We, the Greater Table View Residents & Ratepayers, hereby OBJECT to the COCT’s Informal Trading plan for Subcouncil 1 – Ward 107, based on the following:

According to the Twelfth Draft of the Informal Trading By-Law

• Section 11 . “Informal trading may not be conducted:

On a verge or sidewalk next to –

11.2.1 a building belonging to or occupied solely by the State or City, unless the City has given its prior written consent after it has –

11.2.1.1 duly considered any relevant trading plan; and

11.2.1.2 consulted with the relevant property owner and, where relevant, the tenant of such property;

11.2.2 a place of worship (the said location at Arum & Wood drive is situated between TWO places of Worship. 

• 11.3.5 and in a manner in which it creates a traffic hazard (All 3 areas identified has high vehicular traffic and are single carrige ways)
• 11.3.7  it obstructs the visibility of a display window of business premises, and if the person carrying on business in that business premises objects thereto (Cnr Parklands Main & Regent Roads, Parklands)
• No toilets/ ablution facilities or running water is provided or made provision for.  Where would Informal Traders defecate? This will have a direct impact on surrounding property values and create a potential health risk to customers and residents.
• It will be the responsibility of Law Enforcement to ensure Conditions of permits are met & carried out, but LE is already unable to address a lot of issues in our area and this would create a heavier load on the already understaffed & under equipped Law Enforcement Department as stated by Alderman JP Smith.
• A Statement by the City in the local newspaper confirmed that the number of bays could increase in future (see article in Tabletalk, 24 September 2014, second last paragraph)
• At the Public Participation Process attendees were informed that the areas identified was based on experience in an investigation due to the high volume of pedestrians… Wood/ Arum NEVER had high volumes of foot traffic in the area Identified.
• The recent spate of muggings of school-going children on their way to school in the fields of Arum rd/ Wood Drive makes the area unsafe.  These Informal traders would be a “shield” for the criminals to “hide” behind
• In a recent case in Montague Gardens, an Informal Trader selling fruit & vegetables,  was caught in possession of 10 bags of Tik & 16 Bankies of Dagga.  His informal store was just a front-shop for his illegal activities. Law Enforcement can confirm this as they made the discovery.
• “The City is striving to create an enabling, supportive & well-managed environment for informal traders to operate and develop their businesses….”  It is common knowledge that these Informal Traders don’t “own” these businesses personally, but are EMPLOYED by a single distributor.  Wood sellers are a good example of this practice.
• At R75 per trader, per month, this fee is not sufficient to cover the costs of Solid Waste to remove the discarded carton boxes/rubbish on a DAILY basis. So the ratepayers will have to cover all the additional costs to service these sites.
• These informal traders would not be expected or obliged to keep the area clean, and if they are, who would ensure this practice? Law Enforcement do not have the manpower to police these areas daily.
• All identified area Single carriage roads, makes no provisions for vehicles to stop, and when a “customer” stops, this would cause traffic obstruction. Does the CoCt take responsibility for any traffic related death or injury incurred due to the location of the informal trading areas.
• It is a common fact that the Informal Traders would not serve the residents of the area. Residents prefer, and historically have, supported the formal sectors who are also Ratepayers.
• The process and implementation of an Informal Trading Plan was initiated by a handful of people who did NOT take the opinions of local residents into consideration and did NOT act in the best interests of the MAJORITY of Residents during their representations of the people.
• Only certain informal traders will be allowed to trade.  Informal traders like Wood sellers will not be included in this plan, and neither will the wooden fence makers be included… where should they go?
• This plan does NOT guarantee the elimination of Informal Traders in un-approved areas, and since there is no Policing Powers to enforce it, this plan will simply be creating MORE areas for trading. So what value would these areas offer to the Sub Council if unlawful trading is allowed to continue. How does Law Enforcement Issue fines to traders that have no physical address or money to pay fines?
• As seen on a daily basis in our Area, Informal Traders set up shop at Taxi Hot-spots to boost sales, these services feeds off each other.  Our area cannot afford MORE taxi's in light of the fact that there aren't supposed to be Taxi's due to the MyCiti Roll-out (even in designated areas) 
• Informal trading does NOT suit the HISTORICAL CULTURE of the Greater Table View and therefore should be declared an Area Free of Informal Trading.  The majority of Residents in the area do not want Informal Trading in the area at all, and it is suggested that a PROPER survey is done with at least half of the population of the area to determine the accuracy of this statement.