SCHULPHOEK UISP INFORMAL SETTLEMENT DEVELOPMENT – URGENT: PUBLIC COMMENT NEEDED

CRITICAL UPDATE: ONGOING ENVIRONMENTAL CRISIS

THE REAL EMERGENCY: COASTAL ENVIRONMENTAL DESTRUCTION HAPPENING NOW

While we wait for this “mixed use development” to materialise (completion not until 2027+), ONGOING ILLEGAL INVASION AND ENVIRONMENTAL DESTRUCTION continues unchecked in Schulphoek – and is now spreading into Sandbaai’s neighbouring coastal strip.

KEY QUESTIONS THAT DEMAND ANSWERS:

1. WHY has this illegal invasion and destruction been allowed/indulged for years?
2. WHO is responsible for stopping it?
3. WHAT measures will prevent further invasion during the multi-year construction phase?
4. WHERE will 3,500+ households be temporarily housed (“decanted”) during construction?

What’s Happening?

The Overstrand Municipality appointed an Implementing Agent, ASLA Construction (PTY) LTD, in 2023, to formalise and develop the Schulphoek Informal Settlement (incorrectly referred to as ‘Dubai’) in Zwelihle, Hermanus. This massive development, known as an Upgrading of Informal Settlement Programme (UISP), will affect approximately 54 hectares of coastal land and will entail construction of ‘mixed use’ type formal housing, community and business facilities, a road network, and provision of water, electricity, and sewerage services for around 
3,500+ households.

The current Scoping Report was drafted (for public comment) by Guillaume Nel Environmental Consultants (GNEC), as independent environmental consultants and impact assessors, to facilitate the Integrated Environmental Management (IEM) process in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) and the Environmental Impact Assessment (EIA) Regulations, 2014 for the Formalisation of the Schulphoek Informal Settlement on Erf 11155 and a Portion of the Remainder of Erf 11153.

🔥 CRITICAL CONCERNS INADEQUATE/MISSING FROM THE SCOPING REPORT🔥

1. ONGOING INVASION & ENVIRONMENTAL DESTRUCTION

The Elephant in the Room:

• Illegal invasion of Schulphoek began in 2018 and has never stopped
• 25 hectares of protected Milkwood forest has already been destroyed
• Settlement continues to expand while we wait for formal development
• NO MANAGEMENT PLAN exists to prevent further destruction during the years-long planning and construction phases

Environmental destruction is NOW spreading to:

• Sandbaai coastal strip (west of Schulphoek)
• Hermanus Beach Club area (east of Schulphoek)
• Protected coastal fynbos vegetation, wildlife, and dune systems

DEMAND IN YOUR COMMENT:

“Provide a comprehensive Invasion Prevention & Environmental Protection Management Plan detailing:

• Who monitors and prevents further illegal settlement during construction?
• What enforcement measures will be implemented immediately?
• How will neighbouring Sandbaai and Beach Club coastal strips be protected?
• What legal consequences exist for continued invasion?
• This plan must be approved BEFORE any development authorisation.”

2. THE “DECANTING” CRISIS – WHERE WILL RESIDENTS GO?

During multi-year construction, 3,500+ households must be temporarily relocated (“decanted”). Where will they go? Where will temporary relocation accommodation facilities(TRA) be located?

THE SCOPING REPORT IS SILENT ON THIS CRITICAL ISSUE

Our primary concern: Residents will be “decanted” into Sandbaai, causing:

• Same illegal land invasion as Schulphoek experienced
• Further destruction of Sandbaai’s remaining coastal flora and fauna
• Overload of Sandbaai’s already struggling municipal services
• Permanent informal settlement in a new location

DEMAND IN YOUR COMMENT:

“The Scoping Report fails to address temporary resident relocation during construction. I OBJECT STRENUOUSLY to:

• Use of any portion of Sandbaai as a ‘decanting’ location
• Any temporary relocation that impacts neighbouring coastal areas
• Proceeding without a detailed, publicly reviewed Temporary Relocation Plan

REQUIRE: Full disclosure of temporary housing locations and site preparation plans BEFORE development approval. Sandbaai and Beach Club coastal areas must be explicitly excluded as temporary relocation options.”

3. MUNICIPAL SERVICES CRISIS

Reality Check: Overstrand Municipality already fails to adequately provide services to existing ratepaying Sandbaai residents:

• Sewerage system problems
• Electricity outages
• Water supply issues
• Stormwater drainage

Yet this development proposes adding:

• 3,500+ households
• 1,762 additional vehicles
• Business/commercial zones
• Schools and community facilities

DEMAND IN YOUR COMMENT:

“I object to development approval until OM demonstrates:

• Current service provision to Sandbaai is stabilised and adequate
• Documented proof of capacity for 3,500+ additional households
• Infrastructure upgrades completed BEFORE Schulphoek construction begins
• Independent audit of water, sewerage, and electrical capacity

The Municipality cannot approve new mega-developments while failing to service existing ratepaying communities.”

4. SCHULPHOEK ROAD EXTENSION – THE BIGGEST ENVIRONMENTAL THREAT

MAJOR CONCERNS THE REPORT IGNORES:

Current Schulphoek Road Reality:

• Already experiences unmanageable degradation
• Severe environmental destruction along route
• Heavy pollution impacting surrounding areas

Proposed Schulphoek Road Extension And Connection Will:

• Create a throughway connecting Zwelihle/Schulphoek to Sandbaai’s economic/industrial hubs
• Massively increase traffic through sensitive coastal area
• Runs through/along SENSITIVE COASTAL ZONE (NEM-ICMA protected area) and a wetland
• Destroys remaining protected Milkwood forest (NOTE: Legal protection: Milkwood trees are listed as a protected species under the National Forests Act No. 84 of 1998)
• Create visual, aesthetic, noise and pollution for Sandbaai ratepayers

THE SCOPING REPORT INEXPLICABLY OMITS:

• That the proposed road route traverses Coastal Protection Zones under NEM:ICMA
• Impact assessment of increased through-traffic on Sandbaai
• Consideration of alternative routes through Zwelihle, that would NOT traverse the Coastal Protection Zone

OBVIOUS ALTERNATIVE ROUTES: 

Why can’t the Schulphoek Road extension run UPWARD along the Sewerage Plant wall into Zwelihle?

Why can’t the Schulphoek Road extension run via Landa, Hlobo, and Sisulu streets?

• Avoids sensitive Coastal Protection Zone
• Preserves Milkwood forest
• Reduces visual/noise/pollution impact on Sandbaai ratepayers
• Uses already-disturbed industrial corridor

DEMAND IN YOUR COMMENT:

“I OBJECT to the proposed Schulphoek Road Extension route as currently mapped.

CRITICAL OMISSIONS:

1. The Scoping Report FAILS to disclose that the proposed route traverses sensitive Coastal Protection Zones protected under NEM:ICMA ss 16& 17 (National Environmental Management: Integrated Coastal Management Act 2008).
2. No assessment of cumulative traffic impact on Sandbaai as a throughway to industrial/economic hubs.
3. No consideration of alternative routes that avoid coastal destruction and disturbance to residential areas of Sandbaai.

REQUIRED CHANGES:

• Route the Schulphoek road extension UPWARD along the Sewerage Plant wall into Zwelihle
  OR
• Plan the connecting route to Schulphoek road run through Landa, Hlobo, and Sisulu streets
• These alternatives avoid sensitive legally protected coastal areas, preserves protected Milkwood forest, reduces visual/noise/pollution impacts on Sandbaai ratepayers, and uses already-disturbed industrial corridors

DEMAND:

• Full NEM-ICMA Coastal Protection Zone compliance assessment
• Comparative analysis of alternative routes with public participation
• Traffic impact study specifically addressing Sandbaai throughway effects
• Revised layout showing alternative road alignment

The current road placement is environmentally destructive, legally questionable, and socially unjust to Sandbaai ratepayers.”

Why Should You Care?

ENVIRONMENTAL CONCERNS:

1. Wetlands at Risk: The development will destroy portions of wetlands identified on site
2. Endangered Vegetation: Over 20 hectares of endangered Overberg Dune Strandveld and Southern Milkwood Forest will be cleared
3. Coastal Damage: Development extends within 100 meters of the high water mark 
   (Coastal Protection Zone – NEM-ICMA ss 16)
4. Archaeological Site Threatened: SKP 3 (Later Stone Age camp) rated “High” heritage significance
5. No Alternative Considered: “No-go” alternative dismissed
6. ONGOING DESTRUCTION: No plan to stop current illegal expansion during construction years

SOCIAL & INFRASTRUCTURE CONCERNS:

• No “Decanting” Plan: Where will 3,500 households go during construction?
• Sandbaai at Risk: Potential for displacement spillover into neighbouring communities
• Service Capacity Crisis: OM already fails to adequately service existing neighbouring communities such as Sandbaai
• Traffic Nightmare: 1,762+ additional vehicles on already degraded roads
• Schulphoek Road Extension: Threatens sensitive Coastal Protection Zone, Milkwood forest, and neighbouring Sandbaai quality of life

COMMENT DEADLINE: 8 JANUARY 2026

⚠️ IMPORTANT CLOSURE NOTICE:

DEADP is CLOSED: 15 December 2025 – 5 January 2026

Comments submitted during closure WILL NOT BE RECOGNISED. You MUST RESUBMIT after 6 January 2026 if you comment during closure.

Effective commenting windows:

• ✅ 14 November – 14 December 2025
• ❌ 15 December – 5 January: CLOSED for holiday season
• ✅ 6 January – 8 January 2026

COMPREHENSIVE COMMENT TEMPLATE

Below is an example of a complete commentary letter. Please use your own words and edit to address your concerns and comments.

Subject: COMMENTS - Schulphoek UISP 1st Draft Scoping Report 
(DEA&DP Ref: 16/3/3/6/7/2/E2/15/1285/25)

Dear Mrs Visagie,

I am registering as an Interested and Affected Party to submit the following COMMENTS and OBJECTIONS regarding the proposed Schulphoek development EIA Scoping document:

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1. ONGOING ILLEGAL INVASION & ENVIRONMENTAL DESTRUCTION

The Scoping Report fails to address the CURRENT environmental crisis:
- Illegal invasion began in 2018 and continues unchecked
- 25+ hectares of protected Milkwood forest already destroyed
- Environmental destruction NOW spreading to neighbouring Sandbaai coastal strip and Beach Club areas
- Multi-year planning, development, and construction phases will enable further illegal expansion

I DEMAND:
✓ Comprehensive Human Invasion Prevention & Environmental Protection Management Plan BEFORE any approval
✓ Identification of responsible parties for enforcement during planning, development, and construction phases
✓ Legal consequences for continued invasion
✓ Explicit protection measures for neighbouring Sandbaai and Beach Club coastal areas
✓ Monthly monitoring reports made public

WHO will stop the ongoing destruction? WHEN? HOW?

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2. TEMPORARY RESIDENT RELOCATION ("DECANTING") - CRITICAL OMISSION

The Scoping Report is SILENT on where 3,500+ households will be housed during multi-year phased development and construction.

I OBJECT STRENUOUSLY to:
✗ Use of Sandbaai as a temporary relocation ("decanting") site
✗ Any temporary relocation impacting neighbouring coastal areas
✗ Proceeding without a detailed, publicly reviewed Temporary Relocation Plan

I REQUIRE:
✓ Full disclosure of proposed temporary housing locations
✓ Site preparation and impact assessment for ALL temporary locations
✓ Explicit exclusion of Sandbaai and Beach Club coastal areas as temporary relocation options
✓ Public participation process specifically for temporary relocation plan
✓ This information BEFORE development authorisation

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3. MUNICIPAL SERVICES CAPACITY CRISIS

Overstrand Municipality currently FAILS to adequately service existing Sandbaai ratepayers:
- Sewerage system problems
- Electricity outages  
- Water supply issues
- Stormwater management

Yet this development proposes adding 3,500+ households.

I OBJECT until OM demonstrates:
✓ Current service provision to Sandbaai is stabilised and adequate
✓ Documented proof of capacity for 3,500+ additional households
✓ Infrastructure upgrades for municipal services COMPLETED before Schulphoek construction begins
✓ Independent audit of water, sewerage, and electrical capacity
✓ Financial plan showing how improvements will be funded without degrading existing services

The Municipality cannot approve mega-developments while failing existing ratepaying communities.

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4. SCHULPHOEK ROAD EXTENSION THROUGH COASTAL PROTECTION ZONE- MAJOR OBJECTION

CRITICAL OMISSIONS IN SCOPING REPORT:

A) NEM:ICMA COASTAL PROTECTION ZONE VIOLATION
The proposed road route runs through/along SENSITIVE COASTAL PROTECTION ZONES protected under the National Environmental Management: Integrated Coastal Management Act ss 16&17(NEM:ICMA).

THE SCOPING REPORT FAILS TO DISCLOSE THIS.

B) ENVIRONMENTAL DESTRUCTION
Current Schulphoek Road already experiences:
- Unmanageable degradation
- Severe environmental destruction
- Heavy pollution of surrounding spaces (including Sandbaai)

The extension will:
✗ Destroy remaining protected Milkwood forest
✗ Create increased throughway traffic to Sandbaai economic/industrial hubs
✗ Generate visual, aesthetic, and noise pollution for Sandbaai ratepayers
✗ Violate Coastal Protection Zone requirements

C) OBVIOUS ALTERNATIVE IGNORED
WHY can't the Schulphoek Road extension run UPWARD along the Sewerage Plant wall into Zwelihle?
WHY can the Connecting route to Schulphoek Road not run through Zwelihle via Landa- or Hlobo- and Sisulu Streets?

These alternatives:
✓ Avoids sensitive Coastal Protection Zones
✓ Preserves protected Milkwood forest
✓ Eliminates visual/noise/pollution impacts on Sandbaai ratepayers
✓ Uses already-disturbed industrial corridor
✓ Comply with NEM:ICMA requirements

I REQUEST:
✓ Full NEM:ICMA coastal zone compliance assessment
✓ Comparative analysis of alternative routes with PUBLIC maps
✓ Traffic impact study addressing Sandbaai throughway effects
✓ Revised layout showing alternative road alignment along Sewerage Plant, or entirely through Zwelihle
✓ Public meeting to discuss road alternatives

The current Schulphoek Road Extension placement is environmentally destructive, legally questionable under NEM:ICMA, and socially unjust to Sandbaai ratepayers.

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5. WETLAND DESTRUCTION

I OBJECT to development within wetland areas. The report admits wetlands will be altered, but these provide critical flood protection and water filtration.

Alternative layouts avoiding wetlands entirely must be explored.

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6. HERITAGE PROTECTION INADEQUATE

The SKP 3 archaeological site (High significance - Grade 3A) requires MORE than a 10m buffer.

I REQUIRE:
✓ Minimum 50m buffer around SKP 3
✓ Independent archaeological monitoring during ALL earthworks
✓ Heritage Management Plan with community consultation

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7. COASTAL RISKS UNDERESTIMATED

Development within the coastal protection zone poses long-term risks from sea-level rise and storm surge.

I REQUIRE:
✓ Coastal hazard assessment for 50-year and 100-year scenarios
✓ Increased setbacks beyond minimum 100m from high-water mark (NEM-ICMA)
✓ Prohibition of hard coastal engineering (retaining walls, sea walls)

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8. CONSTRUCTION IMPACTS ON CURRENT RESIDENTS

Residents living on-site during multi-year construction need GUARANTEES for:
✓ Temporary water, sanitation, and waste services
✓ Health and safety protection from dust, noise, pollution
✓ Housing security during phased relocation
✓ Compensation for disruption
✓ Regular community updates in isiXhosa

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PROCEDURAL REQUIREMENTS:

I request that the full EIA report:
✓ Addresses ALL concerns raised above with quantified mitigation
✓ Includes public meetings in Schulphoek (with isiXhosa translation) and in directly impacted, neighbouring Sandbaai.
✓ Provides extended comment period (minimum 60 days) for next draft
✓ Undergoes independent review of all specialist reports
✓ Includes visual simulations of proposed road extension alternatives
✓ Publishes detailed phasing plan showing resident relocation logistics

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SUMMARY OF REQUESTS:

BEFORE any development authorisation, the following MUST be provided:

1. Invasion Prevention & Environmental Protection Management Plan
2. Temporary Resident Relocation Plan (explicitly excluding Sandbaai/Beach Club)
3. Municipal Services Capacity Proof & Upgrade Timeline
4. Schulphoek Road Extension Alternative Routes Analysis (including NEM:ICMA compliance)
5. Revised layout avoiding ALL wetlands
6. Enhanced heritage protection measures
7. Comprehensive coastal hazard assessment
8. Construction-phase resident protection guarantees

Without these, this development should NOT be authorised.

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My contact details:
Name: [Your Full Name]
Address: [Your Full Address]
Phone: [Your Phone]
Email: [Your Email]

I request written responses to ALL concerns raised and notification of all future public participation opportunities.

Sincerely,
[Your Name]
[Date]

Key Points to Emphasise:

FOR SANDBAAI RESIDENTS:

1. “Decanting” into Sandbaai = Repeat of Schulphoek destruction
2. Schulphoek Road Extension threatens coastal zone, Milkwood forest, and quality of life
3. Already inadequate municipal services will be further strained
4. Ongoing invasion and environmental destruction already spreading to neighbouring Sandbaai coastal strip

FOR ALL RESIDENTS:

1. No plan to stop CURRENT illegal expansion during years-long construction
2. Scoping Report conceals NEM:ICMA coastal zone violations
3. Alternative road routes ignored without justification
4. 3,500 households have no disclosed temporary housing plan

FOR ENVIRONMENTAL ADVOCATES:

1. Wetland destruction admitted but not avoided
2. Protected Milkwood forest sacrificed for road placement
3. Coastal Protection Zone ignored
4. High-significance archaeological site under-protected

Why Your Comment Matters:

• NEMA requires public participation – all comments become part of official record
• The Department must respond to all concerns raised
• Volume matters: More comments = more pressure
• Comments can trigger additional studies, alternatives analysis, revised layouts
• Legal leverage: Inadequate response to substantive comments can form basis for appeal

Reality Check:

The GNEC Response We Expect:

GNEC will likely deflect invasion control concerns back to ASLA and Overstrand Municipality, claiming it’s outside their scope.

Our Counter-Strategy:

Make it GNEC’s problem by linking it to NEMA requirements:

“Under NEMA principles, cumulative impacts and ‘no-go’ alternatives must be assessed. Ongoing illegal invasion during multi-year planning, development, and construction constitutes a CUMULATIVE IMPACT that fundamentally alters the baseline conditions upon which this Scoping Report was prepared.

Therefore, an Invasion Prevention Management Plan is not ‘outside scope’ – it is ESSENTIAL to ensuring the validity of the environmental assessment itself. Without it, the baseline will have changed by the time the construction phase begins, rendering all specialist studies obsolete.

GNEC cannot claim independence while ignoring a variable that directly affects ecological, heritage, and social impact predictions.”

But the Schulphoek Road Extension route IS within GNEC’s direct control – and we CAN demand changes.

Spread the Word:

Share with:

• All residents of Sandbaai
• Beach Club residents
• Hermanus environmental groups (Hermanus Botanical Society, etc.)
• Walker Bay Nature Reserve stakeholders
• Local community leaders and churches
• Tourism operators (affected by environmental degradation)

Social Media:

• #SchulphoekUISP
• #ProtectSandbaai
• #SchulphoekRoadExtension
• #OverstrandAccountability
• #WalkerBayEnvironment
• #NEM_ICMA_Violation

Questions?

Don’t let GNEC or OM deflect concerns. Every issue raised here is legally relevant to environmental authorisation:

• Invasion control = Cumulative impact assessment (NEMA requirement)
• Decanting location = Social impact assessment (NEMA requirement)
• Services capacity = Infrastructure feasibility (NEMA requirement)
• Road route = Alternatives analysis (NEMA requirement) + NEM:ICMA compliance
• Coastal Protection Zone= NEM:ICMA ss 16&17 legal compliance (non-negotiable)

ACT NOW – PROTECT SANDBAAI, SCHULPHOEK & WALKER BAY

Your comment is not just about this development – it’s about:

• Stopping ongoing environmental destruction
• Protecting Sandbaai from “decanting” spillover
• Forcing alternative road routes that avoid Coastal Protection Zones
• Holding municipalities accountable for service delivery
• Ensuring legal compliance with NEM:ICMA

Together, we can demand better. Register as an Interested and Affected Party (IAP) and Comment within the timeline, with the final deadline being 8 January 2026.