Thank you for your invitation to comment on the proposed tariffs for e-tolling in Gauteng (Gazette Notice No. 35756).
I wish to object to the proposed tolling system for the following reasons:
1. The implementation of e-tolling will inevitably push additional vehicles onto secondary routes, as motorists attempt to avoid tolled routes.
a. Secondary routes are already congested and will unnecessarily increase congestion. This will increase the time taken for vehicles to reach their destination. This will result will be unproductive and cost in delayed arrival and delivery.
b. Secondary routes (roads) have not been adequately maintained. The increased number of vehicles will speed up wear and tear. If local government is already struggling to maintain these routes, then this scenario is going to get worse.
c. Increased traffic will result in an increase in vehicle accidents and (regretfully) fatalities too. I have seen an international report/study which showed the direct correlation of increase in accidents and fatalities where major arterial routes around cities are tolled. Can South Africa afford this when road death fatalities are already so high, especially in the “UN Decade of Action for Road Safety” which the Department of Transport is committed to.
2. In order to reach my destination and minimise unproductive time spent commuting through the suburbs, I am going to be penalised by e-tolling.
a. This is an expense I cannot afford. Even with the proposed cap in place, my income cannot keep up with the all the increases I must bear, such as double-digit percentage increases in electricity, education and food.
b. On top of all of this, this will almost certainly have an impact on inflation, as all businesses will pass on the costs incurred using these roads to the consumer. By way of example, my plumber is telling me with a 33% increase in charges if the tolls come into place.
c. The Government would have me believe that the GFIP will save me money. I strongly disagree. I have seen nothing yet that will convince me otherwise.
d. If the cost of the road was shared more equally across the population, through a mechanism such as a ring-fenced fuel levy, the impact on individuals in Gauteng would not be so harsh.
3. I am not at all in favour of registering for an e-tag, as I am not at all comfortable with SANRAL having direct access to my bank account. I will be prejudiced, as SANRAL will have authorisation to deduct any amount they deem that I owe. I do not see that I will have any means to contest deductions SANRAL makes.
4. Cloning of number plates in South Africa is a real problem.
a. Arrive Alive, The Automobile Association and Business Against Crime SA have all recently warned the public about this scourge.
b. It is reported that as many as 10% of registration plates in Gauteng are false and/or cloned.
c. A number of my friends have had to defend fines incurred from cloned number plates.
d. The introduction of e-tolling will result in charges being incurred by me, family and friends from cloned number plates. In addition, I am convinced that e-tolling will increase the prevalence of cloned plates.
e. Not enough has been done by the Department of Transport and SANRAL to provide avenues for disputing charges I will incur for cloned plates.
f. Unlike fines incurred for speeding, I will have no physical means to dispute fines unjustly charged to me.
5. Regretfully, the approach by the Department of Transport and SANRAL to e-tolling appears to be quite aggressive in its targeting of user who do not have e-tags and/or do not pay. Unfortunately the tone in which this subject has been approached feels aggressive and vindictive.
a. SANRAL has placed huge emphasis on catching the motorists who do not have e-tags and/or do not pay.
b. If I decide not to get an e-tag (even it is my intention to pay for whatever usage) and I happen to use a tolled route, I get the feeling that I will be targeted by the metro police. It is not clear if this will be through the JMPD or a separate and specially created unit, but such an intent exists.
c. Surely the traffic police will be doing far more good by enforcing the laws of the road, which will decrease accidents and fatalities, than the proposed increased expense of “hunting” for road users who do not have e-tags and/or do not pay.
6. I am extremely reluctant to be a part of this project.
a. The whole project is unnecessarily shrouded in secrecy. If I am to pay for these roads, I want to know what I am paying for. You and I will never buy a product if the content/s of it is not fully disclosed before purchase. So it is too with the GFIP.
b. The costs of the project appear to be significantly inflated, especially considering that for the most part, there was an existing road structure and network before the GFIP.
c. The project does not benefit our country or its citizens. Whilst it can be debated that the improved roads are a benefit to us all, the collection system is built and maintained by an international company. All revenue they earn will leave our country and I do not see the benefit to its citizens. Our local economy is already under immense pressure. Jobs are becoming increasingly scarce. Therefore, I cannot understand why we are benefiting an international company/economy.
d. Indications are that the collection systems are almost virtually two-thirds of every rand collected, which means that we will be paying off this project over a far longer period than is necessary. Surely this will also increase the interest we have to pay.
e. The workmanship is questionable. There are many sections which had to be fixed and/or resurfaced. The project is still in progress and not finished (especially in the East Rand).
7. The adverse economical impact of the project and collection system is unacceptable.
a. For decades now, a significant portion of the fuel levy has been earmarked for roads and infrastructure.
b. I pay personal tax toward the national fiscus. In every product I buy, I pay VAT. I pay licence fees.
c. Through all the levies and taxes I faithfully pay, and having been promised by Government that an adequate portion of this goes toward roads and related infrastructure, I must now pay tolls on top of this.
d. Where has all the money gone, which I and all other citizens have been paying for decades?
8. Why is this whole project shrouded in such secrecy? It is the quickest way to get the citizens riled. I want 100% transparency. I do not want to be treated like an adversary, especially if I am obliged to pay for this project.
9. Why must the burden of this project be so discriminatory?
a. The Gauteng province in land area is 1.4% of South Africa.
b. The contribution to GDP is approximately 33% (
http://www.southafrica.info/about/geography/gauteng.htm#.UJeuTWdICeI).
c. The stark reality is that the province which contributes so much to the country’s economy is being hurt hardest. If Gauteng was to benefit from the 33% contribution to roads and infrastructure, I sincerely doubt we would be tolled as is being proposed.
d. I cannot see why the means of paying for the roads must be through e-tolling, severely lacking in transparency, a mechanism proven to be unacceptably expensive, when it should rightly be collected (if existing taxes are not used) through fuel levies, which can easily be ring-fenced for the purpose it is designed.
10. I do not have an alternative but to use these tolled roads. There is no acceptable and reliable public transport system which I can use to commute to work.
a. Metro Bus and BRT are not reliable. There are too many wild cat strikes and labour disputes to make it reliable.
b. I refuse to use commuter mini taxis along the routes I use to and from work. Their drivers are extremely dangerous. They drive at excessive speeds and swerve in and out of traffic. Many are unroadworthy. Some are overloaded.
c. The Government and Department of Transport should not be forcing me/users to pay for roads in the absence of acceptable and reliable public transport alternatives. If it existed, it might have been a little easier to accept tolling.
Although it is my perception (and I sincerely hope that I am wrong) that Government and the Department of Transport are paying lip service to this period of consultation and comment, I feel it is my civic duty to tell you that I will not buy an e-tag, support the e-tolling system and I will probably not use your roads.
I sincerely hope that Government and the Department will not pursue this uneconomical, burdensome route of recouping funds spent, and will reconsider alternatives.
Yours Faithfully.
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