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Specification, deployment footprint and support model.
South Africa's position here is unusual. The resource base is strong, the regulatory intent is documented, and the execution capacity is thin. Every serious analysis of the sector has to hold all three of those facts at once.
What is actually changing
The detail matters more than the direction. Three provisions in particular change the commercial calculus: the treatment of existing allocations, the sequencing of the compliance deadline, and the point at which liability transfers between parties.
The evidence
Across the reporting municipalities, the spread is wide enough to make the national average close to meaningless. The top decile performs at roughly twice the level of the median, and the bottom decile has not filed a complete return in three cycles.
What it means
For municipalities the implication is uncomfortable: the capability required to administer this properly does not currently exist in most of the entities being asked to administer it. That is a hiring and systems problem before it is a policy problem.
None of this resolves the underlying argument. It does, however, narrow it to a question that can be answered with evidence rather than assertion, which is progress of a kind.
Gerhard Botha
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