MFPFB 3

ERKURHULENI METROPOLITAN MUNICIPALITY

Comments on the Municipal Fiscal Powers and Functions Bill

Your letter dated 19 April 2007 has reference.

In general the proposed legislation is welcomed however, we have the following comments:

Chapter 2

5. This section is very prescriptive and the requirements are onerous.

6. (d) This is too restrictive. Municipalities should be allowed discretion to set limits etc. as they do with most other tariffs. The market forces will ensure the necessary checks and balances.

7. The discretion of who the collection agent should be should rest with the municipality.

Chapter 3

These norms and standards should be guidelines and should not be prescriptive. The legislation should be enabling rather than a case of over regulation. The oversight role must not be stretched to the extent that it becomes control.