E-toll price comments ready to be received

Thanks Jan, but have they confirmed that the date for comments will be extended due to this?
 
So now, after building the whole damn thing, and after the supreme court declared that it's too late to do anything, NOW they ask for comments?
 
So now, after building the whole damn thing, and after the supreme court declared that it's too late to do anything, NOW they ask for comments?

This is to comment on pricing. Ridiculous, I know. Pricing was a pivotal aspect of comments relating to the actual project itself, but somehow the court has ruled against that logic. Everything about this is perplexing, and completely arse about face...
 
So now, after building the whole damn thing, and after the supreme court declared that it's too late to do anything, NOW they ask for comments?

DJ... said:
This is to comment on pricing. Ridiculous, I know. Pricing was a pivotal aspect of comments relating to the actual project itself, but somehow the court has ruled against that logic. Everything about this is perplexing, and completely arse about face...

The way I understand this is that it's just a legal box that needs to be ticked. They'll likely delete all comments upon receipt.

Still, though, here's my comment to SANRAL and the DoT:

middle_finger.png
 
Here's mine:

Dear Mr T.H.M Mphahlele,

Please find below my official comments relating to the Gauteng e-tolling project and the associated pricing.

1) Your price points do not make sense in terms of the value of the Sanral bond issuances, and the specific events of default clauses in the associated prospectuses for the medium term note programme. Based on your existing price points, your cashflow would not be sufficient to repay the outstanding debt and interest component within the time-frames demanded of the bond issuances, as agreed with your creditors. I have attached various calculations that show, using various scenarios based on the information released by Sanral, the challenges associated with meeting your debt obligations.

2) As per the attached calculations, Sanral will need to charge in the region of R1800 per month per vehicle, working on 6 years of income until debt maturity and operating on the assumption that the full amount is paid to creditors and not reinvested into maintenance and further infrastructure development. Anything short of this number will result in a serious shortfall and will over the course of the bond term, trigger a default, which would be a precarious situation considering that the bonds are not only government guaranteed, which would impact negatively on our credit rating and have significant impact on the economy as a whole, but also that they were mostly subscribed to by the GEPF, effectively using the pensions of government employees to fund this project. This is unacceptable on all counts, and requires a complete re-think of the income streams, price-points, and collection agencies. In any business, if a cashflow issue arises, the first thing to look at is minimising costs. In Sanral’s case, a large proportion of the cost component is made up of collection fees, most of which do not remain in the country. This relationship needs re-evaluation in order to minimise costs to South Africans, which should be a priority.

3) The cost of the construction has been officially deemed to be inflated due to collusion from Sanral’s construction partners. Price points have been set without factoring in allocations from the fines paid by the construction industry.

4) There is no transparency into GFIP’s financials, yet you are asking us to comment on the fairness of the proposed tariffs. It is nigh on impossible for a person to properly apply their mind to the pricing issue if Sanral (a government agency) refuses to disclose its financials to the public. It is disingenuous to ask for comment on an issue with so many moving parts while Sanral and government refuse to provide the information relating to those parts, especially the single most important parts.

5) It is clear based on the lack of public uptake of etags, public revolt, political revolt, and union revolt, that Sanral will face massive challenges in managing their debtors book. Once this is finally accepted by management and government, we can move towards a solution. Refusing to acknowledge such a problem means that it has not been properly taken into account when attempting to price the system as a whole. Considering the requirement of a steady cash flow in order to prevent a bond default, it is imperative that Sanral come up with solutions to the problems, that are in the best interests of all stakeholders. The public being the largest stakeholder. To date, all proposed solutions centre around punitive measures which only aggravates the public further, and solidifies their disenchantment with e-tolling. If measures are not put in place to address these issues outside of PR and marketing efforts, Sanral will not be in a position to meet their extensive debt obligations as the public further turn against the system. The public are in a position to legally delay payment through objections, and by not purchasing e-tags. Sanral however are not in a position to further delay income streams. This must, as a matter of utmost importance, be addressed. Punitive measures will not buy the goodwill or support of the public

6) Enforcement of the new Sanral act will requires Gauteng motorists to be subjected to different laws to the rest of the country. It also privatises policing, both of which are unconstitutional. To avoid legal challenges and further unnecessary costs to the general public as the public will inevitably pay for defence of both parties), this needs to be urgently addressed and rectified with appropriate amendments.

...
 
Cont...

7) By adding R2,90 per kilometre to heavy vehicles, you are adding close to a 20% total cost increase to the logistics industry, which in turn adds further inflationary pressures through simple economic principles. The further cost burden to every citizen in Gauteng will result in lower levels of disposable income, not only hampering growth, but for many SMEs, resulting frozen employment and/or retrenchments. In addition, all increases to motorists are an effective 100% increase, while we have seen zero reduction in other levies and taxes specifically intended for road infrastructure development and maintenance. Questions remain as to where the money intended for maintenance was spent, as it wasn’t for a long time spent on the Gauteng freeway road infrastructure. One also has to question why Alex Van Niekerk’s original presentation to government, where he suggested a combined MBUF and fuel levy collection system, was ignored?

8) I also object in principle to the vast majority of payments forming the profits of an international company, for which we derive very little value apart from taxation. Taxation that I may add, is reduced in order to secure so-called investment in the country. This is the exact opposite of investment. Investment for the sake of tax income is to the detriment of the tax payer. It is a value dilution agent, as only a percentage of the spend remains in the country. Kapsch have no vested interest in further investment in infrastructure in the country, nor have they ever. Their involvement in traffic camera systems is not an investment in infrastructure. Kapsch is effectively acting as an agent of government, using the tax payer as a forced client through legislation. This is not good governance.

9) E-tolling has been implemented in the most inefficient manner possible, driving up costs for no apparent rhyme or reason. When compared to similar projects in France, for example, where the country bought the hardware and utilised the platform as a proper job creation tool, the entire CAPEX spend was EUR10m. Their operational costs were also minimised and the system was widely accepted by the public. To force exorbitant pricing points on to tax payers in order to recover the cost of an inefficient implementation is just poor governance and should not be tolerated, either by government, or tax payers. Alex Van Niekerk has stated that the cost of toll operations is R12.5bn until 2020 and the CAPEX expenditure was. That is R2.2bn per annum spent to simply collect money from motorists. Working with the maximum possible cap, for 2million motorists subjected to paying e-tolls, that equates to 20% of total income. 20c of every rand paid by motorists goes to the costs required simply to collect the money in the first place. This doesn’t include the debt repayment and interest components. Eventually we land up in a system where about 60c-70c of every Rand paid for e-tolling goes to costs, and only 30c-40c actually goes towards the upgrades and maintenance. That is not acceptable, and the solution is not to increase price-points. The solution is to identify cheaper recovery methods.

10) While Sbu Ndebele was still minister of transport, he made two critical statements that are pertinent to this issue:

o “Furthermore, it is noted that the costs of the ORT [open road tolling] system and COC are not only applicable to the GFIP, but are potentially applicable to the national road network since it fulfils a national function.”
 Government is refusing to acknowledge the possibility of adopting a fuel levy, on the basis that it is unfair to other provinces to have to pay for Gauteng’s roads. What’s important to take into consideration is that the reasons clearly stated for construction in the first place, are that they are of national importance. Government’s change of heart now plays little role in anything after the fact. It informed the decisions at the time, which is the important aspect.
o “There is not enough money available to fix roads, so more toll gates will probably have to be built on national roads, Transport Minister Sbu Ndebele said in a report on Thursday. More than 4 100 km of roads - or 32 percent of the national road network - are in such a bad state that they only have a "structural life span" of five years left. It would cost more than R35-billion to fix these roads before 2014, Ndebele said in Parliament, according to Beeld newspaper. But his department has only R16,8-billion available to do this “
 Sbu Ndebele stated outright that fixing 4100km of road would cost R35bn. the GFIP in fixing only a fraction of this stretch of road, has spent that same amount, excluding interest. Clearly we either had an incredibly incompetent transport minister at the time, for which the tax payers should not have to pay for now, or we have further evidence that the costs of the project were inflated beyond comprehension. Another outcome that the tax payers should not have to pay for.

11) In conclusion, the tolls’ pricing does not make sense from the get-go, and the tax payers will be funding a project that will not survive the duration of its bond issuances. That much is abundantly clear, so one can only assume that the government is hoping that GFIP can survive until after the elections. It is a reasonable conclusion to draw. Furthermore, all points above indicate that the processes, costs, procedures, and entire business model need to be completely redesigned, from the ground-up, in order to protect the country from further economic issues and civil unrest.
 
Thanks Jan, but have they confirmed that the date for comments will be extended due to this?

Nope. Don't know what they're up to today, but the whole media department seems to be out of the DoT office. No-one from the Ministry was available to take my call either.
 
Someone needs to create a site where all people that won't be buying e-tags (or paying) can add their names so Gov can see how many people they will need to chase down for money.
 
Actually there is one point I can't seem to remember any information on - what is happening to the fuel levy money that is derived from these roads? Surely motorists should be refunded this portion if the etoll system is supposed to fund these roads now since this is a free-standing project under a separate company (although a SOE, it is still a separate legal entity right)?
 
Someone needs to create a site where all people that won't be buying e-tags (or paying) can add their names so Gov can see how many people they will need to chase down for money.

What would actually be great is to form a non-profit (think this is what OUTA should do) and get participating petrol stations to allow you to pay 9 or 10c on every litre you purchase which can then be paid to SANRAL. This can then be used to avoid any prosecution by the SANRAL courts as you have paid your dues for the upkeep of the road fair and square. the extra 1c can go to a class action lawsuit to protect those who are part of this.

Something like the suburb or town (I forget where offhand) who managed their own municipal services in a similar manner due to a similar problem. I would definitely be happy to pay like this (it would be much cheaper too!).
 
What would actually be great is to form a non-profit (think this is what OUTA should do) and get participating petrol stations to allow you to pay 9 or 10c on every litre you purchase which can then be paid to SANRAL. This can then be used to avoid any prosecution by the SANRAL courts as you have paid your dues for the upkeep of the road fair and square. the extra 1c can go to a class action lawsuit to protect those who are part of this.

Something like the suburb or town (I forget where offhand) who managed their own municipal services in a similar manner due to a similar problem. I would definitely be happy to pay like this (it would be much cheaper too!).

Moves payment obligations to the petrol stations and the system to manage that would be a complete shambles. In addition it would add to the cost base of the petrol stations and their parents companies.

Will never happen...
 
If purchasing an e-tag is not required by law, I shall not purchase an e-tag. It seems others do not agree, many of them are buying.
 
Like the petitions?

Yeah, if it is on a website it will just be more difficult for them to notice it...or "we have seen how unreliable the internet can be, Anonymous hacked government websites, maybe it is them putting up fake numbers"
 
Moves payment obligations to the petrol stations and the system to manage that would be a complete shambles. In addition it would add to the cost base of the petrol stations and their parents companies.

Will never happen...

I am not suggesting this as a permanent solution SANRAL should implement, but rather as an interim solution to show them how much cheaper it is to run.

It is VERY easy to manage, petrol stations already have card facilities and they can deduct the card and transfer charges which is easily audited. They already keep track of how many litres you buy each time, so not exactly tough to manage.

A simple online app would do the job, you claim you paid, they verify you paid and then need to pay the total of all the individual "etoll" contributions per day/month (monthly would be easier) in to the non-profit's account who would then pay the 9c/l per the total litres contributed and would be able to account for every user on the system's contribution.

So it is a two factor authentication type system - you select the station you are at on the site (or phone app), type in the litres you buy, then they verify it by accepting each request on their side once your petrol card goes through on the system.

Lets just look at the math, if the transaction cost were double the contribution you would pay 18c per l, most cars do at least 10km per litre, so your actual cost is 1.8c per litre towards tolls, make it 2c. How does that compare to the current etoll system? Hell the transaction and management system could be a lot more and it would STILL be cheaper.
 
I should have added that on the petrol station side it could improve business if the other stations nearby do not offer the service.

Remember the cost of transaction for each petrol payment is a sunk cost, a large number of people use cards for fuel purchases, so a few extra R is not going to affect that transaction cost significantly. And a single monthly payment for the total is also not going to cost that much or incur much work since the accounting would be done by the application. Think Paypal style kinda.
 
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