17/10/2026
WAPFSA RAISES IMPORTANT QUESTIONS ABOUT THE โURBAN WILDLIFE CENTERโ AT KOGELFONTEIN
The rhetoric that the Simonโs Town baboon troops, specifically the Waterfall and Seaforth troops, offer no ecological or genetic value is heavily disputed by conservation biologists, geneticists, and environmental organizations. Presented by city authorities and their consultant experts as a humane alternative to culling, their latest proposal involves capturing and relocating the Waterfall and Seaforth baboons to a purpose-built enclosure at Kogelfontein. This strategy is facing heavy criticism for prioritising urban expansion and expensive property development over natural habitat preservation.
A WAPFSA member and others have submitted several requests to various government authorities using the Promotion of Access to Information Act regarding the Waterfall and Seaforth baboons, and the construction and permitting of the so called urban wild life centre at Kogelfontein.
While these PAIA processes are underway, WAPFSA continues to welcome, and encourage voluntary transparency in response to our questions listed below:
Important Practical Questions Raised About the Wildlife Centre at Kogelfontein:
1. The original phased Action Plan involving Plateau Road was publicly announced and published by the Cape Peninsula Baboon Management Joint Task Team (CPBMJTT) in November 2025. However, the updated, plan to use the Kogelfontein location in Scarborough was, to the best of our knowledge, bypassed administratively and not formally published for public comment before being adopted in mid-2026.
WAPFSA is therefore requesting the documented plan and robust public participation process undertaken for the enactment of the Revised Finalised Action Plan.
2. The City of Cape Town municipality tender process does not skip standard legal frameworks for a "special project". Instead, municipal procurement must comply with the Municipal Finance Management Act (MFMA) and the City's own Supply Chain Management (SCM) Policy.
When a project is considered complex, high-value, or unique (often what is meant by a "special project"), specific legal deviations, alternative mechanisms, or stricter procurement steps are activated. For complex, innovative, or specialized "special projects" where the municipality cannot initially draft precise technical specifications, the City may use a two-stage bidding system:
Stage 1 (Technical Proposal): Bidders submit purely technical, unpriced proposals detailing their methodology, engineering capabilities, or architectural concepts. The City evaluates these to see who meets the functionality thresholds.
Stage 2 (Financial Offer): Bidders who passed Stage 1 are invited to submit specific commercial pricing and final technical bids based on the refined project specifications.
WAPFSA is requesting confirmation, and the specific details, of the City of Cape Town tender process for the construction of the wildlife centre which has been built at the city owned property at Kogelfontein in Scarborough.
3. Under South African municipal law, specifically Clause 329 of the City of Cape Townโs Supply Chain Management (SCM) Policy and Section 36 of the Municipal Supply Chain Management Regulations, the City Manager has the authority to dispense with official competitive bidding processes under exceptional circumstances.
A standard municipal tender process can take many months to advertise, evaluate, and award. To bypass this for immediate construction, the City would have to invoke a formal SCM deviation based on specific criteria.
The City has consistently, and in our opinion, erroneously argued that the intensifying human-baboon conflict in the Southern Peninsula, specifically involving the Waterfall and Seaforth troops, presents an urgent risk to both public safety and animal welfare. If the situation were officially classified as an emergency or an immediate ecological crisis, a deviation would allow the direct appointment of contractors.
4. WAPFSA notes with concern that PAIA records have revealed that as of late September 2026, CapeNature had not yet finalized or completed the official permit applications required for the project, leading critics to question how R10 million in municipal funds could be deployed ahead of final legal approvals.
WAPFSA is therefore requesting full transparency regarding the motivation for entire project, based at Kogelfontein including the regulatory authorization chain.
5. Perhaps the City of Cape Town has diverted funding for the construction of this wildlife centre, sanctuary or zoo by allocating grant funding, or additional grant funding, in terms of their MoA with Shark Spotters, for the roll-out for infrastructure to establish hard boundaries between natural areas and the urban environment.
WAPFSA is requesting confirmation and all details of the grant funding by the City of Cape Town to Shark Spotters since the formalisation of their MoA.
6. The City of Cape Town strictly requires Non-Profit Organisations (NPOs) to submit financial records to receive or maintain funding. Under South African municipal regulations and the City's own Grants-in-Aid Policy, the exact financial documentation required depends entirely on the size of the grant.
WAPFSA is requesting confirmation all details, the financial documents, audited and otherwise of Shark Spotters as presented to the City of Cape Town since the formalisation of the MoA.
7. Is there a legal requirement to carry out an Environmental Impact Assessment (EIA) before a zoo or sanctuary for wild animals can be built in Scarborough in the Western Cape? To the best of our knowledge, under South Africaโs National Environmental Management Act (NEMA), undertaking specific "listed activities" without prior Environmental Authorisation could be problematic.
WAPFSA is requesting a response to this important question and the details of the EIA from the City of Cape Town and CapeNature to include the following:
7.1 Scarborough directly borders the Table Mountain National Park, which is a proclaimed protected area. Under NEMA's Listing Notice 3, any development, infrastructure construction, or clearance of indigenous vegetation within a protected area or its immediate buffer zone automatically triggers a mandatory Basic Assessment EIA process.
7.2 Establishing a zoo or sanctuary requires converting natural coastal fynbos or open space into an intensive facility. Developing infrastructure to concentrate, feed, or confine wild animals commercially often triggers Listing Notice 1 thresholds.
8. To the best of knowledge, and information, the land in Scarborough upon which the wildlife zoo or sanctuary has been constructed must be correctly zoned and requires a formal land-use application in addition, under South African law, you must appoint a registered Environmental Assessment Practitioner (EAP) certified by the Environmental Assessment Practitioners Association of South Africa (EAPASA). Only a registered EAP can legally prepare, investigate, or submit official environmental documents.
WAPFSA is requesting all the relevant EIA documents from the Western Cape Department of Environmental Affairs and Development Planning (DEA&DP).
9. A Wild Animal Captivity Permit is required from CapeNature under the Nature Conservation Ordinance to legally hold captive any wild or exotic animals in captivity.
WAPFSA is requesting a copy of the inspection report from CapeNature of suitability of the property prior to the commencement of construction, as well as a copy of the signed plans by CapeNature prior to commencement of the R10 million structure.
10. The practical ex*****on involves removing the animals from their free-ranging habitat and moving them into long-term captive confinement. The Cape Baboon Partnership is tasked with whole-troop trapping. The Seaforth troop 16 baboons and the Waterfall troop 42 baboons will allegedly be systematically captured.
WAPFSA is requesting a copy of the approved plan signed off by the NSPCA and a copy of the necessary permits from CapeNature. In addition WAPFSA has requested copies of the process whereby these experts have been appointed, and the costs involved.
11. The primary vegetation type in Scarborough is Peninsula Sandstone Fynbos. Fynbos grows in highly nutrient-poor, acidic soils. While wild chacma baboons are highly adapted to eating specific parts of it such as restio seeds, bulbs, and proteas, this vegetation is filled with tannins and heavy "do not eat me" chemical defences. In a natural state, a troop requires massive, open home ranges to wander miles daily just to harvest enough calories.
WAPFSA is requesting a copy of the professional report by an independent primatologist and or zoologist and independent ecologist experts not linked to, or paid for their professional services by the Cape Peninsula Baboon Management Joint Task Team (CPBMJTT).
12. A healthy, wild baboon troop moves across a home range spanning hundreds or thousands of hectares to prevent overexploiting local plants. Compressing 60 baboons into a localized, fenced sanctuary means they would completely strip the palatable natural bulbs, shoots, and roots within days.
WAPFSA is requesting a copy of the professional report by an independent primatologist and or zoologist and ecologist not linked to or paid for by the Cape Peninsula Baboon Management Joint Task Team (CPBMJTT)
13. Scientific research by Hoffman and O'Riain document that wild Peninsula baboons naturally traverse 1.8 to 6.5 kilometres daily, managing home ranges that extend up to 38 square kilometres (3,800 hectares).
Confining wide-ranging troops to a fraction of a percent of their natural territory strips them of environmental complexity and foraging autonomy. Critics point out that international guidelines, such as those from the Global Federation of Animal Sanctuaries (GFAS), were
designed for rehab or captive-bred animals not intact, free-ranging wild troops with intricate social structures.
Forcing healthy, wild-caught primates into permanent captivity is expected to cause severe long-term psychological distress, social disruption, and behavioural abnormalities such as stress-induced aggression or repetitive self-harm.
WAPFSA is requesting copies of reports obtained from independent zoologists primatologists, qualified animal behaviour experts obtained by Cape Peninsula Baboon Management Joint Task Team (CPBMJTT) prior to commencing with the plan to capture and permanently hold captive 60 baboons.
14. A permit or operating license for a zoo or sanctuary cannot legally or safely be produced if there is no proper plan in case of a fire. Operating a captive wildlife facility involves strict intersectional compliance between environmental conservation authorities who issue the biodiversity and wildlife captivity permits and local municipal authorities, who enforce national building and fire safety codes. If a facility lacks an approved fire plan, the issuing of permits is blocked, delayed, or subject to immediate cancellation.
Under National Building Regulations and municipal fire brigade by-laws, any public or commercial structure hosting animals and people must strictly comply with life safety codes. A local fire department must inspect the site and issue a Fire Safety Clearance Certificate.
WAPFSA is requesting a copy of the plan, signed off by independent primatologists and or zoologists, the NSPCA and the relevant fire department for the safe evacuation of the 60 baboons in the case of a fire and the wild life centre at Kogelfontein.
15. Legislation such as the Nature Conservation Ordinances, the National Environmental Management: Biodiversity Act (NEMBA), and the Animal Protection Act 71 of 1962 focuses on physical infrastructure, enclosure adequacy, species protection status, and immediate animal welfare. In many instances, authorities issue a Certificate of Adequate Enclosure or a captivity permit if the land, fencing, and safety measures meet physical specifications, without requiring a multi-year business or financial solvency forecast. Current statutory frameworks generally lack a mandatory requirement for applicants to prove long-term endowment, trust funds, or guaranteed operational budgets to sustain the animal for its entire natural life. The City of Cape Town has agreed to fund the facility for three years.
The potential death or culling of Cape Peninsula baboons due to funding deficits poses a severe reputational risk to the City of Cape Town, CapeNature, and SANParks by directly undermining their positioning as sustainable custodians of a UNESCO World Heritage Site.
Shifting from humane, proactive coexistence measures such as baboon-proof waste management and non-lethal field ranging to lethal elimination methods because of administrative or financial disputes signals a fundamental breakdown in environmental governance and ethical accountability.
This failure triggers intense local and international public backlash, sparking legal interventions from animal welfare groups and highly damaging media scrutiny that exposes structural friction between municipal authorities and conservation agencies. Ultimately, allowing a genetically distinct, native wildlife population to be culled as a matter of convenience or budget failure degrades the eco-tourism brand of the region, transforming the Cape from a celebrated global model of biodiversity into an example of regulatory neglect.
WAPFSA is requesting a copy of the decision making process and the final authorisation from the CEO of CapeNature, SANParks the Mayor of Cape Town, the Premier of the Western Cape agreeing to funding the wildlife centre and the expert care of the baboons at Kogelfontein for a period of thirty to forty-five years, the average life span of a baboon in captivity.
If there is a political transition, or a change in governance or municipal administration. A new ruling party could vote to reduce the facility's operational funding in the next municipal budget cycle, effectively starving the project. WAPFSA is requesting a copy of the decision making process and final authorisation that safe guards the baboons expert care and welfare for the a period of thirty to forty-five years, the average life span of a baboon in captivity. Please also provide the financial break-down of the project costs for this project for the next few decades.
16. Baboons are intelligent, highly social primates used to ranging over vast territories. Seeing or hearing free-ranging troops outside the fence while they are trapped inside can trigger intense frustration, pacing, and severe anxiety. Captive baboons recognize their lost freedom and frequently try to break out. Welfare groups and conservationists warn that animals in this situation often injure or kill themselves trying to scale or force electric and physical barriers to rejoin free troops or escape the confinement.
WAPFSA is requesting a copy of the independent study carried out by qualified expert animal behavioural experts where wild baboons have been captured and held permanently captive in a location where wild, free ranging baboons will be visible to them.
Read full letter addressed to government officials: https://wapfsa.org/urgent-accountability-needed-wapfsa-challenges-authorities-on-the-urban-wildlife-centre-at-kogelfontein/
๐ธ The Wildlife Animal Protection Forum South Africa
