INSTITUTE OF MUNICIPAL FINANCE OFFICERS

COMMENTS ON ELECTRICITY REGULATION AMENDMENT BILL (B20-2006)

The Institute of Municipal Finance Officers considered the above Bill as published and wishes to comment on the following two aspects contained in the Bill: .

1. Definitions:

The definition of "Community" as stipulated, contradicts the definition as per the Municipal Systems Act (Act 32 of 2000), in that the definition as per the Act include all Ratepayers within a municipal jurisdiction and not only households and small businesses.

It is common practice in local government that industries and businesses cross subsidise the cost of supply of electricity to households and small businesses. By excluding the latter from the reticulation performed by local government will have a serious financial impact on municipalities.

2. Powers & Duties of Municipalities:

Powers, Functions and Duties of Municipalities are defined in Section 84 of the Municipal Structures Act (Act 117 of 1998). The inclusion of Section 28 in the Bill is therefore in conflict with the Municipal Structures Act.

It is recommended that the Portfolio Committee on Minerals and Energy give serious reconsideration of the above matters.

Yours sincerely

Mr Krish Kumar IMFO PRESIDENT