The Congress of South African Trade Unions has today, 7 November 2012, sent the following submission to Mr T.H.M. Mphahlele, Director-General at the Department of Transport:
COSATU's submission on e-tolls
The Congress of South African Trade Unions welcomes the Department of Transport's publication of Notice 801 of 25th October 2012 calling for comment on the proposed tariffs for the different categories of road users and classes of motor vehicles using the Gauteng Freeway Improvement Project (GFIP) toll roads.
We hope that this process will not be a formality but the start of a genuine broad public debate not just on the level of tariffs, but the broader implications of a proposal which will have a huge impact on the people of the province and the country, and which remains deeply unpopular. The Government must take the submissions from the public very seriously and keep an open mind.
COSATU has consistently been opposed in principle to the introduction of open road tolling in Gauteng and the likely introduction of the same system in other parts of the country, for the following reasons:-
Tolls will add to the burdens of the poor
The tolls will put a direct burden on the poor of Gauteng, who will be forced to pay to travel on highways which were previously free of charge.
It will not just affect the people of Gauteng, as the government has now conceded that e-tolling will replace the existing toll-gates throughout the country.
It is not true that only the middle class use our highways. Government's own statistics show that a third of all commuters travel by car, and that half of all working people earn less than R3000 a month. This means that many low income earners use private cars to travel to work, because our public transport system is so unreliable that they have no alternative. Public transport is also unavailable outside peak commuter hours, including weekends, when Gauteng residents travel distances across the Province to visit friends, attend funerals, etc.
Levels of personal debt are running at an all time high, particularly for low income earners. The proposed cap of R450 or R500 for e-tag registered private class A vehicles (which amount has not been included in the notice for comment as is therefore currently theoretical) will be cold comfort to low income earners who simply do not have any spare disposable income. In any event, the cap will only apply to e-tag holders. SANRAL's calculation that the majority of e-tag registered private vehicle users will spend less than R300 a month on tolls is also no source of comfort. The point is that large numbers of private vehicle users simply do not have a single extra rand to spend.
Tolls will also put an indirect burden on the poor of the whole of South Africa, by adding to the cost of transporting goods within and to and from our industrial heartland. They will have an immediate effect on food inflation.
Tolls will perpetuate exclusion
We already live in a society highly divided by the unequal distribution of wealth and income. The poorest 10% of the population shares R1.1 billion whilst the richest 10% shares R381 billion.
We see these inequalities reflected in access to public services. Good health and education services currently belong to the wealthier sections of society, who can afford to pay. The poor majority have to suffer underfunded, understaffed and inferior services.
In these areas we are starting to move away from the pernicious and socially divisive ‘User-pays' principle for basic public services. Good progress is being made in the health sector, through the NHI, to bring about one universal service. No-fee schools are another example of how we are trying to escape from the ‘User-pays' principle for basic public services
We should not therefore be moving in the opposite direction when it comes to the equally essential public service provided by our public roads. ‘User-pays' means that you cannot use the best roads if you cannot afford to pay.
Toll roads will become a move back to the kind of social and economic inequality in access to basic services which we are starting to move away from in health and education.
The logic of the ‘User-pays' principle is that those without the money to pay the tolls should be excluded from access to the best roads. They must find the potholed side-roads, while those with the money glide along the highways in their fancy cars.
We have consistently argued that taxation must be the main source of funding for road infrastructure. After all we pay taxes precisely so that government can build and maintain roads, hospitals, schools, etc. If additional revenues have to be raised by government, then this must be done through a progressive tax system where the more you earn the more you pay, rather than tolls which take no account of the ability of the drivers' to pay.
Public transport is totally inadequate
We acknowledge that government has now exempted registered public transport vehicles from the tolls, but very few buses and taxis actually use the tolled highways, and public transport largely remains woefully inadequate both in quality and in the numbers of people that it serves. A third of our people use private cars to get to and from work, not from choice but because our public transport system is expensive, unsafe, and unreliable.
The promise of massive investment in our overcrowded, run-down commuter rail services is good news, but this will take years to come on stream. In any event, the allocations are largely for the improvement of what currently exists, and not the massive expansion of passenger capacity which is so sorely needed.
With regard to bus passenger transport, apart from the BRTs in Joburg and Cape Town, not a single new subsidised bus route has been put in place for over ten years! This has left new settlements completely stranded in terms of affordable mass public transport. In addition, the subsidies allocated to the bus industry for existing subsidised routes have not kept up with inflation, resulting in a deterioration of services.
Regarding the taxi industry, its economic structure and operating model dictates that fares remain high, that levels of vehicle maintenance are low, and driver behaviour is ill-disciplined. As a consequence safety is severely compromised. Enforcement of safety and employment regulation in the industry is virtually nonexistent. The use of our motorways by private cars is therefore not a luxury for most users. If they are forced off the highways because of cost, they will not transfer to non-existent reliable public transport, but take their cars on to the side roads, and create levels of congestion that our municipalities will not be able to cope with. Traffic management will become a nightmare, and it is highly likely that our already shocking road fatality statistics will rise.
Tolls represent a form of privatisation
COSATU has consistently opposed privatisation of public services. The introduction of a tolling system that brings in the private sector to operate the tolled roads is, in our view, a form of privatisation, the commodification of what ought to be an essential publicly funded public service.
What makes it worse is that the contracts signed with the companies operating the tolls remain secret. All the evidence indicates that the revenues from the tolls are going to be enormous and that the loans will be paid off quickly, leaving the private operator to milk the public.
Cost of collection
Another reason for opposing the tolls is the cost of collection, which SANRAL itself has conceded will consume a massive 17 percent of the money collected in tolls. This means that tolls are not only an unfair but also a grossly inefficient way of raising the money for road improvements
Even if the government makes further cuts in the level of tolls, the collection costs will become an increasingly larger percentage of the amount collected. As Cliff Johnston of the SA National Consumer Union has pointed out: "This is the ultimate tragedy of the plan... that the road user will still have to foot the bill of more than R1, 1 billion per annum to cover the electronic toll collection process, regardless of how much they reduce the toll rate and cross-subsidise the revenue required with fuel levies and/or the national fiscus mechanisms".
The fact that the contract for collection is said to be "ad measure" i.e. that it is not fixed, but is based on services provided, makes no difference to our argument. A large portion of the revenue collected will ultimately find its way into the pockets of the toll operators.
Income to be supplemented by fine collection
It has also become clear that in addition to the collection of toll fees, the operator will rely on the technology in the system to administer fines for non payment of toll fees. This back-door generation of income for profit from fines is in COSATU's view an abuse of the rule of law.
Conclusion
For all of the above reasons, we urge the Department of Transport to take note of the mass opposition to these tolls and to communicate a recommendation to Cabinet to immediately halt the Gauteng open tolls for good. At the same time we call upon government to prioritise the roll-out of efficient, reliable, affordable and safe public transport for all the people of South Africa.
Meanwhile we continue to urge motorists not to register with Sanral or buy e-tags, and our members remain mobilised for a campaign of mass action if e-tolling is not scrapped.
Issued by COSATU, November 7 2012
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