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Last week, Axium took some time to submit comments on the Draft Policy on Rural Education. This was a great chance to reflect on our learning over the years in Zithulele and participate in a process that hopefully aims to deal with the structural and systemic issues facing schools in this area. This is part of what we wrote:

Dear Dr PN Langa,


This comment on the Draft Rural Education Policy is submitted by Axium Education, an NPC based in Zithulele, Mqanduli, within the Eastern Cape.


Axium aims to raise learner achievement in rural schools. For the past 9 years, we have been working from the rural village of Zithulele, in the Eastern Cape. Schools here are located in some of the worst performing districts within what we know to be one of the worst performing provinces. Despite this, Zithulele has become a centre for various interventions aiming to improve access to quality education alongside other services such as healthcare.

Our experience here affirms the Draft Policy on Rural Education’s position that existing assets embedded in rural communities can be mobilised for the development of quality education. However, it also demonstrates the immense investment of both human and material resources required for this to be done. We welcome the opportunity to share some of our reflections at the outset of this policy process, and hope the comments are helpful in taking the document forward.


Firstly, we would like to state our hope that the publication of this draft policy is a positive step toward fulfilling the right to basic education for rural learners. It offers a necessary opportunity to tackle specific challenges facing the rural education sector.

In this section we offer an overview of our reflections on the document and note our key requests at this stage. In the addendum below, we offer more specific notes by page or chapter in the requested format and in the hope that it will make clear where our thematic concerns directly apply.

In principle, the objectives of the policy are to be applauded. It provides a good summary of the main issues and we agree with the substantive elements of the conceptual framework included. We particularly appreciate that the policy highlights the potential within rural spaces, and think that the recognition of indigenous social assets and foregrounding of context-specific solutions is a progressive policy direction.

However, while we generally support the principles embraced, we feel that the Policy in its current form lacks the developed detail and clarity that will allow it to effectively realise its stated objectives. The condition of rural education has rightly been recognised as a crisis. Given that this will be the first Policy dealing exclusively with the situation in rural schools post-1994, we believe there is no room for vague statements or underdeveloped plans even at this early stage in the drafting process.

Before detailing our concerns, we would like to state upfront our belief that more meaningful public participation is required at this stage. The Policy appears to rely on a high degree of public and community involvement for implementation, which is very positive, however it is not clear to what extent the public has yet been engaged in its formulation. Our limited sense from reaching out to other organisations is that many were either unaware of the public comments period or unable to mobilise capacity during it. It is particularly important for school SGBs, teachers, principles, community leaders and civil society organisations currently involved in the sector to be involved in the process. Buy-in will be essential for success and that needs to begin now, but the Policy does not offer detail on how such bodies will be drawn in. We would like to know how this comments period was publicised and would appreciate greater information on submissions received, as well as a commitment to further opportunities for more meaningful participation.

Our comments: This Draft aims to provide a framework within which strategies can be developed. It states in the conclusion that the next step is to “provide a detailed implementation plan that includes a carefully constructed financial plan.” However, our experience has been that the implementation of policy is the key challenge in rural areas due to their particular circumstances. Therefore, a Policy that is not clear at the outset about how existing breakdowns in implementation are to be overcome cannot hope to offer an effective way forward. The Policy is unclear on who is primarily responsible for initiating and overseeing planning towards implementation. It also does not set out when this work should happen nor how it should proceed.

Given this, in our view, the Policy currently falls short in the following ways:

1. Significance of classification needs to be elevated and guided

Section 6 sets out the need to establish criteria for classifying rural schools and mentions a set of indicators that could be included in a classification index. However, it does not go further than this. As the Policy correctly explains, classification is essential for formulating any further strategies. This is absolutely key. We think it should be elevated in the policy and that national government needs to set out guidelines for how classification must proceed.

2. Lack of timeframes and deadlines for implementation

Timely planning for and action on all interventions mentioned in this Policy are clearly essential for effective implementation. However, at present the document includes no timeframes or deadlines for when key actions are to be taken. It is not clear when envisioned bodies like the multi-stakeholder advisory committee or department sub-directorates should be constituted. There is also no mention of timeframes within which plans must be finalised, let alone deadlines for implementation. We request that the Department urgently include these essential details and make them known to the public.

3. Too little clarity on roles, responsibilities and coordination of actors

It is positive that the Policy envisages cooperation across multiple platforms, recognising as it does that education connects to many other key social services. The Policy describes the creation of various bodies holding responsibility at multiple levels of government and including, it seems, external stakeholders in certain instances. However, it is vague in terms of their various roles and responsibilities and insufficiently clear on how they should relate to one another. There are no timelines or principles to guide what reads like a complex bureaucratic system to coordinate.

Overall, it is often unclear whether tasks (such as mobilising communities or building partnerships) would fall to schools through teachers or SGBs, to departmental officials, or to other individuals. It is also not obvious how different actors are identified and mandated, how they would be held accountable, or to whom they should report. Equally concerning is the absence of timeframes within which they should initiate and carry out their work.

In particular, the policy mentions mobilising volunteers in communities, the formation of a Rural Education Advisory Committee, establishing a national team of “key heads of branches” and an inter-provincial rural education committee as well as provincial rural directorates. It does not, however, give any sense of how and when these bodies are to be constituted nor how they are to proceed in the work of interpreting the policy, preparing implementation plans, and coordinating activities.

We feel that the significant potential benefits of multi-stakeholder and interdepartmental collaboration can only be realised if this Policy delineates roles, function, and relationships more directly. This is also extremely important for public accountability, as the public must know who is ultimately responsible for each aspect of the Policy.

4. Absence of mechanisms to ensure appropriate funding and budgeting

In a country that allocates a high proportion of its national budget to education, yet underperforms in relation to many of its poorer neighbours, it is often said that money is not the problem so much as how money is being used. We currently face a complex situation with demands requiring funding at various levels of the education system. It is not clear from the Policy how allocation will be made to ensure adequate resourcing, nor is it clear what type of funding is imagined (differential or redistributive budgeting, directly from national Treasury or through Provincial education budgets?). Finally, and importantly, the Policy doesn’t speak to how current problems like under-spending and the loss of resources through poor security or maintenance are to be addressed.

Our conclusion, based on both research and experience, is that rural schools require significantly more financing than schools in urban settings (and indeed our reading of the draft policy affirms this). As such, funding rural schools is not an “efficient” or “rational” use of resources, and will thus require significant advocacy to key decision makers in order to make this happen.

5. Insufficient weighting of functional services and infrastructure

Our experience suggests that the problems are often not with Policy, but with implementation. Functional services and the delivery of adequate infrastructure in terms of the basic norms and standards are still lacking in many rural schools. There is insufficient emphasis in the Policy on why this is the case and how this problem is to be addressed. In our opinion, issues of infrastructure and functional services need to be elevated throughout the policy, or directly addressed in a specific section.

6. Lack of planned engagement, public participation and accountability

This is a core concern for us. Our concerns around public participation up to this point have been detailed above. Here we note our further concern over how public participation and oversight should be integrated into planning and implementation of the policy moving forward, as is required by the principles of transparent and accountable governance.

This also includes the issue of monitoring from government itself. We appreciate the DBE is mentioned as responsible for oversight, however we feel that the Policy is silent on how this should be done. We would like the following questions urgently answered:

6.1. When will monitoring take place by different levels of government?

6.2. How will stakeholders be engaged in this process? 

6.3. When will monitoring reports be published for public 

7. Insufficient detail on how intended civic agency and community participation are to be mobilised

It is extremely positive that the Policy expressly seeks to mobilise community involvement around education. However, in rural areas that currently and for complex reasons are often characterised by low levels of civic agency, mobilising partnerships and cooperation will be no simple task. In our experience, partnering in education requires sustained commitment to the building and maintaining of sometimes difficult relationships. Mobilising people is a substantial undertaking requiring significant input of time and resources. It is unclear whether schools, teachers or parents, the department, or volunteers will carry this project, and there are also no guidelines for how they should proceed nor mention of how they will be supported. Selection criteria for those involved are also not listed.

Importantly, there is also no mention of compensation for volunteers. Our learning has been that stipends are essential for enabling people to continue this kind of work rather than having to seek limited work opportunities elsewhere. Current government initiatives like the Community Work Programme and the Expanded Public Works offer opportunities for partnership that provide stipended employment, and these should be integrated into the Policy.

For this section of the Policy to be effective, how mobilisation is to be initiated and sustained needs to be set out, along with a clear indication of who holds responsibility for this work. Given that this perhaps entails bringing new people into the school environment and into contact with children, there also needs to be a direct mandate to an accountable body for oversight purposes to safeguard the best interests of the child at all times.

8. Failure to account for and address current failings in the provision of functional services:

While the Policy recognises the challenges in rural areas, it doesn’t go on to map how they can be overcome in order for interventions described in the policy to be possible. This is particularly the case in that it apparently ignores current breakdowns in the provision of functional services and existing issues with the effective implementation of those policies that already exist. We feel that a successful policy must speak to why these issues arise and how they will be dealt with to make sure things work differently. This applies intra-governmentally as well. We cannot sidestep the reality that in many instances, schools in our region receive inadequate support from Provincial and District officials, with well-known examples such as subject advisors not arriving when they are supposed to or textbooks not being delivered to schools on time. How does this policy intend to tackle accountability within government and its partners?

Gaps in the Policy

In addition to the above comments on the existing substance of the Policy, we noticed some areas that we feel should form part of the document. These include:

1. Transport and Time: The movement of learners, teachers, and resources in rural areas is a massive challenge that we feel needs to be directly confronted by this Policy, connected as it is to big challenges in terms of time.

2. Inclusive Education: Rural areas face particular challenges in ensuring all students have access to quality education despite any differences in their mental, physical and learning abilities. Given the concurrent lack of health services in many rural areas, special learning needs in children are often not properly picked up, diagnosed or treated. We do not have the direct expertise to comment fully on what needs to be included for the Policy to address this issue, but from our experience in schools can identify that it is a key area that must not be absent for the Policy to function effectively. We encourage further research in consultation with the appropriate bodies to develop this aspect of the document.

3. Safety and Security: A major problem we have encountered in rural schools is safety and security, both of schools’ physical resources (buildings and movable assets) and learners’ personal security. This Policy needs to address the urgent need to keep children safe. For example, in our region, 45% of students report that they never have access to a space that is safe from violence and abuse. We must address how schools can become such safe zones and face up to the issues that mean they currently, sadly too often, are not. In addition to this is the major need for the maintenance and protection of infrastructure so that learning can continue. Schools should be areas of prioritisation when it comes to safety and policing and we urge the development of strategies in this field in collaboration with SAPS and other relevant authorities.

4. Sanitation: This falls within infrastructure, however has proved so problematic in rural schools that it arguably warrants the inclusion of a specific plan within this policy.

5. Learner accommodation: We submit that the department consider the development of hostels as learner accommodation at all rural high schools. In practice, schools often require learners to stay near the school for their final years, which very often results in living in inferior accommodation that exposes children to various harms. This is something this policy might consider addressing.


Again, we would like to state how encouraged we are that a Policy process is seeking to tackle the challenges of rural education specifically. We feel positive about the broad principles embraced in this document. Most significantly, though, our comment is that without detailed mandates and timeframes for the next stage of this process, we risk undue delays and unnecessary complications down the line. What is needed is a Policy that can come into effect with urgency, recognising that our current system fails rural learners and further entrenches urban-rural inequality each day.

Based on the above concerns, we would like to,

  1. Ask for further engagement and more opportunity for submissions to be made in a well-publicised public engagement process.

  2. Request clarity on all questions given herein within a reasonable timeframe (June 30, 2018), not only as part of the preceding overview but also within the attached section-specific submission.

  3. Urge the urgent review of relevant provisions, with particular attention to the determination of timeframes and responsibilities for action.

Without such review, we think government leaves itself open to potential legal challenge, given that the standard of reasonableness in realising a right such as education requires the formulation of rational and considered policy. We do not want to see the State tied up in legal battles. What we want to see is the swift formulation of detailed plans through rigorous, meaningful participation and the urgent implementation of effective strategies for change. We will welcome all opportunities to be involved in any ongoing process in this regard.

We gratefully acknowledge input from colleagues at sister organisations, including Equal Education and the EELC, the Legal Resources Centre in Grahamstown, Tshikululu Social Investments and the Centre for International Teacher Education (CITE) at CPUT as well as the helpful indicators offered by Equal Education’s prior policy engagements.

We look forward to your response.

Craig Paxton Kyla Hazell

Executive Director Communications

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