Attention: Growth and Development Strategy Public Consultation Team City of Joburg By e-mail: gds2040@gmail.

com 19 August 2011

Dear all at GDS, Were delighted to see the level of public interest and participation in the citys Growth and Development Strategy process. As we said in our submission last week, the role of public participation in government cant be underestimated, and strong, vibrant societies are created when government and the people work together in partnership. As an independent civil society group working for best-practice governance, social justice and environmental protection in the City of Joburg, were privileged to be part of the process. Please find herewith our submission on this weeks theme. Week 2: Resource Sustainability Resource sustainability is, of course, a challenge facing people living in cities all over the world, and nowhere could this subject be more important than in the City of Joburg. Managing resources sustainably is important not only because the city is experiencing such rapid growth and change, but also because we have the challenge of addressing the structural inequalities of the past. On the Agenda As you mention on your web site, the supply of electricity (and, needless to say, the way in which electricity usage is billed) is high on the agenda for the citys people. JAG was, in fact, established after a five-day mid-winter power cut in Kensington, which dragged on simply because the systems in place to deal with a fairly routine situation (a burnt-out cable) failed completely. After years of experiencing one service delivery problem after another, as well as witnessing an alarming decline in good governance on the part of the citys administration, the members of the group felt it was important to establish an independent civil society organisation that could advocate for the citys people on issues such as these. Waste management and water are, of course, similarly high on the agenda. As a group, we are particularly concerned about the management of the acid mine drainage problem, which some scientists have called the greatest environmental threat South Africa has ever faced, as well as the desperate state of some rivers and lakes within the citys boundaries. Governance Any attempt to address resource sustainability, like any attempt to create a liveable city, must begin with good and accountable governance at local government level. We therefore urge the city to base its growth and development strategy first and foremost on the standards of good governance as set out in the King Reports, and to commit to building a more participatory and accountable local government system. Unless we begin with this, operational implementation, no matter how well conceived, simply cannot succeed.

With regard to specific issues, however, we offer the following suggestions: Electricity Supply Professional management It is JAGs contention that many of the problems being experienced with power supply and municipal billing are directly due the politicisation of local government; with the deployment or appointment of party officials rather than suitably-qualified and experienced professionals to key management and operational posts. We therefore support the intent of the Municipal Systems Amendment Act, and call on the city to appoint appropriately-skilled management teams to run the citys utilities, including City Power and Joburg Water. We believe these posts should be permanent positions (i.e. not subject to change after each election or to party political manoeuvring); that the recruitment process should be held in accordance with recognised human resource management practice; that appointees be subject to performance reviews and the fulfilment of pre-defined key performance measures; and that each utility be responsible for giving an open report-back in Council on a quarterly basis. Billing We further feel it is vital that the city address the on-going problems with municipal billing, especially with regards to electricity and water usage. The billing crisis in Joburg continues unabated and is now of such a nature that it is a social justice issue. As a group, we have called for an independent forensic audit into the citys billing system, but have received no response. The importance of dealing with this issue openly and effectively cant be overemphasised. Public consultation Above all, we believe there is an urgent and pressing need for more formal and effective channels for public consultation on issues such as the installation of pre-paid meters, geyser control mechanisms, tariff structures, demand side management etc. The recent electricity tariff increases are, for instance, based on tables that seem incomprehensible to people both within local government and in civil society. We have called on the National Energy Regulator (NERSA) to explain the tariff tables for the financial year 2012, on which the citys new electricity tariffs are based, but despite repeated attempts, we have had no success. We are yet to understand the very high average rate of increase for residential customers in particular. Debt collection There is also an urgent and pressing need for the city to normalise its debt collection procedures, which obviously depend on a functional billing system. Firstly, the practice that the citys attorneys have of demanding immediate payment of disputed bills under threat of blacklisting, legal action or cut-offs is highly irregular, and could even construed to be criminal extortion. This practice has to change, and not only are effective dispute resolution procedures required, but so are legal and recognised processes for collecting legitimate debt. Debt collection procedures should also be carried out on an equitable basis across all city areas, without consideration for which areas are the strongholds of any given political party.

Improved debt collection would also mitigate against the need for the citys exceptionally high 117% mark-up on bulk electricity and against the high level of tariff increases residents have experienced in recent years. Simply put, managing debt and cash flow is a key sustainability issue. Macro issues On a macro level, we believe it is important for the city to obtain the support of provincial and national government to begin phasing in alternative energy in the city. Subsidy schemes for the installation of solar geysers are, for instance, something wed very much like to see being implemented, especially as geysers account for approximately 36% of domestic usage. Localised wind turbines are also something that we believe should be on the medium-term agenda. Nevertheless, as business and industry remain the biggest users of electricity in the city, we feel that optimising usage in these areas is essential. This can be done through mechanisms like time-of-usage tariff structures, accurate metering and incentive schemes. Since the transfer of the tender for commercial metering to a new supplier two years ago, the accuracy of commercial metering is in question and this, above all else, requires urgent attention. Similarly, the city reports an exceptionally high loss of bulk electricity and this needs to be investigated as a matter of urgency. Illegal usage of power, which is not only wasteful but dangerous, needs to be addressed, as does possible loss due to management or infrastructural issues. Finally, public education on power saving and sustainability is essential, and should be seen as part of the on-going effort to manage power supply. Waste Management Professional management As in any big city, effective waste management is crucial in the City of Joburg. While we regard Pikitup, the citys waste management utility, to be amongst the citys most efficient utilities, the fact remains that it is technically bankrupt. Like the other utilities, it is important that Pikitup be managed by a suitably-qualified and experienced management team and that it be responsible for delivering quarterly report-backs on performance. Recycling With regard to specific initiatives, we are aware that Pikitup is running a recycling pilot project in some of the citys western areas at present and strongly support the introduction of a mandatory recycling system throughout the city. We also strongly support the citys intention to include informal recyclers, who have been the backbone of the recycling effort in Joburg for many years, in the formalisation of this process. At present, the metro is, in fact, lagging sadly behind many of the worlds other big cities with regard to recycling procedures. Public education about litter, pollution and waste is also absolutely essential, so that a clean city culture can be developed.

Sewage The management of sewage, especially in some of the citys older suburbs, is of great concern to us. This especially as raw sewage is polluting ground water in various places in the city, and this obviously increases the risk of water-borne diseases. Again, experienced personnel are required to assess the extent of the problem and to develop an action plan to deal with it. Water Drinking water As far as we are aware, the drinking water being supplied by Rand Water remains of a high quality and we commend the utility on its track record in this regard. The fact remains, however, that pollution is becoming an increasingly-pressing issue in the bodies of water from which Rand Water draws its supply, and this is not only putting water security at risk, but is adding to the cost of processing potable water considerably. A more integrated approach to water pollution therefore needs to be considered, with more cooperation between the various levels of government and with less red tape. We would therefore suggest that the city consider establishing a multi-disciplinary WATER TASK TEAM, with the mandate of assessing and addressing specific water pollution problems and supply issues in consultation with other levels of government and with civil society. Wastage As with electricity, the city records a high level of loss from the bulk water supply, and we believe two measures should be taken immediately to mitigate against this. Firstly, the public should be encouraged to consider water as Jozis new gold and to report leakages and infrastructure problems immediately (and, needless to say, the relevant city agencies need to act on these reports immediately too). Secondly, a full assessment of the citys water infrastructure needs to be undertaken and weak points identified. These should then become the focus of immediate maintenance intervention to mitigate against water loss. A long-term maintenance plan, if not already in place, should also be considered a fundamental aspect of water management. As far as wastage at point of usage is concerned, the citys planned demand side management campaign is well advised and should be implemented sooner rather than later. Sustainability From a sustainability point of view, public education and a phased approach to introducing certain water management measures should be considered. Consistently communicating the key messages about water conservation in a fun, accessible way is, for instance, essential. Further, measures such as rainwater harvesting and the use of grey water should be encouraged for non-potable usage, such as watering gardens and cleaning (and this applies to business and industry as much as it does to residential users). The use of two-phase flush toilets should also be encouraged, and should possibly become mandatory in all new property developments or when old buildings are being renovated. Engineering innovations that make it easier for householders,
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businesses and industry to store and re-use grey water could possibly be encouraged through a programme such as an annual Jozi Innovator competition, which could be structured in such a way that selected innovations could then be licensed and manufactured locally. Acid mine drainage As mentioned above, some scientists have referred to AMD as the greatest environmental threat South Africa has ever faced. The issues are undoubtedly complex, and this is obviously an issue for all levels of government to deal with, but it is beyond important that the city take a more muscular approach to the problem. This especially as the most pressing threat is of so-called decants (uncontrollable overflows) and ground water pollution from the Witwatersrand Mining Basin, which lies mainly under Greater Johannesburg. Decants of highly acidic and radioactive AMD have already occurred on the West Rand and have irreparably compromised some wetlands and rivers, most notably Tweelopiespruit (see, for instance http://www.fse.org.za/index.php?option=com_content&view=article&id=302:tweelopiespruitcatchment-area-the-evidence&catid=1&Itemid=55). Partially-treated AMD also continues to be pumped directly into the Vaal feeder system and these are just two of the many issues that need to be addressed with extreme urgency. We therefore urge the city to proactively form an ACID MINE DRAINAGE TASK TEAM, which would operate in the same way as the proposed water task team would. We also urge city government to work closely with such civil society organisations as the Federation for a Sustainable Environment (www.fse.org.za), Greenpeace Africa (http://www.greenpeace.org/africa/en/) and Earthlife Africa (www.earthlife.org.za) to take the lead on addressing this most pressing of issues. And, as in all things, we urge a more participatory approach to tackling the challenge of AMD. More next week Kind regards, Lee Cahill

Lee Cahill (Ms) Founding Member Joburg Advocacy Group Working for best practice governance in the City of Johannesburg P.O. Box 28557 Kensington 2101 South Africa e-Mail: jag-sa@telkomsa.net Web: Joburg Advocacy Group (http://jag-sa.blogspot.com) Facebook: Joburg Advocacy Group (www.facebook.com/JoburgAdvocacyGroup Twitter: @JoburgAdvocacy (http://twitter.com/JoburgAdvocacy)

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