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Friday, 26 November 2021


26 November, 2021

CBCRA COMMENT ON CITY OF CAPE TOWN DRAFT 2022 – 2027 WSDP & INTEGRATED WASTE MANAGEMENT PLAN (“the draft report”)                             

The CBCRA has studied the draft report by the City and comments as follows: 

This is a voluminous report with statistics that cannot be easily verified by a volunteer ratepayers’ association, however the City presented data is accepted in good faith.

It is not the remit of the CBCRA to reinvent any wheel in this regard and it will confine itself to comments on the specific waste management problems facing the Atlantic Seaboard.

The reliance on an incredibly outdated Marine Outfall Plant (“MOP”) serving Camps Bay, Glen Beach and Clifton (and other MOPs serving Hout Bay and Mouille Point) is considered as beyond unacceptable and a prime source of the environmental destruction of the marine environment along our coast.

The overwhelming scientific evidence that such MOP’s are outdated, crude and destructive appears to be common cause amongst all those who have knowledge of the workings and effects of these decades-old dinosaurs.

It appears to be only the City of Cape Town which finds such sea-borne sewage disposal as acceptable – both at a political and administrative level.

It must be clearly stated that the destruction of the marine life along the Atlantic Seaboard has been conclusively established by expert academics of all the major local universities.

Yet the City remain stubbornly obstinate to the situation.

It is understood that the City has large commitments in terms of the provision of water and sanitation to the greater metropolitan area of Cape Town, but it is the duty of the responsible department(s) to adequately make provision for these public health and environmental responsibilities and for the City’s elected politicians to ensure that adequate budgetary provision is made available to provide for improved sanitation and waste management in our area and the greater Cape Town area. This will be addressed in the general comments below.

It is clear from the draft report that, although mention is made of finding a balance between sustainable development and improving quality of life, no mention is made of the MOP’s.

It is anticipated that the City’s response will be one of denial of a problem and an insistence that the MOP operates within its licence mandate.

Such City response will be trite as the whole issue of the purported issuance of the licence remains problematic, including the fact that no operating licence was in place for many years.

Further, in the general table of overall Microbial, Chemical & Physical compliance percentages, the e-coli count is blanked out. This is suspicious, as the City claims to test for and record such counts on a very regular basis. The fact that Camps Bay and Clifton are “blue-flag” beaches only adds to the problem.

It is further noted that the e-coli counts for Green Point (Mouille Point) and Hout Bay are also voided.

However, even without predictably low compliance (given the often-reported raw sewerage in the Bay), Camps Bay still fails to comply with the latest discharge standards.

In summary, the continued use of MOP’s needs to be independently and scientifically assessed and if found to be unfit for purpose, as is to be expected given the current scientific data and opinions, then budget must be made available urgently to counter the harmful effects of this MOP on our seaboard and environment.

In general, the sewerage crisis in Cape Town has been manufactured by a political system which promotes development at any cost and a compliant technical City section which has remained quiet despite what must have been an obvious problem in the making: The waste water system doesn’t suddenly become under-capacity overnight.

The draft report clearly states that the treated effluent quality will deteriorate and pollution levels within the receiving water body (river, estuary, bay or ocean) will increase with continued (over-)development. 

The draft report makes much of the future approach of the City toward what is a very essential municipal service. It is important that both the politicians and the officials are held to account going forward as they have clearly failed the citizens of Cape Town and our coastal environment to date.

Although the bulk services’ budget shows an increase from 2021/22 to 22/23, there appears to be a 35% decrease in 2023/24. This is not explained.

Satisfaction with sewage, wastewater and share toilets indicates that 66% of formal settlement dwellers were satisfied with the service. Although this figure is relatively low, final effluent treatment is dysfunctional and this indicator merely expresses satisfaction that the initial removal of waste water from their properties appears to work.

The reality is that large swathes of the City are drowning in sewerage, mostly in the waterways and vlei areas of Cape Town, but also along our Atlantic Seaboard coastline and on our beaches. Fourth, Second, First Beach and Glen Beach have frequent sewerage spillages which contaminate our environment and put our public health at risk.

We trust that the new Mayco member for this important portfolio will grasp the problem and with urgency work towards a solution that benefits the City of Cape Town, its people and our environment.

As always, the CBCRA offers to work with the City and all interested and affected parties to contribute to the betterment of the current situation.


Chris Willemse

Vice Chair


The report can be found here:

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