Mbandazayo faces demand to suspend big bay LSDF over nuclear evacuation risks

In a move that underscores wide spread frustration with Cape Town’s unethical urban planning practices, Michelle Collins, the Community Representative for Blaauwberg, has written a formal letter to City Manager Lungelo Mbandazayo.

The letter demands the immediate suspension of the Big Bay / Blaauwberg Local Spatial Development Framework (LSDF) until the City releases and independently reviews the Koeberg Traffic Evacuation Model (TEM).

The model determines how quickly residents could evacuate in the event of a nuclear emergency at the Koeberg Power Station. Collins argues that the City’s refusal to disclose this data poses a grave public safety risk and violates both national legislation and Cape Town’s own Municipal Planning By-Law.

Dear City Manager,

This letter serves as a formal demand under the Municipal Planning By-Law (2015, as amended 2025), SPLUMA, NEMA, and the Disaster Management Act, for the immediate suspension of the Big Bay/ Blaauwberg Local SpatialvDevelopment Framework (LSDF} process until the Koeberg Traffic Evacuation Model (TEM} and all associatedvinputs, assumptions and outputs are disclosed and independently reviewed.

On 1 O November 2025, I submitted a PAIA Form 2 with Addendum (attached} requesting full disclosure of the Koe berg Traffic Evacuation Model (TEM}. This request is made in the public interest under Section 46 of the Promotion of Access to Information Act, 2000, on the grounds that the withheld information directly concerns an imminent and serious public-safety risk within the Koeberg 0-16 km Emergency Planning Zone (EPZ}. The requested records include all TEM datasets, assumptions, outputs, and correspondence with the NNR, Eskom, and relevant ministers.

Item 158 of the Municipal Planning By-Law (2025) (Koeberg Restriction Area Overlay} prohibits the approval of any planning or development within the Urgent Protective Action Zone (UPZ- 5-16 km} unless the City is “satisfied that the disaster-management infrastructure necessary to ensure effective implementation of the approved traffic-evacuation model … is adequate.”

The Big Bay/ Blaauwberg LSDF proposes substantial population increases within this same zone, yet the TEM results have not been disclosed and, by the City’s own statements, the model is not used to limit development.

SPLUMA s 22(2) and LUPA s 19(1 }(a} require that all spatial frameworks comply with applicable legislation – including overlays, disaster-management requirements and environmental safeguards.

Proceeding with an LSDF that pre-approves growth before verifying TEM compliance would therefore be irrational, procedurally unfair and ultra vires under PAJA s 6, NEMA s 2(4}(a}(vii} and the Constitution ss 11 & 24.

Population densities in the South-East sector of the UPZ already reach densities including visitors of five to seven times the international benchmark of ..,200 persons/krn2 for low-population nuclear zones. lnd.ependent analysis indicates that realistic evacuation times exceed the 16-hour UPZ limit even under current conditions. Any additional densification, such as that envisaged on Erf 1117, will further erode evacuation feasibility and Legal compliance.

Accordingly, the City is requested to:

1. Suspend all LSDF processing and approvals within the 0-16 km Koeberg EPZ until the TEM and its results are publicly disclosed and independently reviewed.
2. Publish on the City’s website, within 14 days, the following:
   1. The full TEM methodology, assumptions, datasets and outputs for all sectors; and
   2. Confirmation that current and proposed population levels comply with the statutory 4- and 16-hour evacuation criteria. ·
3. Provide written confirmation that no part of the LSDF or any related rezoning or development proposal will be advanced, tabled or approved until the above disclosures have been made.

Should the City fail to comply, I reserve the right- individually and on behalf of affected residents-to seek urgent judicial relief to compel disclosure and to interdict any approval process conducted in breach of Item 158, PAIA, NEMA, or the Constitution.

Your sincerely,

Michelle Collins
Community Representative for Blaauwberg