APPROACH

ICMA specifies the minimum requirements for stakeholder engagement. Given that nature and scope of the

project, it was determined that a more consultative approach should be adopted in order to develop a integrated

and comprehensive methodology. WSP adopted a phased approach to stakeholder engagement (Section 2 and

3).

Section 53 (1):

(a) Consultation with all Ministers, the MECs or local municipalities whose area of responsibilities will

be affected by the exercising the powers (within ICMA) in accordance with the principles of co-

operative governance as set out in Chapter 3 of the Constitution

(b) Publishing or broadcasting the intention to do so in a manner that is reasonable likely to bring it to

the attention of the public; and

(c) By notice in the Government Gazette: -

(i.) Invite members of the public to submit, within no less than 30 days of such notice, written

representations or objections to the proposed exercise of power; and

(ii.) Contain sufficient information to enable members of the public to submit representations or

objections

91212D Western Cape Coastal Setback Lines

1.2.1 Aims and Objectives

The aim of the stakeholder engagement process for the development of the coastal setback line methodology

twofold:

a) Design and testing of the methodology

The objective of stakeholder engagement for the development of the methodology phase

was to disseminate information and involve stakeholders by:

� Consulting with specialists, authorities, and key coastal and environmental organis

Western Cape and other provinces (including KwaZulu

� Ensuring that directly and indirectly affected stakeholders are informed of the project;

� Providing all stakeholders with an opportunity to rec

� Promoting support and sustainability during the

b) Review and finalisation of methodology for implementation

The objective was to refine and finalise the methodology for stakeholder engagement

phase to ensure that legal requirements and best practice

The final outcome was to provide a set

Section 3 of this report.

1.2.2 Phased Approach

The approach developed for stakeholder engagement

summarised as in Figure 1 below.

Figure 1 Summary of stakeholder engagement

•Client Steering Committee

•Authority Consultation

•Advertising

•Development of Stakeholder Database

Phase 1: Process Initiation

•Key stakeholder groups

Phase 2: Focus Group Meetings

•Public Meeting

•Comment on Draft Report

Phase 3: Public Stakeholder Engagement

•Final Report distribution

Phase 4: Stakeholder Feedback

Western Cape Coastal Setback Lines – stakeholder Engagement Report

The aim of the stakeholder engagement process for the development of the coastal setback line methodology

the methodology

The objective of stakeholder engagement for the development of the methodology phase

was to disseminate information and involve stakeholders by:

Consulting with specialists, authorities, and key coastal and environmental organis

Western Cape and other provinces (including KwaZulu-Natal, Northern Cape, and Eastern Cape);

Ensuring that directly and indirectly affected stakeholders are informed of the project;

Providing all stakeholders with an opportunity to receive information regarding the project; and

nd sustainability during the implementation stage.

Review and finalisation of methodology for implementation

was to refine and finalise the methodology for stakeholder engagement

to ensure that legal requirements and best practice are met.

The final outcome was to provide a set of guidelines for the stakeholder engagement process are detailed within

proach developed for stakeholder engagement in the development of coastal setback lines, can be

summarised as in Figure 1 below.

Summary of stakeholder engagement process

Client Steering Committee

Development of Stakeholder Database

Phase 1: Process Initiation

Phase 2: Focus Group Meetings

Comment on Draft Report

Phase 3: Public Stakeholder Engagement

Phase 4: Stakeholder Feedback

stakeholder Engagement Report 4

The aim of the stakeholder engagement process for the development of the coastal setback line methodology is

The objective of stakeholder engagement for the development of the methodology phase (section 2 of this report)

Consulting with specialists, authorities, and key coastal and environmental organisations within the

Natal, Northern Cape, and Eastern Cape);

Ensuring that directly and indirectly affected stakeholders are informed of the project;

eive information regarding the project; and

was to refine and finalise the methodology for stakeholder engagement during the implementation

nt process are detailed within

development of coastal setback lines, can be


2 Stakeholder Engagement: Methodology Development

This section outlines the methodology used, and issues raised during, the development of a methodology for

coastal setback lines within the Western Cape. This included engaging with authorities, organisations and local

stakeholders within the two study area, namely Cape Town and Saldanha Bay.

2.1 INTRODUCTION

Stakeholder engagement has formed an important component of the development of the Western Cape Coastal

Setback Line Methodology. Stakeholder consultation has provided the opportunity to communicate the

objectives of the methodology development to key stakeholders, and in turn allow stakeholders to provide

valuable input on options and critical issues to be addressed.

The approach was one of broad stakeholder participation on a provincial level, coupled with focused sector

based consultations. The project has been well received by stakeholders overall response has been positive.

Key elements of the stakeholder consultation process are summarised below.

2.2 PHASED STAKEHOLDER ENGAGEMENT

2.2.1 Phase 1: Initiation

a) Notification and Advertisements

In order to initiate the stakeholder engagement process, WSP advertised the project in several local and

provincial newspapers (Table 1). This was determined to be the most efficient means of communicating the

commencement of the project with the general public. The advert provided a brief outline of the project, the legal

context, and invited members of the public to register with WSP (Appendix A).

Table 1 Advertisement Publications

Newspaper Date of Publication Language

The Cape Argus 22 January 2010 English

Die Burger 22 January 2010 Afrikaans

The Cape Times 22 January 2010 English

Die Weslander 22 January 2010 English & Afrikaans

b) Stakeholder Database

The development and ongoing maintenance of a comprehensive stakeholder database provided the foundation

for the stakeholder engagement process. Following initiation of the project, the primary objective was to

establish a database which was inclusive of all relevant government departments, as well as non-governmental

organisation, community based organisations and other interested and affected parties (I&APs). A list of

registered I&APs for the development of the coastal setback line methodology is included in Appendix B.

The database was continually updated to accommodate new stakeholders as the project progressed. The

stakeholder database provided the means for the distribution of information and continued communications

(including registrations, invitation, and minutes of meetings).

c) Background Information Document

WSP prepared a Background Information Document (BID) which was distributed to all identified authorities, key

stakeholders and registered I&APs (Appendix C). This document constituted the first phase of stakeholder

engagement, which was to provide registered I&APs with project information. The BID was therefore prepared for


information purposes only, however a comment form was included to allow I&APs to register additional persons

or organisations and submit comments at a later stage in the process.

2.2.2 Phase 2: Focus group meetings

The second phase included focus group meetings with local and provincial authorities and key stakeholders, and

a public meeting within each case study area. All issues and aspects raised at these meetings, and via written

communication, with regard to the methodology, will be incorporated into the final report, to be submitted to the

DEA&DP.

It was determined, through the initiation phase of the process, that sector based focus group meetings should be

held in order to obtain input form authorities and specialists in the field.

a) Focus Groups

Four key groups were identified and individual focus groups meetings were held during January and February

2010 (Table 2). Focus group lists of the below meetings are included in Appendix D. A detailed summary of the

key issues raised are included into Appendix E.

Table 2 Focus Groups

Group Description Meeting date

Steering

committee

The Steering Committee (Appendix D), comprising of representatives from a number of authorities, organisations specialists related to coastal, environmental and setback line development, were consulted throughout the methodology development. The committee included representatives from:

� DEA&DP (Integrated Environmental Management, Spatial Planning, and Coastal Management units);

� CapeNature

� City of Cape Town;

� Saldanha Bay Municipality;

� eThekwini Municipality (Durban);

� Northern Cape Department of Agriculture, Land Reform, Conservation and Environment;

� Eastern Cape Department of Economic Development and Environmental Affairs;

� KwaZulu-Natal Department of Agriculture, Environmental Affairs and Rural Development; and

� Council for Scientific and Industrial Research (CSIR).

Ongoing on a monthly basis, starting December 2009 to May 2010

Authorities

The second focus group, with authorities, provided additional strategic input into the process, and included representatives from:

� Department of Water Affairs,

� Department of Agriculture,

� South African National Parks,

� South African National Biodiversity Institute, In addition, the Environmental Evaluation Unit (University of Cape Town) were invited, although were not able to attend.

5th February 2010

Local

Municipalities

The DEA&DP identified key areas within the municipalities of Cape Town and Saldanha Bay as the pilot study areas to determine the functionality of the setback line methodology. Therefore each of these municipalities was engaged in order to obtain the local level input. The Cape Town Municipality was consulted early on in the process, as they had completed extensive work on coastal protection zones within this region.

Saldanha Bay Municipality - 4th February 2010 City of Cape Town – 5

th February 2010

Heritage

Organisations

The South African Heritage Resource Agency (SAHRA) and Western Heritage Cape were consulted on the cultural and heritage aspects of the coastline.

24th February 2010


b) Summary of Key Issues:

Table 3 Summary of key issues raised in focus group meetings

Aspect Description of issues raised

1. Funding � Implementation of setback lines at a local level

� Need funding if the expertise are not available in-house at local municipal level

2. Timeframes for setback lines

� The 1:20 and 1:50 year lines should be considered

� Consider implications of the 1:50 year line for setbacks in the long term

� Need to restrict development within these lines

3. Roles, responsibilities & management

� Identify different levels of development management within setbacks – i.e. no development vs recreation vs urban development.

� Local spatial planning

- Interaction of setbacks and municipal town planning scheme

- Ultimately the setbacks need to interact with the local and regional land use management objectives

4. Data

� Access to data may be limited – e.g. Saldanha Port

� Data needs to be as accurate as possible, especially existing information and mapping

� There should be two options for data collection:

1) Costly but rapid (e.g. Lidar surveys); and

2) Inexpensive but time-consuming (e.g. Stereoscope surveys)

� Local Spatial Development Frameworks (SDF) should be use to provide planning and other data for implementation of setback lines at a local level

� Long term shoreline trends need to considered when determining setback lines

� Available data:

- Cape Nature maps for conservation and ecological information

- Spatial biodiversity plan by SANBI (Biosphere management)

- Data on marine biodiversity is not readily available

� Scale of available data:

- Need to ensure that SDFs and setback lines can be used together, and so need to be at the same scale.

- Biodiversity maps may not include small patches of vegetation that may be crucial to conservation or habitat protection

� Revision timeframes of methodology

- Should be done in line with the Spatial Development Framework (SDF)

� Inclusion of dynamic coastal environments

- Include issues of human impacts on natural processes

- Include management of coastal areas

� Consider river flood lines in context of climate change

� Coastal processes

- Ensure the beach profile is maintained.

- Wind direction is another crucial aspect

- Barometric pressure also an important aspect

� Social aspects

- Socio-political aspects/objectives also need to be included

- Include intangible issues, such as sense of place

- Socio-economic development priorities will be determined through the focus group discussions when determining setback


5. Enforcement � Local and provincial government enforcement

� Enhancement of Coastal Protection Zones protection through implementation of setback lines

� Enforcement of setback lines could potentially vary according to the management of land within the line.

� It has been suggested that the setback line could be revised on a five or ten year cycle (in line with the SDF). This could affect the enforcement of the line if it is not defined or constant.

6. Prioritising for Implementation of setbacks

� Properties under pressure/threat of development

� System to prioritise vulnerable areas is required

� Need to prioritise undeveloped/rural areas:

- Where there are no coastal setback lines to protect the coast,

- Where there is threat of development, and under new rights.

- Especially farms on the west coast, where there are few boundaries, little management or protection.

7. Biodiversity management

� Control development in the high biodiversity areas by the EIA process, rather than only the setbacks

� Cape Town City’s biodiversity network (based on biodiversity targets, not management objectives) could feed into the process.

8. Heritage: � Different levels of significance or priority needs to be allocated according to heritage status or heritage potential of an area.

� An area of 200m from the shoreline should be included into the setbacks to allow for marine/coastal heritage protection

� Aesthetics needs to be considered

� Coastal heritage includes:

- Buildings over 60 years old, burials, shell middens, wrecks, fish traps, cultural landscapes, lighthouses,

- Most likely at the shoreline, tapering off landward

� Nodal development is preferred, rather than strip development, to protect coastal heritage

� Data availability and collection:

- Maps with identified heritage sites can be provided by SAHRA/ Heritage Western Cape

- Heritage assessments and surveys should not be limited to individual sites but rather include neighbouring sites to determine the extent of potential heritage resources.

9. Current legislation & management of coastal areas

� Coastal setbacks need to take the NEMA trigger of 100m (developed) and 1000m (undeveloped) (from high water mark) lines into consideration.

� Implications for EIAs and provincial decision making regarding approval for applications within the setback lines

10. Consultation process

� National process - therefore consult with as many people as possible

� Setback lines should not go to the public for review during the development phase, as it is always going to be split between developers and local conservation/community groups.

� If setback lines must be legally defensible, they must be scientific processes and not determined by the public.

� Before presenting to public the line should be determined, by scientific means, so that it is defendable.

� A robust methodology (and PPP in this methodology development phase) will back up the implementation, and therefore make the implementation more robust.

11. Methodology

� To be a working document

� Capture all issues, describe how they were resolved, to ensure accurate record and to avoid duplication.


12. Private Development Rights within the setback lines

� What private rights do people have?

� Will these properties be appropriated?

� It has been suggested that there be two lines: 1) erosion setback and 2) development setback line

� Would like to see a broad ban within the erosion setback line to limited recreational development

� Setback line should mange development within coastal areas in general

2.2.3 Phase 3: General stakeholder meetings

General stakeholder meetings were held within the Saldanha Bay and the Cape Town areas (one per area). All

registered I&APs were invited to attend these meetings, and to submit written comments to allow their concerns

to be recorded and addressed.

The objective of the general stakeholder meetings was to present the draft methodology to the public and

received feedback on its development. A summary of the issues raised by the stakeholders (Appendix E) are

outlined in Table 4 below:

Table 4 Summary of key issues raised in general focus group meetings


1. Case study areas

� Need to consider sites conjunction with each other and surrounding environment

� Two sites will not define all scenarios

2. Data

� Existing data:

- Amount of data available

- Most current

- Accuracy (E.g. erosion: - Impact of current erosion trend on data and setbacks)

- Need to monitor beaches and the sedimentation of the bay (Saldanha - long-term)

- Consider the impact of development on coastal processes (e.g. Saldanha port dredging and Saldanha study sites)

� Technology:

- Use of current advanced technology to gather data

- There are low tech/cost solutions for data collection

� Biodiversity:

- Need to ensure the marine biodiversity aspects are included.

- SANBI maps prioritised on the land based habitats/vegetation, not marine

3. Time frames � Implementation of setbacks:

- Two years is too short.

- There is inconsistency between different ‘regimes’ within the local municipalities. E.g. the next council might not agree with the previous

� Setbacks:

- The time frames given (1:50 year) are very short and human scale (i.e. within the current generation, and not thinking of future processes).

- Consider 100 year and 1000 year events (conservative approach), especially as these may occur more frequently with climate change

4. Management of areas in setbacks

� Large setbacks are unmanageable (e.g. community can’t manage them and this affects the environment)

� Make setback areas conservation areas, with public access


� What happens to existing properties that will fall within the setbacks and owners rights

� Need to consider how to manage overlap between local by laws and district municipal jurisdiction.

� Consider difference between a general setback lines and more specific to each area of the coast

� Management outcomes need to include actions, e.g. build up beaches where they have eroded

� Local municipal obligations:

- Consider the level of power given to the municipalities to control development

� Interaction with Cape Town City’s coastal protection zone (CPZ)

� Development Approval:

- Will DEA&DP approve development or wait until setbacks are prescribed?

� Need to ensure the objectives of different departments are aligned (e.g. Tourism & Environment)

5. Prioritising of areas in setbacks

� Prioritising

- Should be able to apply to prioritise a specific area

- There needs to be a mechanism for setting of priority areas.

- This could be considered in conjunction with local interest/community groups in terms of which areas need to be looked at.

� Rural areas need larger setback

� Public access needs to be considered

� Sensitive areas:

- Setbacks need to stop development in environmentally sensitive areas

6. Local Community consultation

� Some areas have has a strong environmental communities which need to be consulted (e.g. Macassar).

� The development of coastal setback lines is a scientific process, which should not be altered by preferences of local communities or stakeholders.

� Need to include local community forums in the process, to get the local perspective.

In addition to the capturing of comments arising at stakeholder meetings, stakeholders were encouraged to

submit written comments throughout the process. A number of written comments were received and have been

responded to accordingly (Appendix F). All comments submitted were given due consideration in the

development of the methodology documentation

2.2.4 Phase 4: Comment on draft report

The final phase entailed the distribution of the Draft Report for the “Development of a Methodology for Defining

and Adopting Coastal Development Setback Lines” to stakeholders. This report summarised the process and

outcomes of the methodology development. All I&APs were invited to comment on the draft report. Comments

were received from authorities and general stakeholders (Appendix G) as summarised in Table 5.


Table 5 Summary of key issues raised in response to the draft report


1. Methodology Time period for lines - Need to include more than one line/period - Use precautionary approach, i.e. a shorter period and

reevaluate regularity - Consider the sensitivity of different types of structures and

development - Consider the needs of the local community - Must consider extreme flooding events

Revision time frames - Revision time frames for setback lines should take into

consideration local change and global climate change

Local context - Setbacks must be relative to the local context consideration

of current land uses - Consider the impact of the establishment of setback lines

impact on existing development along the coast - Include local unforeseen change Include local unforeseen

changes in revision process

Coastal public property - Need to integrate coastal public property effectively into the

setbacks

Engage with local municipalities - Inclusion of local SDF & EMFs

Coastal Aquifers - Protection of coastal aquifers should be included

Cost & lack of local capacity - There is a lack of local financial & capacity resources to

implement coastal setback lines - There are substantial cost implications of developing setback

lines for local municipalities - Local municipalities must be consulted if private developers

are developing setback line studies - Recommend a skeleton framework of essential elements to

determine setbacks for under-resourced municipalities - The Methodology should not be constrained by costs and

Allow for natural process Ensure setbacks allow for natural process to continue where possible Global case studies - Need to include global case studies of past events to inform the study - Include a comparison between international best practice Existing Land use - Development pressure, economic development and human needs - Development must not affect the correct location of setback lines - Identify and exclude areas that don’t require setback lines – e.g. coastal conservation

areas - Ensure setbacks facilitate strategic infrastructure development Authorities mandated for set setback lines - Government departments (central and provincial) and Municipalities should be

mandated with the task of determining setbacks, not MECs and Ministers

Unnecessary EIAs - Setbacks must ensure unnecessary EIAs are prevented\ Methodology - must be robust - must be flexible and state outline challenges faced during the methodology

development to be open for revision - Methodology must be specific to allow it to be consistent in application of best

practice. - must be clear, and step-by-step process, which can be duplicated and revised over

time

Response options - Response options must be included into the development of the methodology

Bruun Rule - Include describe the Bruun Rule and other formulae

Data requirements - Include PPP and socio-economic data Include PPP and socio-economic data as

integral part of methodology - biodiversity Include biodiversity in setback to maintain ecological integrity - Include of heritage aspects


timeframes in data collection - Local municipal, provincial, national authorities and state

departments should work together and share costs

Complexity of the system and linkages - between different aspects that determine setbacks

Stakeholder engagement - Address uncertainty in setback development through broad

local stakeholder engagement before finalizing the setback lines

Types of setbacks - Different types should be considered, e.g. erosion, aesthetic - Need to include Mining & biodiversity - Include no-go/Limited development

-

- Include mining activities - Remotely sensed data will probably be available at a good accuracy shortly - If using the vegetation line instead of the HWM, a conservative approach should be

taken - Site assessment and local knowledge may be better to use for estimating the quantity

of wind-blown sand

Legal - Need for inclusion of expertise in terms of legal requirements

Overtopping Manual - should be provided as part of the setback methodology.

Maintain defences – Ensure natural beach defences are kept

Align standards - between different planning and decision-making documents (e.g. 1:100 year flooding).

Include estuarine flooding - as part of setbacks

Wave run-up procedure - Wave run-up procedure should include the increase in water level due to sea level rise.

2. Methodology Report

- Very technical terminology - Need clarity of guidelines to be adopted

- Integrate all four reports, include case studies & PPP as part of methodology report

Inclusion of erosion in formulas

- Including of erosion in formulas for calculating wave-run-up models

Biodiversity maps

- Biodiversity maps must be up to date, and sourced from more than one source

Methodology detail

- Additional detail needs to be included on how to determine setbacks and deal with issues, such as access points

Grain size analysis - More detail is needed for grain size analysis. This should be taken over period of time, not once off samples.

3. Case studies Reports

- Lack of cadastral/property boundary information - Check Highest astronomical tides - Update definition of setback line

4. Public Participation Report

- Include responses to all comments - PPP should not determine, but inform the setbacks - Include a public meeting into the PPP methodology


3 Stakeholder Engagement: Implementation Phase

3.1 INTRODUCTION

The stakeholder engagement component of the methodology provides an opportunity to communicate the

process and objectives of developing coastal setback lines to a wide range of stakeholders. This process will

allow individuals, groups and organisations to provide valuable input into the available options and critical issues

to be addressed at each stage of the process.

A phased approach is presented below as the method to ensure the legal requirements and best practice for

stakeholder engagement are met.

3.2 PHASE 1: PROCESSS INITIATION

Given that the development of coastal setback lines is likely to affect large areas of the coastline, and a wide

range of stakeholders, it is recommended that a comprehensive engagement process is undertaken. This

approach is begins with the process initiation phase.

a) Client Steering Committee

A client steering committee comprising the proponent of the project, key local coastal, environmental and

planning authorities, as well as other elected or identified key stakeholders, must be established at the outset of

the project. This committee will provide high level stakeholder input and strategic guidance for the development

of the setback line. The committee should be engaged throughout the project and the establishment and

implementation of the setback line.

The development and implementation of coastal setback lines must be integrated with the institutional

arrangements outlined in the ICMA. These include national, provincial and municipal Coastal Committees, These

committees, their representatives and associated organisations need to be considered as part of the stakeholder

engagement process and made use of as representatives of the key coastal stakeholders within the study area.

These Coastal Committees, however, have not been regulated, and therefore may not be established in time for

the implementation this methodology. If this is true, then relevant individuals and representatives must be

considered and included where possible on the steering committee.

b) Authority Consultation

All relevant authorities and government department are to be notified of the process and representatives

registered as stakeholders for the duration of the process. This must include all spheres of government relevant

to the study area, including provincial government departments and agencies, local municipalities and non-

governmental organisations. Government departments include provincial, district and local departments of:

� Environmental

� Tourism

� Water Affairs

� Agriculture, Forestry & Fisheries

� Heritage

� Planning and development

� Coastal engineering

� Minerals & Energy (where appropriate)

� Trade & Industry (where appropriate)

� Transport (where appropriate)

c) Advertising

Authorities and the general public must be notified of the initiation of the stakeholder engagement process by

means of the publishing of 1) a public advertisement and 2) notice in the relevant Government Gazette.


Advertisements must be published in at least one regional, local and/or community publications relevant to the

area. This advertisement must include:

� A notice of the intention to develop a coastal setback line for a specific area or region;

� A description of the study area boundaries;

� The key aspects to be considered in the study; and

� An invitation for stakeholders to register as an Interested and Affected Party (I&AP).

The notice in the Government Gazette should be carried out by the competent provincial environmental authority

prior or in parallel to the public advertisement of the process (providing a minimum of 30 days for registration of

I&APs). The notice in the Government Gazette must provide sufficient information potential I&APs to submit

representations or objections to the proposed project.

Both the notice in the Gazette and advertisement should be published in at least two relevant local languages, so

as to ensure the widest range of stakeholders are informed of the process.

d) Development of Stakeholder Database

A comprehensive database of I&APs is to be compiled, including the following relevant authorities and

organisations:

� Local and provincial government departments

� Local community-based organisations

� Non-governmental organisations

� Ward councillors

� Local ratepayers associations

The database should be continually updated to accommodate new stakeholders as the project progresses. The

stakeholder database provided the means for the distribution of information and continued communications

(including registrations, invitation, minutes of meetings, and availability of information for review).

(e) Background Information Document

A Background Information Document (BID) should be prepared and distributed to I&APs in order to provide

project information. The document should be distributed to all identified authorities, key stakeholders and

registered I&APs The BID should be prepared for information purposes only, however a comment form could be

included to allow I&APs to register additional persons or organisations, and submit comments at a later stage in

the process.

3.3 PHASE 2: FOCUS GROUP MEETINGS

Following the initiation phase key stakeholder groups will be identified. Stakeholders will be grouped according to

their sectors or areas of interest (e.g. authorities, environmental, business, residents, community based

organisations, etc.). Sector-based stakeholder meetings are proposed in order to capture the relevant issues of

each group. These issues should be recorded and used to inform the development of the draft coastal setback

line.

3.4 PHASE 3: CIRCULATION OF DRAFT REPORT AND PUBLIC MEETING

Once a draft report and setback line has been compiled, at least one public meeting must be held within the

study area (depending on the size), to provide feedback on the draft setback line to the public. Meeting must be

well advertised using the most appropriate means.


The draft report must be made available to all registered I&APs, for a comment period of at least 21 days. All

comments must be compiled into the “Issues and Response table” for the final report. Responses must be

provided to all comments by the steering committee where appropriate

3.5 PHASE 4: STAKEHOLDER FEEDBACK

The final phase comprises of the dissemination of the final report (coastal setback line and associated

documentation) to registered stakeholders for reference purposes. This will allow stakeholders the opportunity to

view responses to their comments and the final setback line. Stakeholders should be informed of the availability

of the final report.

4 Conclusion

Stakeholder engagement is an essential aspect of the developing coastal setback lines, as it promotes public

engagement, and enables practitioners and authorities to understand local requirements and environments.

Transparency and cooperative governance are key aspect of stakeholder engagement that must be carried

throughout the process.

The four phased approach described above provides a guideline for the stakeholder engagement process for the

development of coastal setback line within the Western Cape. This approach is in line with the legal requirements

of NEMA and ICMA, and provides a best practice approach for the effective engagement.

REFERENCES

1. DEFRA (Department for Environment, Food and Rural Affairs) (2006) Shoreline management plan

guidance, Volume 2: Procedures, DEFRA, March 2006 [including Appendix A and E]


Appendix A Advertisements

� The Cape Argus (22 January 2010)

� Die Burger (22 January 2010)

� The Cape Times (22 January 2010)

� Western Cape Province, Provincial Newspaper(22 January 2010)


� The Cape Argus & The Cape Times (22 January 2010)

� Die Burger (22 January 2010)


� Western Cape Province, Provincial Newspaper(22 January 2010)


� Die Weslander (21 January 2010)


Appendix B Registered Stakeholder List

Organisation Name

GOVERNMENTAL ORGANIZATIONS

CapeNature Alana Duffell-

Canham

Surveyor-General John Obree

Surveyor-General:

Bloemfontein Rosalind Mdubeki

Environmental &

Heritage Management

Branch Environmental

Resource Management

Lesley

Wolfensberger-Betts

Garden Route National Park:

Environmental Planner Maretha Alant

Cape Town Municipality Dave Brook

George Municipality

The Municipal

Manager

Attention:Mr Stiaan

Carstens, PJ Mabula

Hangklip - Kleinmond

Administration, Overstrand

Municipality

Mr. Neville Green

Overstrand Municipality Stephen Muller

NON-GOVERNMENTAL

ORGANISATIONS

Cape West Coast Biosphere

Reserve (CWCBR) Nicole Loebenberg

South African Planning

Institute Western Cape

Branch

Abena Kwayisi


Institute Western Cape

Branch

Sarien Lategan


Insitute Sarien Lategan

Enviro-Fish Africa (Pty) Ltd./

WWF-SA Aidan Wood


Western Cape Branch Allan Rhodes

Cape West Coast Biosphere

Reserve (CWCBR) Jimmy Walsch

Regional Coastal Committee

Member JJP Kotze

WESSA / Saldanha Resident Alan Carnegie

COMMUNITY BASED ORGANIZATIONS

Woodbridge Island Body

Corporate R.A. Rundle

Trustee: Environment and

Waterfront Woodridge

Island Body Corporate

R.A. Rundle

Plettenberg Bay Community

Environment Forum Michael Wadge

Organisation Name

Simon's Town Civic

Association DAVID ERICKSON

Residents’ Association of

Hout Bay Len Swimmer

Noetzie Conservancy

Owners' Association (NCOA) Julie Gosling

West Coast Bird Club –

Conservation Keith Harrison

Plettenberg Bay Community

Environment Forum Dr Nicky Frootko

Macassar Environmental and Nature Conservation Society and Coastal Forum

C W Hendricks

Hout Bay & Llandudno

Heritage Trust Keith Mackie

Jacobsbaai Ratepayers

Association Alf Williams

Overstrand Conservation

Foundation

Rob Fryer (Meg

Campbell)

Chairman of Saldanha

Water Quality committee Christo van Wyk

Noordhoek Conservancy Rory Sales

Table View Ratepayers

Association Dr J McCarthy

Langebaan Ratepayers and

Residents Association Jaco Kotze

Fish Hoek Valley Ratepayers

& Residents Association Janet Holwill

The Noordhoek

Environmental Action

Group.

Glenn Ashton

Milnerton Proper Residents

Association Kevin Thorpe

Vice-Chairman, St Francis

Bay Residents' Association H.B.Thorpe

Chairman Gonnemanskraal

HOA Doug Cleland

EBRA (Elands Bay

Ratepayers Ass) Johnny Kotze

Convenor: Langebaan Action

Group Johan Ackron

Langebaan Action Group

(LAG) -

Chairman Gonnemanskraal

HOA Doug Cleland

Jacobs Baai Ratepayers

Assoc Dan Grobler

Macassar Environmental

and Nature Conservation

Society and Coastal Forum

Dennis Roziers

PRIVATE/RESIDENTS

Private Andre van Greunen


Organisation Name

Private Jac Vos

Private Geoff Neden

Private Philippe Jaques

Private Zamile Mfakadolo

Private Donald Stechman

Private Eion Brown

Private Mr T. E. Everett/

Nikki Everett

Private Chris and Iona

Everett

Private Cathy Shimmin

Private Wendy Dewberry

Private Fern Robertson

Private Chris Williams

Private Mmusa Riba

Private Derek Cockcroft

Private Steve Gettliffe

Private G Bond-Smith

Private D Bond-Smith

Private Mrs Patricia

Margaret Nicolson

Private David Brown

Private Schalk de Waal

Private Dr Penelope C Brown

Private -

Private Maaike Kallenborn

Private David Gwynne-Evans

Private Ena de Villiers

Private Tony Howe

Private Dr P W Nel

Private Irmé van Zyl

Private Mnr en Mev A.S. le

Roux

Private John Robinson

Private Pieter Badenhorst

Private George Sabbagha

Private Keith Nicol

Private Jaco Kotze

Private Ritzema de la Bat

Private Vincent Bergh

Private H Shuman

Private Leone Suckling

Private Andree Lombard

Private Hewlett Llewellyn Miles Sweetnam

Private Rob Munro

Private Mrs Patricia M

Nicolson

Organisation Name

Private Nenriette Schuman

Private Anton Vonk

BUSINESS

Gecko Beach House Doug & Gaynor

Portsmouth

Cape Lowlands

Environmental Services Mark Duckitt

Private developers Peter Liddell

C.A.P.E. Specialist Land-use

Adviser Charl de Villiers

Urban and Regional Planner -

LegalB CC -

Picasso Headline Robin Carpenter-

Frank

Bluegreen Planning &

Design Derek Chittenden

NEIL SCHWARTZ TOWN

PLANNING Neil Schwartz

BCD Town Planning Iwan van Wyk

Horst Psotta c/o West Coast

Miracles (Pty) Ltd Horst Psotta

Knysna Leisure Industries

C.C. A J Wilson

EXXARO Liezel van Zyl

Aurecon John Foord

Environmental Assessment

Practitioner Lwandle

Technologies Associate

Sue Lane

SRK Consulting Matthew Law

Duncan Bates Professional

Land Surveyors Karl Hendriksz

Duncan Bates Professional

Land Surveyors Duncan BATES

TRP(SA), EAP(SA) Sarien Lategan

New Development

Technologies Chavoux Luyt

Cape Coast Properties SB Dorman

Enviro Logic Gert Pretorius

Imbewu Sustainability Legal

Specialists (Pty) Ltd Marie Parramon

SRK Consulting Warrick Stewart

Barry Gould Architect Barry Gould

Creative Profile Town

Planners Francois du Toit

Cape EAPrac Louise-Mari v Zyl

DELplan Urban & Regional

Planning Delarey Viljoen

AVDS Environmental

Consultants

Mr. Andre van der

Spuy

AVDS Environmental

Consultants Ross Cameron

TV3 Architects & Town

Planners -


Organisation Name

Sharples Environmental

Services cc -

Sharples Environmental

Services cc -

mlh architects & planners Nigel Burls

Bau-afrika (Pty) Ltd. Rudy Schwaeble

Professional Land Surveyor David Friedman

WITHERS ENVIRONMENTAL

CONSULTANTS Nelia Maritz

Hout Bay & Llandudno

Heritage Trust Keith Makie

Aurecon Simon Van Wyk

MCM West Coast

Compliance Wade Theron

Bau-afrika (Pty) Ltd. Rudy Schwaeble

Cadastral, Topographic,

Sectional Title and

Engineering Surveys

David Friedman

Managing Member, LegalB

CC [Enterprise No.

2005/067999/23]

Rita Felgate.

Exxaro Carl Skidmore

Club Mykonos A J Shapiro

OTHER

Weslander Heléne

Meissenheimer

Weslander Alida Buckle

University of Cape Town,

Dept of Geological Sciences John Crompton


Appendix C Background Information Document


Appendix D Stakeholder Groups 1. Steering Committee

ORGANISATION NAME

Dept. Environmental Affairs and Development Planning

(Development Facilitation Unit (DEA&DP: DFU) Siyabonga Dlulisa

DEA&DP: DFU Gerhard Gerber

DEA&DP: Integrated Environmental Management Paul Hardcastle

DEA&DP: Spatial Planning Marek Kedzieja / Alexia Julius

DEA&DP: Coastal Management Carmen van Uys or Nontsasa Tonjeni

DEA&DP: (Departmental Project in Bitou) Gosiaan Isaacs / Dennis Laidler

City of Cape Town (Coastal Coordinator: Environmental

Resource Management) Gregg Oelofse / Darryl Colenbrander

Saldanha Bay Municipality John Smith or Lindsey Gaffley

DEA – Marine and Coastal Management Dr Niel Malan

1 representative of Northern Cape Provincial Government Wilna Oppel

1 representative of Eastern Cape Provincial Government Phumla Mzazi

1 representative of KZN Provincial Government Omar Parak

Cape Nature Tierck Houstra

CSIR Andre Theron

Additional consultative members

Ezemvelo KZN Wildlife (GM: Conservation Planning) Dr Jean M. Harris

eThekwini Municipality Andrew Mather

2. Focus Groups

ORGANISATION POSITION NAME

Key Authority Representatives

Department of Agriculture Acting Manger: Land Use

Paul Herselman (Represented

by Liesel Landman)

SANBI

Cloverly Lawrence

SANBI Planning biodiversity input Jeff Manual

Dept. Environmental Affairs: Marine &

Coastal Management

Potlak Khati

SANBI – DEA&DP

Charl Devilliers

Dept. Water Affairs

Wilner Kloppers

SANParks

Mbolelo Dopolo

Additional Registered Authority Representatives

SANPARKS: Marine manager Marine manager Paul Sieben

SANBI Director Mandy Driver

SANBI Dr Phoebe Barnard


SANBI Head marine programme Kerry Sink

University of Cape Town ( EEU ) Prof Merle Sowman

Department of Co-operative Governance,

Human Settlements and Traditional Affairs

Schalk M Grobbelaar TRP

3. City of Cape Town – Environmental Resource Management Department

ORGANISATION NAME

City of Cape Town (ERMD) Keith Wiseman

City of Cape Town (ERMD) Linda Ndlela

City of Cape Town (ERMD) Janet Bodenstein

City of Cape Town (ERMD) Greg Oelofse

City of Cape Town (ERMD) Howard Goud

City of Cape Town (ERMD) Darryl Colenbrander

4. Saldanha Municipality


Saldanha Municipality Town Planning John Smit

5. Heritage Organisations


South African Heritage Resources

Agency APM Unit.

Mariagrazia Galimberti

South African Heritage Resources

Agency

Manager/Maritime

Archaeologist Jonathan Sharfman

Heritage Western Cape

Calvin Van Wyk

Heritage Western Cape

Nick Wiltshire


Appendix E Notes from Focus Groups

� Focus Groups meetings: - Saldanha Bay Municipality - Authorities - Cape Town Municipality - Heritage - Saldanha Bay General Stakeholder - Cape Town General Stakeholder


I&AP Comments

Saldanha Bay Municipality - Saldanha Bay Municipality

- (Town Planning)

- Langebaan - 4

th February 2010

� Funding for implementation of Setback lines

� Time scale of setback line: 1) a 20 year and 2) 50 year line

� Roles and responsibilities for setback lines

� Identify different levels of development management within setbacks

� Revision of the methodology should be done in line with the Spatial Development Framework (SDF)

� Access to data may be limited – e.g. Saldanha Port

� Data

- Needs to be accurate

- Gathering needs to give two options: 1) quick and expensive, and 2) cheap and slow

- SDF provides good planning and other data for implementation phase

- Consider long term shoreline trends

� Enforcement of setback lines:

- How

- Will they afford more protection than Coastal Protection Zones? The Coastal protection zones don’t really help protection of the coast, especially from an enforcement perspective, as there is no legislation to back it up.

� Priorities: - properties under pressure/threat

� Biodiversity: - Development in the high biodiversity areas should be controlled by the EIA process, rather than only the setbacks

� Heritage: - Different importance levels also need to be considered

Authority Focus Group - Dept. Environmental Affairs:

Marine & Coastal Management

- Dept. Water Affairs

- Department of Agriculture

- SABNI

SANParks Cape Town, 5th February 2010

� Current legislation & management of coastal areas:

- How does the NEMA trigger of 100m (developed) and 1000m (undeveloped) (from high water mark) lines relate to the coastal development setbacks?

� Inclusion of dynamic coastal environments:

- Include issues of human impacts on natural processes

- Include management of coastal areas

� Enforcement:

- Enforcement of setback potentially variable and that will be revised

� Data:

- There is potential for a mismatch between real and mapped land cover, especially where with coastal process have not been mapped accurately.


� Roles and responsibilities - implementation

� Flood line timeframes:

- Consider river flood lines in context of climate change

� Prioritising areas:

- Need system to prioritise different areas that are more vulnerable

� Local spatial planning

- Interaction of setbacks and municipal town planning scheme

- Ultimately the setbacks need to speak to the land use management objectives

� Data availability

- Use cape nature maps for conservation and ecological

- Spatial biodiversity plan (SANBI – biosphere management)

� Consultation process:

- National process - therefore consult with as many people as possible

� Methodology:

- Needs to be a working document

- Capture all issues, describe how they were resolved, so these can be traced when the methodology goes through review, and the issues are not duplicated each time.

Cape Town Municipality Focus Group - City of Cape Town (ERMD)

Cape Town, 5th February 2010

� Use of Setback lines:

- In Cape Town, the Coastal Protection Zone delineates the development setback line.

� Private Development Rights within the setback lines:

- What private rights do people have?

- Will these properties be appropriated?

- It has been suggested that there be two lines: 1) erosion setback and 2) development setback line

- Would like to see a broad ban within the erosion setback line to limited recreational development

- Setback line should mange development within coastal areas in general

� Time frames of setback lines:

- Consider implications of the 1:50 year line for setbacks

- Need to restrict development completely

� Coastal processes:


- Ensure the beach profile is maintained.

- Wind direction is another crucial aspect

- Barometric pressure also an important aspect.

� Biodiversity aspects:

- City’s biodiversity network (based on biodiversity targets, not management objectives) could feed into the process.

� Social aspects:

- Socio-political aspects/objectives also need to be included

- Include intangible issues, such as sense of place

- Socio-economic development priorities will be determined through the focus group discussions when determining setbacks

� Scale of data available:

- SDF may not be at right scale to encompass/inform the setback lines

- Biodiversity maps may not include small patches of vegetation that may be crucial to conservation or habitat protection

� Implications for EIAs:

- Will DEA&DP be able to able to make a decision on the EIAs within these setbacks?

� Heritage aspects:

- Need to be included into the precautionary approach - undiscovered resources.

- Aesthetics – The Heritage Act also ensures that aesthetic impacts are considered, e.g. cultural landscape

� Stakeholder engagement process:

- Setback lines should not go to the public for review during the development phase, as it is always going to be split between developers and local conservation/community groups.

- If setback lines must be legally defensible, they must be scientific processes and not determined by the public.

- Before presenting to public the line should be determined, by scientific means, so that it is defendable.

- A robust methodology (and PPP in this methodology development phase) will back up the implementation, and therefore make the implementation more robust.

� Prioritising undeveloped/rural areas:

- Need to prioritise areas:

o Where there are no coastal setback lines to protect the coast,

o Where there is threat of development, and under new rights.


o Especially farms up the west coast, where there are few boundaries, little management or protection.

� Methodology development:

- A suggestion to apply the setback line retrospectively in an area where these has been past contention with development application, and see how the setback would change the outcome of those developments e.g. golf estates, etc.

- Need to instil the ‘Greater Good’ ideal.

Heritage Focus Group - SAHARA

Heritage Western Cape SAHARA, Cape Town, 24 February 2010

� Coastal heritage includes:

- Buildings over 60 years old, Burials, Shell middens, Wrecks, Fish traps, cultural landscapes, Lighthouses,

- Most likely at the shoreline, tapering off landward.

� Coastal heritage sites

- Highest priority within up to 200m of the shoreline.

- Ideally like to see setback for heritage purposes up to this distance.

- Nodal development rather than strip development is preferred

- Heritage buildings and their surroundings should be considered

� Data:

- Maps with identified heritage sites can be provided

- Assessments/surveys should not be limited to parts of individual sites – these should cover neighbouring sites.

Saldanha Bay General Stakeholder Meeting - Langebaan - 10

th February 2010

� Case Study areas

- Need to consider sites conjunction with each other and surrounding environment

- Reasons for choosing the sites - Two sites will not define all scenarios

� Existing properties:

- What happens to existing properties that will fall within the setbacks and owners rights

� Conflicting legal jurisdiction:

- Consider/manage overlap between local bylaws and district municipal jurisdiction.

� Undeveloped areas:

- Rural areas need larger setback

� Public Access

- Public access needs to be considered

� Data

- Existing data: - Need to use up-to-date information and data


- Accuracy of available data - erosion: - Impact of current erosion trend on data and setbacks

� Data availability & predicting coastal processes

- Need to gather and use most current data with precision and newest technology

- Need to monitor the monitoring of the beaches and the sedimentation of the bay

- There are low tech/cost solutions for data collection.

� Impact of other coastal development/processes:

- Impact of other activities on coastal processes (e.g. Saldanha dredging and Saldanha study sites)

� Management of Setbacks

- Large setbacks are unmanageable (e.g. community can’t manage them and affect coast)

- Make them conservation areas, with public access

� Implementation of setbacks – Prioritising areas:

- Should be able to apply to prioritise a specific area

- There needs to be a mechanism for setting of priority areas.

- This could be considered in conjunction with local interest/community groups in terms of which areas need to be looked at.

� Time frames:

- Timeframes for implementation are too short. It will not be affective to implement setbacks along the entire country’s coastline on two years.

- There is inconsistency between different ‘regimes’ within the local municipalities. E.g. the next council might not agree with the previous

� Types of setbacks:

- Consider difference between a general setback lines and more specific to each area of the coast

� Biodiversity:

- Consider marine life

- SANBI maps prioritised on the land based habitats/vegetation, not marine

� Global processes

- Incorporate global warming, change in storms, etc into the methodology

General Stakeholder Group,

- Cape Town

- 11th February 2010

� Impact of developments on coast:

- Need to consider how developments impact on the coast.

- Harbour infrastructure impact the surrounding areas

� Test site:

- Milnerton does not represent the Cape Town areas, as it does not contain rocky beaches, cliffs, etc.


� Sensitive areas:

- Setbacks need to stop development in environmentally sensitive areas

- Management outcomes need to include actions, e.g. build up beaches where they have eroded

� Local municipal obligations:

- Consider the power given to the municipalities to control development

� Purpose

- Interaction with Cape Town City’s coastal protection zone (CPZ),

� Time scale of Setbacks:

- Very short and human scale.

- Consider 100 year and 1000 year events

- Therefore needs to be very conservative

� Local Community consultation:

- Macassar – a strong environmental community and a need to look at this site.

- This is a scientific process.

- Need to include local community forums in the process, to get the local perspective.

� Sea level rise model:

- What model is being looked at for sea level rise?

� Development Approval:

- Will DEA&DP approve development or wait till setbacks are prescribed?

� Management of coastal developments

- Need to ensure the objectives of different departments are aligned (e.g. Tourism & Environment)

� Biodiversity:

- Need to ensure the marine biodiversity aspects are included.


Appendix F Issues & response Table - General I&APs

� Written comments from registered I&APs


I&AP Comments Response

Pieter Badenhorst

- Private

1. � Do not agree with the list of essential data as it is very expensive and the municipalities will not afford such expensive studies.

� Coastal management principles are not included- it should be part of the objective.

� Do not agree it is expensive – refer to costs which show that consultant fees will be the greatest expense by far

� We believe that the principles which affect position of setback line are now covered.

Miss Maaike Kallenborn

- Private

2. � The Saldanha Bay area has many different characters and situations

� Erosion / damage to primary and secondary dunes and damage to property placed too close to the mean sea level

� Exclusive fenced off developments restricting public access to beaches are disgracing the area.

� Fynbos vegetation differs greatly on different locations, same stands for the waves/ swells, currents, soil types, wind and local weather conditions.

� Lots of attention to urban development, little to no attention for rural areas which need protection urgently against erosion, development or damage.

� Noted

� Noted and included implicitly in methodology

� In terms of the latest ICMA legislation and our proposed methodology this will not be allowed

� The methodology accounts for variability in these.

� Not applicable to this study – a setback line alone will not aid in protecting against erosion.

Dr. Joy McCarthy

- Table view Ratepayers association

3. � look forward to sensible planning with respect to the effects of global warming and a halt to the mad scramble to build as much as we can while we can at the beachfront and to heck with the consequences.

� Noted. The method accommodates sea level rise due to global warming in a conservative way and will ensure a much more conservative approach re. development than has been applied to date.

Henriette Schumann

- Private

4. � In Stillbaai, on the east side, degradation of the primary dunes is a big problem. homeowners of the properties just behind the primary dunes are illegally levelling the dunes, planting invasive grasses on them and using it as their own. This has been going on for a long time despite repeated complaints by concerned residents.

� Noted this concern. Strictly not applicable to this study but setback lines placed during the execution phase will render such activity landward of the line illegal.

Mr. Alan Carnegie

- WESSA representative

5. � Setback lines cause more harm than good. � Historically I think a case could be made to back up this comment. We believe the


reason for this statement is poor methodology (and no specific methodology to follow) which has now been remedied

Phoebe Barnard

- SANBI

6. � Aeolian sand corridors, estuaries etc are seemingly treated appropriately, and to voice caution that the setback lines should be VERY precautionary, given the high levels of complexity and uncertainty in modelling sea level rise over the next two centuries. We certainly don’t want a coastline that will in the next generations be littered with rusted hulks and wrecks of infrastructure. But, in fact, that is to some extent what we will be faced with if funds are not made available to help landowners (including cities) remove infrastructure in vulnerable areas. This project will be very helpful in minimizing future loss.

� Comment noted and agreed with.

George Sabbagha

- Private

7. � We have a situation at Stilbaai where coastal dunes have been flattened and used for personal purposes. This matter was brought under the attention of Sandiso Zide and Dr Niel Malan as well as Allan Boyd. A complaint with photos as requested was sent but no feedback.

� Noted this concern. Strictly not applicable to this study but setback lines placed during the execution phase will render such activity landward of the line illegal.

JF Kapp

- Private

8. � To determine beach set back lines is to enter an extremely complex field subject to all sorts of interpretations and understanding. There are no hard and fast rules and it is at best a guess. It is essential that agreement on the period over which the setback line is applicable be reached beforehand. Depending on the ownership the period can vary as stated in the slide show.

� Agreed that this is extremely complex and that it is a challenge to establish rules. At this stage the methodology provides some guidelines and methods which elevate the estimation of the setback line well above “guess” status. However, we also strongly emphasise that coastal practitioners (engineers, scientists) must conduct the work or at the least, review it.

Regarding period of applicability, we have addressed this in our report.

9. � The fact that determining a setback line is becoming a legal requirement in terms of the Integrated Coastal Management Act makes it essential that any Methodology must be able to meet court of law requirements. It is suggested that reference to “all Ministers and MEC’s” be removed and replaced by “Government departments (central and provincial) and Municipalities”.

� Good point, but beyond our brief to change the ICMA. We

assume this is not addressed specifically to us.


10. � The methodology as set out by WSP is probably the best available. The following comments on the draft are offered.

- It is recommended that coastal sections which does not require beach setback lines be identified early on, and be excluded from studies. For example it would appear unnecessary to determine setback lines along the Otter Trial section of the coast.

- The fixing of setback lines is extremely sensitive to the nature of the coastline and of the

subseabed.

- The effect of extreme flooding must be taken into account.

- Bodies not obeying sensible beach management must be seen to be taken to task and repair

damages caused by their activities.

- Setback Line Methodology must not be dependent on cost and time – constraints in data collection.

- The application of rule of thumb techniques to determine water levels is not acceptable.

- Existing natural protection to beach changes to be identified early on and taken into account in determining set-back lines.

� We have recommended a default, interim setback for such sections of coast as the Otter Trail, in our report. Also indicated priority areas.

� Recognised and we propose wave modelling (that takes into account the subsea bed contours) to accommodate this.

� Thank you - addressed in the report

� Agreed, although strictly not in study brief

� Agreed. We propose time-efficient means of data collection up front (such as aerial Lidar topography survey which works out to be economical at the scale required). Details in our report.

� Agreed. We now propose some alternative approaches in our report. Amongst these we propose an upfront study of tidal and water level records to assess storm surge and actual water levels

� Agreed – this is accommodated in our report


John Compton

- University of Cape Town

11. � As a marine geologist involved in coastal projects I would like to comment on the need for coastal setbacks and the factors to consider over long (longer than a single human generation) timescale.

� In response to your comments which were echoed by others, the setback “return period or applicability period” has increased from 50 to 100 years

Nigel burls

- MLH Architects and Planners

12. � We are the appointed town planners for the AECI site in Somerset West which has an extensive edge along the False Bay coast line.

� Noted

Rob Fryer

- Overstrand Conservation Foundation (OCF)

13. � Marine biodiversity protection is essential - that the influence of land-based impacts upon marine biodiversity is considered within any methodology for determining setback lines. Setback lines should apply to all forms of development, including the ploughing and cultivation of land where the topography is such that nutrification or other pollution of the coastal zone may occur to the detriment of marine biodiversity.

� Biodiversity is a key item included in the methodology.

� Comment included in methodology report in the biodiversity section

14. � I am very worried about the proposal to employ modelling techniques. Models can only be used by people who have understanding / insight into the theory used to construct the models. If the models are used by people without this insight then the users will simply plug data into the models and crank the handle to get answers that may not be at all accurate. If models are to be used then they should be used only by people who have been trained to apply them and accredited following passing examinations. Conclusions drawn by those who apply the models should be reviewed by a specialist who is an authority on modelling before the conclusions are accepted by the authority who will authorise the setback lines determined using the modelling technique. The limitations of the model and the circumstances under which it can and cannot be used must be very clearly stated.

� Agreed that the models must be wielded by people with an understanding of these models. This is accommodated within the methodology in three ways (1) specifying the expertise to be employed to execute the setback study and (2) conducting some of the modelling up front in the “enabling studies” (3)Review of the modelling (and entire study).

15. � - The methodology must deal with setback around estuaries as far up the estuary as there is tidal movement of the high water mark. Special attention needs to be given to the case of estuaries that are closed to the sea and only open seasonally after heavy rain. In the case of these blind estuaries, the setback should be greater due to the propensity of these to become polluted during the months when the mouths are closed.

� It was agreed with the client that that estuaries would not be part of this study. Nevertheless the importance of having them included is highlighted and the effect of meandering estuaries on the open (wave-exposed) coast is considered

Penelope Brown 16. � Specifically - concern re proposed hard development in Hout Bay too close to the sea, estuary � Noted and generally in


- Residents’ Association of Hout Bay

and beach dune field as this is not appropriate for orderly development.

� Protection of natural assets (e.g. beach dune fields) as they have a role to play in protecting established residential areas further inland and provide a useful natural buffer.

� They should be protected in their own right as we are obliged to protect our natural environment and biodiversity now and for the benefit of future generations.

� Sea level rise and the increase in frequency and intensity of storm events is of medium to long term concern and must come into decision-making regarding set-back lines, etc. as, otherwise, the authorities will be subjected to legal challenges in the future when natural processes result in the destruction and/or damage to formally approved developments.

� Also such negligence will result in the erosion of our natural heritage which effectively forms the basis of our economy locally, and in the Western Cape in general

agreement but this is not part of the present study.

� Agreed and this is part of the methology.

� Agreed and this is part of the methology.

� This is considered within the methodology.

� This is considered within the methodology.

John Obree

- Surveyor-General: Cape Town

17. � They are really a zoning matter.

� These setback lines will be delineated in the Provincial Zoning Scheme and properties between the sea and these setback lines will be subject to the conditions imposed by that setback line - e.g. height restriction, architectural, sewerage, lighting, size etc.

� These setback lines will vary in distance from the HWM based on the nature of the coastline and the need to conserve the adjacent land.

� It is requested that wherever possible that these setback lines be demarcated and proclaimed relative to fixed rectilinear cadastral boundaries and not be defined as being a stated distance from the HWM.

� The determination in law of the exact position of the HWM is always going to be in dispute, by the nature of the HWM definition, thus making it an unsuitable benchmark for any fixed boundary zoning system.

� Using a line a stated distance from the HWM will also bisect properties, leaving confusion as to exactly where the Setback Line falls. In such cases it should rather be described as following a rectilinear cadastral boundary or as a line a fixed distance from a rectilinear cadastral boundary.

� Noted

� Noted

� Agreed

� It is not intended to establish

setback lines relative to the somewhat “difficult to define” HWM. The setback line/s will be independent lines with their own coordinates.

� Setback lines have their own

priorities as per the methodology developed – they cannot follow cadastral boundaries


Mbulelo Dopolo

- SANParks

Cape Research Centre: Scientific Services: Marine Program Manager

18. � What type of data is to be used that was acquired from SANBI (in particular Kerry Sink)? Is it conservation priority or ecological sensitivity maps? I want to be sure that you will be using an appropriate data (input) that will provide appropriate output in terms of setback lines. Ecological sensitivity maps are what need to be used, if such information has been developed (synthesised) already, because the last time I checked there wasn’t such information. I will make a follow up to verify this with SANBI, and will come back to you to confirm any feedback that I will get from them.

� Biodiversity maps – i.e. those defining critical biodiversity areas, etc. Employment of biodiversity expertise together with recommendations to consider ecological constraints should ensure. Await feedback.

Mr Keith Harrison

Westcoast Bird Club

19. � The project will give a useful tool to the Planners

� It is a pity that there is not a rocky shoreline included in the study

� When the Avifauna Study is carried out it should be remembered that many of our coastal Birds – e.g. terns, only come in after dark and species use of an area differs throughout the year.

� Agreed

� This is not explicitly indicated in the methodology but is included implicitly (i.e. the extent of wave flooding (due to sea level rise and major storms) is to be estimated

� Noted.

Sarien Lategan

- South African Planning Institute, Western Cape

20. � How the issues ( Boundaries, coastal protection zones, Municipal planning zones, military and other special use areas, special mgt areas, cadastral boundaries; Sediment/geotechnical issues; Erosion lines; Flooding; Biodiversity priorities; Other issues e.g. public access, aesthetic features, shading of beaches by structures, meandering estuary channels, heritage sites etc) are going to be assessed and used to determine the setback line.

� More technical detail needs to be provided for comment

� More detail is provided in the final draft of the report.

21. � It is contested that these sites (study areas) do not provide a representative view of the total coastline of the province.

� We would contend that it is impossible to find sites that are generally representative of an entire province. One of the main benefits of the study areas selected is that they have extensive previous measurements. Thus, for example, the setback can be assessed using aerial photographs only (as are generally only available elsewhere) and then the methodology evaluated by referring to survey data.


� The sites are very similar in nature and both are on the Atlantic coast, reconsider the chosen sites and based on sound criteria propose sites which would represent the diverse coastal conditions of the Western Cape.

22. � It is suggested that more detail be provided on similar work elsewhere in the world and potentially best practice guidelines e.g. A literature review to support

� Results of a literature review are included in the report.

23. � Whether the legal context will be dealt with at a later stage when an actual setback line is established is not clear.

� At this stage it is unclear what exactly the status of the setback line is, as the act indicate that it be shown on zoning maps, which make the legal interpretation of the line difficult.

� The act also refers to Development frameworks and it is not clear what the real intention in terms of the legal status is.

� I would assume that the setback line be accommodated in a development framework and only once such SDF is approved can it be translated into zoning regulations and be adopted as part of the zoning scheme regulations.

� The methodology on which the setback line is going to be based is of utmost important and therefore it is suggested that the project engage in more detailed dialogue with professionals working in the field of spatial planning and environmental management.

� Correct – at a later stage

� Noted – not within scope

� Noted– not within scope

� Noted

� Noted – relevant

groups/individuals have been consulted

John Robinson

- Private

24. � There are a number of developers who would certainly not want these setback lines to come to fruition and want to develop right into the dune areas and also to create a situation where the public access to traditionally visited areas becomes severely restricted despite their denials to the contrary.

� You will find the necessary support our area from people who want to force the developers to desist from strip development!

� Comment noted

� Comment noted

Jonathan Sharfman

- Manager/Maritime Archaeologist

- Underwater Cultural Heritage UnitSAHRA

25. � The Underwater Cultural Heritage Unit at SAHRA is the national competency for all heritage sites below the high water mark, but are also involved in the management of maritime sites falling within provincial boundaries. The outcomes of this project may well affect the manner in which maritime related sites are managed in other provinces. For this reason I would be very interested to be included in discussions.

� Noted

Charl de Villiers

- C.A.P.E.

26. CBA maps

� There are instances where coastal features may have been incorrectly mapped in that the depicted land cover does not correspond with actual conditions on the ground which,

Noted – for this reason inclusion of a biodiversity specialist on the project is a prerequisite.


Specialist Land-use Adviser: Land-use Planning and Decision-making

� In these cases, CBA designation should preferably reflect the desired objective of managing the littoral active zone and coastal processes in a 'natural' condition.

� Setback lines that fulfil the role of protecting such processes from human interference and, in turn, protecting property and infrastructure against the effects of coastal erosion, etc, would certainly be a very valuable contribution to 'mainstreaming' CBA maps and priorities into spatial planning and land use management.

Noted

Noted. The methodology proposed aims to achieve this.

27. Alien infestation of dune fields

� Where does one draw the setback line if it is accepted that the dunes have been artificially fixed and may be remobilised in future? The latter would be a definite management objective if a dune system was designated as a terrestrial CBA

The methodology proposes that if there are known plans for remobilisation of a dunefield (e.g. through destruction of alien vegetation), this must be taken account of in assessing the coastal processes setback line.

28. Settlements in the littoral active zone

� Would setbacks be drawn through settlements, i.e. parallel to the coast and corresponding to the former geographic limits of coastal processes, or would the setbacks follow, for example, the seaward edge of the built-up area? Or could the front row of houses conceivably fall within the setback, i.e. not be excluded by it?

It has been decided to indicate setback lines (e.g. to allow for natural coastal processes) through settlements. It is highlighted in our study that this does have legal implications. But establishing the line at the seaward end of a development would be considered irresponsible particularly if this means the seaward property edge is in danger.

29. Coastal development guidelines

� WSP's involvement in this project gives us a rare opportunity to obtain specialist feedback on coastal development issues.

- Including attached setbacks and coastal development planning in the W Cape. The paper by Roets and Duffell-Canham was presented at last year's IAIAsa conference and deals with setbacks in the context of climate change.

- W Cape rural development guidelines which translate the CBA map categories into spatial planning categories (SPCs) which are defined by the W Cape provincial SDF. The spatial planning categories, in turn, provide recommended land-uses.

- The Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape also include a chapter on the implications of development in sandy shore ecosystems http://bgis.sanbi.org/wces/FF_Ecosystem_Guidelines.pdf

� This paper has been referred to

� This document has been referred to

� Noted. Document accessed

and key concepts incorporated.

91212D Western Cape Coastal Setback Lines – Stakeholder Engagement Report 47

Appendix G Authorities & Steering Committee Comments on Draft Report


I&AP No. Comment Response

Environmental Resource Management Department (ERMD) - City of Cape

town

1. Section 1.5.1:

a) The proposed use of the 100-year period for residential setback and 50-year for low-value structures is supported, although the argument presented in the bullets on pages 4/5 appears a little thin. Whilst the CoCT setback for inland rivers for residential development is the 50-year floodline, it is recognised that the destructive forces associated with waves and coastal erosion are more severe than the inundation by the inland floodwaters and are more comparable with the inland “high hazard zone” which is defined for the 100-year flood and within which all development excluded. (For details of high hazard zone definition refer to the City’s Floodplain and River Corridor Management Policy, 2009) Set key facilities even further back, e.g. to the 200-year setback line. The Floodplain and River Corridor Policy further sets certain key development even further back than the 100-year. Such development include community and public facilities such as hospitals, clinics, nursing homes, old age homes, police stations, fire stations, educational facilities, public halls, etc., as these are critical to facilities during any major flooding disaster situation. By application of the same argument in b) above, key facilities should be set further back than the setback line for residential development.

b) In the event that 1:100 year erosion event occurs and being followed by another extreme storm, the predicted setback will be ‘breached’. Assuming development takes place up to this setback in the interim, and considering the above scenario take places, there will be no buffer left in place and we will be back at ‘square one’. The different spheres of government should collaborate and put in place different setbacks with different regulatory mechanisms in place to reduce this from taking place. An example of this would be for the setback line to be included within the CPZ as a safety mechanism.

Agreed. Point included Incorporated in the report Eroded sand moves offshore to bolster the protective sand bar on which waves dissipate – thus protecting the coast to some degree from a large subsequent storm. Tidal conditions change such that a subsequent 1:100 storm (in terms of wave height) is unlikely to occur. The likelihood of a second large (1:100 yr) storm is somewhat covered in the methodology which considers storm systems close to each other. Important to note that the potential problem will only occur towards end of 100 years – once predicted long-term erosion and sea level rise has been realised.


In this methodology, the design life of infrastructure plays a key role in determining appropriate timeframes for applying set-back lines. Irrespective of whether a building has a design working life of 50 or 100 yrs, Cities are dynamic spaces where the landscape, specifically the built, changes differently across different spatial and temporal scales. If a building has a design life of 100yrs and is built today, such a building is expected to still be structurally sound in 2110. A building that was however built 80 years ago (with a design life of 100 years as well) will only have 20yrs left in its design life. Applying a one dimensional timescale in terms of using building longevity as a key informant to determining time period, especially in complex and old Cities, is problematic.

Noted. Another good reason to go for 1:100 and not 1:50 years

2. Section 1.5.2: The setback line revision process may also need to be initiated when there is evidence at a local scale of changes in coastal dynamics or effects of storm damage (due – for example – to activities, processes or events which may have increased the vulnerability of the coast to erosion). The current text only seems to only focus on global processes/trends. In this sense, the document should be strengthened in terms of promoting a consultative approach with local authorities who have detailed knowledge at a local scale as well as historical knowledge which is also key.

This has been incorporated

3. Section 1.5.4: Setback lines and existing development: This situation is analogous to the situation where the high hazard zone of inland floodwaters intersects existing development rights. The CSRM Branch has received preliminary legal opinion(still under discussion and refinement) on the question of Council’s ability to curtail existing rights due to the location of the high hazard zone.

Noted. (this section of the report has been removed on request from DEA&DP legal opinion needed)

4. Section 2.2.1 : General Approach 6. Current land use activities should also be considered when determining the setback line. In section 4.1.1 – zoning – consideration should be given to current land use and plans – not just the future ones. Where plans appear to be a few years old, local authority planners should be consulted for up to date information and trends. Land use activities (permanent or temporary) can affect not only the location of the setback line – but also how effectively it can be implemented and enforced. Coastal activities or infrastructure associated with a land use (e.g. mining of sand or other resources; existence of local infrastructure such as slipways or berms) can affect the coastal dynamics which may have an impact on the setback line. (Another major infrastructure pressure likely to increase in future is the construction of desalination plants).

Noted that current land use activities should be considered. Incorporated in report.

5. Section 3.7

Incorporated in report


End of last paragraph: possible typo: CSIR 1988. Only 1998, 1990, 1999 in reference list.

6. Section 4.3 Coastal public property is critical to this process. Public property, along with other cadastral boundaries are fundamental to the coastal setback line in terms of the 25(1)(a)(i) of the Integrated Coastal Management Act.

Noted – this is included

7. Section 5.4.2 and Section 5.4.3: It appears than the formulas used to calculate wave run-up have not factored in erosion trends. Wave run up models determined now must factor in erosion predicted to take place in the future, even if it is incremental, as this will have significant implications for the outcomes of wave run-up models. Similarly, and what is difficult to be factored in is the micro-scale condition of coastal dune cordons. For example, and irrespective of crest height, grain size, etc., whether or not a stretch of dune has a continuous ‘wall’ or has gaps or breaches in it, will affect the consequent extent of erosion and flooding. Surges get into gaps and swirl in depressions behind dune cordons increasing the rate of erosion often irrespective of crest height.


8. Section 4.1 and 6.1: It is strongly recommended that in terms of sourcing biodiversity maps to determine biodiversity on the ground, local municipalities are engaged with to tap into their knowledge and databases on biodiversity matters. A combination of sources of information is always stronger.


9. Section 6.3: a) More detail must be provided on the use of ‘other issues’ as key informants to

determine the position of the setback line i.e. what channels need to be followed to determine access points, where would appropriate access points be located, how would the carrying capacity of access points be determined and how would this effect the location of these points in relation to determining setbacks etc.

There does not appear to have been any mention of setbacks that would contribute to the protection of coastal aquifers (e.g. prevention of ingress of seawater into aquifer) or any setbacks that address what needs to be done where there is coastal mining underway or planned (i.e. presence of coastal minerals or diamonds).

We deem the placement of public access corridors to be a zoning/planning issue - related to setback but not part of the present scope Coastal mining – we propose to treat same as development. Coastal Aquifer – we deem that the potential contamination of a coastal aquifer by sea-water is an important management issue but will not influence the position of the development setback line. (devleopements can be shifted landward but not coastal aquifers)


10. Section 7.3: In the event that a developer does finance a setback line study, mechanisms must be put in place to ensure that such a study is undertaken in the most professional means possible and that local municipalities/provincial authorities play a significant role in overseeing this process.

This is now addressed in the report

11. MILNERTON CASE STUDY Section 3.1: Assess Boundaries The lack of cadastral information is a weakness in this case study. This is readily available information, and reveals an important aspect- i.e. that Transnet owns a strip of the beach along the full study area. As indicated in 4. above, property boundaries are fundamental to the setback line.

Our perception is that having this information in the case study would not have made a difference to the setback line.

12. Section 3.2.7: Sand Grain Sizes Although sand grain sizes are an important indicator of rate of erosion and other coastal dynamics, the measurement of sand grain sizes must take into consideration the seasonal variation in accretion/erosion of beaches in Cape Town. Conclusions should (not) be drawn from a single sample taken over a point in time.

This variability is recognised in the interpretation of the model results – in which the sand grain information is used. Extent of sensitivity to be tested in enabling study.

13. GENERAL From the outset of this study, the concern was raised that the majority of coastal municipalities, if not all of them, do not have the resources, financially or capacity wise, to apply this very rigorous and scientific application of a setback methodology. In light of this, it is recommended that a skeleton framework listing the bare essentials be provided, as well as a simplified methodology that can work with limited information. Such a methodology must be robust, simple and cost effective for those municipalities that are not in the position to conduct such work. Due to the nature of this research, and as a result of the detail required, key informants to determine this setback methodology have been investigated in isolation. In reality however, there are connections between the various processes, where one may influence the other, resulting in non-linearity. This reflects the complexity of systems and where such complexity cannot always be modeled resulting in a degree of uncertainty. Uncertainty should also be used as a key informant in the process for determining setbacks. Erring on a conservative approach would speak to this matter.

Noted. Interim measures and a rapid assessment approach are proposed. Simplified/classification of highly complex processes to get an “easy estimate” of setback is not recommended. Agreed that some interactions do occur between informants (e.g. as you rightly pointed out runup must be calculated on the eroded profile – this is now incorporated in the report).


Modeling is key to this approach and is necessary for the point of departure. However, considering the uncertainty aspect mentioned above, and considering the conceptual issues that cannot be modeled, it is suggested that prior to finalizing the setback, a broadly consultative process on a local level be a phase in the methodology that deals with uncertainty/conceptual issues and which is the final process in determining the setback.

Consultation with municipality has now been incorporated as part of the methodology.

14. Highest Astronomical Tide and Spring High Tide The HAT of 1.2m (Table 3) in the Milnerton case study is different to that of the HAT of the general methodology which indicates 1.4m (Table 1). The SHTs for Cape Town are around 1.80 - 2.00m, which is more than the HAT. Some clarification on this would be appreciated.

Variations are due to local versus national maxima varying. This is dealt with in the report.

15. MINUTES 2.1 Coastal Development Zone should read Coastal Protection Zone’.


John Robinson - Private

16. The existing properties – I would put the setback line where it should be and grant them leeway or permission to not have to do EIA for alterations. I would also make ruling that they may not subdivide or add new structures to the existing plot. This way you stop guys building mega blocks on postage stamp plots of old houses.

This can be considered. Essentially any re-development would require an EIA. But exceptions could be made.

17. What about developments that are currently in the process of preparing EIA studies – can we not force them to wait for the Set back line placement. Maybe those areas subject to EIA studies for developers could receive priority in the creation of the setback line? It is my opinion that the developers are going to make a mad rush to get their foundations (or some such non-reversible) activity) in so the setback line law cannot be applied to them. We need to make this aspect clear or your whole effort is going to be “set back” a lot with new developments being put established in areas that are inappropriate like the examples you have shown and the average Joe Soap buying these properties with little knowledge of these things is again seriously disadvantaged!

We now have in our report a hierarchy of requirements – the 100 m (or 10 m MSL contour) will be default development setback lines. We are proposing that developers can get setback lines analysed under their funding – but with specified conditions (see report). We will propose implementation of this immediately

Mr CW Hendriks - Macassar

Environmental and Nature Conservation Society and Coastal Forum

18. We are a community based environment association for the Macassar and Helderberg Region and are actively engaged in environmental, nature conservation and coastal management. Therefore I need to bring it to your attention that our association's name is called: The and Nature Conservation Society and Coastal Forum In the register of community stake-holders and participants, it would be appreciated that it be noted as such, so that other participants would know exactly what we represent.

� The I&AP List has been amended to include the correct organisation name

19. The two representatives of our organizaton, at the particular stake-holders meeting in

� Noted


Pinelands was: Chairperson:Cedric Wayne Hendricks and Public LIasson Officer: Dennis Roziers

Christopher Vuba - WC

Department of Environmental Affairs and Development Planning Town and Regional Planner:

20. I did not go through the document thoroughly but I did get the key points and focus areas. I found the report to be, (i) a bit too technical, note I am saying 'too' technical, simpler terminology can be adopted to help the person with no engineering background; (ii) it would be good for the consultants to balance the amount or level of detail with an equivalent level of clear guidelines on the methods to be adopted; (iii) the report is well put together in terms of the work that has gone into it.

(i) We have simplified it slightly and included a glossary.

(ii) We have included “boxes” in which we summarise the methodology minimum requirements

Siyabonga Dlulusi - WC

Department of Environmental Affairs and Development Planning

21. PPP document: Name of sections and department. North Cape Department: should read as Department of Environment and Nature Conservation, Not Department of Agriculture , Land Reform , Conservation and Environment. DEADP: Section should be read as Integrated Environmental Management, Not. Environmental Impact Assessment

Noted

22. Set Back Methodology document: Estuaries : In terms of assumptions which flood line methodology to be applied is the 1:50 years or we adopt CapaNature`s recommendations of 1:100 years. City of Cape Town recommends 1:50 year’s setback line which is equivalent to life span of the building of less value.

Policy on estuaries, and on the period (50 or 100 years) for setback lines is now Included in the report.

23. Types of Setback Lines: Erosion and Aesthetic setback line. Where can we fit is setback line for sand mining?. If you can expand a bit on setback line for biodiversity. Also look at the conservation and coastal ecological processes.

We propose that sand mining be treated similarly to development – in updated report. The biodiversity section is now expanded. And conservation (particularly ensuring presevartion of permanent natural vegetation) is now included.

24. Key Finding : Wind speed , Wave run up and Wind set up. In the case of Western Cape south easterly winds are the strongest winds that push sand grains to the coastal dunes and to the structures along the coast. E.g Baden Powell road from Strandfontein to Muizenburg. Also this type of wind pushes the sand grains to the railways line from


Simons Town to Glern cairn and Fish Hoek, this take place on the False Bay side. On the Cape Town area to West Coast North West winds are the problem. This type of wind usually pushes the waves up to 5 to 10 metres high. This type of waves and sea level rise contribute to the negative impact of coastal erosion in the identified study areas that is Milnerton case and Langebaan case. This is seasonally usually happened during winter times. Setback line is needed to avoid the negative impact of coastal erosion to the existing structures and to the future developments. This argument is supported by NEM:ICMA sec 15 (1) and (2) which sec( 2 ) reads “ No person may construct , maintain or extend any structure , or take other measures on coastal public property to prevent or promote erosion or accretion of the seashore except as provided for in this Act”. The prevention of natural erosion in coastal property cause’s huge damages to the adjacent properties. The prevention of natural erosion is not allowed the nature must take its natural course.

Noted. The methodology accommodates all wind setup and associated wave processes. Noted.

25. International practice vs South African practice South Africa needs to learn from the global world. Developed countries planned proactively for climate change mitigation strategies adaptation, response and preparedness strategies to tackle disasters. Hence Disaster Management Act was adopted in 2002 with the experienced learned from developed countries. South Africa adopted Disaster Management continuum and disaster management paradigm shift moving away from re- active response to pro-active approach. Setback line is also a proactive approach in defense of properties to be built in sensitive coastal areas. Properties developed in sensitive areas are having short life span. These properties don’t stand disasters e.g Eden floods of 2007 and the Ethekwini floods of 2005 and 2006. Setback lines need to be behind risk vulnerable assessed areas as well as disaster prone areas. Setback line need to be inline with the municipal SDFs and must be mirrored on the municipal mapping when the line is delineated. Setback line need to be a thin line behind Coastal protection zone. Developed countries had major disaster as compared to South Africa e.g Tsunamis and Hericane cartriners. These all happened in the coastal areas. Then South Africa can use these coastal disasters as case studies.

Noted and accommodated in report. Noted

26. International best practice: Western Australia Western Australia employ sea level rise of 0.38 and setback line allowance of 38 metres for sea level rise. Is the 38 metres allowance focus inland or wave hight? This might be the cause of storm surges.

The 38 m is an allowance for setback (i.e. applied horizontally back from the shoreline)

27. Setback for : B sedimentary or Geotech , C Setback line for Flooding Noted


This has been mirrored in the False Bay case during winter and also when south easterly winds pushes with high speed set up.

28. Preliminary work: City of Cape Town SDF and Saldahna Bay SDF, Please also check West Coast District Municipality SDF.

Noted –the relevant SDF’s have been applied in the case studies

29. Mapping: Please also go beyond SANBI and CapaNature, also check if there is something at SANPARKS and City of Cape Town: Environmental Resource Management Unit.

Noted

30. Heritage: Kindly visit Cape Agulhas National Park information hub, where two oceans meet if they don’t have some information available. Inside there park the is ship wrecks and the area on its own it’s a heritage destination the Southernmost tip of Africa.

Noted. This may be relevant for setback in that area.

31. Priority areas: Those that have development pressure, economic development and human needs.

32. Developer fund setback line study: I’m uncertain to this precisely because the developer will inform the consultant driving the study of what the developer want. This might compromise the correct outcomes of the study and compromise the objective of setback line. Developer will be pro development. We can site example of City of Town cases of Big bay beach and Muizenburg developments. The new developments in these areas are in sensitive areas, they trigger listed activities ito of NEMA EIA regs. At some point environment is compromised for economic development. Yes job opportunities are positive spin offs and the influence of political landscape. Point need to be considered is the existing developments that might be on the sea ward side of the setback line. Municipal strategic environmental assessments reports need to be reviewed.

Noted. We proposed to avoid setback being placed excessively close to the sea by (1) ensuring minimum methodology requirements are adhered to (2) taking a precautionary approach and (3) including peer review in the methodology.

33. Conclusion: So far I’m convinced with the project. Much appreciated if aforementioned aspects will be carefully considered. Not sure of which approach to adopt in setback line. 1:00 years is recommended in terms of Human Settlement Plans and CapeNature recommend 1:100 years flood line and the City of Cape Town recommend 1:50 years of low valued properties life span. Municipal environmentalist, engineers and Planners will play critical role in setback line delineation. The methodology is complex and more of engineering and scientific in approach. The methodology will be easily understandable by municipal engineers and planners. After project hand over Department has to engage on campaigns of persuading municipal councils to understand the methodology and the implementation of NEM:ICMA sec. 25 of the Act. Number of municipalities already complained that they don’t have funding for coastal programs.

Noted.

Andrew Mather 34. On the whole this looks like a good and well thought out approach although I am still Have included rough costing in the


- eThekwini Municipality Coastal Policy

concerned that costs will be an issue so perhaps the team could give us the average cost per km of the two pilot site so we can get a feel of relative costs for future work.

report

Pg 4 Table 1.1 I have recently redo this table with now four categories (see attached word file) pg 6 I agreed where dev has already overstepped the set back lines these dev must not influence the correct location of the set back line. Essentially this will mean restricted redevelopment of these properties and if they eventually get destroyed they cannot be permitted to be rebuilt.

included this

pg 8 I don't find the references to the Western Aus case useful. Setback depends on the wave climate which in turns shapes the coastal profile and if, as we have along the open coast of KZN, a cut off depth at -18m at between 500-1000m off shore (very typical of our coastline) then the retreat is as low as 25m to as high as 50m using Bruun rule for 1m of sea level rise (verse 40m for 0.38m West Aus.). Or alternatively a rule of thumb for each coastal province needs to be defined to use in the absence of any modelling or info.

We now indicate the following after the

Western Aus case: “It is not advocated

that such values be used, since each

region or site must be analysed

individually, but this provides a useful

indication of the order of magnitude of

setback allowance for sea level rise in a

wave climate roughly similar to that of

South Africa”.

pg 12 Topographical surveys should ideally be at 0.1m RMS vertical accuracy with a default of 0.3m RMS as the coarsest. How do you model SLR when the value of SLR is smaller then the accuracy of the survey? unless you are only going to deal with 1m of SLR which is acknowledged as the most unlikely in 100 years.

Good point – we have revised our

quote to ±0.1 m to ±0.3 m at most

Pieter

Badenhorst

35. Still maintain that you are all coastal engineers with limited coastal management experience.

Perhaps we need more clarification – can you elaborate on what unique experience comes from coastal management? (specifically relating to the siting of the setback line). I would not like to miss anything in our methodology. The question should be asked whether a similar setback could be achieved using experience, Bruun Rule, historical data and CZM.

36. Also note I did not say a handful of aerial photographs are adequate.

Our experience, however, is that only a handful (6 to 10) is available at many


sites.

37. The setback you refer to at Paradise Beach - I do not know who determined that setback – and when – and what it was. There are, however, other processes at play that has an impact and most likely little to do with sea level rise. Remember the CSIR did many studies there MANY years ago. I cannot comment on the Hermanus example – do not know that site. I am making the above comments because I do setbacks here and there using info you refer to except the modeling. The issue is important and not the very few projects I might loose.

We recognize that not every consultant is up to date with computational modeling and as a result are trying not to be exclusive in this regard. To accommodate this, one recommendation we have (now) made is to create a “Wave Atlas” up front, which would allow all consultants to access near beach wave data without having to do the modelling. The only modeling that could not be handled by the “non-modelling” consultant would be beach erosion and if necessary, shoreline modeling (this would only be needed at very limited sites impact by anthropogenic effects).

38. Although you say it will not be “expensive” I wonder what you mean by that. Unless Province will do these setbacks there will be a problem with cost at Municipal level.

We have had a look at costs and estimate that the beach modeling would be some 10% to 15% of the total setback line cost. I would argue that without this modeling you would incur costs in terms of (a) the time spent trying to infer erosion with very limited information and (b) possible cost implications of getting it wrong (storm damage!).

39. Lastly – please let me know from where wind and wave data is available for free.

Sent to I&AP

Frans 40. To determine beach set back lines is to enter an extremely complex field subject to all sorts of interpretations and understanding. There are no hard and fast rules and it is at best a guess. It is essential that agreement on the period over which the setback line is applicable be reached beforehand. Depending on the ownership the period can vary as stated in the slide show.

Agreed that this is extremely complex and that it is a challenge to establish rules. At this stage the methodology provides some guidelines and methods which elevate the estimation of the setback line well above “guess” status. However, we also strongly


emphasise that coastal practitioners (engineers, scientists) must conduct the work or at the least, review it.

Regarding period of applicability, we have addressed this in our report.

41. The fact that determining a setback line is becoming a legal requirement in terms of the Integrated Coastal Management Act makes it essential that any Methodology must be able to meet court of law requirements. It is suggested that reference to “all Ministers and MEC’s” be removed and replaced by “Government departments (central and provincial) and Municipalities”.

Good point, but beyond our brief to change the ICMA. I assume this is not addressed specifically to us.

42. The methodology as set out by WSP is probably the best available. The following comments on the draft are offered. It is recommended that coastal sections which does not require beach setback lines be identified early on, and be excluded from studies. For example it would appear unnecessary to determine setback lines along the Otter Trial section of the coast.

We have recommended a default, interim setback for such sections of coast as the Otter Trail, in our report. Also indicated priority areas.

43. The fixing of setback lines is extremely sensitive to the nature of the coastline and of the subseabed.

- Recognised and we propose wave modelling (that takes into account the subsea bed contours) to accommodate this.

44. The effect of extreme flooding must be taken into account.

- Thank you - addressed in the report

45. Bodies not obeying sensible beach management must be seen to be taken to task and repair damages caused by their activities.

- Agreed

46. Setback Line Methodology must not be dependent on cost and time – constraints in data collection.

47. - Agreed. We propose time-efficient means of data collection up front (such as aerial Lidar topography survey which works out to be economical at the scale required).


Details in our report.

48. The application of rule of thumb techniques to determine water levels is not acceptable.

- Agreed. We now propose some alternative approaches in our report. Amongst these we propose an upfront study of tidal and water level records to assess storm surge and actual water levels.

49. Existing natural protection to beach changes to be identified early on and taken into account in determining set-back lines.

Agreed – this is accommodated in our report

Gerhard Gerber Dept. Environmental Affairs & Development Planning

50. Main Report

Background and Motivation

It is recommended that the background and motivation rather be combined under the heading background. In terms of reference is clear that the setback lines are to be determined in terms of both the NEMA EIA Regulations and the ICMA. The background should touch on this but should also provide the argument and context for the determination of coastal development setback lines. The section could for instance start with a statement along the lines of:

Coastal areas are sensitive, vulnerable, often highly dynamic and stressed ecosystems. Increasingly coastal areas are also being subjected to climate change impacts along the coast related to rising sea-levels, the increase in the frequency and intensity of storm events, and stormwater runoff in coastal areas. Coastal areas therefore require specific attention in management and planning procedures, especially where the coastal areas are subject to significant human resource usage and development pressure.

The National Environmental Management Act and the Environmental Impact Assessment Regulations, as well as the Integrated Coastal Management Act therefore now calls for coastal development setback lines to be determines…etc…etc…

Done Incorporated a similar statement

51. The section on “Facilitation of Development” (1.2.1) should also be amended. It is not so much about reducing delays in the construction of municipal infrastructure through unnecessary EIA, but rather that strategic infrastructure planning is more appropriately informed by strategic environmental assessment with coastal setback lines to be strategically determined, rather than ad hoc project level assessment having to be done for different infrastructure projects. The other point is that the determination of coastal develop setback lines will enable the

This has been amended


refinement of the course “within 100 metres of the high-water mark of the sea” threshold used in the EIA listed activities, with the setback resulting in improved protection being given to the coast and resulting in unnecessary EIA being prevented.

52. The section on “Safety of developments” (1.2.2) end of by referring to “Taking into account sea-level rise it is vital that development setback lines are established so that such problems do not recur”. This should read “Taking into account sea-level rise and increases in the intensity and frequency of storm events it is vital…”.

Not in agreement until this is a certainty (no literature clearly proves this). At the same time, it is recognised that higher water will result in more frequent and higher waves at the beaches.

53. Study Objectives & Requirements

The section on study objectives should be expanded. I would recommend that the study objectives and requirements be combined into one section under the heading “study objectives”. Proposed wording:

In order to ensure that the best available and practicable method, taking due cognisance of our South Africa context, is consistently used for the determination of coastal development setback lines, a project was therefore undertaken to develop and test a methodology for use in the Western Cape, but ideally in the whole of South Africa, for the determination of coastal development setback lines…etc…etc…

We would like to retain the direct reference to the TOR in terms of requirements. Additional conditions etc are included.

54. Assumptions

Time periods

In terms of time periods (1.5.2 and 1.5.2), mention should also be made of the need for a precautionary approach in that while some infrastructure might have a certain design life, there will not be enough resources nor would it be possible for a “retreat” in future in terms of having to in future shift lines and development. The time period therefore becomes important in terms of the minimum information required to make the determination, but a precautionary approach with a long-term focus would be required. The time period also relates to how often setback lines should be revisited, with the clear indication that continuous monitoring should be undertaken.

While in certain circumstances a setback might be determined for a specific development, the setbacks will mostly be determined for entire settlements and extensive stretches of the coast. As such, to make use of different time periods for different infrastructure does not make sense.

The need for a precautionary approach has been incorporated in the report. Monitoring (beach profiles) has been emphasized. Monitoring is recommended Agreed that this could result in a checkerboard with different lines. Can apply a lower period only for a continuous zone. Incorporated in report

55. Number of setback lines

It is agreed that there must be more than one setback line (1.5.3) namely the coastal process

Noted


(“no development”) setback line and a limited or controlled development setback line.

56. Setback Lines and existing development

It is stated in the section dealing with “setback lines and existing development” (1.5.4) that:

“The risk of relocating the coastal setback line seaward of existing developments is that this may transmit the message that such a development is safe from coastal processes. This could have legal implications should any damage to the development occur as a result of the coastal processes. However, the risk of placing the development setback line through an existing development may be that the implementing authority will be held responsible for increased insurance premiums or associated coastal protection costs.

Another scenario is the establishment of a setback line through a proposed development area. In this case, government may be held liable for losses associated with undevelopable property.

DEA&DP is to seek legal advice to guide the establishment of setback lines in these situations.”

In accordance with comments from Paul Hardcastle this section has been modified.

57. While the implications for existing development must be highlighted, these statements contain incorrect assumptions and information, and must be removed/reworded. The only correct assumption is contained in the last sentence which states “It is assumed that the coastal processes (no development) setback line will be situated in its position determined as if no development exists”. The wording in section 25 of the ICMA that deals with the establishment of coastal set-back lines are clear. Firstly, it does not give the authority discretion in terms of whether or not set-backs are to be determined. The authority “must”. Secondly, in terms of this nondiscretionary duty on the authority it is further clear that one of the specific reasons why set-back lines must be determined is to “prohibit or restrict the building, erection, alternation or extension of structures that are wholly or partially seaward of that coastal set-back line”. In this regard it becomes important to distinguish between the coastal process setback line and limited or controlled development setback line. The coastal process setback line is to a large extent a factual determination based on the processes occurring in the area. If an existing development is found to be situated seaward of a coastal process setback line, it does not imply “no development”, but rather that the authority must “prohibit or restrict the building, erection, alternation or extension of structures that are wholly or partially seaward of that coastal set-back line”. While ICMA places a general prohibition on interference with coastal processes and in particular with coastal erosion, an even stronger prohibition is placed on these activities sea-ward of a coastal setback line. But, yes, there are two different setback

In accordance with comments from Paul Hardcastle as well, this section has been modified.


lines. The “no development”/development prohibition line, and the “limited or controlled development”/development restriction line. The ICMA also clearly addresses the matter of existing development and government’s responsibility.

58. Firstly the ICMA defines the “high-water mark” as “the highest line reached by coastal waters, but excluding any line reached as a result of (a) exceptionally or abnormal floods or storms that occur no more than once in ten years; or (b) an estuary being closed to the sea”. With climate change resulting in an increase in the intensity and frequency of storms, it means it is becoming normal that storms that might in the past only have occurred once in ten years, will occur more frequently. The line that will be reached by storms occurring more than once in ten years (i.e.) the high-water mark) must therefore be determined as one of the lines to be determined as part of the bigger coastal setback line determination. Monitoring will also have to be regularly done in order to determine how the high-water mark is in fact moving.

Important to distinguish between this HWM as defined and the waterline as per the aerial photo analysis. We make use of the waterline in determining the setback location, since this is the line which is visible on aerial photographs.

59. The following sections of the ICMA, inter alia, further refer with regards to existing developments, the rights of property owners, and the responsibility of the State:

14(5); 14(6); 15(1); 15(2); 27(6); 59(4); 60(1); 62 (1); 62 (2); 67(1); 67(3); 97(1); 97(2); 97(3); 100.

In summary then: coastal set-back lines must be determined (but informed by public participation), specifically to also prohibit or restrict development; if erosion occurs and even if it impacts on existing development, there is a prohibition on any person doing anything about the (natural) erosion nor can they expect the State to do anything about it and in fact if the high-water mark shifts as a result, the affected portion of private property is automatically expropriated; even if a person was lawfully engaged in carrying out, in the coastal zone, an activity requiring environmental authorisation, the person will have to reapply for authorisation if that person wants to continue carrying out the activity; and the State is not liable for any damage or loss.

Noted

60. Study Approach (the “how”)

Section 1.6 dealing with the “how” should be reworded. Yes, it is about the method used to determine the methodology, but the “how” is also about indicating “how” it came about that the specific setback methodology are being proposed as the methodology of choice. In other words, the reasoning/logic and “development” of the methodology must be clear. In other words: what other methods did the literature review find existed? How do the different methods compare with each other? Why are certain methods or specific criteria or aspects more suitable than others? (For example, it is not good enough to on page 8 simply state that items 4 and 5 are not to be applied without explaining why.) What are the specific reasons for the final

Substantiation of various methods selected (why this and not that) is now provided throughout the report.


methodology being proposed as the most suitable? What was the specific methodological challenges that had to be addressed? What was raised during the testing of the methodology and how were these issues resolved in terms of what is being proposed? Etc…etc…

61. If these aspects are not documented, it opens up the recommended methodology for criticisms without being able to address the criticisms; as well as not allowing for “learning” in terms of being able to revisit the specific considerations as new technology and new information becomes available over time.

Noted – as above, substantiation is now provided throughout the report.

62. One of the reasons why the development of the methodology was commissioned was specifically to be able to make a defendable argument for a best practice practicable methodology that is to be consistency used. If the argument is not made strongly enough for the specific methodology proposed, it will result in other proposing alternative methods without the authority being able to argue why the preferred methodology is to be used. In this regard the specific criteria to be used (and even how the relative importance of the different criteria – i.e. different criteria to be weighted), the specific aspects to be considered, and the specific steps of how to apply the methodology, must be provided. The document is not to simply put forward a broad approach to follow, but rather a specific enough methodology to allow for consistency in the application of a best practice methodology.

The report now provides specifics where possible in an effort to make the methodology repeatable (by different practitioners). It has to be recognised that considerable experienced judgment is still required

63. Form of the Report

In terms of the form of the report (section 1.7), reference should also be made to the other reports (case studies and public participation) to be read as part of the methodology report.

Incorporated in the report

64. Different lines

Section 2.2.1 states “Assessment of the erosion setback line should include separate assessments of long-term erosion trend, short term erosion, (by storms) and erosion (and/or setback) due to sea-level rise. These are added together.” The general approach should also highlight that due consideration must also be made of the fact that historically determined high-water marks must be redetermined. As stated earlier, with climate change resulting in an increase in the intensity and frequency of storms, it means it is becoming normal that storms that might in the past only have occurred once in ten years, will occur more frequently. The line that will be reached by storms occurring more than once in ten years (i.e.) the high-water mark) must therefore be determined as one of the lines to be determined as part of the bigger coastal setback line determination.

It will not be acceptable to specify setback relative to a high water mark that is migrating over the years. We specify the point relative to which the setback must be applied in our study. (end of section 7.2)

65. Together with the comments earlier related to setback lines and existing developments the following must also be considered and highlighted in terms of the different options to be considered in terms of “retreating”, “holding the line” and “advancing the line”. While the

Noted


general approach of the ICMA is to facilitate “retreat” in that the ICMA places a general prohibition on interference with the natural coastal processes, the ICMA does allow for the authority to either itself or to permit a person, to take action to either “hold” or “advance” (reclaim) the line. In terms of deciding whether or not to allow activities that will “hold” or “advance” the line, section 62(2) of the ICMA is clear that a decision on whether or not to allow an activity that may have an adverse effect on the coastal environment must be informed by an environmental impact assessment. The ICMA makes it clear that in deciding the authority must also specifically give effect to the purpose for which the coastal protection zone is established namely to:

• protect the ecological integrity, natural character and the economic, social and aesthetic value of coastal public property;

• avoid increasing the effect or severity of natural hazards in the coastal zone;

• protect people, property and economic activities from risks arising from dynamic coastal processes, including the risk of sea-level rise;

• maintain the natural functioning of the littoral active zone;

• maintain the productive capacity of the coastal zone by protecting the ecological integrity of the coastal environment; and

make land near the seashore available to organs of state and other authorised persons for performing rescue operations

66. The ICMA also states that the authority may only authorise activities that:

• is likely to cause irreversible or long-lasting adverse effects to any aspect of the coastal environment that cannot satisfactorily be mitigated;

• is likely to be significantly damaged or prejudiced by dynamic coastal processes;

• would substantially prejudice the achievement of any coastal management objective: or

• would be contrary to the interests of the whole community;

if the activity is overwhelmingly in the interest of the whole community despite the adverse effect it is likely to cause to the coastal zone, and on condition that any irreversible or long-lasting adverse effects must be mitigated as far as is reasonably possible.

The “Bruun formula” mentioned on page 7 must be described. When referring to the formula being inappropriate in certain instances on page 19, more information must also be provided.

More information on the Bruun Rule is provided


67. Data Collection

The data collection (section 4.1) as part of the preliminary work should also be informed by public participation in order to also collect data on the socio-cultural characteristics of the area under consideration.

In the sections on how the different setback lines are to be determined, the role of public participation and how it should be undertaken is also to be provided.

Included in report Public participation now incorporated in the report

68. Zoning and future plans

On page 11 reference is made to “Strategic Development Framework (SDF) of the local municipality”. This is not correct. It must read “Spatial Development Framework”. Also make this correction in Table 4.1. There is also reference to a “Rural Development Framework (RDF)”. Page 16 also makes reference to “Rural Development Framework”. What is this? There is no such municipal spatial framework. An SDF is developed for the entire municipal area – urban and rural areas.

This section should also make reference to having to consult any Environmental Management Frameworks that have been adopted for the area in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) and the EIA Regulations.

Corrected in report

69. Erosion setback

Section 5.2 refers to the “maximum erosion line on the existing surface of the earth (at the time of establishment) that can reasonably be expected (as a result of elevated water-levels and storms) in the time period applicable”. The comments raised earlier related to the definition of the “high-water mark” and the requirements for different lines to be determined must be considered in this regard.

Noted

70. Setback for biodiversity

The setback for biodiversity is not just about critical biodiversity areas of ecological support areas. The vegetation, regardless of the threatened status therefore, plays an important role in terms of ecological integrity, stability and aesthetics. An adequate strip of coastal vegetation should therefore be protected along the coast to allow for the maintenance of ecological integrity, stability and aesthetics.

Noted and incorporated in report

71. Setback for other issues

The section (6.3) dealing with setback for other issues provides too little information. What exactly is to be considered, how and what data is required? Etc…

Noted: More detail and figures provided.


72. Expertise

In terms of the required expertise mention must also be made of the requirement to have expertise in terms of the legal requirements governing the determination of coastal setback lines.

Noted and incorporated.

73. Priority Areas for setback lines

While section 7.3 proposes that priority be given to areas earmarked for development, there is also a need for priority to be given to areas with existing development that are vulnerable to or already being negatively impacted by coastal processes.

Noted and incorporated

74. “Quick and Dirty” Method

No mention is made in the report of a “quick and dirty” precautionary first line that can be determined (as for instance proposed in the CapeNature Paper) and then later defined using the more detailed methodology.

This is now incorporated

75. International Best Practice

Some of the best practice information provided is very limited and no indication is given of how the methodologies compare.

Now expanded within the report

76. Langebaan Case Study Report

“development setback line”

The “definition” provided of “development setback line” on page 1 reads “that boundary along the beach front landward of which infrastructure development can take place with relative safety”. Setback lines do a lot more than that and this definition is problematic. The terminology used in the Main Report, namely coastal process (“no development”) setback line and a limited or controlled development setback line (i.e. both being coastal development setback lines, but simply being two different types of setback lines), should be used consistently throughout the reports.

Revised to comply with the methodology report

77. Coastal erosion setback only

On page 1 it is stated that “for the purpose of this investigation, an erosion setback line will be determined assessing the shoreline at the study areas (sites)”. In other words the methodology was not tested in terms of determining a “development setback line”? In this regard it is noted that while setback for biodiversity and heritage was considered, in the end (as stated on page 16) no setback was allowed for biodiversity or for heritage or for other issues. Why was aesthetic issues for considered?

This was not correct and has been addressed. Aesthetics and other issues are considered in updated report.


78. Public Participation

Section 4 on page 17 simply states “In a study the above results would be published once comment has been received and addressed where relevant by focus groups”. This is not adequate. As stated earlier part of the data gathering process also includes public participation. The engagement with the public must inform the ultimate setback line. Part of the methodology therefore also consists of public participation, and as such the testing of the methodology should have included the testing of public participation as a component of the bigger method.

As noted in the minutes of the meeting held on 23/02/2010, “Public should participate on methodology ONLY, not on the results of setback line studies”. Also, since the setback line determined in the test cases were not going to be published in the Gazette, there was no need for informing the public of the results

79. Conclusion and recommendations

The conclusion and recommendations on page 18 is not clear and does not address the ultimate options of “retreat” versus “holding the line” versus “advancing the line”. It is for instance not clear if specific measures to firstly reclaim some land (“advancing the line) and second to then “hold the line” are being proposed.

Now clarified and learning points from the case studies are reported. Note that the options mentioned (hold the line etc) are deemed to be a management issue. While requiring consideration not deemed an essential part of the methodology.

80. Milnerton Case Study Report

“development setback line”

The “definition” provided of “development setback line” on page 1 reads “that boundary along the beach front landward of which infrastructure development can take place with relative safety”. Setback lines do a lot more than that and this definition is problematic. The terminology used in the Main Report, namely coastal process (“no development”) setback line and a limited or controlled development setback line (i.e. both being coastal development setback lines, but simply being two different types of setback lines), should be used consistently throughout the reports.

Revised to comply with the methodology report

81. High-Water Mark

It is stated on page 3 that “high-water mark and not the water-line at the time the photograph was taken” was used. Was the high-water mark predetermined as indicated earlier in terms of the IMCA definition of high-water mark?

This was actually not the high water mark (as per ICMA) but rather the water line. Now corrected

82. Overtopping Manual

The Overtopping Manual mentioned on page 14 should be provided as part of the setback methodology.

Reference provided – however important that the most up-to-date information be used at all times.

83. “Coastal Protection Zone” Accommodated in report


Section 3.5 on page 14 states that “the site falls within the coastal protection zone and is thus considered to be a no development zone”. Please note that while a Coastal Protection Zone demarcated in terms of the ICMA does allow for better regulation of land use within this zone, it does not mean “no development”. In fact section 62(2) of the ICMA read with some of the other sections and ICMA provisions highlighted earlier does in fact make it possible for the authority, if it is justified to do so, to authorise land within the coastal protection zone to be used for an activity that may have an adverse effect on the coastal environment. A setback for biodiversity should therefore have been considered.

84. Setback for Hertitage

Section 3.6 on page 14 is not clear on why “no setback distance was allowed for heritage”.

Now accommodated in report

85. Public Participation

Section 4 on page 16 simply states “In a formal setback line study, the above results would be published once comment has been received and addressed where relevant by focus groups. This will not be done for this case study as this study is mainly concerned with the testing of the proposed methodology”. This is not adequate or correct. As stated earlier part of the data gathering process also includes public participation. The engagement with the public must inform the ultimate setback line. Part of the methodology therefore also consists of public participation, and as such the testing of the methodology should have included the testing of public participation as a component of the bigger method.

As noted in the minutes of the meeting held on 23/02/2010, “Public should participate on methodology ONLY, not on the results of setback line studies”. Also, since the setback line determined in the test cases were not going to be published in the Gazette, there was no need for informing the public of the results

86. Conclusion and recommendations

The conclusion and recommendations on page 17 is not clear and does not address the ultimate options of “retreat” versus “holding the line” versus “advancing the line”. It is for instance not clear if specific measures to firstly reclaim some land (“advancing the line) and second to then “hold the line” are being proposed.

It is also stated that “This study was conducted with deliberate disregard for appropriate setback line studies previously conducted at the site (e.g. CSIR (1988) and Smith (2003))”. Why? No reason is given for this.

Now clarified and learning points from the case studies are reported. Note that the options mentioned (hold the line etc) are deemed to be a management issue. While requiring consideration not deemed an essential part of the methodology. Disregard for previous studies now explained

87. Public Participation Report

Public Participation as part of determining the methodology and for implementing the methodology

Yes, public participation had to be addressed both as part of the determination of the

Agreed – public participation is a key component of methodology. Section 3 of the stakeholder engagement report includes the proposed methodology.


methodology and as part of the methodology itself.

88. Heritage Western Cape

In Table 2 mention is made of “Western Cape Heritage”. This must read “Heritage Western Cape” throughout all the documents.

This has been changed

89. Approach

The approach recommended in section 2.3 should have made specific mention of the ICMA coastal management co-operative structures (e.g. the Coastal Committees). It is also not clear if public meetings are being proposed or not.

Public Meetings have been included in the final PPP report

90. Comments and Responses

While Appendix F provides an issues table to shows the comments received, no responses to the issues raised are provided?

These issues were raised at the stakeholder meetings, and where therefore responded to within the meeting. Therefore it is not necessary to respond in this report. All written comments received on the draft report were responded to in Appendix G and H.

91. Some concluding comments

The Department new from the start that the project would be a challenge, in that it deals with many contentious and complex issues. The methodology development process was therefore considered to be a learning process and that the documentation would also record the “development”. In having to deal with many contentious and complex issues, the recommended methodology must ultimately provide clear guidance in order to ensure consistent application of the best practice methodology. While those that will in future actually determine coastal setback lines will have to have the required expertise to implement the methodology, the recommended methodology must be set out in such a way that it clearly provides the step my step methodology to be applied. Being a public document, the methodology report must also speak to the person in the street and use simple language and provide enough explanations of technical terms (e.g. through using text boxes to explain terminology).

Addressed in report through:

• Glossary provided

• Better explanation of why various approaches proposed

• Text boxes indication minimum requirements for setback line assessment.

92. Ultimately the report on the methodology must also form an integrated whole. Currently the different reports do not really speak to each other.

This is being addressed – via cross-reference to learning points in case studies and inclusion of public participation within the report

Alexia Julius 93. Page 11: The paragraph on Zoning and future plans should refer to Spatial Development Corrected


- DEA&DP

Frameworks and not Strategic Development Frameworks. Also, it is not clear to what Rural Development Framework there is being referred to here. Are you referring to the Rural Land Use Planning & Management Guidelines (May 2009)?

Yes - corrected

94. Page 14: In Table 4.1 and under the Data column (4th row down) it should again be Spatial

Development Framework and not Strategic Development Framework. Corrected

95. Page 28: Under paragraph 6.3 there is being referred to limited/controlled development. In one of the Steering Committee Meetings I raised the questioned as to whether it would be indicated in the document what constitutes limited/controlled development. I have not however, picked this up in any of the 4 documents.

Now elaborated on this in section 3.1.

96. Langebaan Case Study:

Page 3: In table 1 the source for the data for the SDF should be the Saldanha Bay Municipality.

Corrected

97. Milnerton Case Study: No comment.

Noted

98. Draft Public Participation Report: No comment.

Noted

CapeNature representatives

99. Section 1.2.5: Could possibly be reworded – “buffer zones between the high water mark and development must be provided where this is critical to protect and maintain biodiversity pattern and/or processes.

Corrected

100. Page 5: Number of Setback lines – need to possibly make it clearer whether line 1 (coastal processes or no development setaback line) is an absolute no go area i.e. development will not be allowed even with an EIA.

We propose that this be a “no go” area even with an EIA – this is included

101. Secction 7.2.3: Could possibly reword second half of sentence “…..to ensure that development is limited/controlled to protect areas of high conservation value.”

Corrected

102. General points: It is clear that many coastal municipalities do not have the resources to apply such a scientific

This is now included – see section 9.6


approach to determining setback lines, or at least not in the near future. We would therefore like to see an interim setback line proposed which will protect infrastructure and maintain biodiversity.

103. With reference to the paper presentation done by Roets & Duffell-Canham (2009) where a 5m amsl is proposed as a setback we would like to make it clear that this was not derived from the table alone, and definitely not by adding up numbers in the table. The table merely gives the various sea level scenarios used to do scenario building that showed the likelihood of water levels reaching 5 m above msl in estuarine systems when these conditions may coincide. The example in the table was measured levels on the Natal coasts that were published by Theron and Rosouw as referenced. Adding up the levels in that Table brings the rolling water on the coasts to an astonishing 13 m above msl. These waves hit the Natal coastline. This type of event can easily cause water levels to rise in an estuary to 5 m above msl, particularly when it coincides with a flood. Whilst some believe that 5 m amsl is too conservative we believe it is better to err on the side of caution until more precise predictions can be made.

For the exact reason of numbers “not adding up”, the table was copied from the original source (with modification of excluding the wave run-up from the table) without a “TOTAL:” value. We believe the wording introducing the table makes it clear that the numbers in the table serve as a basis and not the absolute components summed to result in 5.0m AMSL.

104. It is commonly accepted now by all authorities (co-operative governance) that developments must be kept above the 1 in 100 yr flood line, including a 30 m buffer, and at estuarine systems above the 5 m contour. These levels are also in line with other documents like the PSDF, National Water Act, and published documents of DEADP “Status Quo Report on Climate Change”. We have to be consistent and therefore align standards between different planning and decision-making documents.

Agreed


Appendix H Issues & Response Table – Draft Report


I&AP No. Comment Response

John Robinson - Private

1. The existing properties – I would put the setback line where it should be and grant them leeway or permission to not have to do EIA for alterations. I would also make ruling that they may not subdivide or add new structures to the existing plot. This way you stop guys building mega blocks on postage stamp plots of old houses. What about developments that are currently in the process of preparing EIA studies – can we not force them to wait for the Set back line placement. Maybe those areas subject to EIA studies for developers could receive priority in the creation of the setback line? It is my opinion that the developers are going to make a mad rush to get their foundations (or some such non-reversible) activity) in so the setback line law cannot be applied to them. We need to make this aspect clear or your whole effort is going to be “set back” a lot with new developments being put established in areas that are inappropriate like the examples you have shown and the average Joe Soap buying these properties with little knowledge of these things is again seriously disadvantaged!

We would recommend that developers either be obliged to conduct setback line studies in accordance with the methodology and/or the calculated setback line be reviewed to confirm that the aspects indicated in the methodology are taken account of.

Mr Alf Williams - Jacobsbaai

RatepayersAssociation

2. Thank you for affording us the chance to comment on the final report and to view our concerns. Jacobsbaai is situated halfway between Saldanha Bay and Vredenburg on the Cape West Coast. Jacobsbaai is a small quaint village with only 240 houses and one Hotel/Restaurant which is situated almost right on the beach and close to the dunes. Approximately five houses have been built in this area but unfortunately right on top of the dunes which in my opinion was a major mistake by Municipality to have allowed this to continue. My major concern at this present moment is that further development is planned with many more houses to be built on the same dune area. Time is of an essence now to nip this project in the bud so that further destruction does not take place, not to mention that the natural beauty of the bay will be spoilt forever. Another area of Jacobsbaai is Mauritz Bay where houses have recently been built close to the high water mark. Corrosion is already taking place on the beach and last year high water due to heavy winds and seas flooded this area. There is still some vacant plots of land which could in the future become a victim to the erosion process. Is there any way that your organisation can be of assistance by means of firm notices that further development should not take place without thorough investigation. Further to my mail sent to you yesterday, I have a picture attached which will give you a better idea as to our concerns. All the houses shown on the picture are built right on top of the dunes. Please note the area where many more houses are intended to be built. However I will

Although WSP is involved in developing the coastal setback lines, which will prevent this type of development in the future, unfortunately we assist you in this regard, as this does not fall within the scope of our project Suggest your best course of action would be to obtain a memorandum of ‘no development’ for these areas in conjunction with the local municipality. If your Ward councillor is active, perhaps given him/her a call and find out how they can assist you. These types of development projects should have to go through and Environmental Impact Assessment process. The proposed developments should be advertised, and you should be given the opportunity to register as a


do my best to see to it that this does not happen. stakeholder. Stakeholders should be given an opportunity to submit comments on the EIA and appeals (if a decision is made by the Department of Environmental Affairs and Development Planning).

C W Hendricks - Macassar


3. I just want to thank you for the information about the progress on your study that you are doing. I will give our associations comment after we've studied the documents more closely. We are an community based environment association for the Macassar and Helderberg Region and are actively engaged in environmental, nature conservation and coastal management. Therefore I need to bring it to your attention that our association's name is called : The Macassar Environmental and Nature Conservation Society and Coastal Forum . In the register of community stake-holders and participants ,it would be appreciated that it be noted as such, so that other participants would know exactly what we represent. The two representatives of our organization, at the particular stake-holders meeting in Pinelands was: Chairperson: Cedric Wayne Hendricks and Public Liaison Officer: Dennis Roziers

The name of the organisation has been changed on the list and in the document.

Richard A Rundle - Woodridge Island Body

Corporate

4. 1. The Woodbridge Island setback line was established by the CSIR as described in their 1983 report C/SEA 8373. Over the passage of nearly 30 years this has been shown to be relatively accurate, withstanding with great success a 1:50 year storm. Since that was a successful process it must have some value in determining setback lines along other, less complex coastal stretches.

Agreed - Some of the methodology and results of this CSIR study are referred to.

5. 2. The proposed methodology lists components of the setback calculation as sea level rise, long-term erosion, storm erosion distance, and estuary mouth meander. Our comments: a. Sea level rise: In the proposed methodology a sea level rise of one meter in 100 years is proposed. This is as opposed to a current sea level rise of approximately 3 mm per year, which in 100 years would give a 30 cm rise (all things being equal). Our concern with the United Nations' Intergovernmental Panel on Climate Change projections are that it and its leading scientist, Dr R.K Pachauri, have been discredited for the fabricated data upon which they based their predictions of a global meltdown. For example their prediction of thermal catastrophe in Antarctica was based on temperature readings since 1979 from the few weather stations that were reporting temperatures since that time. The missing

This assumes a linear increase in sea-level rise. Sea level rise is predicted by the IPCC to be exponential. We are aware of some discrepancies, and we have elected not to depend only on the IPCC, due


data was extrapolated by computer model that has not been made available for peer review. In fact last year's Antarctic sea-ice cover was 30 per cent above average. Also the "melting glaciers" in the Himalayas was found to be based on a magazine story, and the global warming "recorded" in Siberia is based on the rings of a single larch that the Climatic Research Unit in Cambridge chose specifically to fit their other data, purposefully dismissing contrary evidence in surrounding trees. One of the conditions that this methodology is required to comply with is that it should be generally conservative in considering the accuracy of data, methods and climate change. We would prefer that such a methodology take cognizance of the lack of statistical verification of the IPCC data, extrapolations and conclusions, and apply a suitable modifier.

to recent shortcomings and their apparently slow reaction time. However, literature on sea-level rise is available from many sources (see section in methodology report). It is literature from diverse sources that has resulted in the CSIR employing an upper limit of 2 m rise in sea level rise by 2100. Thus the selected rise of 1 m is certainly not the most conservative, despite the precautionary approach being prescribed in the ICMA.

6. b. Long term erosion: If one keeps in mind the inaccuracy of taking a waterline from an aerial photograph, when the exact time of the taking of the photograph, and therefore also the tidal level, are frequently not known, then any variance applicable to this component should also be adjusted with a suitable modifier. Evaluation of this process should also take into account the effects of hard structures in the sea, structures that could materially affect long-term beach erosion as with the construction of the Cape Town, Port Elizabeth and Saldanha harbours.

The limitation is recognised and it is for this reason that a supplementary modelling approach is recommended. Effects of offshore structures and dredging is now specifically part of the methodology – when such anthropogenic effects are discerned, the level of the study is to be elevated and includes (calibrated) shoreline modelling

7. c. Storm erosion distance: Computational modelling is well known to be fraught with failures. When applied to a specific task, for example the aerodynamic lift characteristics of a wing, the model can be empirically tested and then deviations in the model can be corrected. But when applied to a complex, multi-dimensional, dynamic, multi-material structure such as an ocean-beach-dunes interface, where there is no prospect of independent verification except perhaps 100 years hence, then we fear the result will almost certainly be suspect and useful only as a guide to a starting point. Characteristics of the different components not taken into account in a model may also have a deleterious effect on the results. For example although the relative size of the sand has been factored in, the shape of the grains of sand has not (the shape determining the aerodynamic characteristics of windblown sand). There is also the ground effect "air cushion" effect as described by Konstantin Tsiolkovsky in his 1927 paper "Air Resistance and the Express Train", an effect that determines how far sand grains will be carried by wind or waves.

We are more than aware of the limitations of computational modelling, which is why we propose (a) validation of models where possible (b) not relying on models as the only source of analysis and (c) peer review.

8. 3. Regarding site visits, we would recommend a detailed digital photographic record in both This recommendation has now been


directions in line with the beach and in both directions across the beach, at intervals of 10 to 30 meters, using high quality digital cameras to provide overlapping views, for a historical record and also for later viewing and reviewing.

specifically incorporated into the methodology

9. 4. Regarding wind and wave data, surfers will be glad to advise that this data is available in detail on a four-hourly basis, seven days a week. Woodbridge Island has this data for 33.8°S / 18.2°E since 2001.

Thank you. We are aware of this freely available data and are accessing this source (Wavewatch III data from the National Centre for Environmental Prediction, USA) and related information.

10. 5. Regarding the slopes of the beaches in Milnerton, they are not constant throughout the year. The slopes in winter are usually substantially more than the slopes in summer.

We are aware of this limitation – now specifically mentioned in the methodology.

11. 6. Regarding Aeolian sand transport, the assumptions may need revision. For Woodbridge Island there are barriers to the south east wind that limits its velocity and its force. For the North West wind there are no barriers and at low tide the beach is rapidly dried so that windborne sand is carried approximately 40 to 50 m into the Woodbridge Island complex. The resulting accretion of sand can be quite substantial.

Observations noted. No diametric disagreement with these statements that directly affects the final setback proposed.

12. 7. Regarding the statement that Dune vegetation has little or no effect, we have reports from the recent tsunami event that demonstrates that most damage occurred where dunes and dune vegetation had been removed.

This statement is not included in the final report

13. 8. In the evaluation 31 storms were listed, mostly in the months May to August. Our data and our research show that the worst months for storms are most often in April and in September.

Important to note that the storms were selected from nearshore wave data and would probably be different from offshore storm data. This may explain the discrepancy.

14. 9. The methodology lists the input data required for modelling the effects of storms as the initial beach profile, the median sand grain size, and the time series of the storm conditions. We would suggest that the bathymetry, or the profile of the underwater beach, also be taken into account as those also have a marked effect on the retardation of incoming waves. Our records show waves peaking at more than 14 m (in 2001) that were quite adequately dissipated before final deceleration on our shores. The time allowed for comments was not adequate for part-time enthusiasts to study the proposal in depth or in detail, but in general we wish to register our approbation for a very difficult and complex task that in our view, at least as an initial effort, was very well done. We believe even without modification by means of the extraneous items listed above and with only appropriate modifiers applied to the primary components, such as sea level rise, the proposed methodology will provide a surprisingly acceptable result.

The bathymetry is now taken account of via the wave transformation enabling study. The latter modelling includes wave energy dissipation from breaking. Thank you – comments well received and incorporated into the methodology where relevant.


Sue Swain - Obo Plettenberg Bay

Community Environment Forum

15. We feel that the report has not adequately addressed estuaries – it was raised in comments during the PPP, but the proposed methodology only really refers to the meandering nature of some estuary mouths and that this needs to be taken into account. We recommend that specific mention should be made of closed estuaries that only open after heavy rains/flooding and the combination of unexpected storm events and other contributing factors that can lead to excessive inundation of the area. Setbacks need to be greater for open/closed estuary systems and need to extend as far up the estuary as there is tidal movement of the high water mark. While artificial breaching may need to be a consideration, of equal consideration should also be the investigation of water-filled flood barriers that could protect properties in the existing flood plains without having to interfere with the natural functioning of the estuary. There is a definite need for a holistic approach (possibly area by area) to dealing with flooding and bank/coastal erosion, so that a standard approach can be adopted which will impact less on neighbours, aesthetics and, in the case of estuaries, downstream properties.

It was agreed with the client that that estuaries would not be part of this study. Nevertheless the importance of having them included (beyond the scope of this study) is highlighted and the effect of meandering estuaries on the open (wave-exposed) coast is considered

Alan Carnegie - Private

16. I shall confine my comments to stable sections of coastline. I am not qualified to express an opinion where there is severe erosion or accretion. Since 19791 have resided alongside such a stable section of beach on the northern cusp of Saldanha Bay. Between the Port Boundary and the Municipal Holiday Resort the setback lines vary from 30m to 70m. Fortunately for me; my house is one of twelve along the length of Parker Crescent that are closest to the beach with a 30m setback line. Advantages of a 30m setback line:

1. Easy access to the beach for high energy water sports such as sea kayaking and kite boarding.

2. As unofficial custodians, we can easily observe if there is any untoward activity taking place within the setback zone and promptly effect remedial action.

3. If there is any rehab required to the coastal vegetation, the home owners can cover the cost without appealing to the municipality.

Disadvantages of a 70m setback line: (See below – Anne Duncan’s comments) I think that the Municipality is unlikely to direct meaningful resources towards rehabbing the area. They have other more pressing problems which tie up their resources. My Recommendations: Wherever possible specify a 30m setback line! Conservancy Areas such as Blouberg should have a setback line to the coastal road of at least 250m. Boardwalks to the beach should be

Comments noted – it may be more appropriate in this particular situation to have a more manageable setback of 30 m. However all of the site-specific factors need to be considered. These considerations would be taken into account during the execution phase of setback line establishment.


the first structures built on a new coastal township layout.

Anne Duncan - Private

17. Destabilization of the Frontal Dune and the destruction of habitat in the Coastal Reserve (Erf 4022) I intend this communication to draw attention to the destabilisation of the frontal dune and the destruction of habitat in the Coastal Reserve (Erf 4022 Parkersdorp, Saldanha Bay) and to contribute in motivating the necessary actions required to rehabilitate and conserve this area that lies within the West Coast Biosphere Reserve. This Coastal Reserve needs to be seen within the framework of an Integrated Conservation Plan (ICP) of the Saldanha Bay - Vredenburg-Langebaan and Berg River Bioregion and within a Global context of rising concern for the destruction of habitat and the need to preserve biodiversity by actively responding to supporting conservation. Observations The following factors contribute to destabilizing the Frontal Dune ecosystem, destroy habitat and compromise biodiversity and the safe access for people walking through this Nature Area and potentially, if left unchecked the stability of residences within this sensitive area.

� Position and length of the stormwater outlets. Water flowing from the tenninal points of the storm water outlets that stop within the dune ecosystem, is contributing to the rapid erosion where the pipe empties out, resulting in the exponential blowout of this most vulnerable sea facing dune area. This needs immediate attention!

� Land owners transgressing their erf boundaries i.e. illegally removing indigenous vegetation, planting and irrigating invasive grass and alien species, dumping garden cuttings and rubble, parking vehicles in the Nature Area and illegal structures.

� Activity in the donga's include: - Dumping rubble and garden refuse as a result the water fans out wider and is

increasing the size of the donga. - Dispersal of the contents of rubbish bags

Thank you for these comments relating to management issues. These are the types of issues that must be taken consideration of in establishing setback lines.


- Nefarious characters using area as a hangout for illicit activities. - Making fires - Use as a toilet

� As well as people not sticking to the paths and unaware of the sensitivity of this dune area, along some of the Original demarcated pathways where the path crosses the direction of water flow from the stormwater drain, the path is no longer safe to use and people are creating new pathways.

� Dumping rubble and garden refuse in the veld and people picnicking destroys vegetation and is aesthetically unpleasing.

� The use of quad bikes, motorbikes and bicycles.

� Dogs being allowed without a leash.

Action

� Apply the law and hold transgressors accountable i.e. the relevant authorities· Municipal law Enforcement or DEAT " must apply the relevant laws e.g. NEMA and the Coastal Management Act. As per Ms Moss the properties bordering the Coastal Reserve have been surveyed and a report has been sent to Province and subsequently followed up on. I await the current status and plan of action from her as agreed to at the Saldanah Bay Forum and as per Mr Frank Mbanze's direction.

� Extend stormwater outlets onto the beach to mitigate further damage caused by stormwater runoff. This could be done in an aesthetically pleasing manner using calcrete stones to cover the concrete.

� Rehabilitate the dune area surrounding the stormwater outlets where dongas have been formed (cages with stone) and revegitate.

� Wooden Recycled Boardwalks to direct access through this sensitive frontal dune area.

� Strategically post (aesthetically pleasing) sign age at e.g. the end of the cui de sacs alerting people they are entering a Coastal Reserve and sensitive Frontal Dune Area.

� Appoint a relevant expert to advise on the rehabilitation of dune areas damaged by erosion and habitat destruction (as implemented at Calypso Beach), the removal of invasive alien vegetation and the restoration of these areas as directed by an expert in rehabilitation.

� Create the necessary bilaws to give authority to local law Enforcement.

� Educational outreach to better inform all interested and affected parties regarding applicable legislation while nurturing sensitivity for the environment and fostering how to


best serve as a custodian of the environment. Partnering to generate appreciation and awareness of local environmental concerns within a Global context, while fostering sensitivity and commitment to the conservation of our Natural Heritage. Outreach including to: Law Enforcement and the SAP, Municipal Workers, NGO's involved e.g. Vital Connection, Coastal Care and those involved with removing litter and alien vegetation, school children, the general public and businesses, including Saldanha Bay Tourism.

The conservation of the Coastal Reserve and the stability of the frontal dunes need to be attended to as a matter of urgency. I herewith appeal to you all to work together for the health and wellbeing of our community. Please do what is necessary to bring together the role players and appoint the relevant expert(s) to assess what needs to be done. I trust we the people, can count on you our elected leaders, Mayoral Committee and this Municipality in service to our community to support this and other conservation initiatives with the same vigour as you are applying to the lDP.

Synopsis of some of the communication from 2001 to the present regarding: The destruction of the Coastal Reserve (Err 4022) and erosion of the frontal dunes and around the storm water outlets. Over the years I have addressed my concerns to the Saldanha Bay Municipality, Marine and Coastal Management, DEA T and the Saldanha Bay Forum, Law Enforcement and the SAP amongst others. I have communicated with and met with various people, including from Town Planning and the Engineering Department Various people have come out at different times to assess what needs to be done and report(s) written. During this time I and others have witnessed the exponential degradation of the Coastal Reserve and Frontal Dune area

� •A registered letter was first sent out by the Saldanha Bay on 16/1112001 by the Acting Municipal Manager (Ref 8/213/1) Onwettige Ontwikkeling van Staatskusreserwe aangresnsend tot Saldanahabaai.

� A registered letter sent by Municipal Manager (Ref 13/41211) Unauthorised use of Erf 4022, Saldanha and Council's intention of Proclamating the area as a Nature Area.

� On various occasions Law Enforcement Officers have been called to the scene.

� DEAT has sent out various people to assess the situation and there has been communication with the Saldanha Bay Municipality.

� The Saldanha Bay Forum (SBF) has communicated to the Saldanha Bay Municipality and DEA T over the past 2 14 years re addressing this situation.

� Environmental Officer, Ms Moss representing the Municipality in consultation with Mr Lindsey Gatfley among others has been in communication with DEAT and people within the


Municipality to address conservation concerns and ascertain who is responsible and what laws need to be applied for transgression in the Coastal Reserve.

� Mr Deon van Eeden of Vula (at a SBF meeting in September 2009, in order to address the stability of our coastline a relevant expert needs to be appointed to assess what needs to be done for the entire area since e.g. what is done in one area to mitigate erosion from the oceanside affects the coastline further along.)

We live in a beautiful area that lies within the West Coast Biosphere Reserve. Let us do together what needs to be done to ensure the preservation of our Natural Heritage. This is a call to all those who have influence and who care to supporting conservation and take the necessary action to ensure the law is upheld in those areas currently demarcated as Nature Areas. Let's motivate and apply the necessary vision to expand current Nature Areas and demarcate land for a West Coast "Central Park" that provides wilderness and recreational areas that serve the health and needs of this Community and motivates the best possible job creation potential in Tourism that this unique area has to offer.

DH Bates - Professional

Land Surveyors

18. • Please note full comments could not be included in this table. Written comments included below

ABSTRACT: This firm has been requested to comment on the Draft Report of the Western Cape Coastal Setback Lines, dated 1 st April 2010, on behalf of the property owner of Erven 149366 and 149367 Cape Town at Kalk Bay, Mr. Peter Lancelot Liddell. 1. INTRODUCTION: The Coastal Setback Lines document introduces two types of setbacks, the ‘no development / coastal process’ and the ‘limited / controlled development’ setback lines. In this report, this firm has substantiated the reasons why the Coastal Setback Lines should not include the subject properties. 2. PROPERTY DETAILS:

Erf 149366 Erf 149367 Consolidated Erf 173908

Extent 371m² 44m² 415m²

Registered Owner: Peter Lancelot Liddell

Title Deed: T25757/2003 T25757/2003 Not yet registered

Zoning Undetermined (Rail)

Zoning Scheme City of Cape Town

The adjacent refers to particular sites and not to the generic setback line methodology and associated case studies. This will be relevant as part of the stakeholder engagement during the execution of the setback line methodology. We suggest that it be submitted at that stage.


5. BASELINE INFORMATION: The following baseline information is provided to support the objection to the proposed position of the Western Cape Coastal Setback Line. 5.1. Property Background: The subject properties were expropriated by the South African Transport Services (SATS). In 1989, SATS identified that most of the same property was surplus land and approached the Liddell family to sell the subject property. These properties were finally transferred into the name of Mr Liddell in 1992. 5.2. Surrounding Zonings and Land Uses: The property is the last privately owned property between Main Road and the railway line in Kalk Bay, closest to Clovelly. Most of the properties in the immediate area are zoned Single Dwelling Residential, with some properties being zoned Undetermined. Further to the north is the Kalk Bay harbour, and the rest of Kalk Bay, where many businesses and restaurants thrive with many tourists who are drawn to this area due to its amazing characteristics and atmosphere. These properties are zoned General Business, Special Business, General Residential or Single Dwelling Residential. The subject property abuts a residential property to the northeast, which is owned by the same owner as the subject property, and an electrical substation to the north. Across Main Road are only residential properties with various building styles. To the south-west of the property are the steps that lead to the subway access, below the railway line, to Woolley’s tidal pool. 5.3. Topography: The slope of the subject property rises north westwards from the railway line up towards Main Road. The ground level of the property starts about 0,50m below the level of Main Road and extends down to the railway line, which is about 3,50m below the level of Main Road. This results in a total fall of approximately 3,00m across the depth of the site. The lowest levels of the property are between 6,40m and 6,70m above Mean Sea Level. The railway line, which directly abuts the property, lies on top of the sea-facing retaining wall and is between 5,35m and 5,48m above Mean Sea Level. Annexure A is a copy of the Topographical Plan that was prepared by this firm, which substantiates the above levels. 5.4. Coastline: In terms of Sea-Shore Act, No.21 of 1935, the definition of the high-water mark means: ‘the highest line reached by the water of the sea during ordinary storms occurring during the most stormy period of the year, excluding exception or abnormal floods.’


The high-water mark (HWM) is also indicated on the Surveyor-General’s Noting Sheets. An extract from the relevant Noting Sheet is attached as Appendix A. It is clear that this line follows the approximate edge of the rocky coastline along Kalk Bay, see Photograph 1 below. 6. MOTIVATION: 6.1. Erosion: The following is an extract from the World Environmental Day website: http://www.bdix.net/sdnbd_org/world_env_day/2004/bangladesh/climate_change_sealevel.htm (25 May 2010) “ Theory of Erosion Due to Sea Level Rise The sea level rise is one of the driving mechanisms of coastal erosion. While this has an indirect effect on coastal erosion through the dynamical processes, it itself has a direct contribution to erosion as well. With a rise in water level, the coastal morphological system will adjust itself to the high water level situations by creating a new coastal profile at a higher level at the coast of the presently existing coastal profile. This process, as described by Vellinga (1986), is as follows a) By a rise in water level, the water line will shift landward. b) As the coastal profile becomes steeper, erosion will occur until a new dynamic equilibrium is reached at a higher level. c) The natural filling rate of lagoons and tidal basins will increase with an accelerated rise in sea level; the sediments required for the filling will come largely from the surrounding areas through erosion. d) Rising sea level will cause a shoaling effect in rivers as a consequence of which (shoaling) sediment yields from rivers will reduce; these sediments will not be available to compensate for any erosion in the coastal area. We shall discuss here the theory of erosion due to sea level rise, following mostly the method developed by Brunn (1962). ” This information verifies many of the implications of sea level rising, as well as which locations will be affected first. This indirectly supports the fact that the subject property will not be affected by any initial rise in sea level, due to its topographical location, as well as the manmade buffer (railway line). It is also evident from comparing the 1945 aerial photography, with the 2009 aerial photography (extract from Google Earth) that no erosion has occurred along this stretch of Kalk Bay’s rocky shoreline. See Photographs 3 and 4 below.


6.2. Sediment Transport: The coastline from Kalk Bay harbour to Clovelly beach is rocky, and has no sandy areas, which does not lead to any significant sediment transport. 6.3. Wind-Blown Sand: There are no sandy beaches within approximately 400m from the subject properties. The properties are therefore not subjected to wind-blown sand. The predominant winds direction in summer is south east, which blows onto the subject properties directly from the ocean. A north westerly wind is predominant in winter. 6.4. Coastal Protection Features: The rocky coastline is a prominent coastal feature along Kalk Bay. 6.5. Estuary Conditions: There is no river close by the subject properties. 6.6. Development Setback: The setback for development is critical to the planning application, which has been submitted to Council as per paragraph 3.2 above. 6.6.1. High water: The table to the right refers to Tidal Levels along the coast of Cape Town. The two schematic drawings shown below are 1. Schematic Illustration of features and their heights above Mean Sea Level 2. Oblique Conceptual View of the topography leading from the ocean to the subject properties utilised to easily compare these tidal levels with the location and topography of the subject properties. Also, refer to Photograph 2 below for a view of the properties, over Woolley’s Tidal Pool. 6.6.2. Conservation / Biodiversity: Appendix B below is an extract from the City of Cape Town’s Critical Biodiversity Areas & Wetlands. The City has clearly identified that there are no critical conservation worthy fauna and flora on the subject property. 6.6.3. Heritage: 6.6.3.1. Urban Conservation Area: A Heritage Specialist was approached with regards the proposed development. He indicated that the development does not trigger the National Heritage Resources Act (No.25 of 1999), and does not require a Notice of Intent to Develop to be submitted to Heritage Western Cape. The design of the proposed dwelling, however, needs to be in accordance with urban fabric of existing dwellings in Kalk Bay. 6.6.4. Public access and amenity: Currently, the only public who accesses the subject properties are vagrants. The properties are desecrated daily. The railway line is still in daily use, which creates a prominent and permanent barrier (physical and visual) between the coastal area and the subject properties. Woolley’s Tidal Pool is the only public amenity in close vicinity, to the south, of the properties.


Access to the pool is via steps off Main Road, to the south west of the subject properties. The tidal pool is frequently whitewashed and repaired. The pool lies to the south of the railway line, and will thus not be materially affected if the Coastal Line were to follow the southern boundary of the subject properties. 6.6.5. Landscape value: The subject property has very little landscape value due to the abutting railway line and its overhead power lines. The property, however, is dwarfed by the overwhelming presence of the Trappies Kop to the north west. 6.7. Storm Erosion: Should a storm be of such magnitude that the retaining wall of the railway lines is damaged, then the railway authority will have to maintain the railway line for the benefit of the general public. This will ensure the continuous protection the property from the seaward side. 6.8. Life Span of a Development: The table to the right (extracted from the Coastal Setback Lines – Draft Report) implies that different approaches should be used for different infrastructure. This could similarly be applied to the construction of dwellings, which need to be serviced by such infrastructure. Therefore, should the planning application be approved, and a dwelling with a life span of 20 to 100 years be constructed on the subject properties, then such dwelling should be planned by taking 1,0m sea level rise into account. Any proposed dwelling on the subject property would therefore be seen to be safe from any implications of sea level rising, since the property is more than 6m above Mean Sea Level, and is protected by a railway line and its supporting retaining structure. 6.9. Coastal Type: As stated above, the coastal type along the shores of Kalk Bay is predominantly rocky. 7. Conclusion: It is evident that, by making use of one of the methods to calculate the coastal setback line, the subject properties should be outside the Coastal Setback Line. Although the necessity to implement setbacks due to the potential implications of sea level rising are acknowledged all over the world, the results of such effects will probably only be reached in the very distant future. The various authorities around the world are correct in implementing a Coastal Setback Line. However, as many other Countries, it is important that this line must not be over analysed. The development setback line should be introduced without negatively affecting the owners of properties, which clearly will not be impacted by initial sea level rising, and which will more than likely not be experience by our generations.


Cedric Wayne Hendricks - Macassar


19. When can you meet with our Community! Your Study is very worrying as it focus on the mainly rich and affluent communities of the western cape and it should be urgently reviewed for not taking into consideration communities on the coast who are black, such as Macassar,Firgrove/Helderberg.It is not a commendable study and true reflection if you should see the destruction in Macassar on the Macassar Beach. Please reconstruct your studies to include vulnerable communities. Why are so-called White communities always considered and not the communities of Blacks and Coloured people of the western cape. I have more than enough photo's and environmental evidence of the shifting of the dunes and rapid rising of the sea levels along the coast. Most citizens are worried of what's happening along the beach but the department of environment seems to be very quite on the issues affecting Macassar Dunes.

Assuming that reference made here to the two selected case studies, please be aware that we were hard-pressed to find suitable case studies representative of the entire province. The latter were selected more for their available data (allowing critical assessment of methods) than the fact that they happen to coincide with more affluent areas. In any event the methodology developed will be applicable when applied to your area.

Neil Schwartz - V&A waterfront

20. Below, please find comments on the 1 April 2010 report on “Setback Lines”.

1. Paragraph 1.2.1: Homeowners conducting house alterations and Municipalities are not the only parties to have been affected by the “unintended consequences” of the 100m HWM NEMA provision. Large commercial developments, which depend on funding and timing of development, have been scrapped directly as a result of NEMA. While the cost to the economy and the loss of jobs is not known, this factor should be taken into consideration when reviewing facilitation of development as a factor for the establishment of setback lines.

Homeowners doing house alterations , while valid , is in my view a gross underestimation of the “unintended consequences” of the requirement for an EIA for development within the 100m HWM. The activities to not be listed (for EIA) if the activity will “occur behind a development setback line as defined or adopted by the competent authority” requires substantial review and revision.

2. Paragraph 6.3: these categories should be broadened to include existing and proposed land uses.

Noted. Noted but beyond the brief of this study. Noted but not fully understood.

Mike Brokenshire - V&A Waterfront

Development Management

21. Existing Development Rights Section 1.5.4 requires elaboration as to how existing development rights will be accommodated within a setback line. Possible setback lines in built-up areas need to be addressed in more detail as the report infers that even if structures exist and development rights are in place, these cannot be assumed to be automatic.

The legal details of development rights, while relevant is not specifically part of this study. What has been established is that coastal process setback lines are to be placed as if development does not


In the V&AW there is a basket of rights already approved, and in order to exercise these rights further detailed plans are to be submitted to and approved by the authorities. The timing of the establishing setback lines and the potential doe setback lines to limit land availability for utilising existing rights requires further clarification.

exist and is likely to constrain re-development.

22. Data Collection (Table 4.1) The table should be expanded to assess information on coastal infrastructure, such as breakwaters, sea walls, and harbours as the effect of wave action etc. In the harbour environment is different to that of the natural coastline. Clarity is sought as to the requirement for setbacks in a harbour environment, given that the effect of wave action etc is negated by the breakwater that forms a ‘harbour mouth’ and any body within a harbour is controlled.

The methodology implicitly takes account of the harbour situation – e.g.. erosion setback falls away and only relevant processes like sea-level rise and wave runup and overtopping will potentially affect setback. Response above applies. The wave runup and overtopping would be calculated taking into account the limited waves that occur (attenuated by the harbour protection structures).

23. Potential Grading of Shoreline Protection Consideration should be given as to whether existing shoreline protection could be graded – for example, if concrete ‘dollose’ are used the risk of shoreline damage is low and therefore may support development safely within the 100m line. Existing sea walls, for example the Sea Point promenade, would be given grading that would allow more than say, rip-rap used around Woodbridge Island.

Interesting concept but we believe it is not necessary and not appropriate to grade these protection structures – the process-based methodology we propose will take the varaiable protection of such structures into account.

Tim Everett - Private

24. As a registered I&AP I wish to make the following comments that appear in the Summary of Key Issues ( Table 4)

Item 6- Prioritisation for implementation of Setback lines

It seems inevitable because of the high cost of creating set back lines on the whole coast, that setbacks will only be looked at once the greed of developers forces action. It would be better to create blanket setback lines for all un-developed land at a maximum that can be obtained in terms of the Integrated Coastal Management act. This will then create a system were the developer has to rather apply for a reduction of the setback lines thus created.

Our updated methodology proposes methods which effectively achieve this. Through rapid (and conservative) assessment, conservative setback lines can be established. These can and must


Reference is made to the west coast particularly, but there are lots of sections of the coast south of Mossel Bay and into the Overberg coastal region that is in series need of action. Prime example is Vleeisebay and Mossgas interest areas.

be revisited with a thorough study before being accepted.

25. Item 10- Consultation Process.

One understands the scientific process, but once again, it is only once greedy developers get involved that the public gets to hear of potential damage to an area. It is therefore imperative that the public is made aware, immediately that setback lines are being considered in a particular area. In fact I would think it is our constitutional right to be made aware of these facts. There are far to many cases in this country of areas of the coast having been effectively blocked to the public, for this process not to be public at all times . This is your chance to stop further degradation of the coast by un-scrupulous developers.

I sincerely hope that this process will be far reaching enough to reduce this ongoing degradation. The Western Cape is to be congratulated on moving forward on this matter so quickly and I hope that it will be implemented quickly in other provinces

Agreed that it is imperative that the public is made aware at the outset – this is now part of the methodology.