Gavilon Dean Basson

Member since 1 July 2026

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Gavilon Dean Basson2 months ago I welcome the City of Cape Town’s intention to revise the Business Support Policy and recognise the important role that micro, small and medium enterprises play in job creation, local economic development, innovation and spatial transformation.However, I respectfully submit that the policy must move beyond general support, training and information-sharing. For many emerging entrepreneurs, the problem is not a lack of ideas, discipline or willingness to work. The real barriers are lack of affordable premises, lack of start-up capital, difficulty accessing City-linked opportunities, complex compliance requirements, poor access to business support in local communities, and the fact that many people are excluded before their businesses are given a fair chance to prove themselves.The revised policy should therefore create a practical Business Starter Pathway for emerging entrepreneurs, especially those from Cape Flats, township and historically disadvantaged communities. This pathway should help small businesses move from idea stage, to pilot stage, to compliant operating stage, without being blocked at the beginning by the same requirements expected from established businesses.I recommend that the final policy include the following practical mechanisms:1. Affordable municipal micro-workspaces The City should identify underutilised municipal buildings, land portions, libraries, halls, transport nodes and civic spaces that can be converted into affordable micro-business spaces. These spaces should include shared utilities, internet access, secure storage, basic safety systems and access to customers. This would assist entrepreneurs who cannot afford private rentals but are ready to trade, manufacture, provide services or test business ideas.2. A temporary “right to test” business permit The City should introduce a 6-to-12-month pilot permit for emerging businesses. This would allow low-risk businesses to test their products or services legally while receiving compliance guidance. Instead of treating every informal or home-based activity as a by-law problem, the City should create a transitional compliance route where entrepreneurs are guided into formality.3. One-stop compliance support The City should create a single Business Compliance Desk that helps entrepreneurs understand all applicable requirements, including zoning, trading permits, health and safety, waste, water, electricity, signage, supplier registration and other relevant municipal processes. Entrepreneurs should not be sent from one department to another without a clear answer.4. Support for entrepreneurs without perfect credit or assets Many capable entrepreneurs cannot access traditional finance because they are unemployed, credit-impaired, asset-poor or still building income. The policy should require the City and its partners to assess business potential using more than credit scores. Assessment should include business viability, community demand, skills, training completion, references, pilot sales, discipline and ability to create jobs.5. City-backed micro-grants and first-contract opportunities The City should consider small start-up grants, equipment vouchers, shared tools, or first-contract opportunities for qualifying micro-enterprises. A small opportunity of R5,000 to R50,000 can be life-changing for a start-up if it is linked to mentoring, reporting and measurable outcomes. The City should also break suitable work into smaller packages so that micro-businesses can realistically compete.6. Community business hubs in the Cape Flats and townships Business support must be brought closer to communities. Entrepreneurs should not always have to travel into the CBD to access meaningful support. Local business hubs should be placed in areas such as Mitchells Plain, Khayelitsha, Delft, Blue Downs, Retreat and other high-need areas. These hubs should be staffed by people who understand entrepreneurship, not only administration.7. Safe modular enterprise nodes The City should pilot secure modular business hubs where small businesses can operate together with shared utilities, solar backup, lighting, CCTV, refuse management, sanitation, Wi-Fi and local management. This would support a wide range of lawful micro-enterprises while reducing crime, fragmentation, unsafe trading conditions and the burden of each entrepreneur having to secure separate premises and services.8. Digital Business Passport The City should create a digital Business Passport where each entrepreneur can store their CIPC documents, tax status, permits, training records, funding applications, supplier registration and compliance progress in one place. This would reduce repeated paperwork and help entrepreneurs move faster between City departments, funding partners and procurement opportunities.9. Measurable targets, not only intentions The policy should include clear annual targets, such as the number of affordable micro-workspaces created, the number of emerging entrepreneurs assisted into compliance, the number of businesses receiving pilot permits, the number of micro-enterprises receiving City-linked work, turnaround times for applications, the number of township and Cape Flats entrepreneurs supported, and the number of jobs created or sustained.10. A future-focused innovation pathway Cape Town should prepare for the next generation of small business. The policy should allow controlled testing of new, lawful and socially useful business models in designated environments where entrepreneurs can receive guidance, operate safely, meet basic standards, and gradually move toward full compliance. If the City creates safe testing zones and clear rules, entrepreneurs can innovate without being blocked before they start.My request is not for special treatment. My request is for a fair, practical and measurable pathway that allows ordinary residents with skills, ideas and discipline to become real contributors to the local economy.The City should not only support businesses that are already established, funded and fully compliant. It must also support the people who are trying to become compliant, trying to create income, trying to employ others, and trying to build something positive in their communities.I respectfully recommend that the final Business Support Policy include a dedicated Business Starter Pathway, affordable municipal micro-workspaces, transitional compliance mechanisms, local business hubs, credit-sensitive support alternatives, and measurable targets for implementation.This would make the policy more than a statement of support. It would make it a real bridge between unemployment, informal survival and sustainable small business ownership.

Gavilon Dean Basson1 month ago Comparison Including Once-Off Setup CostsThe City has not yet disclosed the official capital or annual operating budget for the proposed Kuilsrivier Safe Space. The figures below are therefore estimates based on available Safe Space benchmarks and public housing subsidy information.The Western Cape Government lists the Individual Housing Subsidy as a once-off amount of up to R261,000, which may be used towards buying or building a first home, including a new build or serviced site (Western Cape Government, n.d.). For a practical comparison, this submission uses a rounded working estimate of R300,000 per subsidised housing opportunity, allowing for construction, servicing, professional fees and contingency.Previous public reporting on City Safe Spaces provides useful benchmarks. The SAHRC reported that the proposed Green Point Safe Space was expected to cost approximately R8.25 million to develop and R10 million to operate, while GroundUp reported that the City planned to spend approximately R77 million in one year and R230 million over three years on the Safe Space programme (SAHRC, 2023; GroundUp, 2023).Based on those benchmarks, a reasonable estimated range for the proposed 130-bed Kuilsrivier Safe Space is: Once-off setup cost: approximately R5 million to R10 million; Annual operating cost: approximately R10 million to R18 million per year; Housing comparison assumption: approximately R300,000 per subsidised housing opportunity. 1. Once-Off Setup Cost ComparisonOnce-off setup costEquivalent housing opportunitiesR5 millionapproximately 16 housesR8 millionapproximately 26 housesR10 millionapproximately 33 houses2. First-Year Total Cost: Setup + First-Year OperationsScenarioSetup costAnnual operating costFirst-year totalEquivalent housing opportunitiesConservative/properR5 millionR10 millionR15 million50 housesMid-range/properR8 millionR12 millionR20 million66 housesHigh-support modelR10 millionR18 millionR28 million93 houses3. Five-Year Comparison Including SetupScenarioSetup costFive-year operating costFive-year totalEquivalent housing opportunitiesConservative/properR5 millionR50 millionR55 million183 housesMid-range/properR8 millionR60 millionR68 million226 housesHigh-support modelR10 millionR90 millionR100 million333 houses4. Ten-Year Comparison Including SetupScenarioSetup costTen-year operating costTen-year totalEquivalent housing opportunitiesConservative/properR5 millionR100 millionR105 million350 housesMid-range/properR8 millionR120 millionR128 million426 housesHigh-support modelR10 millionR180 millionR190 million633 housesPublic-Comment WordingIf the proposed Kuilsrivier Safe Space requires an estimated once-off setup cost of R5 million to R10 million, plus annual operating costs of approximately R10 million to R18 million, then the first-year taxpayer exposure could be approximately R15 million to R28 million. Using a rough estimate of R300,000 per subsidised housing opportunity, that first-year amount could potentially equal approximately 50 to 93 permanent housing opportunities.Over five years, including setup costs, the same expenditure could potentially equal approximately 183 to 333 housing opportunities. Over ten years, it could potentially equal approximately 350 to 633 housing opportunities.The City should therefore disclose the full capital cost, annual operating cost, cost per bed, cost per successful reintegration, and explain why this recurring temporary accommodation model is preferred over permanent housing, transitional housing, social housing, affordable rental, serviced sites or family reintegration pathways.Reference ListGroundUp. 2023. Ratepayers get behind new Safe Space for homeless in Green Point. Available at: https://groundup.org.za/article/ratepayers-get-behind-new-safe-space-for-homeless-in-green-point/ [Accessed 11 July 2026]. South African Human Rights Commission. 2023. City’s Safe Space initiative gets a thumbs up. Available at: https://www.sahrc.org.za/index.php/sahrc-media/news/item/3583-city-s-safe-space-initiative-gets-a-thumbs-up [Accessed 11 July 2026]. Western Cape Government. n.d. Individual Housing Subsidy. Available at: https://www.westerncape.gov.za/service/individual-housing-subsidy-0 [Accessed 11 July 2026].

Gavilon Dean Basson1 month ago I acknowledge the City of Cape Town’s intention to develop a 130-bed Safe Space facility in Kuilsrivier on Erven 1211 and 1212. I support the principle that vulnerable residents should not be left to sleep in unsafe, undignified public spaces. People experiencing homelessness require dignity, protection, ablutions, food, healthcare access, social support, documentation assistance, substance-abuse support, mental-health pathways, family reintegration and employment opportunities.However, I respectfully submit that this proposal should not be approved on the basis of good intentions alone.The City must prove that this specific Safe Space is the best long-term use of public land and public money, especially in a city with a severe housing crisis, long housing waiting lists, unresolved temporary relocation areas, and a history of selling or releasing public land that could potentially have been used for housing or mixed public-benefit development.My position is therefore conditional support only. The City should not proceed unless it first publishes a clear cost, land-use, housing-feasibility, operational and reintegration plan.1. Safe Spaces are temporary; housing is permanentA Safe Space may be necessary as an emergency response, but it is not the same as housing. The City’s own rough-sleeping strategy describes Safe Spaces as temporary and transitional. The City’s strategy also confirms that Safe Spaces are financed from the City’s rates account and that, during the 2022/2023 financial year, the City spent approximately R55 million on Safe Spaces and Safe Space security, excluding some staff costs. This raises a serious public-finance question:Are ratepayers being asked to fund a permanent temporary system, instead of permanent housing solutions?A Safe Space can provide a bed tonight. But if the same person remains in temporary systems year after year, or returns to the street after short-term shelter, then the public money has not solved homelessness. It has only managed it.International evidence also supports the view that housing-led and Housing First approaches are essential to long-term homelessness reduction. A systematic review found that permanent supportive housing using a Housing First approach decreased homelessness, increased housing stability and improved quality of life for people experiencing homelessness. The OECD has also recognised housing-led and Housing First approaches as key long-term homelessness responses, although many countries have not yet scaled them adequately. I therefore submit that the Kuilsrivier Safe Space should be assessed against a housing-exit test:What permanent, transitional, social, affordable or family-reintegration outcome will each resident be moved towards?2. Cost to the taxpayer must be disclosed before approvalThe City should publish the full financial implications of this proposal before asking the community to support it.Based on previous City Safe Space information, this proposal could cost taxpayers several million rand per year. The SAHRC reported that the proposed 300-bed Green Point Safe Space had an estimated development cost of R8.25 million and an operating cost of R10 million. It also reported that the City planned to spend R230 million over three years on Safe Spaces. GroundUp similarly reported that the City planned to spend R77 million in one year and R230 million over three years on the Safe Space programme. Using those previous figures only as a rough guide: A basic scaled estimate from a 300-bed model could place a 130-bed facility at around R3.5 million to R5 million in development/setup cost and around R4 million to R5 million per year in operating cost. A more realistic estimate based on City-wide Safe Space/security expenditure could place the annual cost closer to R9 million to R12 million per year, especially once security, operations, utilities, cleaning, maintenance and support services are included. If the facility is done properly, with adequate social workers, healthcare referral systems, substance-abuse support, mental-health pathways, employment support, perimeter management, reporting and community oversight, the cost could reasonably rise to approximately R12 million to R18 million per year, possibly more depending on the final operating model. Over ten years, a properly run facility could therefore cost approximately R120 million to R180 million in operating expenditure, excluding major capital upgrades and excluding any additional City Law Enforcement cost carried by another budget.The City must therefore answer: What is the capital cost of this Kuilsrivier Safe Space? What is the annual operating cost? What is the cost per bed per year? What is the cost per resident assisted? What is the cost per successful reintegration? How much will be spent on security compared with social work, healthcare, skills and housing exits? Will Law Enforcement patrols create additional hidden costs? How long is the facility expected to operate? What will taxpayers have after 10 years: permanent housing assets, or only repeated temporary accommodation? Public money should not only fund beds, security and operations. It should fund measurable movement into stable accommodation and reintegration.3. No Safe Space without a housing-exit planThe City’s own Safe Space model includes more than a bed. The model is reported to include two meals per day, ablutions, on-site social workers, skills training, job-placement assistance, personal development planning, ID-document support, social-grant access and family reconnection. I support those services. But they must be measurable and enforceable.The City must publish a housing-exit and reintegration plan that states: expected average length of stay; maximum length of stay; number of residents expected to exit into stable accommodation each year; number expected to reunite with family; number expected to access employment or EPWP opportunities; number expected to receive ID-document support; number expected to receive substance-abuse or mental-health referrals; number expected to move into transitional housing, social housing, affordable rental, supported housing or other stable accommodation; what happens where a resident cannot be reintegrated within a reasonable time. Without this, the facility may become a managed holding space instead of a route out of homelessness.4. Older Safe Spaces show both value and riskThe City’s rough-sleeping strategy lists older Safe Spaces, including Culemborg Safe Space 1, Culemborg Parking Lot, Paint City in Bellville, Durbanville Safe Space and Ebenezer/Green Point. It records capacities of 230 people at Culemborg Safe Space 1, 280 at Culemborg Parking Lot, 250 at Paint City, 40 at Durbanville and 300 at Ebenezer/Green Point. It also records 789 reintegration-related outcomes from inception to June 2023 across earlier facilities. That shows the model can assist people.However, the same data also shows that Safe Spaces are large, recurring, managed facilities requiring ongoing public money. They must be judged by outcomes, not only by bed numbers.Civil society has welcomed Safe Spaces as a step away from simply displacing people from public spaces, but concerns have been raised that the model must be more than a night shelter. The SAHRC report records views that Safe Spaces must include proper reintegration, health-sector involvement, GBV support, connection to livelihoods, and meaningful engagement with people living on the streets. This is directly relevant to Kuilsrivier. The City must show how the Kuilsrivier facility will avoid becoming a limited shelter model.5. Site suitability must be provenThe City should publish a site suitability assessment for Erven 1211 and 1212, Kuilsrivier.The assessment should explain: Why this site was selected. What alternative sites were considered. Whether the site is close to public transport, clinics, social services and work opportunities. Whether the surrounding community, schools, businesses and residents will be affected. Whether the site can safely accommodate 130 residents plus staff, visitors, vehicles and service providers. Whether the site has sufficient water, sanitation, electricity, waste and stormwater capacity. Whether the site is suitable for temporary shelter only, or whether it could support permanent or transitional housing. Whether the Human Settlements Directorate assessed the site for housing before the Safe Space proposal was advanced. The community should not be asked to accept a 130-bed facility without this information.6. The City must explain why housing is not being prioritised on public landCape Town has a serious housing need. A 2026 report stated that approximately 440,000 applicants were registered on the City’s Housing Needs Register, while the City proposed almost R2.8 billion for human settlements opportunities in 2026/27. Against that background, every significant use of City-owned land should be tested against housing need.The City has also recently released or sought to release major public land parcels. The City’s own investment platform stated that approximately 50 opportunities, zoned for residential, commercial, industrial, community and mixed-use purposes, were made available for sale and lease, involving about 282,000m² of land. The City said these properties were assessed as not required for municipal purposes and that revenue would be used for service delivery. A later City statement on the same land-release process referred to 50 City-owned properties, including the Good Hope Centre, and said the City had a pipeline of 12,000 affordable units. The same statement listed residential sites in areas including Kraaifontein, Westridge, Atlantis, Durbanville, Goodwood, Eerste River, Coniston Park, Bridgetown, Athlone, Maitland and Vredehoek, and industrial sites including Kuils River. This is important because the City cannot treat public land as a revenue asset in one process, a shelter asset in another process, and a housing asset only in selected processes. The public is entitled to a transparent land-use test.Before approving this Safe Space, the City should explain: why Erven 1211 and 1212 are not being used for permanent housing, transitional housing, social housing, affordable rental, BNG housing or mixed-use housing; whether any portion of the land could support housing; whether nearby City-owned land can support housing; whether the Safe Space is temporary or permanent; whether the site could be designed as a combined Safe Space and transitional housing precinct; whether the cost of the Safe Space could be better used for housing assets. 7. Public land must be treated as a constitutional asset, not only a programme siteThe Constitutional Court’s Tafelberg judgment is highly relevant to public land decisions in Cape Town. The PLAAS summary of the judgment states that the Court confirmed the state’s obligation to deliver spatial justice and that location must be placed at the centre of housing decisions. It also states that public land should not be sold off without meaningful consultation and consideration of its potential for social housing. Recent reporting on the Tafelberg ruling further states that the Court found that authorities had not developed a coherent plan for affordable housing in well-located, amenity-rich urban areas, and that relying on cheaper land at the city’s periphery perpetuates spatial inequalities. This principle should apply to the Kuilsrivier Safe Space as well.The question is not only whether a Safe Space is useful. The question is whether this public land and public money are being used in the best way to undo homelessness, housing insecurity and spatial injustice.8. Temporary relocation must not become permanent povertyThe City must also consider families who have been waiting for proper housing for many years, including residents of Temporary Relocation Areas such as Blikkiesdorp.GroundUp reported that Blikkiesdorp residents protested after years of waiting for houses, with residents saying structures were falling apart, stormwater drains were blocked, illegal dumping was present, and emergency services were reluctant to enter the settlement at night because of criminal activity. One resident said she was placed there in 2010 and told it would be for six months. Recent reporting also described Blikkiesdorp as a Temporary Relocation Area where residents say a temporary solution has stretched into many years of waiting for permanent homes. This matters because the City should not keep creating temporary systems while unresolved temporary communities remain in crisis.If land or funding is available, the City should explain why long-term TRA families, backyard dwellers, housing-list applicants and people in emergency housing are not being prioritised for permanent or transitional housing opportunities.Temporary shelter should not become permanent policy.9. Available and developable land must be auditedThe City should not assess this Safe Space proposal in isolation.A public land and housing audit should be published for Kuilsrivier and surrounding areas. This should include: City-owned land; provincial land; national land; underutilised municipal sites; land released or proposed for sale/lease; land suitable for BNG housing; land suitable for social housing; land suitable for affordable rental; land suitable for transitional housing; land suitable for mixed-use housing; land unsuitable because of flood risk, wetlands, servitudes or environmental constraints. There are examples of housing development being assessed in the broader Kuils River area. For example, a site verification report for Remainder Farm 1388, Kuils River describes a proposed mixed-use residential neighbourhood on approximately 12.15 hectares, with about 436 Single Residential 1 erven, general residential erven, a general business erf, public open space and stormwater-management areas. The same report states that the site is within the municipal urban edge and surrounded by residential suburbs including Belhar and Wesbank. I do not rely on that example to say that Erven 1211 and 1212 are identical or suitable for housing. My point is that land-use decisions in Kuilsrivier should be supported by proper technical assessment, not assumptions.If the City can assess housing on environmentally sensitive or well-serviced land elsewhere, it should also publish a clear housing-feasibility assessment for this Safe Space site and nearby public land.10. Community safety and operational controls are essentialIf the Safe Space proceeds, the City must protect both the residents of the facility and the surrounding community.The facility should include: 24-hour security. Access control. CCTV at entrances and perimeter areas. Adequate lighting. Clear perimeter management. No unmanaged loitering outside the facility. Cleaning and waste removal around the site. A resident code of conduct. Rules on weapons, drugs, alcohol, violence, noise, visitors and curfew. Separate protection for women, elderly persons, disabled persons, LGBTQIA+ persons and other vulnerable residents. On-site social work capacity. Healthcare referral pathways. Mental-health referral pathways. Substance-abuse and intoxication protocols. GBV support pathways. ID-document and social-grant assistance. Employment and skills-development links. Family reunification programme. A complaints process for surrounding residents and businesses. A community oversight committee. The proposal says the facility will include 24-hour security and that Law Enforcement patrol support will be requested. That is not enough. The City must publish the operational plan, service standards, patrol plan, response times, complaint process and accountability structure.11. Operator accountability must be publicThe City should disclose who will operate the facility, how they will be selected, and how performance will be measured.The operating agreement should include measurable targets for: occupancy; safety incidents; complaints; response times; cleaning; reintegration; family reunification; employment/EPWP placements; healthcare referrals; substance-abuse referrals; exits into stable accommodation; repeat homelessness; community impact. The City should publish monthly or quarterly performance reports.If the operator fails to meet standards, there must be consequences.12. The Safe Space should not be approved without a housing comparisonThe City should publish a comparison between: spending money on a 130-bed Safe Space; using the same funds for transitional housing; using the same funds for social housing gap funding; using the same funds for serviced sites; using the same funds for upgrading temporary relocation areas; using the same funds for rental support or family-reintegration support; using the same funds to unlock public land for permanent housing. This comparison should include a 5-year and 10-year cost projection.If the Safe Space costs R12 million to R18 million per year when properly operated, the 10-year cost could be R120 million to R180 million, excluding major capital costs. The public must know why that recurring expenditure is better than investing in housing assets or housing-exit pathways.13. My requested conditions before approvalI respectfully request that the City not approve or implement the Kuilsrivier Safe Space unless the following are published and considered: Full capital cost. Full annual operating cost. Cost per bed per year. Cost per successful reintegration. Cost per resident exiting into stable accommodation. Full operational plan. Operator appointment process and performance standards. Security and Law Enforcement plan. Healthcare, mental-health and substance-abuse support plan. Housing-exit plan. Family reunification plan. Skills and employment pathway. Site suitability report. Housing feasibility assessment for Erven 1211 and 1212. Public land audit for Kuilsrivier and surrounding areas. Alternative site assessment. Community impact assessment. Traffic, waste, sanitation and service-capacity assessment. Community oversight committee. Monthly or quarterly public reporting. Six-month and 12-month independent review after opening. Clear power to correct, reduce, pause or restructure operations if serious harm or failure occurs. 14. Proposed policy conditionI propose that the City apply the following condition:No Safe Space facility should be approved unless it is directly linked to a measurable housing-exit and reintegration pathway, supported by a published cost-benefit analysis comparing temporary shelter expenditure with permanent housing, transitional housing, social housing, affordable rental and family reintegration alternatives.I further propose:Where City-owned land is proposed for a Safe Space, the City must first publish a site-specific housing feasibility assessment showing whether the land can reasonably be used, in whole or in part, for permanent housing, transitional housing, social housing, affordable rental, BNG housing, mixed-use housing or other direct public-benefit uses.ConclusionI support dignified assistance for vulnerable residents. I do not support leaving people to sleep in unsafe public spaces. But I also do not support a system where ratepayers fund expensive temporary accommodation year after year while the deeper housing crisis remains unresolved.The Kuilsrivier Safe Space may assist people in the short term, but it must not become a substitute for housing.The City must show that this proposal is not merely a shelter project, but a genuine pathway from homelessness to stability. It must also show that public land and public money are being used in a way that advances housing justice, spatial justice, community safety and long-term reintegration.I therefore request that the City treat this submission as conditional support only, subject to full disclosure of cost, land-use justification, housing feasibility, operational controls, reintegration outcomes and community accountability.Public money should not only manage homelessness. It should help end it.

Gavilon Dean Basson2 months ago I welcome the City of Cape Town’s proposed amendments to the Municipal Planning By-law, 2015, especially the intention to make building plan approvals more transparent, to give surrounding neighbours access to approved plans and reasons, and to introduce a clearer third-party complaint mechanism.In principle, I support greater transparency and accountability in the building-plan approval process. Many residents only become aware of building-plan impacts when construction has already started next door. By that stage, the affected neighbour is placed in a difficult position and must fight from behind. This creates mistrust, conflict between neighbours, and unnecessary pressure on the City’s enforcement system.However, I respectfully submit that the proposed amendments should go further to ensure that transparency is meaningful, fair, enforceable and accessible to all communities, not only those with resources, legal knowledge or influence.My position is that the amendments should protect residents from unlawful, unsafe or harmful building activity, while also ensuring that the system is not abused to block lawful development, affordable housing, small home improvements or responsible densification.1. Public notice after approval is not enough in material-impact casesI support public notice of every building-plan approval. However, notice after approval should not be the only safeguard where a proposed building may materially affect neighbouring properties.If neighbours are only informed after approval, then the process becomes reactive instead of preventative. Affected residents should not first discover an approved impact when builders arrive on site or when construction has already begun.The By-law should distinguish between ordinary building-plan approvals and plans that may materially affect adjoining properties.Where a building plan has no material impact on neighbouring properties, post-approval notice may be sufficient.However, where a plan may materially affect a neighbour, written notice should be given before approval so that the affected neighbour has a fair opportunity to comment.2. Mandatory written notice to affected neighboursI recommend that the amendment should require written notice to affected adjoining neighbours before approval in cases where a proposed building plan may materially affect neighbouring properties.This should include, but should not be limited to, cases involving: building-line departures; height impacts; second-storey or overlooking impacts; privacy impacts; boundary walls; shared walls; servitudes; stormwater or drainage impacts; parking or access impacts; fire-safety concerns; structural impacts close to boundaries; land-use intensification; any deviation from ordinary development rules; or any matter that may reasonably affect the rights, safety, privacy, light, ventilation, access or peaceful enjoyment of adjoining properties. The City should require proof that the affected neighbour was notified in writing, given access to the relevant portion of the plan, and allowed a reasonable opportunity to comment before approval.3. Written neighbour consent for higher-impact mattersIn higher-impact cases, written neighbour consent should be required and kept as part of the official approval record.This should apply where the proposed approval directly affects an adjoining property through matters such as boundary relaxations, encroachments, privacy/overlooking impacts, shared walls, servitudes, stormwater flow, or other material impacts.However, neighbour consent should not replace the City’s legal duty to assess the application properly. Even if a neighbour signs consent, the City must still ensure compliance with zoning, building regulations, fire safety, stormwater requirements, structural safety, title-deed restrictions, servitudes, heritage requirements and all relevant laws.Neighbour consent should mean that the neighbour was properly informed and agreed to the specific impact. It should not be used to legalise an unlawful or unsafe building proposal.4. Refusal of consent or neighbour objection must trigger written reasonsWhere a neighbour refuses consent or raises a valid concern, the City should not simply approve the plan without explanation.The City should be required to provide written reasons explaining how the neighbour’s concern was considered before approval is granted.This would improve fairness and trust in the process. It would also help avoid unnecessary disputes, because affected residents would at least understand why the City made its decision.5. Access to approved plans and reasons must be practical and affordableI support giving surrounding neighbours access to approved building plans and reasons. However, this access must be simple, affordable and practical.Residents should not have to struggle through complicated processes, expensive applications or long delays just to understand what has been approved next to their homes.The City should provide a clear process for affected neighbours to access: the approved plan or relevant affected portion of the plan; the approval conditions; the reasons for the approval; the date of approval; the official responsible department or contact point; the complaint or appeal route; and the deadline for taking further action. Where security or privacy concerns exist, the City can redact sensitive personal information, but this should not be used as a reason to deny affected neighbours meaningful access to the information they need.6. Stronger third-party complaint mechanismI support the proposed third-party complaint mechanism, but it must have clear powers, timelines and accountability.A complaint mechanism is only useful if residents receive proper responses and if the City takes action where there is a serious irregularity.The amendment should include: a simple complaint form; accessible online and offline submission options; acknowledgement of receipt within a fixed timeframe; a clear investigation process; inspection where necessary; written outcome reasons; escalation where the response is unsatisfactory; protection against victimisation of complainants; and clear consequences where unlawful building is confirmed. The complaint mechanism must be available to ordinary residents, including people who do not have lawyers, internet access, technical planning knowledge or money to pay professionals.7. Stop-work review where serious irregularity is allegedWhere a third-party complaint raises a serious issue, such as unsafe building work, construction not matching the approved plan, unlawful encroachment, stormwater risk, fire risk, structural danger or fraudulent/misleading information, the City should have a clear process for urgent inspection and temporary stop-work review.This does not mean every complaint should automatically stop construction. However, where the complaint is serious and evidence-based, there must be an urgent mechanism to prevent irreversible harm while the matter is being assessed.Without this, residents may win a complaint only after the damage has already been done.8. Rectification must not reward unlawful buildingI note that Chapter 8A is proposed to be reworked into a consent-based process dealing with rectification of approvals and building plan approvals.I respectfully submit that the City must be very careful not to create a process that rewards people who build first and seek forgiveness later.Rectification should not become a shortcut for unlawful building, misleading plans or non-compliance.The By-law should make it clear that: unlawful building remains unlawful until properly regularised; rectification must not prejudice affected neighbours; affected neighbours must be notified where their rights or property are impacted; written consent should be required where the rectification materially affects adjoining properties; the City must still assess safety, zoning, stormwater, fire and structural compliance; penalties should apply where a person knowingly built without approval or contrary to approved plans; and repeated offenders should face stronger consequences. The City should not create a system where compliant residents follow the rules while others ignore the rules and later regularise their conduct without meaningful consequences.9. Consent-based process must be clearly definedThe proposed consent-based process must be clearly defined.The amendment should explain whose consent is required in different circumstances. It should not only mean consent from the property owner or applicant.Where the rectification or approval affects neighbouring properties, the consent of affected neighbours should also be considered.At minimum, the By-law should clearly distinguish between: owner consent; applicant consent; adjoining neighbour consent; body corporate or homeowners’ association consent, where applicable; servitude-holder consent; and City approval. This will prevent confusion and reduce disputes.10. Equal enforcement across wealthy and poorer areasThe amended By-law must be applied equally across Cape Town.Planning enforcement must not be strong in affluent areas but weak in poorer areas. Communities in the Cape Flats, townships and lower-income neighbourhoods also deserve safe buildings, proper drainage, fire safety, legal compliance and protection from harmful development.At the same time, the system must not be used by wealthy or influential residents to block lawful affordable housing, backyard upgrading, small home improvements or responsible densification.The City must strike a fair balance. The purpose should be lawful, safe and accountable development — not obstruction of development.11. Protect lawful incremental housing and small property improvementsMany ordinary families improve their homes gradually over time. The By-law should not punish responsible residents who are trying to improve their living conditions lawfully.The City should therefore provide practical support for small property owners to understand the rules before they build. This could include: simple building-plan guidance; local planning help desks; affordable advisory support; standard checklists; translated information; and assistance for elderly residents, disabled persons and people who cannot read or write. The City should make compliance easier before enforcement becomes necessary.12. Digital and physical notice systemThe City should use both digital and physical notice methods.A public online notice is useful, but not everyone checks City portals. Affected neighbours should also receive direct written notice.Where a development has a clear site impact, the City should consider requiring a visible site notice for a reasonable period before approval or before construction starts, especially in material-impact cases.The notice should include: the erf number; the nature of the approval; the date of approval or proposed approval; where to access the plan; the deadline to complain or respond; and the contact details of the responsible City department. 13. Timeframes for City responsesThe amendment should include clear response timeframes.Residents should not be left waiting indefinitely after submitting a complaint or request for reasons.I recommend that the City include timeframes for: acknowledging a complaint; providing access to approved plans and reasons; conducting an inspection where required; issuing a written response; escalating unresolved complaints; and taking enforcement action where non-compliance is confirmed. Without timeframes, transparency can become meaningless.14. Penalties for false or misleading informationThe By-law should include strong consequences where an applicant, owner, builder or professional submits false, misleading or incomplete information to obtain approval.This is important because neighbours and the City rely on the accuracy of submitted plans and information.Where approval was granted based on incorrect information, the City should be empowered to review the approval, require correction, issue penalties, and take enforcement action where necessary.15. Annual public reportingThe City should publish annual data on the operation of the amended building-plan transparency and complaint system.This should include: the number of building approvals issued; the number of public notices published; the number of neighbour complaints received; the number of complaints upheld; the number of inspections conducted; the number of stop-work notices issued; the number of rectification applications received; the number of rectifications approved or refused; enforcement action taken; average response times; and data broken down by area or district. This will allow the public to see whether the amended By-law is working fairly across Cape Town.16. My proposed policy wordingI respectfully recommend that the City consider including wording similar to the following:“Where a building plan approval, rectification application or related approval may materially affect an adjoining property, the City must require written notice to the affected adjoining owner or occupier before approval is granted, unless exceptional circumstances justify otherwise. The notice must provide sufficient information to allow the affected party to understand the nature and potential impact of the proposal and to submit comments within a reasonable period.”“Where the proposal involves a material departure, encroachment, servitude impact, boundary relaxation, privacy impact, stormwater impact, shared-wall impact or other direct impact on an adjoining property, the City may require written neighbour consent as part of the approval or rectification record. Such consent does not replace the City’s duty to assess compliance with applicable planning, building, safety and environmental requirements.”“Where an affected neighbour objects or refuses consent, the City must provide written reasons explaining how the objection or refusal was considered before granting any approval.”“Where a third-party complaint raises a credible allegation of unlawful, unsafe or materially non-compliant building work, the City must conduct a preliminary assessment within a prescribed timeframe and may require temporary suspension of the relevant work pending inspection or determination.”ConclusionI support the City’s intention to improve transparency in building-plan approvals and to create a stronger third-party complaint mechanism.However, the amendments must ensure that transparency happens early enough to matter, that affected neighbours receive written notice where their rights may be impacted, that written neighbour consent is required in higher-impact cases, and that residents have access to clear reasons, plans, timelines and enforcement remedies.The amended By-law should protect communities from unlawful and harmful building activity while also supporting lawful, safe and responsible development.The goal should be a planning system that is transparent, fair, accessible, enforceable and applied equally across all communities in Cape Town.

Gavilon Dean Basson

All input submitted by this participant

Business Starter Pathway for Practical MSME Support

Public Finance, Land-Use and Housing-Outcome Assessment of the Proposed Kuilsrivier Safe Space

Conditional Support Only: Safe Space Must Be Tested Against Housing, Land Use, Cost and Long-Term Reintegration

Transparent Building Plan Approvals, Neighbour Consent and Equal Enforcement