See below a letter from Marius Coetzee of de Jager and Lordan Inc to the Minister of Arts & Culture, The Honourable Gayton McKenzie with copies to other Eastern Cape Provincial Councillors, the Ndlambe Municipality, the Sarah Baartman Municipality and the SA Local Governemnt Association regarding the Proposed Meeting on Wednesday 6th August.

 

 

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 Grahamstown:

2 Allen Street | PO Box 930 | 6140 | Docex 11

Tel: +27 46 622 2799

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Alexandria:

25 Retief Street | PO Box 36 | 6185

Tel: +

 Our Ref/Ons Verw JJM Coetzee/lw/N218

Your Ref/U Verw

Friday, 01 August 2025

 MINISTER OF ARTS AND CULTURE

The Honourable Gayton McKenzie

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SOUTH AFRICAN GEOGRAPHICAL

NAMES COUNCIL

For attention: Ms Thulile Mthembu

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EASTERN CAPE PROVINCIAL

GEOGRAPHICAL NAMES COUNCIL

For attention: Mr Mark Mandita

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For attention: Zandisile Sakata

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For attention: Chuma Mfikili

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For attention: Linda Zileni

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For attention: Sikhokele Langben

 

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SOUTH AFRICAN LOCAL GOVERNMENT ASSOCIATION

For attention: Nkosiyabo Singanto

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NDLAMBE LOCAL MUNICIPALITY

For attention: The Municipal Manager

Adv Dumezweni

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For attention: The Speaker

Mr Andile Marasi

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For attention: Luyanda Dyani

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For attention: Nancy Mezned

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SARAH BAARTMAN DISTRICT MUNICIPALITY

For attention: Councillor Rune

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CC: PORT ALFRED RATEPAYERS AND RESIDENTS’ ASSOCIATION

For attention: Ren Mouton, Chairperson

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Sir/Madam,

RE: ECPGNC Stakeholder Consultation – 6 August 2025, Port Alfred

PROPOSED NAME CHANGE OF PORT ALFRED; KOWIE RIVER

1. We refer to the above matter and confirm that we act on behalf of The Port Alfred Ratepayers’ Association.

2. Our instructions are to record the following:

2.1. On Tuesday, 29 July 2025, an email was circulated to unnamed persons informing them of an attached agenda for “the stakeholder consultation by the Eastern Cape Provincial Geographical Names Committee (ECPGNC) on the proposed standardisation of certain geographical names in Ndlambe Local Municipality” to be held on Wednesday, 6 August, at 10:00 AM in the Civic Centre, Causeway Road, Port Alfred. A copy of the email is attached, marked “PA1”.

2.2. On Wednesday, 30 July 2025, at 10:35 AM, a further email was circulated containing, inter alia:

2.2.1. A list of names to be discussed at the community consultation meeting.

2.2.2. An invitation to the aforesaid consultation, dated 24 July 2025.

2.2.3. The proposed agenda.

2.2.4. A letter of appointment of Cllr. T Mafana to serve on the ECPGNC.

2.3. A copy of the letter and annexures is annexed, marked “PA2”.

3. We do not intend on engaging the statutory matrix underlying the processes envisaged under the South African Geographical Names Council Act, 118 of 1998, its regulations, the policies, guidelines, and procedures relevant to the conduct of the South African Geographical

Names Council, the ECPGNC, the Provincial Geographical Names Committees, or the Promotion of Administrative Justice Act, 3 of 2000 (“PAJA”), other than to record what we were able to glean from the proposed agenda and invitation to “the stakeholder consultation by the Eastern Cape Provincial Geographical Names Committee (ECPGNC) on the proposed standardisation of certain geographical names in Ndlambe Local Municipality”.

4. As we understand it:

4.1. Your invitation appears to be in compliance with the obligations upon submission (in the Application Submission Phase) of an application for a name change, to provide evidence of engagement and consultation with stakeholders.

4.2. This would be followed by a Preliminary Screening Phase, a Public Notification & Consultation Phase, a Committee Deliberation Phase, a Recommendation by Provincial to National Phase, a Ministerial Decision & Gazetting Phase, and an implementation phase.

4.3. The Provincial Geographical Names Committee must make recommendations to the SAGNC after having concluded all preparatory work for submission of names to the SAGNC, and after having ensured that local communities and other stakeholders were adequately consulted.

5. If we are correct in our assumptions, the meeting scheduled for 06 August 2025 is aimed at engaging stakeholders in the application submission phase. For the proper engagement of stakeholders, stakeholders must have had sight of the applications, upon the prescribed ECPGNC form, inclusive of the detailed motivation and historical and/or cultural research in support thereof.

6. The difficulties with which our client (on those it represents) is faced are:

6.1. That it has not had the benefit of insight into the Application and supporting documentation.

6.2. That the notice convening the stakeholder consultation provides for extremely truncated timeframes, even if calculated from 24 July 2025.

6.3. That the notice was not circulated in any media publication or on any public broadcasting platform.

6.4. That a substantial contingent of property owners in Port Alfred, reside elsewhere, and only frequent Port Alfred during holiday times, or sporadically when not away on business.

6.5. That the short notice prevents stakeholders, in this instance, property owners, from preparing for the consultation, and for them to formulate their concerns comprehensively, upon an informed basis.

7. Our client is committed to assisting the ECPGNC and other stakeholders by engaging meaningfully with it and providing evidence in support of its submissions. It can, however, only do so if given an adequate opportunity to engage with its members and relevant stakeholders. Given that our client represents a substantial component of the community, they must participate in the process and are committed to doing so. Unfortunately, they are being constrained from doing so because of the wholly unreasonable imposed, truncated timeframes.

8. Whilst representatives of our client, and, most certainly, several other individuals, will be present at the stakeholder consultation meeting on 06 August 2025, we are instructed to request, as we hereby do:

8.1. That we be provided with the entire application for the name change, and supporting documentation as set out above, by close of business on Monday, 04 August 2025, in order that we may formulate our prima facie views in that regard and advise our client accordingly.

8.2. That you shall urgently, and before 06 August 2025, convene a proper stakeholder consultation meeting upon at least 21 days’ notice, and that such notice be broadly advertised in local printed media, provincial printed media, and radio.

9. Our client’s rights to make submissions and representations remain reserved.

10. Kindly acknowledge receipt hereof as a matter of extreme urgency, and by no later than 12:00 on Monday, 04 August 2025, and provide us with your undertakings as set out in paragraphs 8.1 and 8.2 above, failing which we are instructed to launch an urgent application out of the Makhanda High Court, to set aside the decision to convene the stakeholder consultation meeting of 06 August 2025, coupled with an appropriate orders as to costs, and appropriate relief.

Kind regards,

MARIUS COETZEE

DE JAGER AND LORDAN INC.

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