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DEPARTMENT OF RURAL DEVELOPMENT AND LAND REFORM RESPONSE TO SDF GUIDELINES COMMENTS SEPTEMEBR 2011 1 | P a g e

RESPONSE TO SDF GUIDELINES COMMENTS 2010/2011

THE DEPARTMENT OF RURAL DEVELOPMENT AND LAND REFORM

DIRECTORATE: SPATIAL PLANNING IMPLEMENTATION, SPATIAL

DEVELOPMENT FRAMEWORKS RESPONSE TO COMMENTS PERTAINING

TO THE SPATIAL DEVELOPMENT FRAMEWORK (SDF) GUIDELINES

SEPTEMBER 2011


SDF GUIDELINES COMMENTS INCORPORATION INTO DRDLR SDF GUIDELINES DRAFT 8 SECTOR REPRESENTATIVE/DEPARTMENT RESPONSE

Acronyms National Department of Environmental Affairs National Working Session 22 September 2010

DEA requested the inclusion of the Municipal Finance Management Act (MFMA) into the List of Acronyms.

Definitions Northern Cape Consultation- 5 & 7 October 2010

Definitions for hamlet, village and settlement have been incorporated.

Mpumalanga Local Municipalities & SALGA 26 November 2010

The Department welcomes your definition for an SDF and has been included in the definitions section of Draft 8.

Gareth Evans and Perm Mdingi from ECSECC,

„Credibility‟ is a much contested term; however, it is a term the Department welcomes and through the evaluations component the validity of SDFs will be assessed using a ratings mechanism.

Northern Cape Consultation- 5 & 7 October 2010

„Data integrity and reality coupled with practicality constitutes an SDF as credible‟; „A credible SDF‟s is a document that can give strategic direction on the growth or change of the spatial environment. The document must not be for academic purposes/compliance but it must be an implementable document;‟ the department fully supports these statements

KwaZulu-Natal Consultation 18 November 2010

Definitions for food security and urban sprawl have been included in the guidelines.

DCOG National Working Session 22 September 2010

Raised a concern regarding the misplaced definition in acronyms section of rural areas/development and urban areas/development. This concern has been addressed in this draft submission.

DCOG suggested that the Draft 8 defines communal land and land audit, which has been incorporated into Draft 8.

National Department of Environmental Affairs National Working Session 22 September 2010

This department requested the description / definition of SDF, EIA and SEA. This request was addressed in the Glossary Section.

Water Alka Ramnath (Planner) from Planning Contributions from Alka Ramnath (Planner) from Planning


Services Umgeni Water KZN Services Umgeni Water KZN were incorporated into SDF Guidelines Draft 8.

National Department of Water Affairs National Working Session 22 September 2010

The Water Services Development Plan was addressed on page 106 of Draft 8.

Environment

South African National Biodiversity Institute (SANBI)

Contributions from the South African National Biodiversity Institute (SANBI) were adopted into the SDF Guidelines Draft 8.


DEA highlighted “monitoring and control of alien invasive species”, and “development on dolomite” as typical issues requiring policy statements and guidelines. See table 3.1, more information/ assistance is required from DEA./

Built Environment

National Department of Human Settlements

Comment 10 was amended. Read Page 103.

Western Cape Provincial Department of Transport and Public Works

Efficient urban structure comment was dealt with in 1.10.4 of this draft.

Comment in terms of 4.3.1 (settlement restructuring) was filtered underneath (b) Densification. See Page 62.


Despite the clear linkage between SEAs and EIAs, the department raised a critical comment that indeed is a struggle to spatially allocate projects. This comment is already addressed in this draft document because an SDF itself is a tool that seeks to achieve desired spatial form by guiding distribution of activities on space through development guidelines.

Development Bank of Southern Africa National Working Session 22 September 2010

The Development Bank is commended about the use of communal and mining land that the ownership should not influence development. This concern was addressed under Land Ownership and Value (Page 70) that the SDF should consider what would be the best use of such land than


depending on what the owner wants.

Transport


Comment regarding SDF scope of work (Table 1.4) was addressed, and the Table now includes: major corridors; movement routes; connectivity zone; and identification of strategic locations for growth by virtue of proximity to key transport corridors or nodes.

PRASA, Transnet and ACSA were added as important agencies required to participate in the process in terms of the land use and transport arena (see 2.7.1).

Additions to “THEMES TO BE COVERED IN THE STATUS QUO ANALYSIS” (Table 3.1) were dealt with on Page 52.

Comment around the replacement of the NLTTA with the NTLA was not addressed within these guidelines.

W Cape: Dept of Transport & Public Works 10.12.10 (Dru Martheze)

The following issues were attended to:

Refer to W Cape Roads Ordinance (19/76) and Advertising on Roads and Ribbon Development Act (21/40)

Include “Road Authority” under sec 2.7.1.

P 64, technical note 9, sec 2.3 . activity/development spines can be promoted along mobility routes if “offset and parallel to” (service roads) or “perpendicular and linking to” activity streets (access routes) are provided

Phase 6 – include that “ all stakeholders/public also be informed of the date that the SDF was approved and where an approved copy of the report may be obtained or viewed”

Analysis City of Cape Town, Spatial Planning & Urban Design

In response to the scant use of spatial planning categories from CoCT; we welcome the use of existing guidelines to supplement these guidelines if the need arises.

Marx M Mupariwa (TRP SA), Specialist: Development Planning, SALGA National Office, Ms Maria Coetzee, CSIR Built

The guidelines provide easy tools and clear directives in regard to the analysis and synthesis of the development of municipalities despite providing the „ecological, socio-economic relationship framework‟ example. The guidelines


Environment, Tel 0128412552. Email: [email protected]

particularly target municipalities that may have limited capacity or the skills to produce highly technical matrices. However, we do not discourage the use of these mechanisms to produce qualified results. We welcome examples if you have any at your disposal.

Gerhard de Bruin (Professional Planner) at Northern Province Spatial Planning Unit

Status quo report should include the background and histories of the area were incorporated at Draft 8.

Provincial Growth and Development Strategy (not only NSDP) should form part of policies and programmers relevant to the Spatial Development Framework were included in Draft 8.

Merafong Local Municipality National

Working Session 22 September 2010

The municipality raised a question in terms of the carbon footprint. Where are issues of air quality put when talking of infill and densification (Industrial areas)? This has been addressed in the draft 8 document.

EMFs & SEAs P.S Classen The department shares your sentiments regarding SEAs. The Department of Environmental Affairs has committed to Outcome 4 in its delivery agreement to develop 4 EMFs per annum, DRDLR is also committed to produce 25 Rural SDFs per annum and have sort to select some SDFs which fall within the DEAs project plan for 2010/11/12/13/14. Discussions on how to run the process in a parallel manner are already underway. The preparation of EMFs would also curtail the need for SEAs. Please see section 1.12 in the guidelines for reference purposes.

Focus of the Guidelines

City of Cape Town, Spatial Planning & Urban Design

The SDF Guidelines focus on the District, Metropolitan, Local, rural and urban municipalities. However, the Department will incorporate National Provincial and the regional spheres at a later stage.

Western Cape Consultation 11 November 2010

Phasing of the SDF Guidelines: the two Public Participation Phases (2 & 5) have been intentionally included in order to provide structure for compilers of the SDF in order to know

mailto:[email protected]


the appropriate times to involve stakeholders; however, it does not preclude other process from taking place especially those provided for in phase 1.

Approval City of Cape Town, Spatial Planning & Urban Design

The comments from the received by DRDLR in December 2010 have been incorporated into the SDF Guidelines Draft 8. In regard to the approval status of SDFs especially pertaining to the approval of SDFs in the Western Cape; the SDFs would continue to be approved via the MSA or LUPO in this case the revised LUPO, of which Province intends to align the new LUPO to the DRDLR Spatial Planning and Land Use Management Bill, which has several implications for SDFs.

Northern Cape Consultation - 5 & 7 October 2010

Approval of the SDF should remain as required by the Northern Cape Planning Development Act unless amended to align to the DRDLR SPLUMB.


There must be clarity on the process of approval of the SDF by MEC. Noted.

Legislative and Policy Alignment

City of Cape Town, Spatial Planning & Urban Design

In reference to the comments received from CoCT it would have been more useful to stipulate the inconsistencies between the NSDF and the PGWC: SDF Guidelines, as the PGWC: SDF guidelines were perused.


Comment 8 regarding Section 25 and 26, and Housing Code have been noted.

Comment 9 (i.e. BNG) has been reflected on Page 102 of draft 8.


The comment “Alignment with surrounding SDFs” is amended in 1.13 (Page 26).

National Department of Energy, National Working Session 22 September 2010

Comments with respect to the Integrated Energy Plan 2003 and Integrated Resource Plan 2010-2030 have been addressed in the draft document.


National Department of Water Affairs, National Working Session 22 September 2010

DWA requested the inclusion of the National Water Resources Act and National Environmental Management Biodiversity Act, and this comment has been addressed in this draft submission.

National Department of Environmental Affairs, National Working Session 22 September 2010

DEA has proposed that Nkangala Case Study Paper be consulted in assisting to develop an approach in terms of projects overlapping into more than municipalities. The draft document did not take the paper into cognizance though the guidelines propose various platforms to enhance alignment between the SDFs of different municipalities.

The department requested implications of neighboring SDFs, and District Development Growth and Development Strategies. As much as the draft guidelines encourage that SDFs of the adjoining municipalities should be aligned, they are silent about the implications of the District Development Growth and Development Strategies on the SDFs.

Environmental Affairs urges that in a municipality where an SEA has not been prepared yet, it should be commissioned as part of a phased development of the SDF. This comment was crucial to the department, and the Draft Guidelines have addressed this crucial comment.

Emfuleni Local Municipality, National Working Session 22 September 2010

The municipality advised that adjoining municipalities should have cross boarder meetings to discuss issues and achieve alignment. This comment is very important and it has been addressed in draft 8 submission.

Alignment/ sector Departments

Marx M Mupariwa (TRP SA), Specialist: Development Planning, SALGA National Office, Ms Maria Coetzee, CSIR Built Environment, Tel 0128412552. Email: [email protected]

Alignment of the programmes of sector departments is key to development of a credible SDF. The department agrees that there is a need to investigate possible institutional arrangements that will ensure that the planning, prioritization and implementation of the sector departments programmes are aligned to the SDF.

Northern Cape Consultation - 5 & 7 The Department agrees that departmental forums are



October 2010 required in order to ensure a shared goals and integrated planning. The office of the Premier must be a champion with the alignment of sector plans. “Information from sector departments should be freely shared”. The Department agrees that information must be shared freely, it is a legislative requirement.


It is concurred that sector plans should feature in the planning and preparation of the SDF in order to ensure the success of the SDF, hence emphasizing the coordination required to ensure „good planning‟.


“Budgets allocated to sectors in IDP and should be guiding all actions, the SDFs must be written in a way where all the sectors use in implementing their programs- SDFs should be appearing within the implementation sectors”; This would be a step in the right direction sign off from sector departments would be required!

Free State Consultation Bloemfontein – 22.09.10 Trompsburg – 23.09.10 Welkom - 11.11.10 Kroonstad – 17.11.10 Clarens – 26.11.10

“Propose sectoral departments should also sign service- delivery agreements”. DRDLR agrees with this statement, see page 34.


“The call for sector departments needs to be a requisite from above rather than from municipalities” DRDLR agrees with this statement.

Timmy Shilenge Director SPI Limpopo “Should the sector plans supersede the draft SDF? Should they be developed concurrently? Should they be developed after the SDF is concluded? One thing for sure, the approach of the sector plans first, then SDF has failed to achieve integrated development. A fresh approach will be for


the sector plans to become Detailed implementation/strategic plans of an SDF. This is similar to or will allow the implementation of a concept of “SDF as a Chess Board” (as proposed by CNDV during tender evaluation process). Sector plans may therefore be part of the implementation plan on phase 7.THIS IS A FRESH APPROACH (PMBOK WBS APPOACH WHICH CLEARLY PROMOTE THE ACHIEVEMENT OF A PARTICULAR DELIVERABLE THROUGH DETAILED PLANNING AND EXECUTION OF RELATED WORK PACKAGES)” . The Department agrees with your sentiments and has incorporated your comments into the Guidelines section (v).

Alignment /IDP/SDF

North West Consultation, 30 November 2010

It is agreed that there is a large gap between the SDF and IDP and the IDP has become a wish-list driven by political gain. We support that the NW Developmental Forum must be re-instated (was run by COGTA) perhaps the NW Office of the Premier can be approached to coordinate/reinstitute this forum again for Spatial and IDP integration.


“The IDP sets the objectives and then it is the responsibility of the SDF to deliver on the IDP strategies. The third generation of IDPs need to be improved drastically”, DRDLR agrees with this statement.

Mpumalanga Consultation 31 August 2010

Should SDFs remain a core component of IDPs or should it be a separate entity? The current role of SDFs should be maintained. The role of SDFs is provided for in the Municipal Systems Act (Section 26). This is contrary to the view that SDFs should be the long term plan of the municipality and the IDPs becomes a yearly implementation plan of SDFs.


How do we make the IDP/SDF link a reality? Project the IDP budget spatially and manage the budget by prioritizing projects. This exercise would assist in the process of


developing SDFs. IDPs provide the five year vision and SDFs remain the implementing instrument. SDFs should inform the IDPs and vice versa. SDFs should also inform LUMS; guiding land use management decisions.

Department of Environmental Affairs National Working Session 22 September 2011

Despite the fact that the development and implementation of the performance management system (PMS) remains a challenge in most rural municipalities, DEA recommends that the PMS of the municipality should be linked the IDP Targets and therefore, the SDF Objectives. This critical comment was dealt with in this draft document. Refer to the key performance areas (KPAs).

The Department of Environmental Affairs made a point that the process of developing an SDF should be in line with the process of developing and reviewing an IDP. Although the guidelines advocate that the SDF presents long term vision (15-20 year) and review every 5 year period, the guidelines also recommend that the development, implementation and monitoring, and revision of the SDF should be carefully coordinated with the IDP cycles.

Capacity and Skills Issues


The categorization of municipalities has been provided for and the new SPLUMB that the department is drafting intends to emphasize the need for Provinces and Districts to support municipalities in need according to the requirements provided for in the Constitution.


Raised a concern in terms of its involvement on the Project Steering Committee (PSC). This concern has been addressed under 1.2.1 (Composition of Steering Committee) of which all government departments are included.

DEA recommended effective use of scarce resources that the IDP steering committee could also act as the SDF steering committee. The DRDRLR highly appreciated this

comment and as such, the comment was affected.



City of Johannesburg, National Working Session 22 September 2010

The City recommended that the document states who should prepare an SDF and experience needed. This comment has been filtered into Draft 8 by stating that an SDF can be developed in-house or by reputable consultants with proven track record.

Urban /Rural Definition


Further clarification was provided in Draft 8 for classification of Urban/ Rural.

Climate Change Marx M Mupariwa (TRP SA), Specialist: Development Planning, SALGA National Office, Ms Maria Coetzee, CSIR Built Environment, Tel 0128412552. Email: [email protected]

The Department supports the notion that local area policy plans and other land use management instruments such as local development frameworks, town planning schemes and zoning schemes can assist in mainstreaming response to climate change. A green ratings evaluating mechanism within the evaluation of SDFs should be developed by the department in the near future.

SDF & LUMS Marx M Mupariwa (TRP SA), Specialist: Development Planning, SALGA National Office, Ms Maria Coetzee, CSIR Built Environment, Tel 0128412552. Email: [email protected]

We acknowledge that there is a large gap between SDFs and LUMs, It is imperative that development applications are promoted where it is seen to be in benefit of the Municipality‟s SDF development trajectories. Municipalities LUMs should be revised in order to accommodate the progressive nature of SDFs.

Vision /Status Quo/Public Participation

Free State Consultation Bloemfontein – 22.09.10 Trompsburg – 23.09.10 Welkom - 11.11.10 Kroonstad – 17.11.10 Clarens – 26.11.10

A required status quo analysis before a vision is developed is not necessary as there is an existing status quo which has been summarized in the municipality‟s IDP. The SDF consultation process should occur within the IDP consultation process in order to ensure that the SDF is aligned to the IDP. This does not preclude prior engagement between the SDF drafters and IDP drafters to ensure alignment of the municipal vision before the public consultation. Further analysis would be required to achieve





the desired vision. The is a danger of the vision being nothing more than reaction to status quo if this is prepared first – see the Google approach – company strategists work out where they want to or should be in 5 years time and then work towards it rather than starting from where they are now.


Disagree re sequence of analysis and visioning, a strategic approach required to direct analysis to safe costs, avoid duplication, rational comprehensive overkill and respond more directly to community issues and to achieve policy requirements.

National Department Environmental Affairs, National Working Session 22 September 2010

DEA recommends that public participation processes should not be duplicated since human and financial resources at municipal level is always limited. This recommendation was appreciated by DRDLR and the guidelines propose that participation could be integrated with IDP forum meetings in order to save resources.

Moreover, Environmental Affairs Department advocate that the guidelines should highlight the need for public participation to accommodate the local languages of the area, and that service providers should conduct meetings in the relevant language and provide summarized documentation in local languages. This comment was acknowledged by DRDLR and addressed in the draft document. Refer to 2.3.3 (Public Meetings).


“Municipalities must not over consult; there must be a clear balance all the time between consultation and implementation”. Noted.

It is important to conduct public awareness campaigns to make the public aware of the growth and developments of the municipality. This notion is very much supported.

“Municipalities must not be apologetic to their service providers the documents must clearly state the vision and


mission of government and policies”. This cannot be reiterated enough.

Political Support


„Political and sector involvement is very important in the early stages‟; DRDLR agrees with this statement as is championed in Phase One of the SDF Guidelines


“Political champions need to be on board and should have the same understanding as planners”. The Department agrees, it is important not to detract from the vision and goal of the SDF.

Implementation Limpopo: The Provincial Planning and Development Forum (PDPF) and the South African Planning Institute.

Sector Plans should also be seen as tools to facilitate the implementation of the provisions of the SDF; this implies that sector plans should be aligned to the strategic goals of the municipality‟s SDF. Establishment of an SDF review committee should be suggested. The Review Committee will assist in the practical monitoring and implementation of the guidelines. It will determine what needs to be reviewed in the SDF e.g. spending pattern; see section 7.5.

Role of Traditional Leaders

Limpopo: The Provincial Planning and Development Forum (PDPF) and the South African Planning Institute.

The Department agrees that the SDF needs to emphasize that traditional leaders should form part of the process from the beginning so that they own the process and the end product. The consultation with Traditional Leaders would occur during the Phase Two Issues and Vision. “It has been emphasized that they should be encouraged to submit their plans or issues for their settlements to be incorporated into the SDF. This approach stimulated traditional leaders‟ interest in development issues at Thulamela Municipality. Consulting them after the SDF has been finalized or about to be approved will not yield the intended results. They will not comply with the provisions of


such documents. They will continue doing their own things.”

DCOG, National Working Session 22 September 2011

DCOG commended that the guidelines are silent on the role of traditional leaders on SDFs. This issue is imperative and therefore, it was addressed in this draft document.


Traditional authorities should be included in the initial stage of projects and be a part of Project Steering Committees in order to attend scheduled meetings. Land Use Management Schemes should highlight traditionally owned land as much as possible. Traditional leaders need to understand the development process. See 2.3.5

Merafong Local Municipality, National Working Session 22 September 2010

It was suggested that municipalities should consider having

an office for Traditional Leaders. See 2.3.5

Department of Energy, National Working Session 22 September 2010

Department of Energy suggested the involvement of traditional leaders from the beginning of the planning process. This comment is being sufficiently addressed in these guidelines.

Mpumalanga Toolkit

Limpopo: The Provincial Planning and Development Forum (PDPF) and the South African Planning Institute.

Fig.1.2 has been incorporated into the guidelines. It suggests that the SDF should not do its own comprehensive analysis but build on IDP analysis by spatially interpreting the IDP analysis. It also suggests a Capital Investment Framework and gives effect to the Spatial Development Concept which ultimately influences the operational plans of sector departments. It promotes the same aspects as the National SDF Guidelines that is why the Toolkit flow chart has been included in the Guidelines.

Simplified SDFs Northern Cape Consultation - 5 & 7 October 2010

A simplified SDF/IDP in the form of a Gantt chart will be developed to assist under-capacitated municipalities; this will also assist SDFs/IDPs to become more user-friendly.


“How do SDFs produce exciting projects- muni‟s are having public participation fatigue, IDPs, HSPs SDFs BESP- muni‟s are under pressure to get through the PP process,


implement what happens in SDFs. Look at a smaller streamlined SDFs which get reviewed yearly and 5 yrs” The Department agrees with this statement.

National Department of Environmental Affairs

The draft document satisfactorily responded to the comment regarding Characteristics of Credible SDF by the Department of Environmental Affairs.

Legislation KwaZulu-Natal Spatial Planning and Information Office

National Environmental Management Act was incorporated into Draft 8.


Agricultural Land Act 70 of 70 Table 1.1


“Include the MFMA in order to get political buy in” See Table 1.1

National/Province/Local & Investment


“SDF must be aligned with provincial and national policies and provide a clear signal to what is desired for private sector at the same time it should empower local authority to make decisions especially decisions on LUMS”, the Department supports this notion.

Merafong Local Municipality, National Working Session 22 September 2010

The municipality is concerned about the involvement of private sector in developing an SDF. The SDF is not a tool to attract government investments only but, also private sector investments are encouraged and harnessed through SDFs. DRDLR shares the same sentiment.

Implementation KwaZulu-Natal Consultation 18 November 2010

“SDFs need a Capital Investment Framework”; it is agreed however the existing IDP CIF should be used and modified if necessary.

Timmy Shilenge Director SPI Limpopo “Strategies, policies and guidelines should be part of the implementation plan. Detailed Sector plans and land use schemes should be developed to implement the SDF. The implementation plan should indicate when, what and who will develop the plans. The resources component for the


respective plans. Existing ones should be revised to advance the interest of the SDF.” The Department has accepted your inputs.

Monitoring and Evaluation of SDFs


The Department welcomes the task of monitoring and evaluating SDFs.


„Key Performance Indicators and setting priorities can be used to measure the growth as a result of SDF;‟ the Department supports this notion.


„A miniature SDF is required, looking at what has changed –“, This could be piloted by the DRDLR SDF Evaluations unit.


Lack of processes in monitoring and evaluation because of neglect therefore as a result problems are detected very late in the process because of the lack of monitoring and evaluation. DRDLR shares the same sentiment and cannot be emphasized enough.

Review of SDFs Northern Cape Consultation - 5 & 7 October 2010

“An SDF should be reviewed when there is a need or when there have been some changes in the spatial condition”. The Department agrees with this statement. The review of SDFs should occur every five years and should be reviewed yearly to accommodate only small changes determined by changes in the IDP. However, these changes should not affect the long term 20 year vision for the municipality.


Rigorous amendment procedures of the SDF should be followed. The SDF should be signed off at the Premier‟s level in order to ensure the enforcement of the first principles promoting sustainable development.

Symbology and Mapping


The symbols for mapping have to be accompanied by attribute data and the RGB numbers in order for the correct interpretation of black and white documents.

DCOG, National Working Session 22 DCOG recommended that norms and standards on spatial


September 2011 forms (symbols) needs to be specified i.e. GIS, Technical Platform, and that it will be useful not to use examples only from Western Cape. Noted.

Capacity Northern Cape Consultation - 5 & 7 October 2010

‘How do we address issues of internal capacity, project

management and the lack of resources within municipalities to set aligned frameworks in guiding municipalities in developing credible SDF‟s, without compromising the needs to future generations? SDF‟s, IDP‟s, LED‟s don‟t reflect integrated planning and ignore the natural resources prevalent in municipalities, given their competitive and comparative advantages, less the lack of budgeting by municipalities and public participation policies;‟ The Department is undertaking a capacity building exercise to assist municipalities to develop SDFs by the use of the guidelines simultaneously addressing the issue regarding the skills shortage; it is a priority to tackle the issues mentioned above.


The Department is undertaking a capacity building exercise to assist municipalities to develop SDFs by the use of the guidelines simultaneously addressing the issue regarding the skills shortage. It‟s important that service providers transfer their skills and information (GIS data etc.) to ensure that GIS becomes a feature in all municipalities.

Spatial Planning Categories


Noted on page 67- Spatial Planning Categories are different in the Western Cape.

DATA Gareth Evans and Perm Mdingi from ECSECC,

The Department is also developing the SDF Technical Platform which is a digital medium to ensure the accessibility of data.


SAPI: “SDFs are not taken seriously: data is outdated; data needs to be updated in order to plan; SDFs need to be seen as important as IHSPs”. The Department agrees that authenticity of data constitutes a credible SDF.



“State minimum data levels” The minimum data requirements are obtained from the following sources:

Socio-economic – SSA, up to 2007 community survey housing from HSP, infrastructure from SIPs, transport from Provincial Transport Departments

Econ – provincial economists latest SSA data available =- clearly sourced

Spatial – ENPAT – what may be available from any EMPs, EIAs, SEAs

Natal Parks Board

City of Johannesburg, National Working Session 22 September 2010

CoJ recommended that the document distinguishes aspects to be mapped through GIS. This commentary was addressed. Therefore, Table 3.1 (Themes to be Covered in the Spatial Analysis) was developed.

Sign Off of SDF Mpumalanga Consultation 31 August 2010

SDFs should be signed off by the Premier on recommendation of MEC

Importance of SDFs


The importance of SDFs should be enforced in legislation. Enforce rights in courts to ensure that no corruption persists. The department had an engagement with COGTA that after the project has been finished; we would have to look at whether there is a need to amend legislation to make sure that SDFs are taken seriously.

Ekurhuleni, National Working Session 22 September 2010

Ekurhuleni commented that the guidelines would be of assistance and need to specify on the introduction why the department came up with these guidelines and who is it aimed at. The draft document addresses the comment by stating the reasons why DRDLR identified a need for the guidelines and the guidelines aimed at assisting municipalities.


National Department Environmental Affairs, National Working Session 22 September 2010

The department emphasized the importance of an SDF that the ultimate goal of the SDF is to achieve the desired spatial form of the municipality, which is based on the vision for the development of the municipality as indicated in the municipal IDP.

Categories of SDFs


The Department agrees that different SDFs for different areas are needed because municipalities have different contextual attributes, resources and capacity. The view that a District/Regional SDF will be sufficient curtails the notion for differentiated SDFs. If an SDF was left at a District Level, a substantial amount of interpretation would be required to bridge the gap between the District and Local level. Municipalities would require further guidelines for planning at a local level.

Ekurhuleni, National Working Session 22 September 2010

Ekurhuleni hoped that the guidelines are not to aid the process of drafting of a National SDF only but guidelines for all (provincial, district and local municipal) SDF‟s. The city further stated a need to also differentiate between Provincial, National and Local SDFs. The role of Province should be acknowledged. Thus, the draft document does not differentiate between the national, provincial and local SDFs at this juncture. Currently, the DRDLR is busy drafting terms of reference to appoint regarding differentiation of the National, Provincial and Local SDFs.

General Gareth Evans and Perm Mdingi from ECSECC,

In acknowledgement of the receipt of comments from Gareth Evans and Perm Mdingi from ECSECC, the Departments (DRDLR) objective on our visit to the Eastern Cape was to host a workshop our, intention was not to merely present what was believed to be the final SDF guidelines. The failure of the day may be the manner in which the agenda was formulated and the short time in which to conduct the proceedings due to technical difficulties. It is acknowledged that more research should have been undertaken to


incorporate the research and findings from the EC PSDP. The Department acknowledges the work and amount of effort that went into developing the EC PSDP and encourages the use of the Plan and website.

Tony Williams from ECLGTA “COGTA should be the ones running the project and where are the representatives from COGTA and SALGA?” DCOG has been involved in the process and SALGA have participated immensely in the formulation of the National SDF Guidelines. Further collaboration with the two departments will occur during the capacitation process. Preparatory meetings have already taken place.


DRDLR would appreciate the receipt of the findings from the research process on distinguishing between the SDF requirements for different types of municipalities.

North West Consultation, 30 November 2010

The phases within the guidelines have well defined time frames.

Erna van Zyl Comments from Erna van Zyl are noted and have been incorporated into the guidelines where applicable


Comments 1-7 regarding name change have been partially amended in the draft. Department of Agriculture hasn‟t changed into Department of Agriculture, Forestry and Fisheries (see Page 63/48, Page 86/71). Provincial office hasn‟t been amended into Office of the Premier (see Page 35). Similarly, the Housing Development Agency has not been added.


Comment (regarding the existing and future spatial, economic and housing development, other development initiatives and Spatial Development Initiatives, and Summary of development strategies) was addressed in Draft 8.



No links were established in the draft in terms of the following key principles of the Western Cape Provincial Transport Policy (White Paper). Assess and show the distributional effects of transport

programmes Indicate where the productive potential in the transport

sector can be improved or increased. Indicate broadly the areas – from a transport

perspective – where the most strategic use of resources can be achieved.

Comment around the principles to guide the development of ITP have and therefore as guiding principles for SDF‟s has been effected.

Comment regarding the roles and responsibilities of various government departments has been filtered in Annexure 2.

Mpumalanga Workshops 08 & 17 November 2010

SDF Guidelines were well received and further comments were submitted to the Department.

Jackie Nel (Senior Policy Specialist Department of Water Affairs)

Jackie Nel mentions underpinning the guideline with flow-chart detailing the different phases and then referencing where an individual can read more about the specific step was incorporated into the Guidelines.

KwaZulu-Natal Spatial Planning and Information Office

Time-frames of each phase where taken into consideration included (Page ii).

The contribution about having a box on the end of each section that will point out the crucial information (technical notes) was incorporated in Draft 8 SDF Guidelines.

The inclusion of CRDP in the list of sectoral plans was incorporated into the Guidelines

The following requests have been incorporated into the guidelines - Fig 4.6-spatial vision/idea should be indicated on 1 diagram because this will force the need to be strategic. The idea is to try and restrict what can be depicted so as to avoid over


complication -Spatial planning categories: clarify valuable and non-valuable agric land- Valuable agricultural Land is land suitable for crop production as defined by the Department Agriculture Forestry and Fisheries (see DAFF for further defifnitions) -Fig 4.9 – clarified the meaning of population >5000 -Mention Urban sprawl in sect 4.6 (f) -Environmental sinks include “closure, reuse and management of landfill” -Section 4.8.2 LUMs should align to SDFs - Section 4.7.2add “water usage, integrated infrastructure, promotion of LED, subsidized housing and industry to list. Section 4.7 Strategies instead of policies


The same department requested the spelling of waste water treatments to be corrected, and this comment was addressed throughout the draft document.

PLEASE READ THIS DOCUMENT IN ORDER TO ASCERTAIN WHETHER YOUR COMMENTS HAVE BEEN ADDRESSED; WHILE AT THE

SAME TIME IT IS RECOMMENDED THAT THE REVISED SDF GUIDELINES DRAFT 8 BE PERUSED.

RESPONSE TO SDF GUIDELINES COMMENTS 2010/2011 THE …€¦ · department of rural development and...

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