The two rivers confluence and surrounding wetland is a site of significant environmental importance. The Two Rivers Urban Park (TRUP) has been acknowledged as a vital national resource by Heritage Western Cape.
Even the City of Cape Town's own Environmental Department opposed the proposed development, both to preserve the unique flora and fauna as well as as a vital flood plain. The floodplain handles stormwater from the large catchment of these two rivers and the development proposes raising the land 3.5m above natural ground with only 13% of the site in a semi-natural state. Their appeal, supported by the city’s executive management, listed 12 grounds: among these that “the decision does not align with relevant national and provincial legislation, provincial and city policy and spatial plans, and the Environmental Management Framework approved by DEA&DP”.
The department’s appeal highlighted procedural and due diligence issues on the part of DEA&DP, and noted that the decision did not adequately take into account the city’s previous comments on the environmental reports submitted by the developer. Their report also noted that “the decision does not give due consideration to climate change impacts and resilience, and fails to apply the precautionary principle”.