Government bodies are snubbing SA’s golf estates for no good reason

GOLF estate development remains a focal point for the environmental affairs and tourism department, which continues to grapple with its “balanced scorecard” approach to residential estate development, advocating higher density development and a broader socioeconomic investment base.

To date, the department’s approach has been simply to “sterilise” new projects, particularly in sensitive coastal areas in Western Cape, where more than 30 new developments remain on hold within the office of Western Cape MEC for environment, planning and economic development Tasneem Essop.

Developments that remain in limbo include the R1bn Retief Goosen signature LagoonBay Lifestyle development near George, as well as the R1,4bn second phase of the Arabella Country Estate at Hermanus. Both applications have been in the queue for more than three years, adding significant costs to both marquee developments.

Werner Roux, CEO of LagoonBay, says the deferrals have resulted in a number of investors walking away from the development while its community-based, R150m social upliftment programme could be in jeopardy given further delays.

John Bumpsteed, director of golf at Arabella’s Western Cape Hotel & Spa, says Arabella has appealed against the department’s initial negative verdict on the second phase more than a year ago, based on its favourable environmental assessment, shared by Cape Nature Conservation. Arabella is hopeful of a positive outcome.

Bumpsteed says the approval delay was difficult to understand given that the development would benefit the region by creating a greenbelt into perpetuity, as well as creating about 1000 sustainable jobs, with a further 7000 during construction.

Andy Bean, MD of golf course developers Matkovich & Hayes, says modern developers are acutely aware of the impact they have on the environment. “Golf estates are well regulated and the utmost attention is given to ensuring that contractors don’t misbehave. Certainly, the fines handed out in the event of nonadherence don’t make it worth their while.”

Dave McGregor, sales and marketing director of Pinnacle Point Holdings, says developers need to find design and operational solutions that are both creative and economical. “One major cost element in the development of our flagship Pinnacle Point golf development at Mossel Bay was the R24m upgrade and relocation of the inefficient sewage treatment plant, which up until recently had spewed unfiltered sewage into the sea. The upgrade has also allowed grey water to be used to maintain the golf course.”

McGregor says indigenous animals have been reintroduced into the 120ha game reserve, and there has been significant investment to help preserve and encourage the growth of the 264 fynbos varieties indigenous to the region.

Riaan Gous, Arabella Holdings’ executive director and chairman of the Golf Estate Developers’ Forum, says while the continued adversarial relationship between the sector and government is obviously of deep concern to the industry, it is clear that golf plays an important role in the tourism market, accounting for an estimated R23 out of every R100 spent by international visitors.

Yet despite its acknowledged importance to tourism and to the local tax base, local authorities are notoriously uncooperative with golf estates. Pezula Championship Golf Course, for instance, is known to be affected by a water shortfall of about 1,8-million litres a day, as the city has limited its supply of effluent water to 1,2-million litres a day.

Pezula golf superintendent Andre Gerber says formal representation to the municipality has fallen on deaf ears. “Pezula has not taken municipal water for more than two years, so we are reliant only on rain and effluent water.

“But the lack of rainfall in December has taken its toll on our cool-season grasses, so we are focusing on ensuring our greens are watered — to the detriment of the fairways and rest of the course. The director of water affairs has basically told us that their doors are closed to us,” Gerber says.

Bean agrees that within the South African context, water is the biggest issue. “Grasses such as coastal paspalum are being used that can be irrigated with salt water and we are continuously assessing and researching better irrigation methods,” he says.

At Elements Private Golf Reserve, for instance, water usage has been reduced through the bush oasis style of the course, while Ebotse Golf and Country Estate has rehabilitated a disused kaolin mine, covering the surface with indigenous bushes, grasses and trees. At Cotswold Golf Estate, Matkovich & Hayes is growing more than 15000 indigenous trees as well as 3,2- million sprigs of indigenous grass.

“Most developers are going well above and beyond environmental regulations, and most also have substantial spin-off economic benefits for local communities. Delays simply send the wrong international message,” says Roux.

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Pebble bed fuel gets nod

January 30 2007
The government has given the final go-ahead for the production of nuclear fuel for the controversial Pebble Bed Modular Reactor (PBMR) project at Koeberg, and for the transport of both this fuel and the raw material used to produce it.

This follows Environmental Affairs and Tourism Minister Marthinus van Schalkwyk's dismissal of several appeals against his department's earlier approvals of the project.

The nuclear fuel will be manufactured by the Nuclear Energy Corporation of South Africa (Necsa) at a pilot plant within its Beva complex at Pelindaba in North West.

The raw material for the fuel will be transported to Pelindaba from Durban, and the manufactured fuel will be brought from Pelindaba to Koeberg.

Meanwhile, the closing date for comments on the Revised Final Scoping Report for the project has been extended to March 10. Scoping is the first phase in the statutory environmental impact assessment (EIA) process.

The extension was welcomed by the Cape Town branch of Earthlife Africa.

The organisation had earlier expressed "outrage" at the four-week comment period for the highly technical, 633-page report, which it described as "attempts to curtail public participation in decision-making" about the PBMR project.

A former director general in Van Schalkwyk's department, Chippy Olver, issued a positive record of decision (RoD) approving the application to manufacture and transport the nuclear fuel in June 2003.

He issued a positive RoD to Eskom Holdings Limited at the same time, approving the environmental aspects of the proposed PBMR project at Koeberg. He linked the two decisions with a clause stating that the authorisations were dependent on each other.

There were appeals against both RoDs but, before any decision was made, Earthlife Africa successfully challenged the RoD granting in respect of Eskom's application to build the PBMR at Koeberg in a review action in the Cape High Court.

Announcing his decision on the appeals, Van Schalkwyk said legal advice to his department was that, despite the initial linking of the two RoDs, the decision on the nuclear fuel manufacturing plant was not affected by the court judgment.

Appeals had related to:
# Dissatisfaction with the EIA process, notably the public participation aspect.
# Concern about the long-term storage of high-level radioactive waste and contaminated materials.
# Alleged inadequate consideration of alternatives to the fuel plant.
# Environmental impacts associated with the fuel plant in terms of radiological safety and accident scenarios.
# Economic feasibility, financial guarantees and public funding of the project.
# Opposition to the de-linking of the fuel plant and the PBMR, "with the contention that neither process should be viewed in isolation".

Van Schalkwyk said the two projects would be established in different places, were different in nature, and had "vastly different" environmental risks.

"Although they might be related, it is clear that each project could be implemented independently from the other."

Referring to concerns about graphite fires, Van Schalkwyk said the nuclear energy corporation had said there were "no feasible scenarios for such an occurrence".

"Adequate measures are in place to ensure that safety and health aspects are sufficiently catered for through the various phases of project evaluation and approval.

"Negative environmental impacts ... can be sufficiently mitigated, provided the conditions contained in this record of decision are implemented and adhered to."

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Lion breeders in uproar about canned hunting

South African lion breeders are prepared to go to court to test regulations on canned hunting, specifically of lions, the deputy chairperson of the South African Predator Breeders' Association said on Wednesday.

While the regulations, to come into force in March, do not ban lion hunting outright, they stipulate the circumstances under which it can take place. What they do not specify is the size of properties on which hunting would be allowed to take place, the association's Thys Mostert complained.

The new laws also require that lions be free-ranging for six months before they can be hunted, he said.

A Department of Environmental Affairs and Tourism statement on the Biodiversity Act regulations on threatened and protected species notes only that hunting camps be "reasonably big", said Mostert.

"We have a problem with this. This could mean that certain people would hunt lions in a two-hectare area. We want the area to be a thousand hectares," he said.

Questioning the period for which the lions have to be free to roam, Mostert said lion breeders do not understand the provision. "Where does [Environment and Tourism Minister Marthinus van Schalkwyk] get the six months from? Why must other animals not walk six months before being hunted?" he asked.

Mostert said lion breeders are aware of the problems in the industry and want to resolve them. "Things need to happen in a proper and ethical manner," he said.

In the Free State alone, up to 100 people have bred lions in captivity in one way or another -- some for tourism purposes, he said, estimating there are about 3 000 captive-bred lions in the country.

Mostert said the answer to the problem of canned hunting does not lie in a complete ban on lion hunting. "Then you have to ban all hunting. This includes buck hunting. Everything," he said.

Banning lion hunting altogether would also leave the government open to claims for costly infrastructure put in place in line with legislation.

The draft regulations on norms and standards for hunting in South Africa were put together by a panel of experts appointed by Van Schalkwyk. In December last year, his department said it had recommended a ban on captive breeding for anything other than scientific and conservation purposes.

Captive bred is defined as "bred in a controlled environment" and refers to enclosures that prevent the escape of listed, threatened or protected species, but facilitate intensive breeding. It excludes breeding on fenced land on which self-sustaining wildlife populations are managed in an extensive wildlife system.

The panel also recommended a prohibition on hunting in national and provincial parks.

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Kortbroek gets new teeth

SA's coast is a treasure and a new law makes sure it stays that way If you own property on the coast, read this carefully.

SA's coast is a treasure and a new law makes sure it stays that way If you own property on the coast, read this carefully. Government is proposing powerful legislation to ensure that SA's 3 000 km coastline is made pristine and kept that way.

Department of environmental affairs & tourism spokesman Niel Malan is adamant that the Integrated Coastal Management Bill will be used conservatively amid fears that government could stick to the letter of the law, which provides it with new draconian powers over private properties.

But the draft bill's 105 sections and three schedules are necessarily tight to protect a vital economic and natural resource. How they will be applied is crucial but the rights given to environment minister Marthinus van Schalkwyk are powerful. They include :

Extending the prohibition on the common law property right that gives families who built illegal coastal holiday homes effective ownership after 32 years beyond the seashore to other public land; Expropriating any property through the Expropriation Act if he wants to add to the coastal public zone (see table, right);

Reducing all leases and occupational rights of restaurants and businesses (including hotels) in harbours or on beaches or other areas in the coastal public zone to leases of between two and four years;

Issuing repair and removal notices for structures, even on private property, in the coastal zone that have been built illegally, or will "adversely affect the environment". Ignoring such an order could result in a fine of R500 000 or five years in prison or community service, or both;

Prohibiting or controlling buildings facing the coastal zone, but located outside it, that might aesthetically or otherwise undermine the zone's precedence over commercial or residential interests; Taking over any private land that falls within the high water mark without compensation; this could be adjusted should the high water mark rise in future;

Declaring portions of private land coastal access land to ensure there are public routes to beaches or other state-owned coastal properties. This can be done without compensation to owners ;

Taking effective control of provincial or municipal environmental management by instructing them to carry out specific actions if he is not happy with the way they manage their coastline;

Creating a national coastal management programme and committee whose decisions override provincial and local committees; and Imposing a coastal zoning scheme that takes precedence over a municipal zoning scheme. Malan says this is to ensure consistency.

The bill attempts to overcome the biggest threat to the coastal environment: poor environmental management by municipalities, most of which are relatively small, or provinces because of lack of skills or corruption.

Malan says that thousands of houses, slipways, jetties and other structures along the coast could be affected. "We are already ordering the demolition of 100 houses on the Groen river and another 100 on the west coast, using other legislation," he says. "But it isn't powerful enough to deal with all the structures."

But he insists that the bill's powers are not excessive. "The powers given to the authorities by the bill are all set within strict processes, including public participation, to ensure they are used transparently and fairly.

"For instance, we intend honouring existing leases and rights and the people who have them have nothing to fear as long as what they are paying for them is market-related and their activity doesn't threaten the environment." But Malan concedes that existing leases and rights will automatically be reduced to a maximum of 49 months until the minister converts them to coastal leases - which he can refuse.

Environmentalists are thrilled with the bill and the rewards of a pristine coastline should be incalculable for tourism and the economy. But the minister's new powers over private property and local authorities may raise serious concerns about infringing existing rights. They could have a tough passage through public participation and parliamentary processes.

The bill comes at a time when government is considering other measures that could affect private coastal property ; this week agriculture & land affairs minister Lulama Xingwana received the final report of the panel of experts appointed to look into the regulation of property purchases by foreigners. The report is likely to be published early next year.

In its interim recommendation, the panel suggested an immediate freeze on the sale of properties to foreigners, but that was rejected by government.

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New hunting legislation makes no difference

The government says it has banned canned hunting, but wildlife organisations claim it has not.

All the government has done with its new hunting legislation, say wildlife organisations, is to rule that no large captive-bred predators, like lions, may be hunted within six months of their being released onto a property.

After six months, there is nothing in the legislation to say they cannot be hunted, nor is there any stipulation of the size of the property on which the hunt can take place.

When the legislation was released in Gauteng on Tuesday, media were told by Fundisile Mketeni, a deputy director at the department of environment affairs and tourism, that Environment Minister Marthinus van Schalkwyk had been threatened with major lawsuits by lion breeders and hunters if he banned canned hunting.

But on Wednesday Environment Affairs' director-general Pam Yako issued a statement which contradicted this, and said "canned hunting will continue to be prohibited in terms of yet-to-be-promulgated regulations".

Yako added: "While we endorse the notion of sustainable use, the department shall never condone unacceptable hunting practices, including the so-called canned hunting, or purely economic activities disguised as industry contributions to wildlife management strategies."

But Jason Bell-Leask, of the International Fund for Animal Welfare, says the regulations do allow canned hunting. He says the government has clamped down on the practice, by outlawing the hunting of drugged animals and other measures, but it has not banned it.

"Breeding of lions is still allowed, and the captive-bred lions are still allowed to be hunted. What is different is that they cannot be hunted immediately, but you will have to wait six months to do so.

"And the legislation makes no stipulation of the size of the property on which these captive lions can be hunted. One of the issues about canned lion hunting was the small size of the enclosures that they were hunted on. So we still have captive-bred lions being hunted on small properties, some of them smaller than rugby fields.

"If that is not canned hunting, what is? Where is the principle of fair chase?" Bell-Leask said.

He said the business interests of the hunting industry had prevailed over the welfare of the animals.

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Cops watch as crayfish is poached

Fishermen and women illegally poached hundreds of crayfish off the coast of Paternoster in broad daylight, after first warning authorities of what they planned to do.

Police kept a low profile on Tuesday, with only one car in the beach parking lot, as the fishers went ahead with their act of defiance to highlight their exclusion from the fishing rights process, along with the environment minister's failure to respond to repeated requests for relief.

In spite of not having the necessary permits or licences, the fishers put to sea about 7am in 20 fishing boats to harvest crayfish.

After hauling about 12 full crates back to shore about noon, unchallenged by the authorities, and applauded by supporters, the fishers stood selling their catch to passing tourists.

A group of traditional fishermen and women from Paternoster and neighbouring West Coast fishing towns gathered on the beach in support of those who risked being jailed.

Naseegh Jaffer, director of Masifundise, a trust that promotes the rights of fishing communities, said a request had been made to environment minister Marthinus van Schalkwyk to provide emergency relief for the fishers during the Christmas season. The request was to allow fishers to remove 10 crayfish and 50 linefish each day.

Jaffer said Masifundise had contacted Marine and Coastal Management inspectorate about their planned harvest and had invited Van Schalkwyk to the beach to meet them.

Following the successful protest, Jaffer said: "What it did was to build a sense of solidarity and openly displays a net of defiance."

Christa Taylor of Paternoster waited anxiously on the shore for her husband Derrol and the other fishers to return on Tuesday.

The Taylors have three children, one of whom works in a fishing factory, and have lived in Paternoster all their lives.

"Our people have nothing. The government is making criminals of us," she said.

The family has a permit to remove and sell four crayfish a day. Selling these on the black market brought in about R100 "on a good day".

"But not every day is a good day," she said.

André Share, chief director responsible for resource management at the marine and coastal management branch of the department of environmental affairs and tourism, told the Cape Argus his department could not allow the lawlessness to continue.

He said they were awaiting reports of Tuesday's illegal fishing operation from fishing control officers.

Share was unaware that the department had advance warning of the action.

"Nowhere in the world would fish and fish alone be able to sustain an entire community," he said.

The department would conduct a socio-economic impact study to determine the damage and would look into alternative possibilities for the people involved in the action, he said.

The fishers said they had invited Van Schalkwyk because they wanted to show him that they were only trying to feed their families.

They also wanted him to see the traditional boats and gear so he could understand proposals they had submitted requesting the prioritising of the rights and needs of the traditional fishing sector.

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Scramble to ease jitters over foreign land sales

Environmental Affairs and Tourism Minister Marthinus van Schalkwyk yesterday moved to calm a jittery property market, saying the draft Integrated Coastal Management Bill would not restrict foreign purchases of coastal land — as threatened by a senior government official last week.

A cabinet statement last week that said draft legislation would help curb the sale of coastal land to foreigners caused consternation, especially at the luxury end of the market. Of an estimated R2-trillion worth of property assets in SA, about R22,5bn worth is owned by foreigners.

There have been repeated threats of a curb on the sale of land, especially coastal land, to foreigners, and last week’s cabinet statement appeared finally to give effect to these threats.

The cabinet statement said: “The environment and tourism minister (Van Schalkwyk) will announce further details on what steps government could take to arrest this trend. Otherwise, South Africans could wake up one day and discover that only foreign nationals and the super-rich had access to our coastline.”

Just hours later, however, government spokesman Themba Maseko issued another statement conceding he had erred in his earlier interpretation of the bill.

He said government had no plans to limit the sale of coastal land to foreigners.

Explaining the confusion, Van Schalkwyk yesterday said the draft adopted by the cabinet last week would give government more teeth to control illegal structures built in the coastal zone.

Although the property industry accepted the clarification, an observer, who declined to be named, said the bill would still shut out foreigners in the coastal areas. “They want stability and do not want to create the notion that foreigners are being shut out. That will be bad for investment. But the reality is that this is some form of regulation.”

The bill, which for the next three months will be open for public comment, gives legal effect to the white paper for sustainable coastal development of 2000 and replaces the Seashore Act and the Control of Dumping at Sea Act. Van Schalkwyk said the bill aimed to preserve the integrity of SA’s coastline but would not restrict the foreign purchase of coastal land as initially reported. It declares the seashore, tidal waters (such as estuaries) and SA’s territorial seas to be coastal public property over which the state must act as trustee, conserving and using it for the benefit of the community and future generations.

“This is the first piece of legislation that gives authority to control illegal structures through issuing of repair and removal notices. This will help government ensure that the ecological integrity of the coastal zone is not compromised”, the minister said.

“The bill also provides new measures to protect coastal areas from being degraded by inappropriate developments and pollution. It will establish a buffer zone inland of the high-water mark within which certain activities will be prohibited and additional development controls will be applied.”

Government will be empowered to prevent development too close to the sea by establishing “set-back lines”.

One provision of the bill will require that public-access servitude be established to ensure that everyone can have access to the coast, which in the past has been restricted by exclusive golf and residential developments.

The bill will also establish a system of coastal planning at national, provincial and local level.

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South Africa to regulate sale of coastal land

The South African cabinet on Thursday approved draft legislation regulating the sale of coastal land to foreigners and the wealthy.

Government spokesman Themba Maseko said the cabinet had approved the Integrated Coastal Management Bill to halt the "unmitigated sale of coastal land which has the effect of limiting public access to South Africa's coastline.

"Otherwise, South Africans could wake up one day and discover that only foreign nationals and the super-rich have access to our coastline," he said.

Further details were expected to be announced by the Minister of Environmental Affairs and Tourism, Marthinus van Schalkwyk on Sunday.

The property boom of recent years has seen a proliferation of houses and golfing estates built along South Africa's coast, reducing public access as well as raising concerns about the effect on the environment.

Earlier this year a government-appointed panel of experts recommended a moratorium on foreign ownership of property in South Africa, after concerns were raised that international bargain hunters in countries with strong currencies were pushing up property prices beyond the reach of the average citizen.

However, Maseko said the bill was aimed at addressing the issue of coastal land being parceled off and sold, but said: "This may be the first legal instrument government is putting on the table as a way of opening the discussion about the sale of land to foreigners in this country."

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Foreigners face SA property ban

The South African government is to take its first step to regulate foreign land ownership - particularly along the Cape coastal area - which it says is being increasingly sold off at excessively high prices which only foreigners and "the super rich" can afford.

Fuller detail of the Integrated Coastal Management Bill will be made known on Sunday by Environmental Affairs and Tourism Minister Marthinus van Schalkwyk.

Government spokesperson, Themba Maseko, said on Thursday that cabinet was extremely concerned about "the mushrooming of estates in many parts of the country particularly in the Cape".

Certain sections of land had "basically been closed off and sold off" at a very high price which "only the super rich and foreigners" could afford.

Maseko, reading a written statement on Thursday after Wednesday's cabinet meeting in Pretoria, said cabinet had expressed its concern about the unmitigated sale of coastal land "which has the effect of limiting public access to South Africa's coastline".

He said the minister of environmental affairs and tourism "will announce further details on what steps government could take to arrest this trend".

"Otherwise South Africans could wake up one day and discover that only foreign nationals and the super rich had access to our coastline," said Maseko.

Focus on foreign ownership of land first arose in August 2004 when then Land and Agriculture Minister Thoko Didiza named a nine-person committee to probe the issue of land ownership and land use by foreigners headed by Professor Shadrack Gutto, director of the Centre for African Renaissance Studies.

Earlier this year Gutto in an interim report recommended an immediate moratorium on the sale of land to foreigners.

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Elephant calves need help

Interim legislation was urgently needed to stop elephant calves from being removed from herds for use in the safari and film industry and as working animals.

This was the opinion of a working committee, consisting of provincial conservation agencies across the country, as formulated in a document compiled by the KwaZulu-Natal department of agriculture and environmental affairs.

This working committee believed tourists should be informed about the "serious ethical and moral" issues regarding the capture and taming of these animals and called upon the national department of environmental affairs and tourism to immediately establish interim legislation on a national level to stop these "unethical practices".

According to the document, permits were still being issued (by provincial authorities who did not form part of the work-group) for the capture and sale of elephant calves. These elephant calves were broken-in and tamed for use in elephant safaris and the film industry.

The working committee proposed that Marthinus van Schalkwyk, minister of environmental affairs and tourism establish interim legislation until the department's norms and standards for elephant management had been finalised, as the lack of legislation created loopholes for the exploitation of these animals for financial gain.

The working committee proposed that the interim legislation should determine that no elephant calves be removed from herds and that the import of these animals, whether tame or wild, to South Africa be banned.

According to the document, people who supported elephant safaris were under the false impression that these animals were saved from culling.

The working committee believed that cruel methods were used to tame the elephants for these industries.

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Numerous flaws with R6bn toll road

The national roads agency has been accused of manipulating a multibillion-rand highway project in a secret report commissioned by the government two years ago.

The 97-page report was quietly released by the Department of Environmental Affairs and Tourism (DEAT) a few weeks ago, following pressure from environmental groups.

The report is a scathing review of the proposed N2 Toll Road between Durban and East London, and details numerous flaws with the controversial R6-billion venture, which was approved by then Environmental Affairs Minister, Valli Moosa, in 2003 but rejected by his successor, Marthinus van Schalkwyk, a year later.

Van Schalkwyk accepted the report’s conclusions that there was a lack of independence of the part of the environmental consultants, Bohlweki, who were partly owned by one of the member companies in the consortium.

But the report has also accused the roads agency, a staunch supporter of the project , of "manipulating" the bidding process to overcome the glaring conflict of interest between the environmental consultants and the consortium.

The report claims the agency achieved this by inserting itself as a co-applicant in the project , thereby hoping "to save the process from legal attack" and "cure the deficiency surrounding Bohlweki’s independence".

Nazir Alli, chief executive of the South African National Roads Agency Limited (Sanral) has yet to see the report. But he defended his agency this week, vehemently denying that it had manipulated the process.

"We didn’t understand the process in terms of who should or should not be the applicant. We did not try to manipulate the process . . . it would be downright stupid of us to do that. It is a total misrepresentation of the facts."

The report also found that:

# The motive for the project was financial gain rather than the provision of developmental infrastructure for surrounding communities;

# The numerous scoping studies and impact assessments that were submitted were flawed and, in most cases, vital information was omitted;

# There were insufficient public meetings and those that were held were used to promote the project , rather than inform people; and

# The impact on historical heritage, and sites of cultural, spiritual and religious importance, as well as the issue of land claims, was not addressed.

All these problems were apparently overlooked by the department when then Director-General Dr Chippy Olver approved the project in December 2003.

It took a flood of appeals and the subsequent report’s findings to convince Van Schalkwyk that his officials had erred, and he reversed the decision a year later. The consortium has since been busy compiling a fresh application.

The department’s spokesman, JP Louw, said approval came from the director-general’s office based on the information submitted to them at the time. "Once the report was commissioned, new details obviously came to the fore," he said.

Cathy Kay of Save the Wild Coast Campaign, which, along with the Endangered Wildlife Trust, pressured the department into releasing the report, said their concerns had been vindicated.

"It’s nothing but a financially driven thing for the benefit of a privileged few. And one can only then query what the vested interests were in this whole issue, from DEAT right down to Sanral, down to municipalities," said Kay.

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