]Draft Norms and Standards document seriously deficient 

It is disappointing that the latest "greatly improved" draft Infrastructure Norms and Standards is only a minor improvement on the previous version. 

The latest draft has major deficiencies, is highly vague and fails to provide detail in critical areas. 

The DA's full comment is contained in our submission. Our concerns can be summarised as follows: 

The document fails to define a safe school. There is no indication that a school should not be built from, for example, mud or asbestos.

There are no specific requirements with respect to hostels. The DA has witnessed first-hand the appalling conditions that prevail in many public school hostels. Stating that the plans for hostels are "subject to needs" allows for too many loopholes and limited accountability. 

Ten years is too long for schools to achieve compliance norms for classroom availability, water, sanitation, electricity and security. What about the many schools that currently have no water or no sanitation? There needs to be a temporary solution in the interim - we would argue it is an infringement of rights to expect learners to go without these basic necessities for a decade. 

Provincial Education Departments have 17 years (until 2030) to ensure that all existing schools have, at least, "universal access", a name board, library facilities, laboratories, sport and recreation facilities, electronic connectivity, and safety and security measures. How has this time period been determined? Has it been based, for example, on the findings of the School Monitoring Survey 2011, and on the budgets available? To not have done an extensive calculation of reasonable practicalities is an insult to learners who are deprived of opportunities.

The square meterage allocated per learner will, it is proposed, be measured as an average across the school. No child studies in an average environment. It is essential that every class, and not just the school as a whole, have adequate space for learners (and that, if this is not "reasonably practical", reasons be provided.) 

All compliance with the norms and standards will be subject to "reasonable practicability". "Reasonable practicability" is not defined within the document. Who decides what is "reasonably practical", and when? 

Compliance with applicable legislation was omitted as a requirement; this must be corrected.

The failure to provide detail and clarity provides education departments an escape clause. An official in one province might find certain aspects "reasonably practical" whilst another might find it impractical. The implication is a lack of standardisation of minimum norms and standards due to subjectivity. 

This draft raises more questions rather than answering them. The consultant hired to draft these regulations failed to address pertinent issues.

I will raise questions about the qualifications of the consultant hired to draft these regulations, and the cost incurred. I will write to Minister Motshekga, urging her to acquire a different expert to assess the comments now submitted, and to draft the final regulations. 

The Minister must now gazette the final norms and standards, applicable to all provinces, by 30 November 2013.

We call on her to involve all interested stakeholders in this process and to, at the very least, table the regulations in Parliament before gazetting. We need to get this right - our learners cannot continue to wait for basic infrastructure and resources because regulations are poorly drafted. 

Statement issued by Annette Lovemore MP, DA Shadow Minister of Basic Education, October 14 2013

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