Development of a Methodology for

Defining and Adopting Coastal

Development Setback Lines.

VOLUME 2: APPENDICES

DATE: 31 May 2010

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks For discussion For final Final Deliverable comment 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

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 – Appendix E: Case Study Report – Langebaan Appendix G: Stakeholder Engagement Report (PPP)

208100E Setback Line Methodology 10 Appendix A: Minutes of Meetings

208100E Setback Line Methodology 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 Development Setback Lines. 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 : Darryl Colenbrander (DC) WSP: Geoff Smith (GS), Frans van Eeden (FE)

No. SUBJECT Action Date required by 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 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 DC 18/12/2009 download links there to) is to be provided by CoCT the relevant authorities and consulting team. 2.5 SD together with the Saldanha Bay Municipality (JS) to provide SD/JS 18/12/2009 the Consultant Team with the information on the work undertaken in Saldanha Bay. 2.6 SD to also provide the Consultant Team with all the available SD 18/12/2009 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. 2.7 SD provide the Consultant Team with a copy of the Climate SD 18/12/2009 Change Vulnerability Report (2005) as well as the Western Cape Climate Change Strategy (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 FE 14/12/2009 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. The Consultant Team to provide refined Project Schedule and FE/GS 15/12/2009 final Payment Schedule (with payments linked to specific deliverables, project days and timeframes) The Consultant Team to provide refined information on the FE/GS 15/12/2009 public participation and stakeholder engagement process proposed to be followed during the development of the methodology.

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 [email protected] tel: 043 604 6924 1 representative of KZN Omar Parak [email protected] tel: 033 355 9438 1 representative of Cape Nature Tierck [email protected] tel: 028 316 3338 1 representative of CSIR WSP will contact the representative from the CSIR and report GS 14/12/2009 back to the Committee. 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 Minutes of Meeting

Date of meeting : 26/01/2010 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 Development Setback Lines. Subject : Coastal Setback Progress Meeting Present : See attached Attendance Register

No. SUBJECT Action Date required by 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 JS 29/01/2010 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

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 GS Ongoing methodology The schedule for the PPP for the project is as follows: GROUP DATE VENUE TIME SB Municipality 4 Feb SB 10H00 Municipality – 13H00 Other 5 Feb DEAD&DP 10H00 Authorities – 13H00 CT Municipality 5 Feb CT 15h30 Municipality – 16h30 SB Public 10 Feb Langabaan 17H30 Town Hall – 18H30 CT Public 11 Feb TBC 17H30 – 18H30 DEA&DP 11/16 DEA&DP 10H00 Feb – 13H00

5 Next scheduled meeting 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 OF MINUTES OF MEETING

Approval by DFU By: ______Date:______

Approved by WSP

By: Geoff Smith Date: 27/01/2010

MEETING NOTES

WSP Environment & Energy Job Title Western Cape Coastal Setback Lines WSP House, 1 on Langford Langford Road Project Number 91212D Westville Durban Date 4 February 2010 3629 Tel: +27(0) 31 240 8860 Time 14:00 – 16:00 Fax: +27(0) 31 240 8861 Saldanha Bay Municipal Offices, Bree St, http://www.wspenvironmental.co.za Venue 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 Registered office: WSP House, Bryanston Place Office Park, 199 Bryanston Drive, Bryanston, Johannesburg, South Africa Registered number 1995/08790/07

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: JS to give Saldanha  Is there beach survey data for the study areas (Saldanha)? Port - Not detailed data. contact  WSP may need to contact Saldanha Port/other municipality reps for data. details (Nimi) to  Saldanha Municipality/WSP will need to get permission from the Saldanha port to GS 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). JS to give Aerial photos & Long term shoreline trends: SDF GIS data to GS  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. 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.

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

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

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

WSP Environment & Energy Job Title Western Cape Coastal Setback Lines WSP House, 1 on Langford Langford Road Project Number 91212D Westville Durban Date 5 February 2010 3629 Tel: +27(0) 31 240 8860 Time 10:00 – 12:00 Fax: +27(0) 31 240 8861 Venue DEA&DO Offices, Dorp Street, Cape Town http://www.wspenvironmental.co.za Subject Draft methodology & Authority input discussions Client DEA&DP Present Geoff Smith (GS), Danielle Michel (DM) Apologies None

MATTERS ARISING ACTION  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.

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

MATTERS ARISING ACTION 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.

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

MATTERS ARISING ACTION 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 SNABI – Biosphere - They include the different management activities required within each management area and priority areas in terms of ecosystems. information - Dr Steve Holding (PE – SANparks) is the biodiversity specialist who can needs to be provide insight into the development of biodiversity mapping obtained

- 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) 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

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

MATTERS ARISING ACTION 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: DM Steering Committee All present (See attached)

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

WSP Environment & Energy Job Title Western Cape Coastal Setback Lines WSP House, 1 on Langford Langford Road Project Number 91212D Westville Durban Date 5 February 2010 3629 Tel: +27(0) 31 240 8860 Time 14:00 - 15:00 Fax: +27(0) 31 240 8861 Venue Cape Town Municipal Offices, Wale Street http://www.wspenvironmental.co.za Draft methodology presentation & Cape Town Subject Municipality input Client DEA&DP Geoff Smith (GS) Present See attached attendance sheet Apologies

MATTERS ARISING ACTION 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.

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

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.

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

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.

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

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)

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

WSP Environment & Energy Job Title Western Cape Coastal Setback Lines WSP House, 1 on Langford Langford Road Project Number 91212D Westville Durban Date 10 February 2010 3629 Tel: +27(0) 31 240 8860 Time 17:30 – 19:00 Fax: +27(0) 31 240 8861 Langebaan Community Hall, Bree St, http://www.wspenvironmental.co.za Venue Langebaan Subject Public stakeholder meeting Client DEA&DP Geoff Smith (GS), Danielle Michel (DM), John Present Smit, see attached Apologies None

MATTERS ARISING ACTION 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.

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

3. Existing data: Copy of report  CSIR has compiled a report for Paradise beach - Yes this information is being incorporated

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

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

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.

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

12. Implementation of setbacks – Prioritising areas:

 How are the areas prioritised?

- Proposed development areas (under pressure)

- Rural and urban will both be included

For discussion  Could one apply to prioritise a specific area? with DEADP  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 For discussion - However, provincial and local governments will be working together on this, with DEADP 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. 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.

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

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: Forward  All registered I&APs presentation  Steering committee with notes for comment

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

WSP Environment & Energy Job Title Western Cape Coastal Setback Lines WSP House, 1 on Langford Langford Road Project Number 91212D Westville Durban Date 11 February 2010 3629 Tel: +27(0) 31 240 8860 Time 17:30 – 19:00 Fax: +27(0) 31 240 8861 Pinelands Community Hall, St Stephens Road, http://www.wspenvironmental.co.za Venue Pinelands, CT Subject Public stakeholder meeting Client DEA&DP Geoff Smith (GS), Danielle Michel (DM), see Present attached Apologies

MATTERS ARISING ACTION 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.

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

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. 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.

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

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 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.

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

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: Consolidate &  Al present circulate meeting  Steering committee minutes, & presentation.

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

Minutes of Meeting

Date of meeting : 23/02/2010 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 Development Setback Lines. Subject : Coastal Setback Progress Meeting Present : See attached Attendance Register

No. SUBJECT Action Date required by required by 1 Minutes of meeting held on 26/01/2010 Minutes accepted and approved that all actions required were 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. Comments from Committee regarding presentation 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 GS Ongoing methodology

5 Next scheduled meeting The next meeting will be held on Tuesday 23 March 2010 at 10h00.

6. Addendums sent with the minutes The presentation (by GS) and the attendance register are sent out with the minutes.

APPROVAL OF MINUTES OF MEETING

Approval by DFU By: ______Date:______

Approved by WSP By: Geoff Smith Date: 26/02/2010

MEETING NOTES

WSP Environment & Energy Job Title Western Cape Coastal Setback Lines WSP House, 1 on Langford Langford Road Project Number 208100 Westville Durban Date 24 February 2010 3629 Tel: +27(0) 31 240 8860 Time 10:00 – 12:00 Fax: +27(0) 31 240 8861 Venue SAHRA, 111 Harrison Street, Cape Town http://www.wspenvironmental.co.za Subject Heritage meeting Client DEA&DP Geoff Smith - WSP Mariagratzia Galimberti - SAHRA Present Nick Wiltshire, Belinda Mutti – Heritage Western Cape Jim Hallinan – City of Cape Town Apologies None

MATTERS ARISING ACTION 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.

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

Minutes of Meeting

Date of meeting : 23/03/2010 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 Development Setback Lines. Subject : Coastal Setback Progress Meeting Present : See attached Attendance Register

No. SUBJECT Action Date required by required by 1 Minutes of meeting held on 23/02/2010 Minutes accepted and approved that all actions required were 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. Comments from Committee regarding presentation 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 WSP study 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 GS Ongoing groups and other external sources into methodology

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

6. Addendums sent with the minutes The presentation (by GS) and the attendance register are sent out with the minutes.

APPROVAL OF MINUTES OF MEETING

Approval by DFU By: ______Date:______

Approved by WSP By: Geoff Smith Date: 23/03/2010 Minutes of Meeting

Date of meeting : 13/05/2010 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 Development Setback Lines. Subject : Coastal Setback Progress Meeting Present : See attached Attendance Register

No. SUBJECT Action Date required by required by 1 Minutes of meeting held on 13/05/2010 Minutes accepted and approved that all actions required were 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. Comments from Committee regarding presentation 3.1 Erosion setback line The concern was that two different specialists could determine WSP 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. 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 WSP 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 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 WSP or not the line should be revised – to be highlighted in the report Estuaries: According to the ICMA only permanently open estuaries are included in the coastal setback line Different setback lines for biodiversity, heritage, aesthetics etc WSP must be available at the stage where the EIA process is carried out. These lines can be made available – include in report 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.

5. Addendums sent with the minutes The presentation (by GS) and the attendance register are sent out with the minutes.

APPROVAL OF MINUTES OF MEETING

Approval by DFU By: ______Date:______

Approved by WSP By: Geoff Smith Date: 17/05/2010 Appendix B: Project Terms of Reference

208100E Setback Line Methodology Department of Environmental Affairs and Development Planning Departement van Omgewingsake en Ontwikkelingsbeplanning ISebe leMicimbi yeNdalo esiNgqongileyo noCwangciso loPhuhliso

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

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

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 2 of 10 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;

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 3 of 10 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.

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 4 of 10

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.

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 5 of 10 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.

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 6 of 10

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)

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 7 of 10 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] .

For enquiries concerning the bid documentation please contact Ms Naomi Gideon at tel: (021) 483 2777.

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 8 of 10 Appendix A

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)

DFU: Coastal Development Setback Lines - Development & Testing of Methodology TOR Page 9 of 10 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]

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

208100E Setback Line Methodology

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 rehabilitatedg, 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 Reference1 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

208100E Setback Line Methodology 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).

208100E Setback Line Methodology Appendix D: Case Study Report – Milnerton

208100E Setback Line Methodology

Development of a Methodology for Defining and Adopting Coastal Development Setback Lines MILNERTON CASE STUDY

31 May 2010

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks Final Submission

Date 13/05/2010 31/05/2010

Prepared by F van Eeden, F van Eeden,

S Roux, S Roux,

I Du Plessis 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

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

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

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 1

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 ftp://polar.ncep.noaa.gov/pub/history/waves No cost wind Historical aerial Chief Directorate for Surveys and Mapping R 7-00 per contact print photography (CDSM) R75-00 per photo enlargement Geo-referencing of Centre for Geographical Analysis R400 / photograph historical photographs Bio-diversity maps Cape Nature / SANBI No Cost (GIS) Sediment grain size Analysis of site samples by CSIR R285 / Sample distribution Spatial Development City of Cape Town No cost Framework Heritage maps Heritage Western Cape No cost Survey data City of Cape Town No cost Bathymetry Naval navigation charts / 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 2

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.

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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.

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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.

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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.

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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

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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 . 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 44m 39m 27m 67m 58m 56m Erosion

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

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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 7 8 9 9 9 9 points Minimum 158 147 147 210 233 235 Maximum 186 176 190 239 257 260 Mean 173 164 167 219 242 249 Maximum 28 29 43 29 24 25 difference Standard 8 10 16 10 8 9 deviation

Short term 35 43 66 41 32 38 erosion (m) 1 in 100 yr 43 38 27 67 58 56 erosion (m) Average beach 0.0564 0.0428 0.0298 0.0144 0.0211 0.0257 slope (-) Setback allowed for 18.0 24.0 34.0 70.0 48.0 39.0 sea level rise (m) Total setback 97 106 127 178 138 132 distance (m)

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

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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.

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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.

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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 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).

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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

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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

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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

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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)

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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.

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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

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• 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.

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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 .

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.

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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

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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.

Milnerton beach profiles

6 Prof_Line_6 Prof_Line_5 5 Prof_Line_4 Prof_Line_3 4 Prof_Line_2 Prof_Line_1 3

2 Height aboveHeightMSL(m) 1

0 0 50 100 150 200 250 300 Cross Section (m)

Figure 3: Cross sections of beach profiles taken at six locations along the site.

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

General trend of highwater mark over time

300 Ref_6 280 Ref_5 260 Ref_4 Ref_3 240 Ref_2 220 Ref_1 200

180

160

140

120 Distance from reference line (m)linefrom reference Distance 100 1940 1950 1960 1970 1980 1990 2000 2010 2020 Year

Figure 8: General trend of the variation of the high water mark over time.

Variations in highwater line over time

300

280

260

240 Ref_6 Ref_5 220 Ref_4 200 Ref_3 Ref_2 180 Ref_1

Distance from reference line (m) 160

140

120 1940 1950 1960 1970 1980 1990 2000 2010 2020 Year

Figure 9: Variations of the high water mark over time as measured relative to the reference line.

Variations in highwater line over time

280

260

240

Ref_6 220 Ref_5 Ref_4 200 Ref_3 Ref_2 180 Ref_1 160 Distance from reference line (m) line reference from Distance

140

120 1940 1950 1960 1970 1980 1990 2000 2010 2020 Year

Figure 10: De-trended variations of the high water mark over time

Figure 11: Model domain indicating outer and inner model grids.

Figure 12: Bathymetry and location of nearshore wave extraction point.

Figure 13: Wave refraction patterns computed through SWAN 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

208100E Setback Line Methodology

Development of a Methodology for Defining and Adopting Coastal Development Setback Lines LANGEBAAN CASE STUDY

31 May 2010

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks Final Issue

Date 13/05/2010 31/05/2010

Prepared by F van Eeden, F van Eeden,

S Roux, S Roux,

I du Plessis 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

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

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

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).

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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.

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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 ftp://polar.ncep.noaa.gov/pub/history/waves No cost and wind Historical aerial Chief Directorate for Surveys and Mapping R 7-00 per contact photography (CDSM) print R75-00 per photo enlargement Geo-referencing Centre for Geographical Analysis R400 / photograph of historical photographs Bio-diversity Cape Nature / SANBI No Cost maps (GIS) Sediment grain Analysis of site samples by CSIR R285 / Sample size distribution 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

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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.

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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.

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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.

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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.

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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.

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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 56 59 66 91 262 of Erosion

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:

• 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

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Table 6: Shoreline variation and statistical analysis of the variation of the high water mark over time (de-trended data).

Ref_Line_5 Ref_Line_4 Ref_Line_3 Ref_Line_2 Ref_Line_1

(m) (m) (m) (m) (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 9 19 17 27 27 difference Standard 4 8 7 11 11 deviation Short term 19 34 30 48 47 erosion (m) 1 in 100 yr 86 81 80 65 41 erosion (m) Average 0.190 0.249 0.126 0.152 0.283 beach slope ) Setback allowed for 5.28 4.01 7.91 6.57 3.53 sea level rise (m) Total setback 110 120 118 120 92 distance (m)

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:

• 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 • 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 and Setback allowed for sea- level rise

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Table 7: Shoreline variation and statistical analysis of the variation of the high water mark over time.

Ref_Line_5 Ref_Line_4 Ref_Line_3 Ref_Line_2 Ref_Line_1 (m) (m) (m) (m) (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 16 22 4 17 32 difference Standard 6 10 1 7 12 deviation 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.

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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).

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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

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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.

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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

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(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.

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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

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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.

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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).

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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.

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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.

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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.

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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.

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Appendices, Figures & Tables

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

18

16

14

12

10

8

6 Profile5_N Profile4_N Heightabove(m) MSL 4 Profile3_N 2 Profile2_N Profile1_N 0 0 20 40 60 80 100 120 140 Cross Section (m)

Figure 5: Cross sections of beach profiles taken at six locations along the site of Paradise Beach.

Leentjiesklip beach profiles

18

16

14

12

10

8 Profile5_S 6 Profile4_S

Heightabove MSL (m) 4 Profile3_S Profile2_S 2 Profile1_S 0 0 50 100 150 200 Cross Section (m)

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.

General trend of highwater mark over time

400

350

300 Ref_Line_5 250 Ref_Line_4 Ref_Line_3 200 Ref_Line_2 Ref_Line_1 150

100

50 Distance from reference line (m) reference from Distance

0 1920 1940 1960 1980 2000 2020 Year

Figure 12: General trend of the variation in the high water mark over time for Paradise Beach

General trend of highwater mark over time

360

340 Ref_Line_5 320 Ref_Line_4 300 Ref_Line_3

280 Ref_Line_2

260 Ref_Line_1

240

Distance from reference line (m) reference from Distance 220

200 1950 1960 1970 1980 1990 2000 2010 Year

Figure 13: General trend of the variation in the high water mark over time for Leentjiesklip.

Variations in highwater line over time Ref_Line_5 Ref_Line_4 240 Ref_Line_3 Ref_Line_2 220 Ref_Line_1

200

180

160

140

Distance from reference line (m) line reference from Distance 120

100 1930 1940 1950 1960 1970 1980 1990 2000 2010 2020 Year

Figure 14: Variation in the high water mark over time for Paradise Beach.

Variations in highwater line over time Ref_Line_5 Ref_Line_4 240 Ref_Line_3 Ref_Line_2 220 Ref_Line_1

200

180

160

140

Distance from reference line (m) line reference from Distance 120

100 1930 1940 1950 1960 1970 1980 1990 2000 2010 2020 Year

Figure 15: Variation in high water mark over time for Paradise Beach after the long term erosion trend has been removed.

Variations in highwater line over time

360

340 Ref_Line_5

320 Ref_Line_4 300 Ref_Line_3 Ref_Line_2 280 Ref_Line_1 260

240

Distance from reference line (m) reference from Distance 220

200 1950 1960 1970 1980 1990 2000 2010 Year

Figure 16: Variation in high water mark over time for Leentjiesklip.

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)

208100E Setback Line Methodology

STAKEHOLDER ENGAGEMENT FINAL REPORT:

Western Cape Coastal Setback Line Methodology

WSP Group Africa: Coastal

May 2010

91212D Draft PPP Report - WC Setback Lines

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3 Remarks Draft Draft Final Final

Date March 2010 May 2010 May 2010

Prepared by Danielle Michel Danielle Michel Danielle Michel

Signature

Checked by Hilary Hilary Hilary Konigkramer Konigkramer Konigkramer

Signature

Authorised by Danielle Michel Danielle Michel Danielle Michel

Signature

Project number 91212D

File reference ES /91212D_2010-05-20

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

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

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:

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

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).

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1.2.1 Aims and Objectives The aim of the stakeholder engagement process for the development of the coastal setback line methodology is twofold: a) Design and testing of the methodology The objective of stakeholder engagement for the development of the methodology phase (section 2 of this report) was to disseminate information and involve stakeholders by:

 Consulting with specialists, authorities, and key coastal and environmental organisations within the 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  Promoting support and sustainability during the implementation stage.

b) Review and finalisation of methodology for implementation The objective was to refine and finalise the methodology for stakeholder engagement during the implementation phase 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 Section 3 of this report.

1.2.2 Phased Approach The approach developed for stakeholder engagement in the development of coastal setback lines, can be summarised as in Figure 1 below.

Phase 1: Process Initiation

•Client Steering Committee •Authority Consultation •Advertising •Development of Stakeholder Database

Phase 2: Focus Group Meetings

•Key stakeholder groups

Phase 3: Public Stakeholder Engagement

•Public Meeting •Comment on Draft Report

Phase 4: Stakeholder Feedback

•Final Report distribution

Figure 1 Summary of stakeholder engagement process

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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

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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 The Steering Committee (Appendix D), comprising of representatives Ongoing on a monthly committee from a number of authorities, organisations specialists related to basis, starting coastal, environmental and setback line development, were consulted December 2009 to throughout the methodology development. The committee included May 2010 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). th Authorities The second focus group, with authorities, provided additional 5 February 2010 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. Local The DEA&DP identified key areas within the municipalities of Cape Saldanha Bay Municipalities Town and Saldanha Bay as the pilot study areas to determine the Municipality - 4th functionality of the setback line methodology. Therefore each of these February 2010 municipalities was engaged in order to obtain the local level input. The Cape Town Municipality was consulted early on in the process, City of Cape Town – as they had completed extensive work on coastal protection zones 5th February 2010 within this region. th Heritage The South African Heritage Resource Agency (SAHRA) and Western 24 February 2010 Organisations Heritage Cape were consulted on the cultural and heritage aspects of the coastline.

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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  The 1:20 and 1:50 year lines should be considered setback lines  Consider implications of the 1:50 year line for setbacks in the long term  Need to restrict development within these lines 3. Roles,  Identify different levels of development management within setbacks – i.e. no responsibilities development vs recreation vs urban development. & management  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

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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  Properties under pressure/threat of development Implementation  System to prioritise vulnerable areas is required of setbacks  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  Control development in the high biodiversity areas by the EIA process, rather than management 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  Coastal setbacks need to take the NEMA trigger of 100m (developed) and 1000m legislation & (undeveloped) (from high water mark) lines into consideration. management of  Implications for EIAs and provincial decision making regarding approval for coastal areas applications within the setback lines 10. Consultation  National process - therefore consult with as many people as possible 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. 11. Methodology  To be a working document  Capture all issues, describe how they were resolved, to ensure accurate record and to avoid duplication.

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12. Private  What private rights do people have? Development  Will these properties be appropriated? Rights within the  It has been suggested that there be two lines: 1) erosion setback and 2) setback lines 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

Aspect Description of issues raised 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  Large setbacks are unmanageable (e.g. community can’t manage them and areas in setbacks this affects the environment)  Make setback areas conservation areas, with public access

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 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  Prioritising areas in setbacks - 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  Some areas have has a strong environmental communities which need to be consultation 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.

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Table 5 Summary of key issues raised in response to the draft report Aspect Description of issues raised 1. Methodology Time period forlines Allow for natural process - Need to include more than one line/period Ensure setbacks allow for natural process to continue where possible - Use precautionary approach, i.e. a shorter period and Global case studies reevaluate regularity - Need to include global case studies of past events to inform the study - Consider the sensitivity of different types of structures and - Include a comparison between international best practice development - Consider the needs of the local community Existing Land use - Must consider extreme flooding events - Development pressure, economic development and human needs - Development must not affect the correct location of setback lines Revision time frames - Identify and exclude areas that don’t require setback lines – e.g. coastal conservation - Revision time frames for setback lines should take into areas consideration local change and global climate change - Ensure setbacks facilitate strategic infrastructure development Local context - Setbacks must be relative to the local context consideration Authorities mandated for set setback lines of current land uses - Government departments (central and provincial) and Municipalities should be - Consider the impact of the establishment of setback lines mandated with the task of determining setbacks, not MECs and Ministers impact on existing development along the coast - Include local unforeseen change Include local unforeseen Unnecessary EIAs changes in revision process - Setbacks must ensure unnecessary EIAs are prevented\

Coastal public property Methodology - Need to integrate coastal public property effectively into the - must be robust setbacks - must be flexible and state outline challenges faced during the methodology Engage with local municipalities development to be open for revision - Inclusion of local SDF & EMFs - Methodology must be specific to allow it to be consistent in application of best practice. Coastal Aquifers - must be clear, and step-by-step process, which can be duplicated and revised over - Protection of coastal aquifers should be included time Cost & lack of local capacity Response options - Response options must be included into the development of the - There is a lack of local financial & capacity resources to methodology implement coastal setback lines - There are substantial cost implications of developing setback Bruun Rule - Include describe the Bruun Rule and other formulae lines for local municipalities Data requirements - Local municipalities must be consulted if private developers - Include PPP and socio-economic data Include PPP and socio-economic data as are developing setback line studies integral part of methodology - Recommend a skeleton framework of essential elements to - biodiversity Include biodiversity in setback to maintain ecological integrity determine setbacks for under-resourced municipalities - Include of heritage aspects - The Methodology should not be constrained by costs and

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timeframes in data collection - Include mining activities - Local municipal, provincial, national authorities and state - Remotely sensed data will probably be available at a good accuracy shortly departments should work together and share costs - If using the vegetation line instead of the HWM, a conservative approach should be taken Complexity of the system and linkages - between different - Site assessment and local knowledge may be better to use for estimating the quantity aspects that determine setbacks of wind-blown sand Stakeholder engagement Legal - Need for inclusion of expertise in terms of legal requirements - Address uncertainty in setback development through broad local stakeholder engagement before finalizing the setback Overtopping Manual - should be provided as part of the setback methodology. lines Maintain defences – Ensure natural beach defences are kept Types of setbacks Align standards - between different planning and decision-making documents (e.g. - Different types should be considered, e.g. erosion, aesthetic 1:100 year flooding). - Need to include Mining & biodiversity - Include no-go/Limited development 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 - Very technical terminology - Need clarity of guidelines to be adopted Report - 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 - Lack of cadastral/property boundary information Reports - Check Highest astronomical tides - Update definition of setback line 4. Public - Include responses to all comments Participation - PPP should not determine, but inform the setbacks Report - Include a public meeting into the PPP methodology

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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  Planning and development  Tourism  Coastal engineering  Water Affairs  Minerals & Energy (where appropriate)  Agriculture, Forestry & Fisheries  Trade & Industry (where appropriate)  Heritage  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.

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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.

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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]

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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)

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 The Cape Argus & The Cape Times (22 January 2010)

 Die Burger (22 January 2010)

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 Western Cape Province, Provincial Newspaper(22 January 2010)

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 Die Weslander (21 January 2010)

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Appendix B Registered Stakeholder List

Organisation Name Organisation Name Simon's Town Civic GOVERNMENTAL ORGANIZATIONS DAVID ERICKSON Alana Duffell- Association CapeNature Residents’ Association of Canham Len Swimmer Surveyor-General John Obree Hout Bay Noetzie Conservancy Surveyor-General: Julie Gosling Rosalind Mdubeki Owners' Association (NCOA) Bloemfontein West Coast Bird Club – Environmental & Keith Harrison Conservation Heritage Management Lesley Plettenberg Bay Community Branch Environmental Wolfensberger-Betts Dr Nicky Frootko Environment Forum Resource Management Macassar Environmental Garden Route National Park: Maretha Alant and Nature Conservation C W Hendricks Environmental Planner Society and Coastal Forum Cape Town Municipality Dave Brook Hout Bay & Llandudno Keith Mackie The Municipal Heritage Trust Manager Jacobsbaai Ratepayers George Municipality Alf Williams Attention:Mr Stiaan Association Carstens, PJ Mabula Overstrand Conservation Rob Fryer (Meg Hangklip - Kleinmond Foundation Campbell) Administration, Overstrand Mr. Neville Green Chairman of Saldanha Christo van Wyk Municipality Water Quality committee Overstrand Municipality Stephen Muller Noordhoek Conservancy Rory Sales NON-GOVERNMENTAL Ratepayers Dr J McCarthy ORGANISATIONS Association Cape West Coast Biosphere Langebaan Ratepayers and Nicole Loebenberg Jaco Kotze Reserve (CWCBR) Residents Association South African Planning Valley Ratepayers Janet Holwill Institute Western Cape Abena Kwayisi & Residents Association Branch The Noordhoek South African Planning Environmental Action Glenn Ashton Institute Western Cape Sarien Lategan Group. Branch Milnerton Proper Residents South African Planning Kevin Thorpe Sarien Lategan Association Insitute Vice-Chairman, St Francis Enviro-Fish Africa (Pty) Ltd./ H.B.Thorpe Aidan Wood Bay Residents' Association WWF-SA Chairman Gonnemanskraal South African Planning Doug Cleland Allan Rhodes HOA Western Cape Branch EBRA (Elands Bay Cape West Coast Biosphere Johnny Kotze Jimmy Walsch Ratepayers Ass) Reserve (CWCBR) Convenor: Langebaan Action Regional Coastal Committee Johan Ackron JJP Kotze Group Member Langebaan Action Group - WESSA / Saldanha Resident Alan Carnegie (LAG) COMMUNITY BASED ORGANIZATIONS Chairman Gonnemanskraal Doug Cleland HOA Woodbridge Island Body Jacobs Baai Ratepayers R.A. Rundle Dan Grobler Corporate Assoc Trustee: Environment and Macassar Environmental Waterfront Woodridge R.A. Rundle and Nature Conservation Dennis Roziers Island Body Corporate Society and Coastal Forum Plettenberg Bay Community PRIVATE/RESIDENTS Michael Wadge Environment Forum Private Andre van Greunen

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Organisation Name Organisation Name Private Jac Vos Private Nenriette Schuman Private Geoff Neden Private Anton Vonk Private Philippe Jaques BUSINESS Doug & Gaynor Private Zamile Mfakadolo Gecko Beach House Private Donald Stechman Portsmouth Cape Lowlands Mark Duckitt Private Eion Brown Environmental Services Mr T. E. Everett/ Private Private developers Peter Liddell Nikki Everett C.A.P.E. Specialist Land-use Chris and Iona Charl de Villiers Private Adviser Everett Urban and Regional Planner - Private Cathy Shimmin LegalB CC - Private Wendy Dewberry Robin Carpenter- Picasso Headline Private Fern Robertson Frank Private Chris Williams Bluegreen Planning & Derek Chittenden Private Mmusa Riba Design NEIL SCHWARTZ TOWN Private Derek Cockcroft Neil Schwartz PLANNING Private Steve Gettliffe BCD Town Planning Iwan van Wyk Private G Bond-Smith Horst Psotta c/o West Coast Horst Psotta Private D Bond-Smith Miracles (Pty) Ltd Mrs Patricia Knysna Leisure Industries Private A J Wilson Margaret Nicolson C.C. Private David Brown EXXARO Liezel van Zyl Private Schalk de Waal Aurecon John Foord Private Dr Penelope C Brown Environmental Assessment Private - Practitioner Sue Lane Technologies Associate Private Maaike Kallenborn SRK Consulting Matthew Law Private David Gwynne-Evans Duncan Bates Professional Karl Hendriksz Private Ena de Villiers Land Surveyors Private Tony Howe Duncan Bates Professional Duncan BATES Private Dr P W Nel Land Surveyors TRP(SA), EAP(SA) Sarien Lategan Private Irmé van Zyl New Development Mnr en Mev A.S. le Chavoux Luyt Private Technologies Roux Cape Coast Properties SB Dorman Private John Robinson Enviro Logic Gert Pretorius Private Pieter Badenhorst Imbewu Sustainability Legal Private George Sabbagha Marie Parramon Specialists (Pty) Ltd Private Keith Nicol SRK Consulting Warrick Stewart Private Jaco Kotze Barry Gould Architect Barry Gould Private Ritzema de la Bat Creative Profile Town Francois du Toit Private Vincent Bergh Planners Private H Shuman Cape EAPrac Louise-Mari v Zyl DELplan Urban & Regional Private Leone Suckling Delarey Viljoen Planning Private Andree Lombard AVDS Environmental Mr. Andre van der Hewlett Llewellyn Private Consultants Spuy Miles Sweetnam AVDS Environmental Ross Cameron Private Rob Munro Consultants Mrs Patricia M TV3 Architects & Town Private - Nicolson Planners

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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 Nelia Maritz CONSULTANTS Hout Bay & Llandudno Keith Makie Heritage Trust Aurecon Simon Van Wyk MCM West Coast Wade Theron Compliance Bau-afrika (Pty) Ltd. Rudy Schwaeble Cadastral, Topographic, Sectional Title and David Friedman Engineering Surveys Managing Member, LegalB CC [Enterprise No. Rita Felgate. 2005/067999/23] Exxaro Carl Skidmore Club Mykonos A J Shapiro OTHER Heléne Weslander Meissenheimer Weslander Alida Buckle University of Cape Town, John Crompton Dept of Geological Sciences

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Appendix C Background Information Document

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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 Paul Herselman (Represented Department of Agriculture Acting Manger: Land Use by Liesel Landman) SANBI Cloverly Lawrence Planning biodiversity SANBI input Jeff Manual Dept. Environmental Affairs: Marine & Potlak Khati Coastal Management 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

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SANBI Head marine programme Kerry Sink University of Cape Town ( EEU ) Prof Merle Sowman Department of Co-operative Human Settlements and Schalk M Grobbelaar TRP Governance, Traditional Affairs

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 ORGANISATION POSITION NAME Saldanha Municipality Town Planning John Smit

5. Heritage Organisations ORGANISATION POSITION NAME South African Heritage Resources APM Unit. Agency Mariagrazia Galimberti South African Heritage Resources Manager/Maritime Agency Archaeologist Jonathan Sharfman Heritage Western Cape Calvin Van Wyk Heritage Western Cape Nick Wiltshire

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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

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I&AP Comments Saldanha Bay Municipality  Funding for implementation of Setback lines - Saldanha Bay Municipality  Time scale of setback line: 1) a 20 year and 2) 50 year line - (Town Planning)  Roles and responsibilities for setback lines

 Identify different levels of development management within setbacks - Langebaan - 4th February 2010  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  Current legislation & management of coastal areas: - Dept. Environmental Affairs: - How does the NEMA trigger of 100m (developed) and 1000m (undeveloped) (from high water mark) lines relate to Marine & Coastal Management the coastal development setbacks? - Dept. Water Affairs  Inclusion of dynamic coastal environments: - Department of Agriculture - Include issues of human impacts on natural processes - SABNI - Include management of coastal areas SANParks  Enforcement:

Cape Town, 5th February 2010 - 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.

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 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  Use of Setback lines: Group - City of Cape Town (ERMD) - In Cape Town, the Coastal Protection Zone delineates the development setback line. Cape Town, 5th February 2010  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:

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- 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.

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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  Coastal heritage includes: - SAHARA - Buildings over 60 years old, Burials, Shell middens, Wrecks, Fish traps, cultural landscapes, Lighthouses, Heritage Western Cape - Most likely at the shoreline, tapering off landward. SAHARA, Cape Town, 24 February  Coastal heritage sites 2010 - 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  Case Study areas Meeting - Need to consider sites conjunction with each other and surrounding environment

- Reasons for choosing the sites - Two sites will not define all scenarios - Langebaan - 10th February 2010  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

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- 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,  Impact of developments on coast: - Cape Town - Need to consider how developments impact on the coast. - 11th February 2010 - 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.

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 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.

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Appendix F Issues & response Table - General I&APs

 Written comments from registered I&APs

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I&AP Comments Response Pieter Badenhorst 1.  Do not agree with the list of essential data as it is very expensive and the municipalities will not  Do not agree it is expensive – - Private afford such expensive studies. refer to costs which show that  Coastal management principles are not included- it should be part of the objective. 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 2.  The Saldanha Bay area has many different characters and situations  Noted Kallenborn  Erosion / damage to primary and secondary dunes and damage to property placed too close to  Noted and included implicitly in - Private the mean sea level methodology  Exclusive fenced off developments restricting public access to beaches are disgracing the area.  In terms of the latest ICMA legislation and our proposed methodology this will not be

allowed  Fynbos vegetation differs greatly on different locations, same stands for the waves/ swells,  The methodology accounts for currents, soil types, wind and local weather conditions. variability in these.  Lots of attention to urban development, little to no attention for rural areas which need protection  Not applicable to this study – a urgently against erosion, development or damage. setback line alone will not aid in protecting against erosion. Dr. Joy McCarthy 3.  look forward to sensible planning with respect to the effects of global warming and a halt to the  Noted. The method - Table view mad scramble to build as much as we can while we can at the beachfront and to heck with the accommodates sea level rise Ratepayers consequences. due to global warming in a association conservative way and will ensure a much more conservative approach re. development than has been applied to date. Henriette Schumann 4.  In Stillbaai, on the east side, degradation of the primary dunes is a big problem. homeowners of  Noted this concern. Strictly not - Private the properties just behind the primary dunes are illegally levelling the dunes, planting invasive applicable to this study but grasses on them and using it as their own. This has been going on for a long time despite setback lines placed during the repeated complaints by concerned residents. execution phase will render such activity landward of the line illegal. Mr. Alan Carnegie 5.  Setback lines cause more harm than good.  Historically I think a case could be made to back up this - WESSA comment. We believe the 91212Drepresentative Western Cape Coastal Setback Lines – stakeholder Engagement Report 38

reason for this statement is poor methodology (and no specific methodology to follow) which has now been remedied Phoebe Barnard 6.  Aeolian sand corridors, estuaries etc are seemingly treated appropriately, and to voice caution  Comment noted and agreed - SANBI that the setback lines should be VERY precautionary, given the high levels of complexity and with. 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. George Sabbagha 7.  We have a situation at Stilbaai where coastal dunes have been flattened and used for personal  Noted this concern. Strictly not - Private purposes. This matter was brought under the attention of Sandiso Zide and Dr Niel Malan as well applicable to this study but as Allan Boyd. A complaint with photos as requested was sent but no feedback. setback lines placed during the execution phase will render such activity landward of the line illegal. JF Kapp 8.  To determine beach set back lines is to enter an extremely complex field subject to all sorts of  Agreed that this is extremely - Private interpretations and understanding. There are no hard and fast rules and it is at best a guess. It is complex and that it is a essential that agreement on the period over which the setback line is applicable be reached challenge to establish rules. At beforehand. Depending on the ownership the period can vary as stated in the slide show. 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 Good point, but beyond our Coastal Management Act makes it essential that any Methodology must be able to meet court of brief to change the ICMA. We law requirements. It is suggested that reference to “all Ministers and MEC’s” be removed and assume this is not addressed replaced by “Government departments (central and provincial) and Municipalities”. specifically to us.

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10.  The methodology as set out by WSP is probably the best available. The following comments on the draft are offered.  We have recommended a - It is recommended that coastal sections which does not require beach setback lines be identified default, interim setback for such early on, and be excluded from studies. For example it would appear unnecessary to sections of coast as the Otter determine setback lines along the Otter Trial section of the coast. Trail, in our report. Also indicated priority areas.

- The fixing of setback lines is extremely sensitive to the nature of the coastline and of the  Recognised and we propose subseabed. wave modelling (that takes into account the subsea bed contours) to accommodate this.

- The effect of extreme flooding must be taken into account.  Thank you - addressed in the

report

- Bodies not obeying sensible beach management must be seen to be taken to task and repair damages caused by their activities.  Agreed, although strictly not in study brief

- Setback Line Methodology must not be dependent on cost and time – constraints in data collection.  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. - 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 - 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

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John Compton 11.  As a marine geologist involved in coastal projects I would like to comment on the need for coastal In response to your comments - University of setbacks and the factors to consider over long (longer than a single human generation) timescale. which were echoed by others, Cape Town the setback “return period or applicability period” has increased from 50 to 100 years

Nigel burls 12.  We are the appointed town planners for the AECI site in which has an extensive  Noted - MLH Architects edge along the False Bay coast line. and Planners

Rob Fryer 13.  Marine biodiversity protection is essential - that the influence of land-based impacts upon marine Biodiversity is a key item - Overstrand biodiversity is considered within any methodology for determining setback lines. Setback lines included in the methodology. should apply to all forms of development, including the ploughing and cultivation of land where the Conservation  Comment included in topography is such that nutrification or other pollution of the coastal zone may occur to the Foundation methodology report in the detriment of marine biodiversity. (OCF) biodiversity section

14.  I am very worried about the proposal to employ modelling techniques. Models can only be used  Agreed that the models must be

by people who have understanding / insight into the theory used to construct the models. If the wielded by people with an models are used by people without this insight then the users will simply plug data into the models understanding of these models. and crank the handle to get answers that may not be at all accurate. If models are to be used This is accommodated within then they should be used only by people who have been trained to apply them and accredited the methodology in three ways following passing examinations. Conclusions drawn by those who apply the models should be (1) specifying the expertise to reviewed by a specialist who is an authority on modelling before the conclusions are accepted by be employed to execute the the authority who will authorise the setback lines determined using the modelling technique. The setback study and (2) limitations of the model and the circumstances under which it can and cannot be used must be conducting some of the very clearly stated. 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 It was agreed with the client that movement of the high water mark. Special attention needs to be given to the case of estuaries that estuaries would not be part that are closed to the sea and only open seasonally after heavy rain. In the case of these blind of this study. Nevertheless the estuaries, the setback should be greater due to the propensity of these to become polluted during importance of having them the months when the mouths are closed. 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

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- Residents’ and beach dune field as this is not appropriate for orderly development. agreement but this is not part of Association of the present study.

Hout Bay  Agreed and this is part of the  Protection of natural assets (e.g. beach dune fields) as they have a role to play in protecting methology. established residential areas further inland and provide a useful natural buffer.

 Agreed and this is part of the  They should be protected in their own right as we are obliged to protect our natural environment methology. and biodiversity now and for the benefit of future generations.  This is considered within the  Sea level rise and the increase in frequency and intensity of storm events is of medium to long methodology. 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.  This is considered within the  Also such negligence will result in the erosion of our natural heritage which effectively forms the methodology. basis of our economy locally, and in the Western Cape in general John Obree 17.  They are really a zoning matter.  Noted - Surveyor-  These setback lines will be delineated in the Provincial Zoning Scheme and properties between General: Cape the sea and these setback lines will be subject to the conditions imposed by that setback line -  Noted Town 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  Agreed the need to conserve the adjacent land.

 It is requested that wherever possible that these setback lines be demarcated and proclaimed  It is not intended to establish relative to fixed rectilinear cadastral boundaries and not be defined as being a stated distance setback lines relative to the from the HWM. somewhat “difficult to define”  The determination in law of the exact position of the HWM is always going to be in dispute, by the HWM. The setback line/s will nature of the HWM definition, thus making it an unsuitable benchmark for any fixed boundary be independent lines with their zoning system. own coordinates.  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  Setback lines have their own rectilinear cadastral boundary or as a line a fixed distance from a rectilinear cadastral boundary. priorities as per the methodology developed – they cannot follow cadastral boundaries

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Mbulelo Dopolo 18.  What type of data is to be used that was acquired from SANBI (in particular Kerry Sink)? Is it  Biodiversity maps – i.e. those - SANParks conservation priority or ecological sensitivity maps? I want to be sure that you will be using an defining critical biodiversity appropriate data (input) that will provide appropriate output in terms of setback lines. Ecological areas, etc. Employment of Cape Research sensitivity maps are what need to be used, if such information has been developed (synthesised) biodiversity expertise together Centre: Scientific already, because the last time I checked there wasn’t such information. I will make a follow up to with recommendations to Services: Marine verify this with SANBI, and will come back to you to confirm any feedback that I will get from them. consider ecological constraints Program Manager should ensure. Await feedback.

Mr Keith Harrison 19.  The project will give a useful tool to the Planners  Agreed Westcoast Bird  It is a pity that there is not a rocky shoreline included in the study  This is not explicitly indicated in Club 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  When the Avifauna Study is carried out it should be remembered that many of our coastal Birds – Noted. e.g. terns, only come in after dark and species use of an area differs throughout the year. Sarien Lategan 20.  How the issues ( Boundaries, coastal protection zones, Municipal planning zones, military and  More detail is provided in the - South African other special use areas, special mgt areas, cadastral boundaries; Sediment/geotechnical issues; final draft of the report. Planning Erosion lines; Flooding; Biodiversity priorities; Other issues e.g. public access, aesthetic features, Institute, shading of beaches by structures, meandering estuary channels, heritage sites etc) are going to Western Cape be assessed and used to determine the setback line.  More technical detail needs to be provided for comment 21.  It is contested that these sites (study areas) do not provide a representative view of the total  We would contend that it is coastline of the province. 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.

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 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 Results of a literature review best practice guidelines e.g. A literature review to support are included in the report. 23.  Whether the legal context will be dealt with at a later stage when an actual setback line is  Correct – at a later stage 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 Noted – not within scope 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 Noted– not within scope of the legal status is.

 I would assume that the setback line be accommodated in a development framework and only  Noted once such SDF is approved can it be translated into zoning regulations and be adopted as part of

the zoning scheme regulations.  Noted – relevant  The methodology on which the setback line is going to be based is of utmost important and groups/individuals have been therefore it is suggested that the project engage in more detailed dialogue with professionals consulted working in the field of spatial planning and environmental management.

John Robinson 24.  There are a number of developers who would certainly not want these setback lines to come to  Comment noted - Private 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.  Comment noted  You will find the necessary support our area from people who want to force the developers to desist from strip development!

Jonathan Sharfman 25.  The Underwater Cultural Heritage Unit at SAHRA is the national competency for all heritage sites Noted - Manager/Maritim below the high water mark, but are also involved in the management of maritime sites falling e Archaeologist 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 - Underwater to be included in discussions. Cultural Heritage UnitSAHRA Charl de Villiers 26. CBA maps Noted – for this reason inclusion  There are instances where coastal features may have been incorrectly mapped in that theof a biodiversity specialist on the project is a prerequisite. - C.A.P.E. depicted land cover does not correspond with actual conditions on the ground which,

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Specialist Land-  In these cases, CBA designation should preferably reflect the desired objective of managing theNoted use Adviser: littoral active zone and coastal processes in a 'natural' condition. Land-use  Setback lines that fulfil the role of protecting such processes from human interference and, Noted. in The methodology Planning and turn, protecting property and infrastructure against the effects of coastal erosion, etc, wouldproposed aims to achieve this. Decision-making certainly be a very valuable contribution to 'mainstreaming' CBA maps and priorities into spatial planning and land use management. 27. Alien infestation of dune fields The methodology proposes that if  Where does one draw the setback line if it is accepted that the dunes have been artificially fixedthere are known plans for and may be remobilised in future? The latter would be a definite management objective if a duneremobilisation of a dunefield (e.g. system was designated as a terrestrial CBA through destruction of alien vegetation), this must be taken account of in assessing the coastal processessetback line. 28. Settlements in the littoral active zone It has been decided to indicate  Would setbacks be drawn through settlements, i.e. parallel to the coast and corresponding to thesetback lines (e.g. to allow for former geographic limits of coastal processes, or would the setbacks follow, for example, thenatural coastal processes) seaward edge of the built-up area? Or could the front row of houses conceivably fall within thethrough settlements. It is setback, i.e. not be excluded by it? 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 This paper has been Roets and Duffell-Canham was presented at last year's IAIAsa conference and deals with referred to setbacks in the context of climate change.

- W Cape rural development guidelines which translate the CBA map categories into spatial  This document has been planning categories (SPCs) which are defined by the W Cape provincial SDF. The spatial referred to planning categories, in turn, provide recommended land-uses.

- The Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western  Noted. Document accessed Cape also include a chapter on the implications of development in sandy shore ecosystems and key concepts http://bgis.sanbi.org/wces/FF_Ecosystem_Guidelines.pdf incorporated.

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Appendix G Authorities & Steering Committee Comments on Draft Report

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I&AP No. Comment Response Environmental 1. Section 1.5.1: Resource Management a) The proposed use of the 100-year period for residential setback and 50-year for low-Agreed. Point included Department value structures is supported, although the argument presented in the bullets on pages (ERMD) 4/5 appears a little thin. Whilst the CoCT setback for inland rivers for residential - City of Cape development is the 50-year floodline, it is recognised that the destructive forces town 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 Incorporated in the report 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 anotherEroded sand moves offshore to bolster extreme storm, the predicted setback will be ‘breached’. Assuming development takesthe protective sand bar on which waves place up to this setback in the interim, and considering the above scenario takedissipate – thus protecting the coast to places, there will be no buffer left in place and we will be back at ‘square one’. Thesome degree from a large subsequent different spheres of government should collaborate and put in place different setbacksstorm. with different regulatory mechanisms in place to reduce this from taking place. AnTidal conditions change such that a example of this would be for the setback line to be included within the CPZ as a safetysubsequent 1:100 storm (in terms of mechanism. 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.

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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,Noted. Another good reason to go for changes differently across different spatial and temporal scales. If a building has a design life1:100 and not 1:50 years 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. 2. Section 1.5.2:

The setback line revision process may also need to be initiated when there is evidenceat a This has been incorporated 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. 3. Section 1.5.4: Setback lines and existing development: This situation is analogous to the situation where Noted. (this section of the report has the high hazard zone of inland floodwaters intersects existing development rights. The CSRMbeen removed on request from Branch has received preliminary legal opinion(still under discussion and refinement) on theDEA&DP legal opinion needed) question of Council’s ability to curtail existing rights due to the location of the high hazard zone.

4. Section 2.2.1 : General Approach 6. Current land use activities should also be considered when determiningNoted that current land use activities the setback line. In section 4.1.1 – zoning – consideration should be given to current land useshould be considered. Incorporated in and plans – not just the future ones. Where plans appear to be a few years old, local authorityreport. 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). 5. Section 3.7 Incorporated in report

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End of last paragraph: possible typo: CSIR 1988. Only 1998, 1990, 1999 in reference list. 6. Section 4.3 Noted – this is included 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. 7. Section 5.4.2 and Section 5.4.3: Incorporated in report

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: Incorporated in report 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: We deem the placement of public a) More detail must be provided on the use of ‘other issues’ as key informants toaccess corridors to be a determine the position of the setback line i.e. what channels need to be followed tozoning/planning issue - related to determine access points, where would appropriate access points be located, howsetback but not part of the present would the carrying capacity of access points be determined and how would this effectscope the location of these points in relation to determining setbacks etc. Coastal mining – we propose to treat There does not appear to have been any mention of setbacks that would contribute to the same as development. protection of coastal aquifers (e.g. prevention of ingress of seawater into aquifer) or any Coastal Aquifer – we deem that the setbacks that address what needs to be done where there is coastal mining underway or potential contamination of a coastal planned (i.e. presence of coastal minerals or diamonds). 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)

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10. Section 7.3: This is now addressed in the report 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. 11. MILNERTON CASE STUDY Our perception is that having this Section 3.1: Assess Boundaries information in the case study would not The lack of cadastral information is a weakness in this case study. This is readily availablehave made a difference to the setback information, and reveals an important aspect- i.e. that Transnet owns a strip of the beach alongline. the full study area. As indicated in 4. above, property boundaries are fundamental to the setback line. 12. Section 3.2.7: Sand Grain Sizes This variability is recognised in the Although sand grain sizes are an important indicator of rate of erosion and other coastalinterpretation of the model results – in dynamics, the measurement of sand grain sizes must take into consideration the seasonalwhich the sand grain information is variation in accretion/erosion of beaches in Cape Town. Conclusions should (not) be drawnused. Extent of sensitivity to be tested from a in enabling study.

single sample taken over a point in time. 13. GENERAL From the outset of this study, the concern was raised that the majority of coastal municipalities,Noted. 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 recommendedInterim measures and a rapid that a skeleton framework listing the bare essentials be provided, as well as a simplifiedassessment approach are proposed. methodology that can work with limited information. Such a methodology must be robust,Simplified/classification of highly simple and cost effective for those municipalities that are not in the position to conduct suchcomplex processes to get an “easy work. estimate” of setback is not recommended.

Due to the nature of this research, and as a result of the detail required, key informants toAgreed that some interactions do occur determine this setback methodology have been investigated in isolation. In reality however,between informants (e.g. as you rightly there are connections between the various processes, where one may influence the other,pointed out runup must be calculated resulting in non-linearity. This reflects the complexity of systems and where such complexityon the eroded profile – this is now cannot always be modeled resulting in a degree of uncertainty. Uncertainty should also beincorporated in the report). used as a key informant in the process for determining setbacks. Erring on a conservative approach would speak to this matter.

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Consultation with municipality has now Modeling is key to this approach and is necessary for the point of departure. However,been incorporated as part of the considering the uncertainty aspect mentioned above, and considering the conceptual issuesmethodology. 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. 14. Highest Astronomical Tide and SpringHigh Tide Variations are due to local versus The HAT of 1.2m (Table 3) in the Milnerton case study is different to that of the HAT of thenational maxima varying. This is dealt general methodology which indicates 1.4m (Table 1). The SHTs for Cape Town are aroundwith in the report. 1.80 - 2.00m, which is more than the HAT. Some clarification on this would be appreciated. 15. MINUTES Incorporated in report 2.1 Coastal Development Zone should read Coastal Protection Zone’. John Robinson 16. The existing properties – I would put the setback line where it should be and grant them leewayThis can be considered. Essentially - Private or permission to not have to do EIA for alterations. I would also make ruling that they may notany re-development would require an subdivide or add new structures to the existing plot. This way you stop guys building megaEIA. But exceptions could be made. blocks on postage stamp plots of old houses.

17. What about developments that are currently in the process of preparing EIA studies – can weWe now have in our report a hierarchy not force them to wait for the Set back line placement. Maybe those areas subject to EIAof requirements – the 100 m (or 10 m studies for developers could receive priority in the creation of the setback line? It is my opinionMSL contour) will be default that the developers are going to make a mad rush to get their foundations (or some such non-development setback lines. We are reversible) activity) in so the setback line law cannot be applied to them. We need to make thisproposing that developers can get aspect clear or your whole effort is going to be “set back” a lot with new developments beingsetback lines analysed under their put established in areas that are inappropriate like the examples you have shown and thefunding – but with specified conditions average Joe Soap buying these properties with little knowledge of these things is again(see report). We will propose seriously disadvantaged! implementation of this immediately Mr CW Hendriks 18. We are a community based environment association for the Macassar and Region The I&AP List has been amended to - Macassar and are actively engaged in environmental, nature conservation and coastal management. include the correct organisation Environmental name and Nature Therefore I need to bring it to your attention that our association's name is called: The and Conservation Nature Conservation Society and Coastal Forum 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. 19. The two representatives of our organizaton, at the particular stake-holders meeting in  Noted

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Pinelands was: Chairperson:Cedric Wayne Hendricks and Public LIasson Officer: Dennis Roziers Christopher 20. I did not go through the document thoroughly but I did get the key points and focus areas. I (i) We have simplified it Vuba found the report to be, (i) a bit too technical, note I am saying 'too' technical, simpler slightly and included a - WC terminology can be adopted to help the person with no engineering background; (ii) it would be glossary. Department of good for the consultants to balance the amount or level of detail with an equivalent level of (ii) We have included “boxes” Environmental clear guidelines on the methods to be adopted; (iii) the report is well put together in terms of in which we summarise Affairs and the work that has gone into it. the methodology minimum Development requirements Planning Town and Regional Planner: Siyabonga 21. Dlulusi Noted - WC PPP document: Name of sections and department. Department of Environmental North Cape Department: should read as Department of Environment and Nature Affairs and Conservation, Not Department of Agriculture , Land Reform , Conservation and Development Environment. Planning DEADP: Section should be read as Integrated Environmental Management, Not. Environmental Impact Assessment 22. Set Back Methodology document: Policy on estuaries, and on the period Estuaries : In terms of assumptions which flood line methodology to be applied is the (50 or 100 years) for setback lines is 1:50 years or we adopt CapaNature`s recommendations of 1:100 years. City of Cape now Included in the report. Town recommends 1:50 year’s setback line which is equivalent to life span of the building of less value. 23. Types of Setback Lines: Erosion and Aesthetic setback line. Where can we fit is setback line We propose that sand mining be for sand mining?. If you can expand a bit on setback line for biodiversity. Also look at the treated similarly to development – in conservation and coastal ecological processes. 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

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Simons Town to Glern cairn and Fish Hoek, this take place on the False Bay side. On Noted. The methodology the Cape Town area to West Coast North West winds are the problem. This type of accommodates all wind setup and wind usually pushes the waves up to 5 to 10 metres high. This type of waves and sea associated wave processes. 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 Noted. 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. 25. International practice vs South African practice Noted and accommodated in report. 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 Noted Hericane cartriners. These all happened in the coastal areas. Then South Africa can use these coastal disasters as case studies. 26. International best practice: Western Australia Western Australia employ sea level rise of 0.38 and setback line allowance of 38 metres The 38 m is an allowance for setback for sea level rise. Is the 38 metres allowance focus inland or wave hight? This might be (i.e. applied horizontally back from the the cause of storm surges. shoreline) 27. Setback for : B sedimentary or Geotech , C Setback line for Flooding Noted

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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 Noted –the relevant SDF’s have been West Coast District Municipality SDF. applied in the case studies 29. Mapping: Please also go beyond SANBI and CapaNature, also check if there is Noted something at SANPARKS and City of Cape Town: Environmental Resource Management Unit.

30. Heritage: Kindly visit Cape Agulhas National Park information hub, where two oceans Noted. This may be relevant for meet if they don’t have some information available. Inside there park the is ship wrecks setback in that area. and the area on its own it’s a heritage destination the Southernmost tip of Africa. 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 Noted. We proposed to avoid setback developer will inform the consultant driving the study of what the developer want. This being placed excessively close to the might compromise the correct outcomes of the study and compromise the objective of sea by (1) ensuring minimum setback line. Developer will be pro development. We can site example of City of Town methodology requirements are adhered cases of Big bay beach and Muizenburg developments. The new developments in these to (2) taking a precautionary approach areas are in sensitive areas, they trigger listed activities ito of NEMA EIA regs. At some and (3) including peer review in the point environment is compromised for economic development. Yes job opportunities are methodology. 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. 33. Conclusion: Noted.

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. 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

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- eThekwini concerned that costs will be an issue so perhaps the team could give us the average report Municipality cost per km of the two pilot site so we can get a feel of relative costs for future work. Coastal Policy Pg 4 Table 1.1 I have recently redo this table with now four categories (see attached included this 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. pg 8 I don't find the references to the Western Aus case useful. Setback We now indicate the following after the depends on the wave climate which in turns shapes the coastal profile and if, as we Western Aus case: “It is not advocated have along the open coast of KZN, a cut off depth at -18m at between 500-1000m off that such values be used, since each shore (very typical of our coastline) then the retreat is as low as 25m to as high as 50m region or site must be analysed using Bruun rule for 1m of sea level rise (verse 40m for 0.38m West Aus.). Or individually, but this provides a useful alternatively a rule of thumb for each coastal province needs to be defined to use in the absence of any modelling or info. 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 Good point – we have revised our default of 0.3m RMS as the coarsest. How do you model SLR when the value of SLR is quote to ±0.1 m to ±0.3 m at most 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.

Pieter 35. Still maintain that you are all coastal engineers with limited coastal management Perhaps we need more clarification – Badenhorst experience. 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

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sites.

37. The setback you refer to at Paradise Beach - I do not know who determined that We recognize that not every consultant setback – and when – and what it was. There are, however, other processes at play is up to date with computational that has an impact and most likely little to do with sea level rise. Remember the CSIR modeling and as a result are trying not did many studies there MANY years ago. to be exclusive in this regard. To accommodate this, one I cannot comment on the Hermanus example – do not know that site. recommendation we have (now) made is to create a “Wave Atlas” up front, I am making the above comments because I do setbacks here and there using info you which would allow all consultants to refer to except the modeling. The issue is important and not the very few projects I access near beach wave data without might loose. 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 We have had a look at costs and Province will do these setbacks there will be a problem with cost at Municipal level. 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 Agreed that this is extremely sorts of interpretations and understanding. There are no hard and fast rules and it is at complex and that it is a challenge best a guess. It is essential that agreement on the period over which the setback line is to establish rules. At this stage applicable be reached beforehand. Depending on the ownership the period can vary as the methodology provides some stated in the slide show. guidelines and methods which elevate the estimation of the setback line well above “guess” status. However, we also strongly

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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 Good point, but beyond our brief Integrated Coastal Management Act makes it essential that any Methodology must be to change the ICMA. I assume this able to meet court of law requirements. It is suggested that reference to “all Ministers is not addressed specifically to us. and MEC’s” be removed and replaced by “Government departments (central and provincial) and Municipalities”.

42. The methodology as set out by WSP is probably the best available. The following We have recommended a default, comments on the draft are offered. interim setback for such sections of It is recommended that coastal sections which does not require beach setback lines be coast as the Otter Trail, in our report. identified early on, and be excluded from studies. For example it would appear Also indicated priority areas. unnecessary to determine setback lines along the Otter Trial section of the coast.

43. The fixing of setback lines is extremely sensitive to the nature of the coastline and of the - Recognised and we propose wave subseabed. 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 - Agreed repair damages caused by their activities.

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).

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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 Agreed – this is accommodated in our account in determining set-back lines. report

Gerhard Gerber 50. Main Report Dept. Background and Motivation Environmental Affairs & It is recommended that the background and motivation rather be combined under the headingDone Development background. In terms of reference is clear that the setback lines are to be determined in terms Planning 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 Incorporated a similar statement 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…

51. The section on “Facilitation of Development” (1.2.1) should also be amended. It is not so muchThis has been amended 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

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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-Not in agreement until this is a certainty level rise it is vital that development setback lines are established so that such problems do not(no literature clearly proves this). At recur”. This should read “Taking into account sea-level rise and increases in the intensity andthe same time, it is recognised that frequency of storm events it is vital…”. higher water will result in more frequent and higher wavesat the beaches. 53. Study Objectives & Requirements We would like to retain the direct reference to the TOR in terms of The section on study objectives should be expanded. I would recommend that the study requirements. Additional conditions etc objectives and requirements be combined into one section under the heading “study are included. 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…

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 The a need for a precautionary approach precautionary approach in that while some infrastructure might have a certain design life, therehas been incorporated in the report. will not be enough resources nor would it be possible for a “retreat” in future in terms of havingMonitoring (beach profiles) has been to in future shift lines and development. The time period therefore becomes important in termsemphasized. 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 beMonitoring is recommended undertaken. Agreed that this could result in a While in certain circumstances a setback might be determined for a specific development, the checkerboard with different lines. Can setbacks will mostly be determined for entire settlements and extensive stretches of the coast. apply a lower period only for a As such, to make use of different time periods for different infrastructure does not make sense. continuous zone. Incorporated in report

55. Number of setback lines Noted It is agreed that there must be more than one setback line (1.5.3) namely the coastal process

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(“no development”) setback line and a limited or controlled development setback line.

56. Setback Lines and existing development In accordance with comments from Paul Hardcastle this section has been It is stated in the section dealing with “setback lines and existing development” (1.5.4) that: modified. “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.”

57. While the implications for existing development must be highlighted, these statements containIn accordance with comments from incorrect assumptions and information, and must be removed/reworded. The only correctPaul Hardcastle as well, this section assumption is contained in the last sentence which statesIt “ is assumed that the coastal has been modified. 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 toprohibit “ 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

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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” asthe “ highest line reached by coastal waters, Important to distinguish between this but excluding any line reached as a result of (a) exceptionally or abnormal floods or storms thatHWM as defined and the waterline as occur no more than once in ten years; or (b) an estuary being closed to the sea”. With climate per the aerial photo analysis. We change resulting in an increase in the intensity and frequency of storms, it means it make is use of the waterline in becoming normal that storms that might in the past only have occurred once in ten years, willdetermining the setback location, since occur more frequently. The line that will be reached by storms occurring more than once in tenthis is the line which is visible on aerial years (i.e.) the high-water mark) must therefore be determined as one of the lines to bephotographs. 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.

59. The following sections of the ICMA,inter alia, further refer with regards to existing Noted 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.

60. Study Approach (the “how”) Substantiation of various methods selected (why this and not that) is now Section 1.6 dealing with the “how” should be reworded. Yes, it is about the method used to provided throughout the report. 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

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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 criticismsNoted – as above, substantiation is without being able to address the criticisms; as well as not allowing for “learning” in terms ofnow provided throughout the report. being able to revisit the specific considerations as new technology and new information becomes available over time.

62. One of the reasons why the development of the methodology was commissioned wasThe report now provides specifics specifically to be able to make a defendable argument for a best practice practicablewhere possible in an effort to make the methodology that is to be consistency used. If the argument is not made strongly enough formethodology repeatable (by different the specific methodology proposed, it will result in other proposing alternative methods withoutpractitioners). It has to be recognised the authority being able to argue why the preferred methodology is to be used. In this regardthat considerable experienced the specific criteria to be used (and even how the relative importance of the different criteria judgment– is still required 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.

63. Form of the Report Incorporated in 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.

64. Different lines It will not be acceptable to specify setback relative to a high water mark Section 2.2.1 states Assessment “ of the erosion setback line should include separate that is migrating over the years. We assessments of long-term erosion trend, short term erosion, (by storms) and erosion (and/or specify the point relative to which the setback) due to sea-level rise. These are added together.” The general approach should also setback must be applied in our study. highlight that due consideration must also be made of the fact that historically determined high- (end of section 7.2) 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.

65. Together with the comments earlier related to setback lines and existing developments theNoted 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

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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 formulaMore information on the Bruun Rule is being inappropriate in certain instances on page 19, more information must also be provided. provided

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67. Data Collection Included in report

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 publicPublic participation now incorporated in participation and how it should be undertaken is also to be provided. the report

68. Zoning and future plans Corrected in report 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 aRural “ 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.

69. Erosion setback Noted 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.

70. Setback for biodiversity Noted and incorporated in report 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.

71. Setback for other issues Noted: More detail and figures provided. 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…

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72. Expertise Noted and incorporated. 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.

73. Priority Areas for setback lines Noted and incorporated 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.

74. “Quick and Dirty” Method This is now incorporated 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.

75. International Best Practice Now expanded within the report Some of the best practice information provided is very limited and no indication is given of how the methodologies compare.

76. Langebaan Case Study Report Revised to comply with the methodology 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, namelycoastal 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.

77. Coastal erosion setback only This was not correct and has been addressed. Aesthetics and other On page 1 it is stated that “for the purpose of this investigation, an erosion setback line will be issues are considered in updated determined assessing the shoreline at the study areas (sites)”. In other words the methodology report. 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?

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78. Public Participation As noted in the minutes of the meeting held on 23/02/2010, “Public should Section 4 on page 17 simply states “In a study the above results would be published once participate on methodology ONLY, comment has been received and addressed where relevant by focus groups”. This is not not on the results of setback line adequate. As stated earlier part of the data gathering process also includes public participation. studies”. Also, since the setback line The engagement with the public must inform the ultimate setback line. Part of the methodology determined in the test cases were not therefore also consists of public participation, and as such the testing of the methodology going to be published in the Gazette, should have included the testing of public participation as a component of the bigger method. there was no need for informing the public of the results

79. Conclusion and recommendations Now clarified and learning points from the case studies are reported. Note The conclusion and recommendations on page 18 is not clear and does not address the that the options mentioned (hold the ultimate options of “retreat” versus “holding the line” versus “advancing the line”. It is for line etc) are deemed to be a instance not clear if specific measures to firstly reclaim some land (“advancing the line) and management issue. While requiring second to then “hold the line” are being proposed. consideration not deemed an essential part of the methodology. 80. Milnerton Case Study Report Revised to comply with the methodology 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, namelycoastal 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.

81. High-Water Mark This was actually not the high water mark (as per ICMA) but rather the It is stated on page 3 that “high-water mark and not the water-line at the time the photograph water line. Now corrected was taken” was used. Was the high-water mark predetermined as indicated earlier in terms of the IMCA definition of high-water mark?

82. Overtopping Manual Reference provided – however important that the most up-to-date The Overtopping Manual mentioned on page 14 should be provided as part of the setback information be used at all times. methodology.

83. “Coastal Protection Zone” Accommodated in report

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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 Now accommodated in report Section 3.6 on page 14 is not clear on why “no setback distance was allowed for heritage”.

85. Public Participation As noted in the minutes of the meeting held on 23/02/2010, “Public should Section 4 on page 16 simply states “In a formal setback line study, the above results would be participate on methodology ONLY, published once comment has been received and addressed where relevant by focus groups. not on the results of setback line This will not be done for this case study as this study is mainly concerned with the testing of the studies”. Also, since the setback line proposed methodology”. This is not adequate or correct. As stated earlier part of the data determined in the test cases were not gathering process also includes public participation. The engagement with the public must going to be published in the Gazette, inform the ultimate setback line. Part of the methodology therefore also consists of public there was no need for informing the participation, and as such the testing of the methodology should have included the testing of public of the results public participation as a component of the bigger method.

86. Conclusion and recommendations Now clarified and learning points from the case studies are reported. Note The conclusion and recommendations on page 17 is not clear and does not address the that the options mentioned (hold the ultimate options of “retreat” versus “holding the line” versus “advancing the line”. It is for line etc) are deemed to be a instance not clear if specific measures to firstly reclaim some land (“advancing the line) and management issue. While requiring second to then “hold the line” are being proposed. consideration not deemed an essential It is also stated that “This study was conducted with deliberate disregard for appropriate part of the methodology. setback line studies previously conducted at the site (e.g. CSIR (1988) and Smith (2003))”. Why? No reason is given for this. Disregard for previous studies now explained 87. Public Participation Report Agreed – public participation is a key component of methodology. Section 3 Public Participation as part of determining the methodology and for implementing the of the stakeholder engagement report methodology includes the proposed methodology. Yes, public participation had to be addressed both as part of the determination of the

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methodology and as part of the methodology itself.

88. Heritage Western Cape This has been changed In Table 2 mention is made of “Western Cape Heritage”. This must read “Heritage Western Cape” throughout all the documents.

89. Approach Public Meetings have been included in the final PPP report 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.

90. Comments and Responses These issues were raised at the stakeholder meetings, and where While Appendix F provides an issues table to shows the comments received, no responses to therefore responded to within the the issues raised are provided? 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 Addressed in report through: • Glossary provided 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 Better explanation of why therefore considered to be a learning process and that the documentation would also various approaches proposed • record the “development”. In having to deal with many contentious and complex issues, Text boxes indication minimum the recommended methodology must ultimately provide clear guidance in order to ensure requirements for setback line consistent application of the best practice methodology. While those that will in future assessment. 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). 92. Ultimately the report on the methodology must also form an integrated whole. Currently theThis is being addressed – via cross- different reports do not really speak to each other. 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 DevelopmentCorrected

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- DEA&DP Frameworks and not Strategic Development Frameworks.

Also, it is not clear to what Rural Development Framework there is being referred to here. AreYes - corrected you referring to the Rural Land Use Planning & Management Guidelines (May 2009)?

94. Page 14: In Table 4.1 and under the Data column th(4 row down) it should again be Spatial Corrected Development Framework and not Strategic Development Framework. 95. Page 28: Under paragraph 6.3 there is being referred to limited/controlled development. InNow elaborated on this in section 3.1. 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. 96. Langebaan Case Study: Corrected Page 3: In table 1 the source for the data for the SDF should be the Saldanha Bay Municipality.

97. Milnerton CaseStudy: Noted No comment. 98. Draft Public Participation Report: Noted No comment.

CapeNature 99. Section 1.2.5: Corrected representatives 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. 100. Page 5: We propose that this be a “no go” area Number of Setback lines – need to possibly make it clearer whether line 1 (coastal processeseven with an EIA – this is included or no development setaback line) is an absolute no go area i.e. development will not be allowed even with an EIA.

101. Secction 7.2.3: Corrected Could possibly reword second half of sentence “…..to ensure that development is limited/controlled to protect areas of high conservation value.” 102. General points: This is now included – see section 9.6 It is clear that many coastal municipalities do not have the resources to apply such a scientific

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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 5mFor the exact reason of numbers “not amsl is proposed as a setback we would like to make it clear that this was not derived from theadding up”, the table was copied from table alone, and definitely not by adding up numbers in the table. The table merely gives thethe original source (with modification of various sea level scenarios used to do scenario building that showed the likelihood of waterexcluding the wave run-up from the levels reaching 5 m above msl in estuarine systems when these conditions may coincide. Thetable) without a “TOTAL:” value. We example in the table was measured levels on the Natal coasts that were published by Theronbelieve the wording introducing the and Rosouw as referenced. Adding up the levels in that Table brings the rolling water on thetable makes it clear that the numbers in coasts to an astonishing 13 m above msl. These waves hit the Natal coastline. This type ofthe table serve as abasis and not the event can easily cause water levels to rise in an estuary to 5 m above msl, particularly when absoluteit components summed to coincides with a flood. Whilst some believe that 5 m amsl is too conservative we believe it resultis in 5.0m AMSL. better to err on the side of caution until more precise predictions can be made.

104. It is commonly accepted now by all authorities (co-operative governance) that developmentsAgreed 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.

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Appendix H Issues & Response Table – Draft Report

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I&AP No. Comment Response John Robinson 1. The existing properties – I would put the setback line where it should be and grant themWe would recommend that - Private leeway or permission to not have to do EIA for alterations. I would also make ruling that theydevelopers either be obliged to may not subdivide or add new structures to the existing plot. This way you stop guys buildingconduct setback line studies in mega blocks on postage stamp plots of old houses. accordance with the methodology What about developments that are currently in the process of preparing EIA studies – can weand/or the calculated setback line be not force them to wait for the Set back line placement. Maybe those areas subject to EIAreviewed to confirm that the aspects studies for developers could receive priority in the creation of the setback line? It is my opinionindicated in the methodology are that the developers are going to make a mad rush to get their foundations (or some such non-taken account of. 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!

Mr Alf Williams 2. Thank you for affording us the chance to comment on the final report and to view ourAlthough WSP is involved in - Jacobsbaai concerns. Jacobsbaai is situated halfway between Saldanha Bay and Vredenburg on thedeveloping the coastal setback RatepayersAssociation Cape West Coast. Jacobsbaai is a small quaint village with only 240 houses and onelines, which will prevent this type of Hotel/Restaurant which is situated almost right on the beach and close to the dunes.development in the future, Approximately five houses have been built in this area but unfortunately right on top of theunfortunately we assist you in this dunes which in my opinion was a major mistake by Municipality to have allowed this toregard, as this does not fall within continue. the scope of our project

My major concern at this present moment is that further development is planned with manySuggest your best course of action more houses to be built on the same dune area. Time is of an essence now to nip this projectwould be to obtain a memorandum in the bud so that further destruction does not take place, not to mention that the naturalof ‘no development’ for these areas beauty of the bay will be spoilt forever. in conjunction with the local municipality. If your Ward councillor Another area of Jacobsbaai is Mauritz Bay where houses have recently been built close to theis active, perhaps given him/her a high water mark. Corrosion is already taking place on the beach and last year high water duecall and find out how they can assist to heavy winds and seas flooded this area. There is still some vacant plots of land whichyou. could in the future become a victim to the erosion process. These types of development Is there any way that your organisation can be of assistance by means of firm notices thatprojects should have to go through further development should not take place without thorough investigation. and Environmental Impact Assessment process. The proposed Further to my mail sent to you yesterday, I have a picture attached which will give you a betterdevelopments should be advertised, idea as to our concerns. All the houses shown on the picture are built right on top of theand you should be given the dunes. Please note the area where many more houses are intended to be built. However I willopportunity to register as a

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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 3. I just want to thank you for the information about the progress on your study that you areThe name of the organisation has - Macassar doing. I will give our associations comment after we've studied the documents more closely. been changed on the list and in the Environmental and document. Nature Conservation We are an community based environment association for the Macassar and Helderberg Society and Coastal Region and are actively engaged in environmental, nature conservation and coastal Forum 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 Richard A Rundle 4. 1. The Woodbridge Island setback line was established by the CSIR as described in theirAgreed - Some of the methodology - Woodridge Island Body 1983 report C/SEA 8373. Over the passage of nearly 30 years this has been shown to beand results of this CSIR study are Corporate relatively accurate, withstanding with great success a 1:50 year storm. Since that was referred a to. successful process it must have some value in determining setback lines along other, less complex coastal stretches. 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 Thisis assumes a linear increase in proposed. This is as opposed to a current sea level rise of approximately 3 mm per year,sea-level rise. Sea level rise is which in 100 years would give a 30 cm rise (all things being equal). predicted by the IPCC to be Our concern with the United Nations' Intergovernmental Panel on Climate Change projectionsexponential. 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 theirWe are aware of some prediction of thermal catastrophe in Antarctica was based on temperature readings since 1979discrepancies, and we have elected from the few weather stations that were reporting temperatures since that time. The missingnot to depend only on the IPCC, due

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data was extrapolated by computer model that has not been made available for peer review. Into recent shortcomings and their fact last year's Antarctic sea-ice cover was 30 per cent above average. Also the "meltingapparently slow reaction time. glaciers" in the Himalayas was found to be based on a magazine story, and the globalHowever, literature on sea-level rise warming "recorded" in Siberia is based on the rings of a single larch that the Climaticis available from many sources (see Research Unit in Cambridge chose specifically to fit their other data, purposefully dismissingsection in methodology report). It is contrary evidence in surrounding trees. literature from diverse sources that has resulted in the CSIR employing One of the conditions that this methodology is required to comply with is that it should bean upper limit of 2 m rise in sea level generally conservative in considering the accuracy of data, methods and climate change. Werise by 2100. Thus the selected rise would prefer that such a methodology take cognizance of the lack of statistical verification of 1 m is certainly not the most the IPCC data, extrapolations and conclusions, and apply a suitable modifier. 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 aerialThe limitation is recognised and it is photograph, when the exact time of the taking of the photograph, and therefore also the tidalfor this reason that a supplementary level, are frequently not known, then any variance applicable to this component should also bemodelling approach is adjusted with a suitable modifier. Evaluation of this process should also take into account therecommended. Effects of offshore effects of hard structures in the sea, structures that could materially affect long-term beachstructures and dredging is now erosion as with the construction of the Cape Town, Port Elizabeth and Saldanha harbours. 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.We are more than aware of the When applied to a specific task, for example the aerodynamic lift characteristics of a wing, thelimitations of computational model can be empirically tested and then deviations in the model can be corrected. But whenmodelling, which is why we propose applied to a complex, multi-dimensional, dynamic, multi-material structure such as an ocean-(a) validation of models where beach-dunes interface, where there is no prospect of independent verification except perhapspossible (b) not relying on models 100 years hence, then we fear the result will almost certainly be suspect and useful only as asa the only source of analysis and guide to a starting point. (c) peer review.

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. 8. 3. Regarding site visits, we would recommend a detailed digital photographic record in bothThis recommendation has now been

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directions in line with the beach and in both directions across the beach, at intervals of 10 tospecifically incorporated into the 30 meters, using high quality digital cameras to provide overlapping views, for a historicalmethodology record and also for later viewing and reviewing. 9. 4. Regarding wind and wave data, surfers will be glad to advise that this data is available Thankin you. We are aware of this detail on a four-hourly basis, seven days a week. Woodbridge Island has this data for 33.8°Sfreely / available data and are 18.2°E since 2001. 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 theWe are aware of this limitation – year. The slopes in winter are usually substantially more than the slopes in summer. now specifically mentioned in the methodology. 11. 6. Regarding Aeolian sand transport, the assumptions may need revision. For WoodbridgeObservations noted. No diametric Island there are barriers to the south east wind that limits its velocity and its force. For thedisagreement with these statements North West wind there are no barriers and at low tide the beach is rapidly dried so thatthat directly affects the final setback windborne sand is carried approximately 40 to 50 m into the Woodbridge Island complex. Theproposed. resulting accretion of sand can be quite substantial. 12. 7. Regarding the statement that Dune vegetation has little or no effect, we have reports fromThis statement is not included in the the recent tsunami event that demonstrates that most damage occurred where dunes andfinal report dune vegetation had been removed. 13. 8. In the evaluation 31 storms were listed, mostly in the months May to August. Our data andImportant to note that the storms our research show that the worst months for storms are most often in April and in September.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 theThe bathymetry is now taken initial beach profile, the median sand grain size, and the time series of the storm conditions.account of via the wave We would suggest that the bathymetry, or the profile of the underwater beach, also be takentransformation enabling study. The into account as those also have a marked effect on the retardation of incoming waves. Ourlatter modelling includes wave records show waves peaking at more than 14 m (in 2001) that were quite adequatelyenergy dissipation from breaking. dissipated before final deceleration on our shores. The time allowed for comments was not adequate for part-time enthusiasts to study theThank you – comments well proposal in depth or in detail, but in general we wish to register our approbation for a veryreceived and incorporated into the difficult and complex task that in our view, at least as an initial effort, was very well done. Wemethodology where relevant. 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.

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Sue Swain 15. We feel that the report has not adequately addressed estuaries – it was raised in commentsIt was agreed with the client that that - Obo Plettenberg Bay during the PPP, but the proposed methodology only really refers to the meandering nature ofestuaries would not be part of this Community some estuary mouths and that this needs to be taken into account. We recommend thatstudy. Nevertheless the importance Environment Forum specific mention should be made of closed estuaries that only open after heavy rains/floodingof having them included (beyond the and the combination of unexpected storm events and other contributing factors that can leadscope of this study) is highlighted to excessive inundation of the area. Setbacks need to be greater for open/closed estuaryand the effect of meandering systems and need to extend as far up the estuary as there is tidal movement of the high waterestuaries on the open (wave- mark. While artificial breaching may need to be a consideration, of equal consideration shouldexposed) coast is considered 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.

Alan Carnegie 16. I shall confine my comments to stable sections of coastline. I am not qualified to express anComments noted – it may be more - Private opinion where there is severe erosion or accretion. appropriate in this particular situation to have a more Since 19791 have resided alongside such a stable section of beach on the northern cusp ofmanageable setback of 30 m. Saldanha Bay. Between the Port Boundary and the Municipal Holiday Resort the setback linesHowever all of the site-specific vary from 30m to 70m. Fortunately for me; my house is one of twelve along the length offactors need to be considered. Parker Crescent that are closest to the beach with a 30m setback line. These considerations would be Advantages of a 30m setback line: taken into account during the 1. Easy access to the beach for high energy water sports such as sea kayaking and kiteexecution phase of setback line boarding. establishment. 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

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the first structures built on a new coastal township layout.

Anne Duncan 17. Destabilization of the Frontal Dune and the destruction of habitat in the Coastal Reserve (ErfThank you for these comments - Private 4022) relating to management issues. I intend this communication to draw attention to the destabilisation of the frontal dune and theThese are the types of issues that destruction of habitat in the Coastal Reserve (Erf 4022 Parkersdorp, Saldanha Bay) and tomust be taken consideration of in contribute in motivating the necessary actions required to rehabilitate and conserve this areaestablishing setback lines. 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

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- 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

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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

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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 18. • Please note full comments could not be included in this table. Written The adjacent refers to particular - Professional comments included below sites and not to the generic setback Land Surveyors ABSTRACT: This firm has been requested to comment on the Draft Report of the Western line methodology and associated Cape Coastal Setback Lines, dated 1 st April 2010, on behalf of the property owner of Erven case studies. This will be relevant 149366 and 149367 Cape Town at , Mr. Peter Lancelot Liddell. as part of the stakeholder engagement during the execution of 1. INTRODUCTION: The Coastal Setback Lines document introduces two types of the setback line methodology. We setbacks, the ‘no development / coastal process’ and the ‘limited / controlled suggest that it be submitted at that development’ setback lines. In this report, this firm has substantiated the reasons stage. 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

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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.’

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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.

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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.

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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 beserviced 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.

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Cedric Wayne Hendricks 19. When can you meet with our Community! Your Study is very worrying as it focus on the mainlyAssuming that reference made here - Macassar rich and affluent communities of the western cape and it should be urgently reviewed for notto the two selected case studies, Environmental taking into consideration communities on the coast who are black, such asplease be aware that we were hard- and Nature Macassar,Firgrove/Helderberg.It is not a commendable study and true reflection if you shouldpressed to find suitable case studies Conservation see the destruction in Macassar on the Macassar Beach. Please reconstruct your studies torepresentative of the entire province. Society and include vulnerable communities. Why are so-called White communities always considered andThe latter were selected more for Coastal Forum not the communities of Blacks and Coloured people of the western cape. I have more thantheir available data (allowing critical enough photo's and environmental evidence of the shifting of the dunes and rapid rising of theassessment of methods) than the sea levels along the coast. Most citizens are worried of what's happening along the beach butfact that they happen to coincide the department of environment seems to be very quite on the issues affecting Macassarwith more affluent areas. In any Dunes. event the methodology developed will be applicable when applied to your area. Neil Schwartz 20. Below, please find comments on the 1 April 2010 report on “Setback Lines”. - V&A waterfront Noted. 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 Noted but beyond the brief of this development within the 100m HWM. The activities to not be listed (for EIA) if the study. activity will “occur behind a development setback line as defined or adopted by the competent authority” requires substantial review and revision. Noted but not fully understood. 2. Paragraph 6.3: these categories should be broadened to include existing and proposed land uses.

Mike Brokenshire 21. Existing Development Rights The legal details of development - V&A Waterfront Section 1.5.4 requires elaboration as to how existing development rights will berights, while relevant is not Development accommodated within a setback line. Possible setback lines in built-up areas need to bespecifically part of this study. What Management addressed in more detail as the report infers that even if structures exist and developmenthas been established is that coastal rights are in place, these cannot be assumed to be automatic. process setback lines are to be placed as if development does not

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In the V&AW there is a basket of rights already approved, and in order to exercise these rightsexist and is likely to constrain re- further detailed plans are to be submitted to and approved by the authorities. The timing of thedevelopment. establishing setback lines and the potential doe setback lines to limit land availability for utilising existing rights requires further clarification. 22. Data Collection (Table 4.1) The methodology implicitly takes The table should be expanded to assess information on coastal infrastructure, such asaccount of the harbour situation – breakwaters, sea walls, and harbours as the effect of wave action etc. In the harboure.g.. erosion setback falls away and environment is different to that of the natural coastline. only relevant processes like sea- level rise and wave runup and overtopping will potentially affect setback. 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 anyResponse above applies. The wave body within a harbour is controlled. 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 Interesting concept but we believe it Consideration should be given as to whether existing shoreline protection could be graded is– not necessary and not appropriate for example, if concrete ‘dollose’ are used the risk of shoreline damage is low and thereforeto grade these protection structures may support development safely within the 100m line. Existing sea walls, for example the Sea– the process-based methodology Point promenade, would be given grading that would allow more than say, rip-rap used aroundwe propose will take the varaiable Woodbridge Island. protection of such structures into account.

Tim Everett 24. As a registered I&AP I wish to make the following comments that appear in the Summary of - Private Key Issues ( Table 4)

Item 6- Prioritisation for implementation of Setback lines Our updated methodology proposes It seems inevitable because of the high cost of creating set back lines on the whole coast, thatmethods which effectively achieve setbacks will only be looked at once the greed of developers forces action. It would be betterthis. Through rapid (and to create blanket setback lines for all un-developed land at a maximum that can be obtained conservative)in assessment, terms of the Integrated Coastal Management act. This will then create a system were theconservative setback lines can be developer has to rather apply for a reduction of the setback lines thus created. established. These can and must

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Reference is made to the west coast particularly, but there are lots of sections of the coastbe revisited with a thorough study south of Mossel Bay and into the Overberg coastal region that is in series need of action.before being accepted. Prime example is Vleeisebay and Mossgas interest areas.

25. Item 10- Consultation Process. Agreed that it is imperative that the One understands the scientific process, but once again, it is only once greedy developers get public is made aware at the outset – involved that the public gets to hear of potential damage to an area. It is therefore imperative this is now part of the methodology. 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

91212D Western Cape Coastal Setback Lines – Stakeholder Engagement Report 88