## Comment on the Draft Heritage Resource Management Strategy

I support the City of Cape Town’s intention to modernise and strengthen heritage management. However, greater efficiency and “streamlining” must not weaken heritage protection, public scrutiny or residents’ rights to participate in decisions affecting their communities.

1. Streamlining and exemptions

Heritage protection must take precedence over administrative convenience. Streamlining must not become deregulation or enable developments that would otherwise attract legitimate heritage or community objections to avoid proper scrutiny.

No heritage exemption should be introduced until the affected area has been comprehensively surveyed; its heritage resources have been publicly identified and mapped; affected communities and recognised conservation bodies have been consulted; and appropriate protections have been established.

Notification, objection and appeal or review rights should not be removed in the interests of administrative efficiency.

2. Comprehensive heritage mapping

The City should maintain an accessible, regularly updated public map identifying individual heritage resources, Heritage Protection Overlay Zones, conservation areas, significant streetscapes and landscapes, graded buildings, and areas awaiting comprehensive heritage assessment.

Absence from a City database must not be interpreted as absence of heritage significance, particularly where an area has not yet been adequately surveyed.

3. Protecting neighbourhood character

Heritage protection should extend beyond individual buildings to the collective character of historic neighbourhoods, including streetscapes, architectural character, scale and height, historic plots, mature landscapes, views and public spaces.

This is particularly important in areas such as Muizenberg and Lakeside, where incremental development or alterations can cumulatively erode neighbourhood character, even when individual applications appear relatively minor.

Cumulative impact should therefore form part of every heritage assessment.

4. Meaningful public participation

Residents, ratepayers’ associations, civic organisations and recognised conservation bodies must be involved early enough to influence decisions meaningfully.

The Strategy should guarantee clear procedures for notification; access to applications and supporting documents; reasonable comment periods; proper consideration of objections; publication of decisions and reasons; and transparent appeal or review mechanisms.

Public participation should not begin only after substantive decisions have effectively been made.

5. Preventing “demolition by neglect”

The Strategy must specifically address “demolition by neglect”, whereby heritage properties are allowed to deteriorate until demolition is presented as the only safe or economically viable option.

Owners should not benefit from deliberately or negligently allowing heritage buildings to deteriorate and then relying on that deterioration to justify demolition or redevelopment.

The City should be empowered to intervene before deterioration becomes irreversible, including by requiring reasonable maintenance and securing vulnerable structures.

Where demolition is sought because a building is allegedly unsafe or restoration is said to be uneconomic, the assessment should consider its maintenance history; how and why deterioration occurred; whether it was preventable; whether warnings were ignored; independent structural evidence; and whether stabilisation, restoration or adaptive reuse remains possible.

Years of avoidable neglect should not make demolition automatically acceptable. Deliberate or avoidable neglect must never provide a route around heritage protection.

6. Transparency, monitoring and enforcement

Heritage decisions—particularly approvals for demolition, substantial alteration, redevelopment or exemptions—and the reasons for those decisions should be publicly accessible. Where objections were received, the record should show how substantive concerns were considered.

The Strategy must also identify responsible City departments, provide for adequate staffing and resources, establish monitoring mechanisms and procedures for identifying neglected heritage resources, and set out enforcement measures, measurable targets and implementation timeframes.

Enforcement must occur early enough to prevent irreversible loss, rather than only after damage or demolition has occurred.

Conclusion

Cape Town’s heritage is finite and irreplaceable. Once an historic building, streetscape or neighbourhood character is destroyed, it cannot authentically be recreated.

I therefore support modernising the heritage management system, provided that streamlining does not weaken heritage scrutiny, community participation or existing protections.

The final Strategy should ensure that heritage resources are properly identified, mapped and protected; residents retain meaningful notification, objection and review rights; cumulative neighbourhood character is considered; and owners cannot gain an advantage by allowing heritage properties to deteriorate.