LAW HAMMERS WESTERN CAPE PLANNERS

Noseweek Issue # 135 January, 2011

Things are far from well in the Mother City's Planning Department. In 
noses127&133 we reported on how a group of Bantry Bay residents 
successfully opposed the construction of an eight-storey, 39-unit 
apartment block slap-bang in the middle of their lovely suburb.

Now, in a recent letter to the Atlantic Sun, Dr Patrick Morton says 
that the Camps Bay Residents & Ratepayers Association has brought no 
fewer than eight successful cases against the City's Planning 
Department, and is currently involved in a further three cases. Morton 
speaks passionately of a "recurrent failure of the Planning Department 
of our City Council to provide the protection that all residential 
communities in our town not only deserve, but actually pay handsomely 
for with their rates".

Morton says it's incumbent on councillors "to grasp the nettle and 
take up the challenge of addressing the chronic and dire situation 
that prevails, where developer after developer succeeds in attempts to 
maximise their profits at the expense of the whole community, by being 
granted approval of plans that are, quite frankly, illegal". He ends 
colourfully: "Alarm bells are sounding as loud as the Mouille Point 
foghorn. Can anyone up there in council hear them? And if you can — 
do you have what it takes to do something about the situation? The 
ratepayers are calling for a clean, competent and effective 
administration for their city."

The judgment in one of the cases launched by the the association was 
handed down by Judge Binns-Ward of the Western Cape High Court on 16 
November. The case pitted the association against David and Susan 
Hartley who were seeking to build a double dwelling on a single 
dwelling property in Camps Bay. The association sought an order 
setting aside a City Council approval for the building, and the 
Hartleys opposed the application. On the day before the hearing, the 
City Council submitted an affidavit explaining that the approval had 
in fact been subject to certain conditions or "departures". As these 
conditions had clearly not been complied with, the Hartleys' 
opposition fell away, and the only issue was whether they should have 
to pay the association's legal costs, which were no doubt significant 
as the court record ran to some 700 pages.

So why should the Hartleys, the losing parties in the case, not be 
liable for costs? The couple argued that they were in no way to blame 
for having needlessly opposed the application, and that it was all 
down to the City's incompetence. They said that they made various 
attempts (using town planning consultants) to find out whether there 
were in fact any conditions attached to the approval, but that they 
got nowhere because the file was missing and because letters were 
ignored.

The judge accepted that, although each local authority is obliged to 
keep a "register of departures", the word "register", certainly in the 
case of Cape Town, is a complete misnomer – far from being an easily 
accessible record, it consists of thousands of files at any number of 
locations. And, said the judge, as for the "zoning maps" that councils 
are obliged to keep, in the case of Cape Town these seem to be next to 
useless.

Although the judge had sympathy for the couple's plight, he held that 
they were liable for the association's costs. The reason – the 
conditions had in fact been communicated to the Hartleys' agent (the 
architect) in the standard "final notification letter", but 
unfortunately he had failed to pass this information on to the couple, 
with the result that the architect who replaced him knew nothing of 
conditions and proceeded with something quite different to what had 
been approved.

Judgments dealing with planning issues are generally turgid affairs 
– you have to familiarise yourself with terms that are understood by 
only the few who cultivate the dialect, but are incomprehensible to 
anyone possessed of a life. Terms like LUPO (Land Use Planning 
Ordinance) and SPELUM (Spatial Planning, Environment and Land Use 
Management). So a big hand for Judge Binns-Ward for doing an admirable 
job of making very tedious subject matter comprehensible. Well done 
for applying the one thing that's so often missing in court judgments: 
common sense (if things don't work out on the bench, or perhaps Hlophe 
becomes a bit much, a job awaits you at noseweek).

Now you might say that if God had wanted judges to tell government 
officials how to run their departments, he would never have created 
management consultants. That may well be so, but clearly the 
consultants aren't doing their jobs. So here's what Judge Binns-Ward 
had to say to those at the City of Cape Town, and indeed to planning 
types throughout the land. He started off with some generalities: "I 
consider it to be appropriate... to highlight some of the pertinent 
shortcomings in the administrative process and draw to the attention 
of the relevant organs of state certain measures which require 
attention if cases similar to this are to be avoided."

Making the point that zoning schemes "regulate land use and 
development so as to promote the co-ordinated and harmonious use of 
land", he said that clarity is all-important: "The public, and most 
certainly the owners and occupiers of land in the close proximity... 
have a cognisable legal interest in compliance with, and the 
enforcement by, the local authority with the provisions of the 
applicable zoning scheme. It is a basic tenet of the rule of law that 
law cannot be effective if its content is not clear and readily 
accessible."

Then on to the register that should record the departures – dealing 
with its "abstruse nature", the judge described it as "illusive... not 
only to the public, but also to professionals engaged in the field of 
land use and development and even the local authority's own 
officials".

And the zoning map: "It was remarkable that none of the witnesses, 
whether they be municipal officials or professional town planners or 
architects, made any mention of having had reference to the zoning 
map. I think it may safely be inferred from this common omission that 
the map also does not fulfil an effective role in informing anyone of 
the existence or the nature of departures applicable to any land unit. 
It is furthermore not clear how accessible the zoning map is to the 
public."

As to whether sending a "final notification letter" to the owner and 
putting a copy in a musty old file notifies the public of departures: 
"The duty could be carried out by publishing the conditions in the 
Provincial Gazette, or, even more effectively, by requiring them to be 
registered against the title deed of the affected land unit. Had the 
conditions been registered in the current case, the unlawful and 
invalid approval of building plans would in all likelihood not have 
occurred."

Next. the issue of the delegation of authority by a municipal council 
of its functions: "The respondents [the Hartleys]... pointed to the 
difficulties they and their representatives had had in trying to 
obtain a copy of the record of delegations. They averred that they had 
been pushed from pillar to post by various officials of the 
municipality during their endeavours to obtain the relevant 
information. They had eventually been informed that they were required 
to make a formal application for the information in terms of PAIA. I 
consider that a local authority's system of delegations is something 
that, by its nature, should be available to the public without the 
formality of a request, as defined in the Promotion of Access to 
Information Act."

The final issue for the judge was "the unwholesome situation of a 
partly completed building standing unattended for months while 
litigation took its course". This, according to his Lordship, could've 
been avoided if the City had heeded earlier advice from the 
Constitutional Court to invite comment from neighbours. "This would 
significantly reduce the chances of approval of plans in cases where 
some of the disqualifying factors exist but were not discovered by a 
local authority."

A timely reminder of why lawyers run the world. Will this advice be 
heeded? The judge did order the registrar of the court to send his 
judgment to the Western Cape Minister responsible for development 
planning, as well as to the City Manager. At least the "Nuremburg 
defence" will no longer be available.
Last Updated ( Monday, 10 January 2011 09:23 )
Posted on 10/01/2011 by Administrator