COSATU+Comments+on+ASGISA



=COSATU Comments on ASGISA=

1. Introduction and background
In 2005, at the Presidential Working Group, a slide presentation was made on ASGI-SA. Subsequently COSATU held two meetings with the Deputy President. The first meeting was another slide presentation and at the second meeting the Deputy President received our draft response to the framework document.

COSATU has not had an opportunity to discuss ASGI-SA in its constitutional structures. Interaction has been with small numbers of leaders. For this reason, these inputs remain in draft form, acknowledging the possibility that the broader leadership may still make further inputs that may change some of our positions. COSATU held a workshop on industrial trade policy on the 26 January 2006, where another broader leadership interacted with ASGI-SA and made critical comments that inform this further submission. The next meeting of the constitutional leadership will be the CEC on February 13 to 15, 2006.

It would have been ideal if our constitutional structures had an opportunity to comment and engage with the document. Indeed, it would have been even better if such an engagement had extended to an Alliance Summit.

COSATU would have preferred ASGI-SA to be a more comprehensive overarching economic programme centred on a coherent industrial strategy. Such a strategy would seek to restructure our economy and deal with the deficiencies we inherited from our past. It would place us in a new developmental path that would grow our economy, create quality jobs and ensure greater equity.

As explained to us, ASGI-SA is only a package of measures geared to take advantage of the current economic environment in order to push growth to 6% whilst ensuring that all our people share in the benefits.

COSATU supports the need to intervene and fully supports efforts to push growth to higher levels and for benefits of such growth to be shared. We support some of the proposed interventions, will seek to improve others, and propose to engage on yet other areas. We welcome the government’s emphasis on the need to share benefits of a growing economy. We seek to ensure that the ASGI-SA goes beyond rhetoric to define policy instruments and programmes that are deliberately and specifically designed to create a more equitable society.

The fact remains, however, that all the Alliance parties agree that a comprehensive development strategy is required. Yet we do not have a timetable or process to develop the elements we all agree are needed for such a strategy. The risk is that an effective, transformatory development strategy, including industrial and agrarian strategies, may come too slow or never even emerge.

We here first outline the main gaps we see in ASGI-SA, and the implications for how it is taken forward. We then make more detailed points about the proposals.

The ASGI-SA framework identifies an important problem – slow and inequitable growth – and points to some key reasons rooted in the inherited economic structure. While many of the proposed solutions have considerable merit, they do not adequately reflect the overall aim of inclusive, shared growth, and taken together seem inadequate to achieve the desired aims. This means we must locate ASGI-SA clearly and narrowly as a commitment to shared growth, rather than as a statement of consensus on how to get there.
 * 2. Positioning ASGI-SA**

The lack of a broader strategy that can mobilise the Alliance must be urgently addressed. We identify some areas in the course of this document which we believe need to be prioritised if a practical strategy to promote equity and redistribution is to be placed at the centre of ASGI-SA.

We agree that:

1. The commodity price boom and prospects for a more expansionary fiscal policy, in particular, support accelerated economic expansion. In this context, ASGI-SA should seek above all to ensure prioritisation of shared growth. In other words, it must send a clear signal that growth on the historic path, which enriched only a relative few, is not acceptable. We cannot have growth for some, and pain and misery for the core constituency of the ANC and the liberation movement.

2. While the document may be seen as an improvement in some respects, it largely continues the existing //ad hoc//, inconsistent, and sometimes contradictory approach to key strategic challenges. The absence of a coherent strategy to deal with the critical issues of inequality, unemployment and poverty bedevils the good intentions of ASGI-SA.

3. The //Growth Strategy// pays lip service to the issues of redistribution and inequality, but lacks any systematic attempt to ensure that Growth of whatever figure – 6% or more - doesn’t perpetuate the current Growth Path of inequality - i.e. it doesn’t address the critical question of how to ensure that the //beneficiaries of growth// don’t continue to be largely the same suspects. (There is no deliberate strategy of redistribution in ASGI-SA - chasing of growth or employment targets is not specifically biased towards a deliberate impact on the poor- e.g. there is no mention of decent work, combating casualisation etc. to ensure that rising employment figures are not accompanied by a growth in the working poor- in fact the proposals in relation to textiles would achieve precisely this result). Strategies to address the economically marginalized, second economy etc. tend to be add-ons, to a //largely// market-driven strategy- although there are some tentative shifts in the direction of a more interventionist role for the state.

4. We can ensure more equitable growth through measures that ensure growth is combined with:

a. Employment creation, on a enough large scale drastically to reduce the level of unemployment, which requires a shift in the structure of production b. Combating casualisation of labour which is building a large army of working poor c. More equitable ownership, for instance through aggressive agrarian reform that will ensure faster and wide spread land redistribution, food security and livelihood support programmes in the rural areas. We require more social protection funded through the progressive tax system. We need a deliberate strategy to change patterns of ownership through empowerment of the majority through a much more aggressive development of coops and such other scheme that promotes collective ownership of the economy. d. Investment in human capital – education, skills development and healthcare. We need a more deliberate strategy for employment equity to ensure promotion of black people, women and people leaving with disabilities.

5. ASGI-SA identifies only some programmes to achieve these aims. Moreover, COSATU cannot agree with the details of some of its proposals.

6. As agreed at the last Alliance Summit, the Alliance must still develop a more comprehensive vision that will guide long-run development to build a more dynamic and equitable economy.

COSATU is only able to support ASGI-SA if agreement is reached that:
 * ASGI-SA needs to be fundamentally designed to ensure that our common commitment to shared, rather than inequitable, growth runs through all its programmes
 * Proposals to introduce reduced rights for workers in small businesses, weaken the scope of centralised bargaining and possibly use regulatory impact assessments to review and attack labour rights, are removed
 * The specific proposals in the document, for instance on sectors and infrastructure projects, require much more work to secure alignment around a common developmental vision
 * The Alliance will set in place a practical programme to develop a common understanding of the broader growth trajectory, identifying the role in all the major sectors and social programmes in establishing a more equitable economy.

While we appreciate the important contribution a programme such as ASGI-SA could make, without a broader development strategy it will be measured against the Alliance commitment to a transformatory growth project, and found wanting. Indeed, parts of it could be used to erode the commitment to a better life for all.

3. Overall assessment
As we understand it, the core elements of ASGI-SA are:

1. An effort further to reduce fiscal dissavings and maintenance of the current inflation-targeting regime, with some efforts to ensure a competitive rand through increased reserves.

2. A substantial increase in public-sector investment.

3. Sector strategies that target labour-intensive activities, starting with back-office processing (BPO) and tourism.

4. Programmes to improve education and training and, where necessary, import skills from abroad, led by a new, high-level tripartite council.

5. Support for selected “second-economy” activities and deregulation for SMEs.

Taken together, the elements of ASGI-SA are not adequate to achieve the desired transformation of the economy. Indeed some aspects, if not corrected, could undermine it. As ASGI-SA itself points out, the core challenges are to define the way forward from a history of impoverishment of the majority and dependence on a relatively capital-intensive, concentrated mineral-energy complex. In this context, shared growth requires decisive action to support employment creation, more equitable ownership and income redistribution through social-protection programmes. From this standpoint, ASGI requires more work:

1. To ensure that the sector strategies for both the first and second economy and infrastructure investment are co-ordinated around a long-term vision for more equitable growth. Such a vision should suggest how the core sectors of the economy (mining, agriculture, manufacturing and both public and private services) must develop in order to support shared growth. Activities that create quality jobs must be at the core of the economy, not just added on enclaves. That means, too, that economic policies must seek to retain existing jobs and make them sustainable. This approach would make it possible to align infrastructure projects to encourage a more appropriate economic structure, rather than reinforcing existing inequities.

It is further critically important to massively expand agrarian reform, addressing in particular the mass poverty of the former homeland areas and the oppression of farm workers. In addition, we need a strategic perspective on mining to define its contribution to growth irrespective of price fluctuations and the maturing of resources.

2. To identify the role of social protection in economic development. The RDP expected redistribution through the state combined with regional co-operation to expand domestic demand especially for domestic products. This proposal built on the recognition that successful industrialising economies have all undertaken extensive programmes to support more equitable growth through a combination of infrastructure and housing programmes, massive investment in education and training, and support for small enterprise, including agrarian reform. In the current version of ASGI, however, social protection plays no visible role in supporting broad-based economic growth.

3. To define what kind of jobs constitute acceptable employment. We have to talk about the quality of jobs that are being created. Will they help us halve poverty by 2014? For instance, Checkers Shoprite now employs 80% casual and part-time workers – a total of 40 000 in its 300 stores. The CEO earned R57 million last year. The COSATU Treasurer has been working there for 25 years and gets R4008 a month before deductions. Virtually all studies show that real wages have stagnated in the past ten years.

We must talk about these types of inequalities that are becoming a feature of our economy. It is a huge weakness that the document does not discuss the issue of quality jobs as a critical element for reducing inequalities and ensuring shared growth.

4. To have a genuine Alliance debate on fiscal and monetary policy. Will it be a feature of our democracy that we just agree to disagree on this question? Will we ever have a proper debate on it? Clearly, the relatively expansionary fiscal policy of recent years has underpinned improvements in growth rates as well as permitting expanded social protection. What are the lessons for ASGI-SA? With our very low budget deficits, and large tax cuts, there is room to adopt a more aggressively expansionary fiscal policy.

In contrast, the continued relatively rigid monetary stance has contributed to slower growth by maintaining high interest rates by world standards and in real terms (despite the rapid decline in nominal terms). Moreover, it has contributed to inflows of short-term capital that in turn support the overvaluation of the rand. If the state continues with inflation targeting – which COSATU opposes – it should at least ensure a more co-ordinated approach to reducing costs, for instance by controlling administered prices and cutting the cost of wage goods like transport, water and electricity, rather than relying almost exclusively on interest rates. Moreover, we must urgently establish speed bumps to deter speculative capital inflows that help overvalue the rand and support an unsustainable trade deficit.

5. To identify the contribution to shared growth of current initiatives around broad-based BEE. The proposals in the BBBEE Codes represent the most important state intervention in the private sector since 1994. Yet many of the proposals are not aligned with equitable growth. For instance, they provide little or only inadequate support for employment creation, local procurement, growth in co-operatives or broad-based ownership. Government risks sending contradictory signals to big business on the relative importance of developing a small black capitalist class and achieving shared growth.

Unless and until these tasks are undertaken, it will be difficult to take ASGI-SA seriously as a strong programme to bring about shared growth. We need a practical programme of work, above all for the Alliance to build unity around a strong economic and social development strategy in response to the current commodity boom and the past ten years’ experience of persistent economic exclusion for many of our people.

Finally, ASGI-SA faces the massive challenge of ensuring adequate support from both inside and outside the state. In terms of the state, a developmental state requires strong central co-ordination. That means ASGI requires a central institution with the capacity to evaluate progress and the power to guide departments to achieve national aims. Cabinet as a collective lacks the necessary technical back up. The country needs a strong and united agency to drive economic policy.

As for the rest of society, stakeholder mobilisation needs legitimate consultation plus the mobilisation of ANC constituencies through the Alliance. That means, first, that the demands on key stakeholders must be spelled out in greater detail. Proposals for social compacts have so far largely failed because the government’s expectations of its partners have remained very vague.

The rest of this document critiques the sections of ASGI-SA framework document.

//Section I: Background//
The introductory section tends to emphasise economic growth quite narrowly, with inadequate attention to the importance of ensuring greater equity, including through employment creation. In addition, the target of 6% is not very ambitious when compared to other middle-income countries.

//Section II: Achieving balanced and sustainable growth//
The structural analysis in this section, which points to the risks of dependence on commodity exports as well as massive inequalities, is very helpful. Unfortunately, the analysis of constraints does not adequately pull out the implications.

First, the analysis should explore the impact of commodity dependence more rigorously. We need to understand how the historic dependence on commodity exports shapes responses to encourage exports. Dependence on minerals has persisted, not only because of growing demand from Asia, but also because it is easier for business and state institutions to expand sectors that have formed the basis of the economy for the past century. Over the decades since mining became the lead sector, biases were built up against other activities, such as light manufacturing and services. These biases are deeply rooted in, amongst others, transport, energy, financial, taxation and education systems, as well as in monetary policy.

From this standpoint, regulations are not the main reason for the relative unimportance of small and micro enterprise in South Africa. Rather, they remain marginalised because of the systematic impoverishment of the majority under apartheid combined with the dominance of the minerals economy, which generally provides opportunities only for larger firms. In these circumstances, the opening of the economy with the transition to democracy often led large companies and even government departments to shift to imports at the cost of small domestic suppliers.

Second, the domestic market has to be seen in dynamic terms, in line with the RDP’s philosophy. A critical task is to stimulate domestic demand in ways that support growth in local production. This can be achieved – as the RDP expected – by ensuring that government services both


 * support local production of inputs through targeted procurement policies, and
 * provide services to poor communities in ways that enable better engagement with the economy, for instance through urban densification, primary health care that supports productivity, etc.

//Section III: Macroeconomic issues//
ASGI-SA states ‘no review of macroeconomic policy is required’. This is a mistake. COSATU believes that current macroeconomic policies are not appropriate for development imperatives. Fiscal and monetary policies have not helped as much as possible to accelerate meeting of basic needs. Adoption of relatively conservative policy stances in the face of massive social backlogs has not been helpful.

Fiscal and monetary policy must support overall growth. The section on macroeconomic issues, however, does not set clear guidelines on how this alignment can best be assured.

Macroeconomic policy should explicitly take into account the contribution of the moderately expansionary fiscal policy of recent years to economic growth. In this context, the statements on dissaving need to be explained. This approach should not lead to a contractionary fiscal policy or cuts in social spending.

COSATU has long rejected inflation targeting because it tends to encourage efforts to stabilise the inflation using the blunt instruments of interest rates, at the cost of other major social goals, especially employment creation and growth. In contrast, ASGI-SA suggests that inflation targeting helps to lower interest rates and reduce the cost of capital - in fact it is likely to have the opposite effect, since low inflation targets require high real interest rates (when compared with our trading partners), and make capital and productive investment more expensive, while encouraging speculative investment.

As a minimum, ASGI-SA needs to ensure that efforts to control inflation are not limited to interest rate increases, but rather where possible look to more targeted measures – for instance on import-parity pricing and administered prices - as well as long-run improvements in productivity.

ASGI-SA ignores the impact of short-run, speculative capital inflows in recent years, which both maintain a high rand and fund an unsustainable balance of trade deficit. COSATU has long argued that these inflows should be limited by “speed bumps,” for instance requiring at least 5% of inflows to be placed in long-term bonds. At the same time, we reject efforts to cut exchange controls, which can play a critical role in stabilising capital flows especially if commodity prices fall unexpectedly.

A major concern remains the broad-based BEE process. COSATU participates in a number of BEE Charter processes, including consultations around the Codes of Good Practice under the Broad-based BEE Act and the Financial Sector Charter. Our experience is that many (not all) officials in these processes focus narrowly on shifts in ownership. They underplay the commitment to broad-based empowerment through development of economic capacity and employment creation as well as improved services for communities.

In this context, the draft Codes include strong measures focused on supporting black entrepreneurs that could have undesirable economic and social consequences, for instance by committing state resources to warehousing funds and undermining the support for lower-level workers included in the Employment Equity Act. Given these problems, we cannot afford to accelerate publication of the broad-based BEE Codes at the cost of consultation and, as a result, end up with poorly designed measures.

Efforts to use state pension funds to support investment must ensure adequate involvement of worker representatives in related decisions. Even in the case of defined-benefit funds, worker contributions make up a substantial share, and the quality of financial management will, in the long run, affect payments.

//Section IV: Infrastructure development//
Increased public investment is clearly critical for enhancing overall capital formation. It will have the greatest effect if it crowds in private capital through attention to backward and forward linkages, ensuring the greatest possible multiplier effect and job creation. In this context, we welcome the proposals to support local production of inputs for infrastructure projects, control import-parity pricing and enhance engineering education.

Still, the current projects seem more a shopping list of ideas from individual state entities than a coherent strategy to support shared growth. As a group, they seem unlikely to restructure the economy decisively toward more equitable and diversified growth. The SOE investments, in particular, are geared to support the existing structure of mining and energy dependent growth. While they are certainly necessary, they should be reviewed to ensure that as far as possible they open doors to new industries and to rural development.

In short, the proposals for public investment should be analysed as a package and guidelines developed to ensure the greatest possible contribution to equity and employment creation. Ideally, ASGI-SA would include an understanding of the structural changes needed in the economy, which would permit evaluation of infrastructure proposals in terms of their contribution to those changes. For instance, how do the proposals on transport support the proposed agrarian reform? As a minimum, projects should be included in ASGI-SA only if they will support employment creation or small enterprise directly or indirectly. That means the proponents should have to develop estimates of the likely multiplier effect through linkages to other activities and/or generation of tax revenues or foreign exchange earnings.

ASGI-SA proposes that cost-recovery measures largely fund community infrastructure. But making basic services depend on cost recovery can shut out poor communities. Analysis of income/expenditure data suggests that current charges for education, water and electricity lay a disproportionate burden on the poor. ASGI-SA should establish a monitoring mechanism for tariffs and ensure that they are not regressive.

The proposed expansion in PPPs also needs more reflection. PPPs in basic service can lead to an excessive emphasis on profitability at the cost of delivery in poor communities. Moreover, our experience in the Financial Sector Charter is that government departments cannot define their needs and expectations around public-private partnerships. In these circumstances, it is extraordinarily difficult for private stakeholders to identify appropriate needs and projects.

Finally, this section introduces a rather cavalier approach to the importation of skills. Experience shows that foreign experts are often out of their depth, no matter how strong their qualifications. The continual reference to importing skills reads like a recipe for dependence on foreign expertise.

//Section V: Sector investment strategies//
COSATU has long called for sector strategies, as agreed at the GDS. The proposals in ASGI-SA, however, seem geared to development of a few limited activities, rather than ensuring that all the major sectors of the economy contribute to shared growth through direct and indirect support for employment creation and more equitable ownership.

More far-reaching and coherent proposals would arise if we asked, not what sectors the state should promote, but rather how stakeholders in the most important value matrices can identify and address the main obstacles to job-creating, shared growth. This approach would mean:

1. Sector strategies should be developed for //all// major sectors, including public services and mining, located in a broad vision of the structural changes needed to ensure shared growth.

2. In this context, the strategies should start by asking how the sector can contribute more to equitable growth, and what prevents expansion in that direction. A critical question becomes whether an industry can only produce for export or if it can provide goods that can raise living standards for the poor South Africa and the region. The latter would generally be supported initially by government’s redistributive programmes such as health, housing and education – but only if the state goes further to ensure local procurement. Both types of production are needed for sustainable growth, but currently business (and to a large extent the dti) seems to prefer a narrow emphasis on exports.

Specifically, in terms of the current proposals:

1. The sector strategy on back-office processing (BPO) should be linked to broader development of services, rather than appearing as a single-minded effort to compete for a single segment of global value chains. BPO is amongst the least valuable elements in the services value chain. While it should be encouraged initially as a quick hit on jobs, we should not lock ourselves into competition only on that basis, since that could lead to a race to the bottom.

2. Tourism needs a strategy on internal tourism that is also about nation building and cultural development. Even from a narrow economic perspective, in the long run social cohesion is as important for growth as economic policies.

3. Agriculture and land reform must be linked to issues of food security and basic food processing, for the region as well as South Africa. The current proposals seem to emphasise only relatively high-tech projects, ignoring the importance of developing a strategy on local food processing both to meet basic needs and expand employment. That, in turn, requires a review of rural transport and the (highly concentrated) retail industry.

4. Clarity is required on the proposed approach on bio-fuels. Apart from the economic risks involved, international experience suggests that large scale growth of crops for fuels occupies large areas of arable land, could undermine the growth of food, and therefore food security.

5. The proposals on the chemical sector ignore fast-moving consumer goods like plastics and consumer chemicals as well as construction materials. These subsectors can both provide cheaper wage goods, raising living standards and productivity, as well as generating employment on a large scale.

6. The furniture and white goods sectors are treated as a single sector in ASGI-SA proposals, but they are quite different. Furniture/forestry/paper is an important value chain in itself. White goods needs to look at basic packages for poor households and explore the scope for local production of inputs.

7. We need a broader discussion of mining that, in addition to beneficiation, looks at

a. The potential for diversification through development of new products as well as the prospects for maturing mines. b. Developing capital equipment and chemical inputs production as well as engineering services for export. c. A better understanding of the relationship between the mining, chemicals and energy sectors and how it impacts on the overall structure of the economy and consequently the prospects for shared growth.

8. The importance of a beneficiation strategy needs to be more clearly stated in the document, including the urgent introduction of the comprehensive legislative framework (which has been previously announced) to ensure implementation of this strategy. It is also proposed that this strategy needs to be designated as high priority, given its strategic economic significance, rather than ‘medium term priority’ as is currently the case.

9. The high-tech proposals should build on the core of the economy or social imperatives. It would make more sense to focus on cutting edge mining, tooling, medical and ICT than on aerospace and the Pebble Bed Nuclear Reactor, which are expensive gambles with little hope of substantial domestic multiplier effects.

10. In the section on cross-cutting issues, the emphasis on competition as the main solution for monopoly practices may be problematic in some cases. Given a relatively small economy, we should not ignore the need for economies of scale. In some cases, the only solution is to ensure regulation of prices and profits to compel socially desirable behaviour by monopolies. It would not make sense to encourage competition to SASOL as a way to deal with import-parity pricing; rather, the state must use its influence to ensure that they adopt cost-plus prices.

11. Generally, in line with the MERS approach, a conservative economic perspective appears to be the reference point. The idea of “removing the binding constraints to growth” could refer to ideological issues that are usually used by the right to attack workers, including: ‘labour market rigidity’, ‘high wages’, ‘strong unions’ etc, or could refer to other issues which may not be problematic for workers. Similarly, the notion of ‘reducing the cost of doing business’ can be interpreted in conservative ways, including cutting workers’ pay. Obviously these are contested concepts, but we need to raise the question of who is driving and shaping their use in the context of ASGI-SA, and in whose interests?

12. Further, the issue of the extent of poverty amongst the majority of South Africans is not identified in any serious way as a major constraint to growth, nor, as a related point, is the lack of demand in South Africa and the region. References to such issues, if at all, are largely afterthoughts.

//Section VI: Education and skills development//
The strong prioritisation of education as well as training, and the emphasis on bolstering the contribution of state institutions to skills development, is all very welcome indeed. Still, the specific proposals could be strengthened. General education critically needs a vast expansion in in-service training for educators. There should also be an analysis of learners’ access to better-resourced schools. Currently, the main criteria appear to be residence plus ability to pay, rather than merit or equity. As a result, the suburban schools remain unrepresentative, while continuing to enjoy the best facilities. Finally, maths and science are not the only skills required by the modern economy. Many historically African schools also do not offer cultural skills and computer literacy, both of which are important in today’s workplace.

Higher education remains very unrepresentative in both race and class terms. Overcoming these problems requires both an increase in funding for poor candidates and the introduction of bridging programmes to overcome the shortcomings of schools in poor communities.

Last but not least, there is a widespread perception that the skills development strategy is not delivering adequately. ASGI-SA should provide for an objective tripartite evaluation to propose improvements and set KPIs. ASGI-SA must avoid taking short cuts to problems. This approach may lead to creation of parallel structures instead of making interventions to sort out problems.

//Section VII: Second economy interventions//
This section is by far the weakest in the document. Critical concerns are:

1. The measures on the second economy seem entirely delinked from the proposals for infrastructure development and sector strategies. That will inevitably lead to perpetuation of the inequitable two-tier economy, rather than overcoming it. The main driver for the second economy must be the guarantee that both public investment and sector strategies prioritise more equitable growth and employment in terms of class, race, gender and location.

2. ASGI-SA must include a commitment on sub contracting that ensures that support for small and micro enterprises (and for BEE) does not just downgrade existing jobs, rather than creating new ones. The proposal to encourage outsourced cut, make and trim enterprises in clothing, for instance, seems geared to downgrading jobs in the industry. This was a major concern for delegates at COSATU’s recent Central Committee.

3. There is no mention of support for the co-op movement, including consumer, financial and service co-ops. Yet co-ops are important for social mobilisation, provide a basis for more equitable growth. Experience in both Europe and Asia demonstrates that they can play a major role in economic growth.

4. We still have no visible strategy on the former homeland areas, which remain the poorest regions with the highest levels of un- and underemployment.

5. Traditional healing provides an important source of income and care for many people – but we need accompanying measures to ensure we don’t end up encouraging ineffective remedies for life-threatening illnesses like HIV.

Finally, the ASGI-SA framework proposes research into the impact of the labour laws, especially centralised bargaining, on small and micro enterprise. Research already done with the Presidency demonstrates that centralised bargaining has very little impact on small enterprise. In our view this section does not belong in ASGI and should be removed.

//Sections VIII and IX: Governance and consultation//
The Alliance must do more to understand the obstacles to co-ordination of the state around developmental goals. Unfortunately, the document refers to a Cabinet memorandum on the state that has not been made available, so we cannot comment on it. As noted above, we see a stronger agency, either in the Presidency or through an economic planning ministry, as critical for progress in this regard.

COSATU is concerned about proposals for a regulatory impact assessment, given its historic use by conservatives as a way to attack worker rights. Legislation should only be evaluated against our common objective of shared growth through the creation of decent work, more equitable ownership and investment to achieve those aims. Monitoring and evaluation of ASGI should include a tripartite process, with well-defined criteria and procedures based in NEDLAC.