
Natalie-Jane Van Dieman•3 days ago FORMAL PUBLIC COMMENT ON PROPOSED CITY OF CAPE TOWN BY-LAWCHAPTER 3: BEEKEEPING — CLAUSE 38: KEEPING OF BEESSubmitted from the perspective of a backyard farmer, beekeeper and community volunteerSubject: Comment, objection and recommendations regarding Clause 38 — Keeping of BeesI submit this comment as a backyard farmer, beekeepHER and community volunteer who works at grassroots level with food growing, environmental education, community development and bees.I support responsible beekeeping, appropriate training and sensible measures to protect residents, animals and public safety. However, I have serious concerns that Clause 38, in its current form, does not adequately recognise the realities of urban and township communities, backyard food production, the loss of natural bee habitat, or the ecological importance of our indigenous Cape honeybee, Apis mellifera capensis.The proposed provisions appear to regulate bees primarily through permits, exclusion zones and restrictive distances. This approach risks making responsible small-scale beekeeping inaccessible or impossible in densely populated communities.The City should regulate risk and irresponsible practices, rather than effectively excluding responsible community beekeeping from urban spaces.COMMENTS ON CLAUSE 38(1)–(17)Clause 38(1): Permit requirementI am concerned that requiring a permit for all beekeeping on land not zoned for agricultural purposes could disproportionately affect backyard farmers and small-scale community beekeepers.Urban and township residents often do not have access to agricultural land. Yet backyard farming and beekeeping can contribute directly to household food security, pollination and emerging livelihoods.Recommendation: Create a simplified, affordable category for small-scale residential and community beekeeping, with requirements proportionate to the number of hives and the actual level of risk.Clause 38(2): Use of beekeepersThis requirement could create barriers to accessing skilled local beekeepers for bee rescue and relocation.Recommendation: The City should recognise trained community-based beekeepers and bee-rescue practitioners through an accessible registration or accreditation system.Clause 38(3): Registration, association membership and trainingI support appropriate training and competency requirements. However, compulsory membership of a formal beekeepers' association may create an unnecessary barrier for grassroots residents.Recommendation: Recognise practical, community-based and accredited training as evidence of competency. Training should be encouraged as a tool for improving safety, reducing fear and preventing unnecessary destruction of colonies.Clause 38(4): Hive constructionI support appropriate standards for hive construction.However, requirements should allow affordable hive options suitable for small-scale community beekeeping while maintaining appropriate standards of safety, durability and responsible management.Clause 38(5): Five-metre and fifty-metre distancesI strongly object to these blanket distance requirements.These requirements are likely to be impractical or impossible to meet in densely populated urban and township areas.Many backyard farmers have limited land. Such restrictions could effectively prohibit responsible beekeeping in communities where bees already exist and where their pollination services are important for food gardens.Recommendation: Replace blanket distances with a risk-based assessment considering factors such as:
hive placement;
barriers and walls;
hive orientation;
bee flight paths;
number of colonies;
colony behaviour;
water availability;
hive management; and
actual proximity to people.
Clause 38(6): 1.5-metre barrierI support the principle of using barriers to direct bee flight upwards and away from people.However, the City should recognise existing walls, hedges and other structures where they provide equivalent protection.Clear, practical guidance should also be provided so that residents understand what constitutes an acceptable barrier.Clause 38(7): Warning signsI support this requirement.Clear warning signage is a reasonable and inexpensive public-safety measure.The City could provide standard signage templates to make compliance accessible to residents.Clause 38(8): Five-metre separation between hivesA rigid five-metre separation may not always be necessary where hives are properly arranged and managed.Recommendation: Allow alternative hive arrangements where the beekeeper can demonstrate safe access, appropriate hive orientation and responsible management.Clause 38(9): Permanent water sourceI support the principle of providing water.Responsible water provision can reduce bees seeking water from neighbours' swimming pools, taps and other sources.However, the requirement should recognise practical alternatives, including properly maintained shared or community water sources.Clause 38(10): Council determining the number of hives and beekeeper knowledgeI am concerned about the broad discretion given to Council to determine the number of hives and whether an applicant has sufficient knowledge.Recommendation: Establish clear and transparent criteria based on measurable factors such as:
property size;
number of hives;
management practices;
training or competency; and
demonstrated risk-mitigation measures.
Residents should be able to clearly understand what is required to comply.Clause 38(11): Limits by geographic area or suburbI strongly object to blanket geographic restrictions.Such restrictions could disproportionately disadvantage township and lower-income communities and prevent residents from participating in food-security initiatives and green enterprise.Recommendation: Geographic restrictions should only be imposed where supported by clear, evidence-based public-safety or environmental considerations and should not automatically exclude an entire suburb or community.Clause 38(12): Informing neighboursI support neighbour communication.Keeping neighbours informed when working with bees is responsible practice.However, this should not become a mechanism whereby an individual neighbour can effectively veto responsible beekeeping.Education and communication should be prioritised.Clause 38(13): Compost, garbage and manureI am concerned that this requirement could unintentionally conflict with backyard farming and food-growing practices.Compost and manure are important resources for small-scale food production.Recommendation: Properly managed compost and manure should not automatically be prohibited. The focus should be on actual nuisance, contamination or attraction of pests rather than the mere presence of compost or manure.Clause 38(14): Health or nuisanceI support the principle that beekeeping must not create an unreasonable health or safety nuisance.However, the definition and assessment of nuisance should be objective and evidence-based.Normal bee activity should not automatically be classified as a nuisance simply because someone is afraid of bees.Fear can and should be addressed through education, awareness and safe management.Clause 38(15): Removal of bees and hivesI have serious concerns about this provision.Cape Town already has wild and semi-wild bee colonies living in tree cavities, walls, roofs, drains, schools, houses, tyre stacks and other structures.As natural habitat continues to disappear through development, bees are increasingly forced to establish colonies wherever suitable shelter can be found.Before a colony is removed or destroyed, the City should prioritise safe rescue and relocation by trained beekeepers wherever reasonably possible. Not using Pest Control cowboys in beesuites.A clear bee-rescue protocol should be established.The cost of removal should also not automatically be placed on residents, particularly where the resident is unable to afford professional services or where the colony established itself naturally.Clause 38(16): Database, inspections and Standard Operating ProceduresI support the principle of a City beekeeping database and appropriate inspections.However, the purpose of such a system should not simply be to police residents.It could also help the City understand where colonies are located, where bee habitat is being lost, and where intervention or relocation is required.The City's Standard Operating Procedures should be developed with meaningful participation from:
backyard farmers;
grassroots beekeepers;
bee-rescue practitioners;
community gardens;
environmental organisations;
agricultural specialists;
youth programmes; and
township communities.
Clause 38(17)(a): 400-metre restrictionI strongly object to a blanket 400-metre restriction around schools, hospitals, churches, cinemas and other gathering places.Such a restriction could make beekeeping impossible across large portions of densely populated communities.Bees already exist around schools, churches, homes, parks and other public spaces.The practical question should be how they are safely managed, not whether responsible beekeeping can exist within an arbitrary radius.Recommendation: Replace the blanket 400-metre restriction with a site-specific risk assessment.Clause 38(17)(b): Nuisance to neighbours or the publicI am concerned that this provision gives Council significant discretion.Recommendation: Establish objective criteria for determining nuisance, including actual incidents, hive management, colony behaviour and reasonable mitigation measures.A person's fear of bees should be acknowledged and addressed through education and appropriate safety measures, but fear alone should not automatically determine whether responsible beekeeping is permitted.Clause 38(17)(c): Swarm-management practicesI support responsible swarm management.However, the City should ensure that accessible training is available so that grassroots beekeepers can meet this requirement.The objective should be to build local capacity rather than exclude people who cannot afford expensive professional training.ADDITIONAL RECOMMENDATION: DESIGNATED TOWNSHIP BEE LAND AND COMMUNITY BEE RESCUEI further recommend that the City of Cape Town designate suitable municipal land within townships and other densely populated communities as protected community bee habitat and bee-relocation sites. Grassroots dont know what space is belonging to which department or provincial or government. Help us your departs that work in silos should get together like an interdisciplinary team for our BEE care.This would provide a practical solution when bees need to be removed from homes, schools, public buildings or other unsuitable locations.The City already has processes for dealing with bee removals when colonies are found on City property. However, the situation is very different for an unemployed or low-income household when a colony establishes itself inside a wall, roof, ceiling or other part of a home.A safe bee removal from a wall may require the wall to be opened, honeycomb and honey to be removed, the area cleaned and sealed, and building work undertaken afterwards.This can become a complicated and expensive process that many township households simply cannot afford.When residents cannot afford professional services, the alternatives may be to leave the colony untreated, attempt unsafe removal themselves, use harmful chemicals or destroy the colony.None of these outcomes serves public safety or bee conservation.Township Bee Rescue and Relocation ProgrammeI recommend that the City consider establishing a Township Bee Rescue and Relocation Programme, including:
designated municipal land for safe relocation of rescued colonies;
a register of trained local beekeepers and bee-rescue practitioners;
subsidised or City-supported bee removals for qualifying low-income households;
partnerships with local builders to assist with opening and restoring walls and structures;
training opportunities for unemployed residents in bee rescue and beekeeping;
community and school education programmes;
monitoring of relocated colonies; and
planting and protection of indigenous flowering plants and pollinator habitat.
This could create a practical pathway:Bee colony in an unsuitable location → Safe rescue → Relocation to designated community bee habitat → Managed colony → Pollination, education, biodiversity and enterpriseDesignated bee land as a community assetAppropriate parcels of municipal land within townships could potentially be developed as community pollinator reserves, bee sanctuaries or managed apiary sites, subject to appropriate environmental, land-use and safety assessments.These spaces could combine:
rescued Cape honeybee colonies;
community food gardens;
indigenous flowering plants;
environmental education;
youth skills development;
beekeeping apprenticeships;
honey and beeswax enterprises; and
biodiversity restoration.
This would be particularly valuable in communities where natural habitat has already been heavily reduced through development.It would also give residents somewhere safe to relocate colonies that might otherwise be destroyed.THE INDIGENOUS CAPE HONEYBEE MUST BE RECOGNISEDThe proposed by-law should specifically recognise the ecological importance of the indigenous Cape honeybee, Apis mellifera capensis.These bees are not simply a nuisance to be controlled.They are important pollinators and part of the ecological heritage of the Western Cape. What does our department of Heritage and Culture got to add value in the care of our Indigenous Bee...As urban development removes natural habitat, colonies increasingly establish themselves in houses, walls, drains, schools, tree cavities and other structures.We cannot simply regulate urban bees out of existence.Where natural habitat is removed, alternative habitat and relocation options must form part of the City's response.FOOD SECURITY, LIVELIHOODS AND COMMUNITY RESILIENCEThis issue must also be considered within the broader reality of township communities.Many households face unemployment, rising food costs and limited economic opportunities.Backyard farming can provide food.Bees provide essential pollination (pollination is still not understood here...an apple tree with bees produces 100apples, with no bees maybe 2 apples just making a simple example)Beekeeping can provide skills and they certainly have the best governance with discipline, our human race could also learn more from observing the hive.Honey, propolis, pollen, beeswax and other bee-related products can provide opportunities for small green enterprises.Youth can be trained in environmental stewardship, agriculture and beekeeping.At a time when communities are looking for ways to become more self-reliant, municipal policy should support these opportunities rather than unintentionally remove them.We should be teaching the next generation how to work safely with bees, not simply teaching them to fear them.There are irresponsible people in every sector. Where individuals fail to manage bees safely, those practices should be dealt with appropriately.Deal with the irresponsible beekeeper — do not penalise every responsible beekeeper.CULTURAL AND COMMUNITY KNOWLEDGEBees also connect communities to knowledge passed down through generations about honey, beeswax, plants, wellness and our relationship with nature.There is an opportunity for the City to support the transfer of this knowledge while ensuring that modern safety and environmental standards are followed.Community knowledge and formal regulation do not have to compete with one another.They can work together.OVERALL POSITIONI respectfully request that the City reconsider Clause 38 in its current form and undertake meaningful consultation with grassroots beekeepers, backyard farmers, community gardens, environmental organisations and residents of densely populated communities before the by-law is finalised.I am not advocating for unlimited or irresponsible urban beekeeping.I am advocating for safe, practical and equitable coexistence.The City should:
Recognise small-scale residential and community beekeeping;
Introduce proportionate and affordable permit requirements;
Replace blanket distance restrictions with risk-based assessments;
Recognise and protect Apis mellifera capensis;
Establish a City-supported bee rescue and relocation programme;
Prioritise relocation over destruction of viable colonies;
Establish designated bee habitat and relocation sites within appropriate township areas;
Provide accessible training for grassroots beekeepers;
Support unemployed residents to develop bee-related skills and green enterprises;
Ensure nuisance provisions are objective and evidence-based;
Provide assistance to qualifying low-income households facing bee removals;
Involve local beekeepers and backyard farmers in developing the City's Standard Operating Procedures; and
Ensure that the by-law does not unintentionally undermine household food security, pollination, youth development, biodiversity or community enterprise.
CONCLUSIONOur communities already live with bees. Wolgat Nature Reserve impacts the Tafelsig and Rocklands communities during swarming. Allow us to put in beehives like Boulders allows for Penguin domes. Our backyard farmers already depend on them.Our natural habitat is disappearing, and the bees are adapting to the spaces that remain.We cannot simply tell the bees that they are no longer welcome in our communities.The question should not only be:“Where are bees allowed to be kept?”It should also be:“Where are we going to put the bees when development removes their natural homes?”If the City wants responsible bee management, then responsible bee management must be made accessible to the communities being regulated.Let us create a system that protects people and protects bees.Let us turn bee conflict into an opportunity for food security, biodiversity, skills development, youth education and green enterprise.Our bee is not the enemy. Our indigenous Cape honeybee is part of the solution.And in communities facing unemployment, food insecurity and violence, we should be creating more opportunities for life, not unintentionally removing them.Let us choose our indigenous bees over the bullets killing our people every day.Submitted by: Natalie-JaneBackyard Farmer | Community Volunteer| Local Aunty from the Block | Chairwoman of Mitchell's Plain AgrihubFounder of Brother Nathan Foundation | Member of Western Cape Bee Industry AssociationIm a BeekeepHER officially Trained by BeeGoodAfrica Cohort 1 facilitated by Dawn Noemdoe "Honey@Dawn". Descendant of the First Nations Peoples honouring my heritage by protecting our Indigenous Bee