On 29 June 2017, the municipal council of the City of Johannesburg (the City) approved the City of Johannesburg Draft Land Use Scheme, 2017. The land use scheme intends to give effect to section 24(1) of the Spatial Planning and Land Use Management Act 16 of 2013 (SPLUMA) by replacing the 16 prevailing town planning schemes with a single consolidated land use scheme, which will apply to the entire municipal area. In City published the land use scheme in August 2017 and invited interested parties to submit comments. SERI submitted written comments on 13 October 2017.
SERI's submission raises a number of concerns about the land use scheme and makes various recommendations on how the council can amend or rectify these concerns. In particular, SERI is concerned that the scheme criminalises unauthorised land uses, fails to give the users and occupiers of land sufficient standing, and fails to make progressive use of special zones and the incremental introduction of land use management to address the challenges posed by informal settlements.