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Full text of "2nd FAQs Circular No. 88 (final) May 2019"

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21 May 2019 



national treasury 

Department 
National Treasury 

REPUBLIC OF SOUTH AFRICA 


Circular No. 88 Frequently Asked Questions 
Part 2 


Since the introduction of Circular No. 88, metropolitan municipalities have raised questions of 
clarity and asked for more practical guidance for specific indicators. Many of the questions 
raised apply across municipalities and they have therefore been documented and collated in the 
following list of frequently asked questions (FAQs). This is the second list of FAQs produced 
by National Treasury, to be read in conjunction with the previous FAQs, dated 10 April 
2018. The following presents FAQs organised around common themes or lines of questioning. 
Additional FAQs may be periodically released as part of the reform process. 


National and Shared indicator queries 

The following refers to questions related to indicators listed as "National" and "Shared" 
reporting responsibilities in Circular No. 88 


Question National Treasury response 


2.1 When will National and Shared 
indicators with data elements be provided 
for Municipal reporting timeframes? 


National and Shared indicator data will be released 
during annual, synchronised releases for each of the 
respective sources of data elements. For the time 
being, municipalities should ensure they can supply the 
data elements within their control until such time as 
those releases are formalised and communicated to all 
metros. The first release of StatsSA data for financial 
years 2016/17-2018/19, which is one of the sources of 
National and Shared indicators, will occur before the 
end of May 2019 as an appendix to the official release 
of the General Household Survey report at 
metropolitan municipal level. 


1 








Question National Treasury response 


2.2 Once these [National and Shared] No, as per the previous Frequently Asked Questions 
indicators are included in the IDP, they released in April 2018, "Data elements sourced and 
become subject to Municipal reporting supplied outside of the municipality for'National'and 
timeframes. Is there agreement from the 'Shared' indicators will be audited once centrally. The 
AG that these indicators will not be responsibility of the municipality for these indicators 
audited at the Municipal level? should therefore only be to demonstrate that they 

have utilised the information centrally supplied 
(applicable to the metro) as per the calculations 
included in the TID. The process of obtaining the 
information on the various data elements from the 
identified sources and the actual collation/ calculation 
of the actual achievement (if not already provided by 
the external data source) should be addressed in the 
SOP to clarify the responsibilities and documentation 
used in reporting the achievement." Further, "The 
Auditor-General audits all indicators included within 
the IDP, SDBIP and Annual Report...". 

The following Tier 1 and Tier 2 National indicators have 
been recommended for exemption by National 
Treasury. They have not yet been released in standard 
form and cannot yet be uniformly reported on for 
2018/19 or reflected in planning for 2019/20: 

ENV1.1 
TR3.1 
TR3.2 
TR7.1 
TR7.2 
IC8. 

The following Tier 1 and Tier 2 Shared indicators have 
been recommended for exemption by National 
Treasury. They have not yet been released in standard 
form and cannot yet be reported on for 2018/19 or 
reflected in planning for 2019/20: 
EE4.3 
ENV6.1 
HS1.21 

Unless indicators are specifically identified as 
exempted, they should find expression in annual 
reports for 2018/19 and planning for 2019/20. 


2.3 Which National and Shared indicators 
have yet to formalise the central supply 
and distribution protocols for the release 
of data and therefore cannot yet be 
reported by municipalities for 2018/19? 


2 




Question 


National Treasury response 


2.4 How far along is the discussion with 
StatsSA to set up the working group for 
the resolution of the problems with the 
StatsSA household counts? 

StatsSA remains a participating member of the Metro 
Support Forum but it is unlikely there will ever be a full 
resolution of StatsSA household counts with 
alternative figures because they rely on different 
methodologies which provide an approximation. It is 
intended that there would be a convergence in the 
reported figures over time. StatsSA data are considered 
officially recognised statistics that meet SASQAF 
criteria. The onus is upon any alternative 
methodologies to prove themselves more reliable and 
accurate measures of the constructs as defined for the 
purpose of this exercise. The inclusion of StatsSA data 
does not preclude the inclusion of metro customised 
indicators. 

2.5 Is it compulsory for National indicators 
to be included in the IDP & SBDIP? 

Yes, it is compulsory to include National indicators in 
the IDP at outcome level and in the SDBIP at output 
level. This excludes indicators that have been 
exempted. In the event that data has not been released 
nationally at the time of planning and/or reporting for 
an indicator that has NOT been exempted, the 
municipality should state "Data not yet available from 
national". 

2.6 The municipality's billing system 
reflects individual connections for various 

services and is a more accurate reflection 
of service access. The municipality has 
engaged National Treasury and the 
Auditor-General to find a solution and/or 
best practice for aligning household 
figures to actual service delivery 
(connections). How is this being resolved? 

Municipalities are still conflating dwellings with 
households and reference to the two definitions in 
Circular No. 88 appendices are referred to here (*Note 
these definitions are consistent with StatsSA 
definitions). Good practice in this regard is to recognise 
that there will never be an exact match between 
"households with service access" and "dwelling 
connections" as they measure two different things. 
Instead, data confrontation is inevitable and the 
municipality should ensure it is regularly considering 
the reported output level service provision in relation 
to the outcome level household service access with a 
view towards convergence over the medium-long 
term. 

2.7 How will the StatsSA household 

service access data be shared? 

Refer to question 1. Annual household service access 
data for all metros for all data elements will be shared 
in a table in the appendix of the General Household 
Survey report at metropolitan municipal level at the 
end of May 2019. 


3 




Question National Treasury response 


2.8 What is the time lag on the release of The General Household Survey will be undertaken 
the StatsSA general household service annually during the start of the same financial year for 
data? which it is expected to be reported, as agreed during 

the indicator development process. For instance, the 
General Household Survey conducted in the latter half 
of 2018 will be released in May 2019 and serve as the 
official annual reporting figures for the 2018/19 
financial year. 


Auditing and Standard Operating Procedures queries 

The following refers to questions related the process of audit and standard operating 
procedures (SOPs) for measuring indicators 


Question National Treasury response 


2.9 Are there examples of SOPs for data Nationally, there is not a standard SOP template to 
elements? refer municipalities to as the intention is that existing 

municipal SOP formats should be applied to the TIDs. 
For benchmarking purposes, City of Cape Town PIMS is 
a useful example. 

2.10What happens if we can't report on As per the previous Frequently Asked Questions 
any KPIs? released in April 2018, "The Auditor-General audits all 

indicators included within the IDP, SDBIP and Annual 
Report...". Also read see the response to the question 3 
below. 

Further, this then becomes a matter for National 
Treasury to address with municipalities in the event of 
disregarding MFMA Circular No. 88. 

2.11 Will the Auditor-General be lenient MFMA Circular 88 now forms part of the performance 
when auditing in relation to Circular No.88 management and reporting framework (PMRF) which 
for 2018/19? metros need to apply in planning and reporting 

performance information. 

The Auditor-General audits the performance 
information in terms of the PMRF and the audit 
approach is therefore not affected. The only "lenience" 
that will be considered is with regard to specific 
itemised exemptions noted by National Treasury for 
specific provisions of Circular No.88 and/or indicators. 
Municipal feedback and participation in the Metro 
Support Forum has assisted to identify some instances 
that merit exemption, but National Treasury has not 
yet finalised these instances. Municipalities should 
therefore measure and report performance on all 
Circular No.88 indicators at Tier 1 and Tier 2 as for all 
indicators included in the IDP and SDBIP. 






General Circular No. 88 queries 

The following refers to general questions about the application of Circular No.88 in metros 


Question 

National Treasury response 

2.12 Do we need to track backlogs? 

No, not in terms of the Circular No.88 prescribed 
indicators, but yes, they do need to be tracked by the 
metro as this should be crucial information informing 
service delivery strategies in the metro. The Circular 
No. 88 indicators provided are considered compulsory 
for reporting purposes, but they are not exhaustive and 
it is in the interest of the municipality to know the scale 
of its own backlogs. 

2.13 For some indicators the targets in our 
municipality were only finalised during 
Q2, even though these indicators are in 
our SDBIP, but we cannot report against 
the targets until they're approved during 
the Mid year adjustment (MTA) process. 
Therefore, reporting on these indicators 
will only begin in Q3. 

Given the lead time for this reform there should not 
have been any indicators without targets set prior to 
the start of the 2018/19 financial year. Use of the MTA 
process is the right way to correct this, but it is not 
considered acceptable to have omitted targets for 
Circular No.88 indicators included in the SDBIP. 

2.14 A range of internal indicator specific 
commentary was shared with National 
Treasury for specific indicators. Most of 
these inputs fail to acknowledge or 
distinguish between key determinants 
related to 1) Reporting Responsibility and 
2) Readiness tier. 

Municipal staff are referred to these specific provisions 
for each indicator and reminded that these indicators 
are not "optional" nor can they be "combined" 

2.15 Can there be clarity and a clear 
process or methodology for costing 
indicators particularly in OpEx driven 
indicators? 

Please refer to MFMA Budget Circular 93 and the 
annexure aligned to Circular No. 71. 

2.16 We need to start looking at possible 
indicators to measure economic growth 
and development - is this possibly on the 
agenda for future iterations of the 
indicators? 

Yes, this is on the agenda for future iterations of the 
indicators and should be formally updated for the 
2020/21 planning and reporting period by November 
2019. If there are any suggestions, please put them 
forth a circular88@treasury.gov.za 

2.17 What is the protocol for reflecting 
Mid-Term Adjustments to targets and 
reported data for Circular No.88 
indicators? 

At present, there is not a protocol provided outside of 
the existing municipal Mid-Term Adjustment 
resolution from Council which would need to be 
submitted with Annual Reports to justify and account 
for inconsistencies between planning and reporting. 

2.18 When is it expected that the C88 
indicators appear on the performance 
agreements of senior managers? 

The output level indicators should reflect in the SDBIP 
for 2018/19 as per Circular No. 88, and therefore by 
extension in the performance agreements of Senior 
Managers for 2018/19 already. 

2.19 We've been raising specific questions 
about individual indicators with National 
Treasury based on feedback from our staff 
but have not yet received responses to 

No. Many of the individual indicator questions and 
issues raised with National Treasury are related to 
municipal standard operating procedures and should 
be handled internally. Where National Treasury has 
received multiple questions, it has endeavoured to 


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Question 


National Treasury response 


date. Is it OK if we ignore the indicators 
which we still have questions about? 

respond to them but it has not undertaken to respond 
to every question or query, particularly where the 
matter has been previously addressed directly via 
FAQs. Where there are common definitional and 
rationale issues, although raised belatedly in relation to 
the release of the circular, they have been 
acknowledged here and will be rectified as part of the 
periodically updated release of the Tier 1 and Tier 2 
indicators next scheduled for November 2019. 

2.20 Will all Tier 3 and 4 indicators be 
moved up to Tier 1 and 2 for the 2019/20 
planning and reporting period? 

No. These indicators have not undergone further 
definitional clarification and are not expected to be 
introduced as part of the 2019/20 planning and 
reporting period. Municipalities are not expected to 
report on the current Tier 3 and Tier 4 indicators until 
they reflect in an updated released as Tier 1 and Tier 2 
indicators. The next release is expected for the 

2020/21 planning and reporting period by November 
2019. 


6 




Energy and Electricity (EE) specific indicator queries 

The following refers to questions relating to the application EE indicators from Circular No. 
88 


Question 

National Treasury response 

2.21 EE3.1 to EE3.4 - as indicated 
numerous times previously, we are unable 
to report on this indicator and are 
awaiting the convening of the working 
group by National Treasury to address the 
concerns raised by Metros with regard to 
these indicators. 

Reliably reporting on indicators EE3.1-3.4 is a common 
challenge across metros and their inclusion as Tier 1 
indicators was made with certain assumptions around 
systems that have not held. A motivation has been 
made to alter the Tier positioning of these indicators to 
Tier 2 and change the frequency of reporting to Annual 
for the 2020/21 planning and reporting period by 
November 2019. For the time being, municipalities 
should continue attempting to report on it on a 
quarterly basis as per Circular No. 88. 

2.22 EE3.11 The current reporting 

requirements of some municipalities refer 
to NSR 047 requirements which 
distinguish between five different 
categories of restoration time (X= 1.5, 3.5, 
7.5, 24, 168 or less). This differs from the 
TID which consists of only four categories 
and refers to (X= 0.5, 1.5, 3.5, and 24 or 
less). 

The TID set standards on the basis of the NSR provisions 
which Eskom applied, and fewer categories were set to 
start with, noting that there may be some differences 
across municipalities. For the time being, any deviation 
from the TID categories as formulated should be 
explained in the SOP and consideration will be given to 
revising the TID as part of the annual review for Circular 
No. 88 indicators scheduled for November 2019. 

2.23 EE4.11 Total renewable energy 
capacity available through IPPs - We will 
only be able to report on those that are 
registered with the Municipality, i.e. not 
the illegal generators. 

Yes, that is correct. The expectation is that this would 
only apply (in the future) to those registered with the 
municipality. Note this is a Tier 3 indicator and so does 
not yet apply. 


7 





Environment and Waste (ENV) specific indicator queries 

The following refers to questions relating to the application ENV indicators from Circular No. 


88 


Question 

National Treasury response 

2.24 EIW1.11 l.The numbers that are 

preceding each route are not clear where 
they are coming from. 

2. Section 40 of the National 
Environmental Management Air Quality 
Act (Act 39 of 2004) stipulates that: the 
decision period is 60 days by the licencing 
authority (Municipality) to decide on the 
application, a further 30 days to inform 
the applicant whether successful or not 
for a new/ renewal / variation application. 
However the NT KPI description indicates 
60 days for renewal and 10 days for 
variation which is incorrect and not in 

accordance with the Act. 

It must be noted that the 60 days trigger 
once the municipality is in possession of all 
documentation that are required to make 
a decision. 

3. The NT KPI description is making 
reference of "guidelines" where the Act 
clearly stipulates time periods. 

The indicator was formulated specifically on the basis 
of the guideline timeframes as agreed during the 
consultation process. While the inputs regarding the 
legislated timeframes are noted, the guidelines are 
considered good practice and the basis on which the 
timeframes were set. The indicator operates within the 
legislative provisions and should be applied as 
currently formulated. 

2.25 ENV1.2 Should be amended to 
include measurement per station. Our 
municipality has more than one station 
and will distort reporting if updated. 

The indicator does not presuppose only one station per 
metro and measures the number of days where any 
monitoring site averages above the exceeded PM2.5 
levels. In a future TID update, a note on calculation 
could clarify that where multiple sites record averages 
in excess of the indicated threshold, it only counts as 
one day for the entire metro (no double-counting 
multiple sites for the same day). 

2.26 ENV1.12 Proportion of AQ 

monitoring stations providing adequate 
data over a reporting year - how do we 
report on stations that are not yet 80% 
compliant and more? Are we even able to 
report on these? 

AQ monitoring stations that are not yet 80% compliant 
are included in the denominator of the indicator. The 
numerator only refers to those that are fully 
operational as per the definition. 

2.27 ENV4.1 Ecosystem/vegetation type 
threat status - Unable to calculate targets 
- no municipality/ university is going to be 
able to calculate the targets per 
vegetation type. - Biodiversity targets: 
Even the most well-resourced 

municipalities will not be able to set local 
biodiversity targets. Biodiversity targets 
for vegetation types are based on 
extensive botanical surveys and the 

The indicator is Tier 4 and so these comments are 
noted and will feed into the process of refinement but 
this indicator does not yet apply. 


8 




Question 


National Treasury response 


resources to undertake such a task simply 
does not exist. 


2.28 ENV4.1 Timeframes for reporting: 
The required reporting timeframes for this 
indicator is bi-ennially. It is important to 
note that this will only be possible if 
municipalities have aerial photography 
required to assess condition every two 
years. Assessing condition at a desktop 
level is not ideal, but it is probably the only 
practical approach... Note also that there 
could be a timeframe of up to a year 
between the aerial photographs being 
taken and the mapping completed and 
analysed so a further complication is how 
up-to-date the information supplied is. 

This is an important consideration to inform further 
indicator refinement but it is reiterated that this 
indicator is currently Tier 4 and so does not yet apply. 

2.29 ENV4.3 Wetland condition index - 
Contexts are different e.g. CT has a 
mountain so difficult to develop unlike 
DBN which is easier to develop. KPI's 
should not be used to compare Cities - 
could compromise Cities during audit as 
well. DMOSS area will not change all the 
time but we will specify this in the 
SOP. When our officials met with National 
Treasury at their offices in Pretoria, it was 
agreed that this indicator would be 
removed because the data (particularly 
temporal data) does not exist and all 
municipalities present at the time 
indicated that we do not have the 
resources to report on this indicator. 

The indicator is Tier 4 and so these comments are 
noted to feed into the process of refinement. 


9 



Housing and Community Facilities (HS) specific indicator queries 

The following refers to questions relating to the application HS indicators from Circular No. 
88 


Question 

National Treasury response 

2.30 HS1.12 "Number of formal sites 
serviced". For this indicator, the rationale 
lists basic services which include 
"Electricity". The KPI owners who are 
responsible for the implementation of this 
Indicator have indicated that it is not 
possible for a site serviced to have 
electricity, only when the structure is up 
can electricity connections be installed. 

This feedback is noted but disagreed with. The process 
is not intended to retrofit a definition of the indicator 
for convenience of water and sanitation services only. 
The output indicator was deliberately formulated to 
include electricity as a basic service because there is an 
intention to measure serviced sites inclusive of the 
suite of services, not disaggregated on the basis of 
organisational service department separation. 

2.31 HS1.12 - Please provide further 
clarity on the definition of site? 

A site refers to a pre-determined area where basic 
services can be provided, there is some degree of 
security of tenure and to which a household can be 
situated or relocated and/or upgraded. This can be 
added to the list of definitions in future updates to the 
TIDs for the 2020/21 planning and reporting period by 
November 2019. 

2.32 HS1.21 - does the figure reported 
need to include the historic backlogs, 
where housing developments were not 
subjected to all the current planning 
requirements? This has resulted in a 
backlog of properties that cannot be 
transferred due to planning/ land 
surveying issues, etc. 

The indicator should only refer to the title deeds issued 
since the introduction of the indicator. It should not 
refer to a backlog in historic properties. The indicator 
definition clarifies that this refers to all deeds 
registered in the financial year for which the indicator 
is being reported. It therefore does not include 
backlogs in historic properties. 

2.33 HS2.21 Number of rateable 

residential properties in the subsidy 
housing market entering the municipal 
valuation roll - Targets are currently only 
for GAP and Social Housing that is 
facilitated by Human Settlements as we 
have no access to other information. 

The indicator only refers to residential properties 
within the responsibility of the metro. This clarification 
can be provided at the SOP level. 

2.34 HS2.22 - Number of days varies 
depending on the size of the property, per 
legislated requirements. Averaging the 
results makes the actual figures 
meaningless. We have created 2 
indicators based on the property size but 
perhaps the indicator should be revisited. 

As per the TID, this indicator refers to residential 
building plans only, unless it is not possible to 
disaggregate this information within the municipality. 
The detail in this regard should be provided in an SOP 
to clarify. 


10 





Good Governance (GG) specific indicator queries 

The following refers to questions relating to the application GG indicators from Circular No. 


88 


Question 

National Treasury response 

2.35 With regard to municipal entities, 
there are some Governance indicators 
that will apply to them e.g. GG5.1. We 
have 2 entities but they are not 
responsible for delivery of services on 

behalf of the Municipality. Are the 

Entities required to show results 
separately or should the Municipality's 
reporting take the entities results into 
account? 

Good Governance indicators generally apply to all 
municipal entities for which Council exercises 
oversight. Entities are not required to show separate 
results for these in their reporting, but municipal 
reporting should reflect an aggregate of instances for 
which municipal Council has oversight, particularly as it 
relates to Good Governance. 

2.36 GG 2.12 "Average number of 
councillor-convened community meetings 
per ward ". For this indicator, the indicator 
name talks to "average number", 
definition talks to "number of community 
meetings" , indicator formula is "(1) Total 
number of councillor convened ward 
community meetings/(2) Number of 
wards in the municipality * 100" and the 
rationale reads as follows "The indicator 
provides an indication of the extent of 
public participation opportunities in the 
municipality at ward level. Each ward 
councillor should convene at least one 
quarterly meeting in his/her ward." The 
formula of this indicator will not drive the 
municipalities into desired impact as 
outlined in the rationale. The indicator 

formula does not limit the calculations of 
the results to 1 meeting per ward. Overall 
results might give an impression that all 
communities are afforded opportunity to 
participate as ward level if some of the 
wards meet more than once a quarter. 

This is a legitimate critique of the formulation of this 
indicator that can be considered for review as part of 
the refinements for the 2020/2021 planning and 
reporting cycle. For the time being, the indicator stands 
as it was formulated in Circular No.88 and should 
reflect in annual reporting for 2018/19. 

2.37 GG2.12 The formula converts the 

numbers into a % but the unit of measure 
is meeting. Further, the indicator name 
refers to average number of... This 
indicator name either needs, the unit of 
measure needs to be % or the formula 

must be amended. 

The formula should not include the ’xl00' and the TID 
will be amended accordingly. Please omit the ’xlOO’ as 
per the quarterly reporting template and calculations 
that have been applied to date. This will be further 
clarified in an erratum/supplementary communication 
with the exemptions. Updated TIDs will reflect for the 
2020/21 planning and reporting period by November 
2019. 


11 






Question 


National Treasury response 


2.38 GG2.12 Why is the average over the 
year only being aggregated in Q4 and not 
each quarter? The results may show a 
major difference in Q4, which may not be 
easily understood by a reader. 

The cumulative total at the end of Q4 is intended to 
serve as the annual value, although the disjuncture 
between the preceding three quarters is noted. This is 
acknowledged as benefiting from definitional 
clarification for Q4 and the Annual indicator result. 
This can be further clarified in the TID for the 2020/21 
planning and reporting period by November 2019. 

2.39 GG3.13 Please provide the definition 
of administrative i.e. does it include all 
employees or specific types? 

The indicator is Tier 3 and so does not yet apply. These 
comments are noted to feed into the process of 
refinement. 

2.40 GG4.11 Request that this indicator be 
moved from output to outcome 
indicator...This is the outcome of the 
council meeting and its not within the 
direct control of a directorate of a 
municipality. 

This is an argument to be made that this is the case but 
the formulation at output level was agreed that this 
should be included at the output level and reported on 
a quarter basis and so that is the expectation for 
2018/19 reporting. 

2.41 GG 6.11 Percentage of the 
municipality's operating budget spent on 
free basic services to indigent households- 
We do not report on our FBS spend 
against our operating budget as it is 
difficult to determine the exact value e.g. 
how do we split the salary spend into 
expenditure on FBS vs on services that are 
paid for? The spend in the budget booklet 
is an estimate. As a result, right now this is 
not practical and figures cannot be 
audited. 

This indicator does not refer to the salary spend related 
to staff responsible for FBS, but only in relation to the 
operational costs of providing free basic services in 
terms of water, sanitation, electricity and waste 
removal only. 


12 




Transport and Roads (TR) specific indicator queries 

The following refers to questions relating to the application TR indicators from Circular No. 
88 


Question 

National Treasury response 

2.42 TR1.1 The definition of data element 

B1 includes taxi ranks as scheduled access 
points. However, taxi ranks are not always 
scheduled stops. Further, taxi's stop 
wherever they please and these stops are 
currently not being considered. However, 
measuring these stops remains an issue. 
Further, counting only enumerated 
dwellings is a problem. Many non- 
enumerated dwellings may also be 
serviced, and the result may therefore not 
reflect the actual position. 

The indicator is Tier 3 and so these comments are 
noted to feed into the process of refinement. 
Nevertheless, the indicator is defined as it is because it 
becomes the best metric of an inclusive definition of 
"public transport" access. Yes, there are embedded 
assumptions in how it is defined and these can be 
elaborated on in the process of refinement. 

2.43 TR1.1 Data element C2 refers to 
dwelling units. Some indicators measure 
households and some dwelling units. 
Metro's don't necessarily measure both, 
and neither does Stats SA. There should be 
consistency across all indicators. 

The indicator is Tier 3 and so these comments are 
noted to feed into the process of refinement. Dwelling 
units and households are defined differently and 
clearly in C88. At no point are municipalities asked to 
report on households as this is a social construct they 
are not expected to have the methodologies to reliably 
produce data for annually. 

2.44 TR1.11 The definition of data 

element B1 includes taxi ranks as 
scheduled access points. However, taxi 
ranks are not always scheduled stops. 
Further, taxi's stop wherever they please 
and these stops are currently not being 
considered. However, measuring these 
stops remains an issue.What happens 
with mixed use developments i.e. do we 
exclude these? 

The indicator is Tier 3 and so these comments are 
noted to feed into the process of refinement. 

2.45 TR1.12 Number of operational public 
transport access points added - the issue 
of access points need to be clarified. Per 
the KPI definition, access points include 
railway stations, etc. which are not Metro 
competence/ responsibility. The TID 
further indicates that the access points 
counted should be operational. Where the 
access point has not been added by the 
City, the City should not be held 
accountable for it. This is an output KPI 
which will be on the individual 
performance plan of the management. It 
is therefore not fair to hold them 
accountable when adding/ 

operationalization of some access points 
is not within their control. 

The indicator definition should be clarified to identify 
only those transport access points that are the 
responsibility of the municipalities. This will be further 
clarified in an erratum/supplementary communication 
with the exemptions. Updated TIDs will reflect for the 
2020/21 planning and reporting period by November 
2019. 


13 





Question 

National Treasury response 

2.46 TR1.12 This is an output indicator but 
the definition for data element B3 include 

commuter rail stations. The indicator 
definition (A6) also indicates that the 
access points should be operational. 
Construction and ensuring rail stations are 
operational are not the responsibility of 
the Municipality. As such, the Municipality 
is not fully in control of this indicator. Rail 
stations should be excluded. 

This point is noted and the definitional clarification 
excluding rail stations is supported. This can be 
formalised for the 2020/21 planning and reporting 
period by November 2019. 

2.47 TR1.12 The same comments made 
previously regarding taxi ranks also 
applies. 

See previous comments in response on the taxi ranks. 

2.48 TR1.12 The word "operational" in the 
A6 definition for the indicator needs to be 
further clarified - what is meant by 
operational? 

"Operational" refers to access points that are in use by 
service providers and commuters during the period of 
reporting. This will be further clarified in an 
erratum/supplementary communication with the 
exemptions. Updated TIDs will reflect for the 2020/21 
planning and reporting period by November 2019. 

2.49 TR1.2 Do we need to count cycle 
lanes which are essentially road lanes that 
are restricted for cyclist use during certain 
times of the day? 

The indicator is Tier 3 and so these comments are 
noted to feed into the process of refinement. 

2.50 TR1.2 Does data element Cl refer to 
surfaced road network only or both 
surfaced and un-surfaced? 

Surfaced, but this can be clarified as part of the process 
of refinement. 

2.51 TR1.2 In terms of data element B6, 
please provide further clarity i.e when it 
says "counted double", does it mean 
count once for each side of the road? 

It is referring to both sides of the road, but this is a Tier 

3 indicator and so will be further clarified as part of the 
process of refinement. 

2.52 TR3.11 Definition of data element B1 
talks about fare collection on weekdays. 
What happens in the case of monthly or 
weekly tickets which are paid upfront for 
a number of trips? 

This depends on how the fare/tickets are collected or 
charged which may differ in different municipalities. 
The SOP of a municipality is where the municipality 
should explain how it has accounted for weekly or 
monthly fare collection. 

2.53 TR4.21 We are currently unable to 
report on this indicator. The unit 
responsible has indicated that they 
currently measure departures on time and 
not arrivals on time. Could we measure 
departures instead and indicate as such in 
the SOP? 

Yes, it is more important to measure something that 
approximates the exact definition of the indicator than 
not to report on it. Note that while this will produce a 
slightly different indicator than what was intended, this 
will be provided for in an erratum/supplementary 
communication with the exemptions. Updated TIDs 
will reflect for the 2020/21 planning and reporting 
period by November 2019. 

2.54 TR4.21 What is referred to as a 

"scheduled" bus? 

This refers to the time at which the bus is scheduled for 
arrival and departure against which to measure 
whether it is "on-time". This will be further clarified in 
an erratum/supplementary communication with the 
exemptions. Updated TIDs will reflect for the 2020/21 
planning and reporting period by November 2019. 


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Question 

National Treasury response 

2.55 TR6.11 Please clarify if this figure 
should be cumulative over the years as it 
does not seem to be meaningful if only 
figures for the year are reported. 

Yes, it is cumulative over the year and this can be 
clarified in an update to the TID for the 2020/21 
planning and reporting period by November 2019. In 
the meantime, it should be treated as cumulative. 

2.56 TR6.11 Is there a specified time 
required between grades i.e. can we count 
the road even if it's only been graded once 
in the year? 

Yes, even if it was only graded once within the year 
financial year being reported upon. 

2.57 TR6.12 The definition for date 

element B3 refer to class 3-5. Is the 
classification known by all role players and 
standardised across the board? 

That is the understanding at present. 

2.58 TR6.12 Definition C3 refers to 
municipal road lanes classified as surfaced 
in kms - Is this the total network length or 
annual target length? 

This is understood as the total network length, not the 
annual target length. This will be further clarified in an 
erratum/supplementary communication with the 
exemptions. Updated TIDs will reflect for the 2020/21 
planning and reporting period by November 2019. 

2.59 TR6.12 Please clarify what is meant 
by road lanes. Past discussions held 
alluded to the fact that it should be actual 
length as opposed to lane km's as the 
concept of road lanes was not clearly 
understood by all. 

Roads have different widths, and maintenance of 
paving is two-dimensional - a question of length and 
width. 

The number of lanes is simply a way to account for road 
width. 

E.g. Maintaining 1km of a two-lane road (one lane in 
each direction) is equivalent to 500m of four-lane road 
(two in each direction). This will be further clarified in 
an erratum/supplementary communication with the 
exemptions. Updated TIDs will reflect for the 2020/21 
planning and reporting period by November 2019. 


Water and Sanitation (WS) and Fire and Emergency (FE) specific indicator queries 

The following refers to questions relating to the application WS and FE indicators from 
Circular No. 88 


Question 

National Treasury response 

2.60 WS2.11 The minimum standards is 
not defined and there is no legislation / 
criteria referred to in the TID, on which an 
assessment will be made to assess the 

minimum standard. 

Basic standards are defined in the preceding outcome 
indicator (WS2.1) and can be referred to for this 
purpose. Explicit acknowledgement in the definitional 
update can be provided. This will be further clarified in 
an erratum/supplementary communication with the 
exemptions. Updated TIDs will reflect for the 2020/21 
planning and reporting period by November 2019. 

2.61 FE 1.21 Number of reservists and 
volunteer responders per 1000 population 
- Currently does not apply to [our] Fire 
Services as we do not have reservist or 
volunteer fire fighters because the 
municipality employs full time 

professional fire fighters through its 
recruitment and training processes. If this 

The indicator is currently Tier 3 and so does not yet 
apply. These comments are noted to feed into the 
process of refinement. 


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indicator is required to be included in 
2019/20, how do we deal with the 
reporting? Is it sufficient to say Not 
applicable? 


16 


City Transformation specific indicator queries 

The following refers to questions relating to the application 1C and CC indicators from 
Circular No. 88 


Question 

National Treasury response 

2.62 IC2, IC5, IC7 - National Treasury's 
assistance is requested. We have no 
baseline information as the land use 
information has not been updated for the 
past 15-18 years. This work requires a fair 
amount of resources over a sustained 
period and our attempt to outsource 
proved to be too expensive (submissions 
received were between R20-30m). We 
have now started doing this internally on 
an incremental basis but this is not ideal as 
it will take us more than 3 years to cover 
the integration zone alone by which time 
most of the info will be out of date. Going 
forward, a mechanism to generate 
baseline info and update same on an 
ongoing basis is required and this is where 
we require assistance from NT. In the 
meantime, we can attempt to define 
realistic 3-5 year targets within the 
parameters of the prevailing constraints. 

The constraints and challenges in this regard are noted, 
but nevertheless these indicators still apply on the 
basis of Circular No.88. Consideration of any definition 
revision will be made for the 2020/21 planning and 
reporting period by November 2019. 

2.63 CC1. Hectares approved for future 
development outside the 2015 urban 
edge as a percentage of Hectares 
allocated for future development as 
defined by the 2015 MSDF - Using wrong 
year for urban edge - 2018 adopted in SDF 
and it's a very different line now. Some 
areas outside urban edge have their own 
development lines, which have their own 
"urban" areas. Which urban edge is being 
referred to? 

This refers to the municipality defined urban edge for 
clarity, this may refer to the closest preceding year for 
the urban edge. Consideration of any definition 
revision will be made for the 2020/21 planning and 
reporting period by November 2019. 

2.64 IC6 - We are unable to calculate 
complete figure - subsidy units also 
provided by private sector. Subsidies 
catering for new CRU units including 
GAP/Social Housing units have been 
factored into the MTEF delivery within the 
Prime Investment Corridor. The latter is 
largely provided by the private sector and 
Social Housing Institutions. We can supply 
BNG housing figures. 

The TID for IC6 does not specify that this should include 
subsidy units provided by the private sector, but 
specifically refers to those provided by public sector 
subsidy. The metro need only account for these. 


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