RESPONSE TO CITY OF CAPE TOWN’s PUBLIC PARTICIPATION PROGRAMME RE MARINE OUTFALL PLANTS
The CBCRA is strongly opposed to the use of Marine Outfall Plants (MOP’s) to discharge land-based effluent into the ocean.
This commentary refers specifically to the Camps Bay MOP, unless otherwise specified.
Firstly, the actual advertisement by the City for its citizenry to respond to the Public Participation Process (PPP), is both disingenuous and misleading. The City appears to have learnt absolutely nothing from its impugned (and set aside) PPP of 2015, or thereabouts.
In its online message, the City claims that MOP’s safely disperse wastewater and that such wastewater is diluted to nearly undetectable concentrations (my emphasis). It fails to recognise the fact that it is not wastewater but raw, untreated sewerage that is pumped into the ocean.
The scientific research by all of Cape Town’s universities’ pre-eminent scientists (including Professor Emeritus Jo Barnes PhD (Stellenbosch), Professor Leslie Petrik PhD (UWC) and Professor Lesley Green PhD (UCT) reveal that this statement by the City is simply wrong and not evidence-based.
Further, the City attaches its much criticized CSRI report, of a few years back, to the online notice.
It must be borne in mind that this “independent” study by the CSRI, used City-supplied base data and even then, the findings were not favourable toward the continued use of MOP’s. The City managed to cherry-pick one statement (that there was no indication of an immediate environmental catastrophe) to justify the use of an archaic and environmentally dangerous process of disposal of raw sewerage.
The City also claim that the outfall pipe’s discharge point is far from land. Again, this is simply not true:
The Camps Bay pipe is a short 1,3km from a section of a Blue Flag beach but less than 800m from the popular Maidens Cove beach and tidal pool. With prevailing currents from the south-west and winds from the north-west, it is an ineluctable fact that the raw sewerage will return to land, where it poses extreme health risks to the thousands of residents and tourists who frequent the beaches in Camps Bay and Clifton.
The CBCRA received a senior counsel ex parte opinion from two of Cape Town’s most highly regarded environmental lawyers.
One of their findings was that it remained illegal for the City to discharge effluent into a Marine Protected Area (MPA), such as the bay at Camps Bay. Therefore, the Minister’s power to issue such a CWDP is questionable at best.
There is no facility on the City’s portal for the actual document to be uploaded but the CBCRA will make it available to the Minister on request.
However, despite the long history of opposition to the MOP’s in Cape Town – and Camps Bay specifically – some dating back a century (for Green Point), the City has pursued this cheap and nasty option to avoid high infrastructural costs.
Cost cannot be a factor where public health and the destruction of the marine environment are concerned.
The City also fails to mention that, in Camps Bay alone, hundreds of millions of rand have been collected by the City, over the years, via sewerage tariffs. Clearly, none of this has been spent on any upgrade of the local MOP system!
It is also common cause that the City has failed to adhere to any CWDPs that have (or have purported to have) been issued previously. Two such clear failings are:
- Periodic exceeding of discharge quantities
- Failure to establish a Permit Advisory Committee, to ensure oversight of the City-run operation.
The latter condition needs to be urgently addressed and the Minister must insist that local public representatives are installed onto such committees.
The real issue is that the MOP’s exist and the City, although recently admitting that such a system is problematic, has set itself long timelines, of many, many years, to address the matter. The MOP’s are extremely dangerous to public health and the marine environment and the City, the author of this problem in the first instance, cannot be trusted to leisurely ponder the future of its foul sewer water disposal.
To this end, the CBCRA requests that the Minister, if she decides to issue any CWDP, attaches meaningful conditions to such permit.
- The first condition must be to address the actual problem: There are many affordable and relatively easy solutions provided by so-called “package” plants. These small plants can be located next to a MOP and offer treatment of the effluent prior to it being pumped out to sea by the MOP. This will ensure that wastewater quality is of a high enough standard to make it harmless to humans and the environment.
- The Minister could make it a condition of approval of the CWDP that the City have such a system designed and installed within a stipulated period, which would not be unreasonable at 4 or 5 years from issuance.
- With immediate effect, a Permit Advisory Committee must be established by the City, with local civic representation.
The CBCRA wishes to thank the Minister for creating this opportunity to comment on this extremely important issue.
Regards
CHRIS WILLEMSE
CHAIRPERSON
CBRRA contact: Chris Willemse Mobile 083 6536363
City launches public participation process for marine outfalls and more
21 September 2023
Residents and interested stakeholders will have the opportunity from today, Thursday, 21 September 2023 until Tuesday, 21 November 2023, to submit their comments during the 60-day public participation period on the marine outfalls discharge permits applications. They can also comment on the permits for the Wastewater Treatment Works (WWTW) in Mitchells Plain, Simon’s Town, Millers Point, Oudekraal and Llandudno.
The City of Cape Town’s Water and Sanitation Directorate launched the public participation process and outlined its details at a public meeting last night held at Camps Bay High School.
- The marine outfalls are located offshore discharging beyond the intertidal zone at Hout Bay, Green Point and Camps Bay.
- These discharge wastewater into the ocean that has gone through degritting and screening.
- All other areas in Cape Town are serviced by 23 wastewater treatment works (WWTWs) which treats sewage, removing the various nutrient loads before it is released as treated effluent into the ocean. In total, 95% of Cape Town’s wastewater is discharged from WWTW, compared to 5% from the three outfalls.
- The City is making major investments to improve wastewater treatment and upgrade sewers, to the benefit of inland and coastal water quality, with a 226% increase in the overall infrastructure budget, from R2,3bn in 2022/23 to R7,8bn in 2025/26.
- Coastal outfalls are a global practice which is guided by local engineering and environmental pollution legislation and guidelines.
- In some cases, spatial and environmental constraints inhibit wastewater treatment works at small coastal enclaves. For example, there are major spatial, practical, and financial constraints to building a multi-billion rand WWTW in the area to service the Green Point, Hout Bay and Camps Bay catchments. Substantial reconfiguring of the existing sewer network would also be required in these areas.
- An expert summary report on seven major studies into the outfalls concluded that “the marine outfalls are meeting their design objectives in reducing potential deleterious ecological and/or human health effects of discharged effluent by taking advantage of increased effluent dilution offered by deep water”.
Published by:
City of Cape Town, Media Office
