nelson mandela bay municipality integrated environmental...

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Nelson Mandela Bay Municipality

Integrated Environmental Policy

Final draft

Directorate: Public Health Sub-Directorate: Environmental Management

NMBM Project Number: 19/3/1/1/3

April 2011

NMBM Env Policy_final draft.doc

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MANAGEMENT PLEDGE

“We, as the leadership of the Nelson Mandela Bay Municipality, commit ourselves to the implementation of this Integrated Environmental Policy. We commit to applying the general principles of sustainable development, as well as the sector commitments as detailed in this policy, in all NMBM plans and programmes and implementation thereof. We commit to supporting compliance with this Integrated Environmental Policy, and to providing resources therefore.” Signed: _____________________ Name: _____________________ Designation: Executive Mayor________ Date: _____________________ Signed: _____________________ Name: _____________________ Designation: Municipal Manager Date: _____________________


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INTEGRATED ENVIRONMENTAL POLICY CONTENTS

Chapter Description Page

1 INTRODUCTION 1

1.1 What is an Integrated Environmental Policy? 1

1.2 What is the “Environment” 1

1.3 Why an IEP and what is its function? 1

1.4 How was it compiled? 2

1.5 To who is it directed and in which areas does it apply? 2

1.6 The Nelson Mandela Bay Context 2

2 VISION FOR THE ENVIRONMENT IN NELSON MANDELA BAY 4

2.1 General vision and values of NMBM 4

2.2 Vision for the environment 4

3 GENERAL PRINCIPLES 6

4 SECTORS SPECIFIC COMMITMENTS 8

4.1 Biodiversity and conservation 8

4.2 Water resources 8

4.3 Air quality & noise 9

4.4 Energy and climate change 9

4.5 Waste 10

4.6 Heritage 11

4.7 Land use and housing 11

4.8 Transportation 12

4.9 Environmental education & awareness 12

4.10 Economic development 13

4.11 Environmental governance 13


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5 IMPLEMENTATION AND REVIEW 14

5.1 Implementation 14

5.2 Tools 14

5.3 Roles and responsibilities 16

5.4 Access & Review 16

LIST OF ABBREVIATIONS CETT Corporate Environmental Task Team EIA Environmental Impact Assessment EMF Environmental Management Framework EMP Environmental Management Plan EMS Environmental Management System IDP Integrated Development Plan IEM Integrated Environmental Management IEP Integrated Environmental Policy IWMP Integrated Waste Management Plan NEMA National Environmental Management Act NMBM Nelson Mandela Bay Municipality SDF Spatial Development Framework SEA Strategic Environmental Assessment SMMEs Small, Medium and Micro Enterprises SOER State of the Environment Report This document was prepared by: Nelson Mandela Bay Municipality Public Health Directorate Environmental Management Sub-directorate PO Box 11 Port Elizabeth 6000 Assisted by: Arcus GIBB (Pty) Ltd P.O. Box 63703 Greenacres Port Elizabeth 6057 Photo credits: Mrs P. Jennings Mr. W. Fyvie

NMBM Env Policy_final draft.doc 1

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1 INTRODUCTION

1.1 What is an Integrated Environmental Policy? An Integrated Environmental Policy (IEP) outlines the vision, priorities and commitments, in this case of the Nelson Mandela Bay Municipality (NMBM), with regard to the management of the environment of the area within its jurisdiction. It is integrated in that it applies to all, and all that the NMBM does, across all sectors, from planning to implementation. It is not a detailed action plan, but provides a framework from which such plans could be developed. It acts as a high level strategic guide in directing the NMBM towards its vision for sustainable development.

1.2 What is the “Environment” The environment is defined as per the National Environmental Management Act (Act 107 of 1998) (NEMA). It is the surroundings within which humans exist and that are made up of:

i. The land, waste and atmosphere of the earth;

ii. Micro-organisms, plant and animal life;

iii. Any part or combination of i) or ii) and the interrelationships among and between them; and

iv. The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being.

1.3 Why an IEP and what is its function? Section 24 of the Constitution of South Africa (Act 108 of 1996) guarantees everyone the right to inter alia “an environment that is not harmful to their health or well-being” and to having the environment protected for the benefit of present and future generations. Hence government, including local authorities, have environmental responsibilities and duties. Other legislation such as the Municipal Systems Act (Act 32 of 2000) and the NEMA require that local authorities provide services in an environmentally sustainable manner and require local authorities to compile development and sector plans which address these issues. Simply, this IEP:

• Presents the NMBM’s vision for, and its commitment to, practising and promoting sustainable development during its day to day execution of duties which have an impact on the environment; and

• Produces a framework for all other policies, strategies, plans and programmes to consider environmental issues.

The NMBM is committed to fulfilling the above national, as well as international requirements, through a series of subsequent strategies and plans. An environmental policy is seen as the first key strategic step guiding these plans. It is hoped that this policy will also provide guidance to all inhabitants of the NMBM, as we all have a civic responsibility to be good custodians of our environment.


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1.4 How was it compiled?

The NMBM’s first Environmental Policy was adopted by council in October 2004. This policy review process, the first review since 2004, was undertaken by the Environmental Management Sub-Directorate (Public Health Directorate) of the NMBM and facilitated by Arcus GIBB. The policy was informed by a literature review including the previous policy; sector plans; the NMBM’s draft State of the Environment Report (2010) which was finalised during this policy review process; interviews with relevant NMBM staff; and public participation. Further details are provided in “NMBM Environmental Policy 2011 Review, Status Quo Report (Arcus GIBB, 2011)”.

1.5 To who is it directed and in which areas does i t apply? The policy addresses only that geographical area falling within the jurisdiction of the NMBM. It covers all activities which the NMBM controls or could reasonably be expected to influence. The NMBM Environmental Management Sub-Directorate is tasked with strategic planning for environmental issues, and as such have drafted this policy. However the policy is integrated in nature, addressing issues which cut across a range of functions and Directorates, and hence every NMBM manager must read and understand it, and its key principles should be communicated to every employee. While the policy is of particular value to those executing the responsibilities of the NMBM, it is a public document and of relevance to all within the Nelson Mandela Bay area including civil society.

1.6 The Nelson Mandela Bay Context The NMBM is located in the western regions of the Eastern Cape Province in South Africa. It is a coastal municipality bordered by 110 km of coastline which includes two island groups, famous sandy beaches and Algoa Bay which supports a wealth of marine life. The large Swartkops and Sundays Rivers flow through the area. The NMBM has floral and faunal diversity to be proud of. It is floristically extremely diverse, being located in the eastern extreme of the Cape Floral Kingdom. Dominant vegetation biomes include Fynbos and Sub-tropical Thicket. Regrettably, approximately one third of the natural environment has already been lost due to urban expansion,


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cultivation, overgrazing, mining and alien plant infestation and hence there is a strong need to correctly conserve and manage the remaining environment. Fauna is well represented both on and off-shore and up to nine species of whales, dolphins and seals are found along our coast. The NMBM borders the Groendal Wilderness Area and the southern section of the Addo Elephant National Park, with its approximately 550 elephants. The value of this diversity cannot be over emphasised, nor can the importance of conservation thereof. The NMBM is the only metropolitan municipality in the Eastern Cape Province, and the economic hub of the Province. It is a national and international tourist destination famed for its water sports and being a launch pad to the Garden Route. It is in this diverse setting that the approximately 1.1 million diverse people of NMBM live.

The Nelson Mandela Bay Municipality


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2 VISION FOR THE ENVIRONMENT IN NELSON MANDELA BAY

2.1 General vision and values of NMBM The NMBM has the long term vision to be: “A globally competitive and preferred metropole that works together for the people” (NMBM, IDP 2010/2011 review) The NMBM is also committed to the Batho Pele principles of “people first”; courtesy; consultation; service excellence; access to services; information; openness and transparency; redress; and value for money. The environmental vision for the NMBM must be seen within the context of the NMBM’s main strategic objectives, as expressed in the IDP. These strategic objectives are:

• Correcting spatial imbalances;

• Combating poverty and unemployment;

• Ensuring access to basic services by all;

• Socio-economic growth and sustainability;

• A safe, secure, healthy and sustainable environment;

• Development of integrated and sustainable settlements;

• Responsive, people-centred and integrated institution;

• Democratisation of planning and decision-making;

• Elimination of growth and maintenance backlogs; and

• Sound and sustainable finances.

It is against the backdrop of these objectives that our vision for the environment is defined.

2.2 Vision for the environment NMBM’s vision for key aspects of its environment is:

• A society well aware of its environment and the importance thereof.

• A healthy environment which is managed in a manner which balances both its biophysical needs as well as the human development needs of present and future generations.

• Basic services provided for all.

• A growing economy and reduced unemployment.

• Sustainable water resources and a sustainable potable water supply for all.

• An area with clean air for all.


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• A society acknowledging the challenges of climate change and accordingly prioritises renewable energy generation and efficient consumption thereof.

• Safe, secure and tourist-friendly environment for all, including coast and beaches.

• Comprehensive waste management which encourages and facilitates waste minimisation and recycling.


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3 GENERAL PRINCIPLES

International conventions, our Constitution, and environmental legislation such as the National Environmental Management Act (Act 107 of 1998) define general guiding principles which are to underpin all that we do as civilians and civil servants. The NMBM is committed to adopting and implementing these and other key principles which include: Sustainable development: integrating environmental, social and economic considerations in all that we do so as to ensure our development activities serve present generations, without compromising the ability of future generations to meet their needs. To achieve sustainable development, the NMBM is committed to adhering to the seven key principles of the Local Agenda 21 to which South Africa is a signatory. These include:

• Integration of social, economic and environmental issues;

• Adopting a multi-sectoral approach;

• Concern for the future;

• Working within ecological limits;

• Ensuring transparency and developing partnerships with civil society;

• Linking local issues with global impacts; and finally

• Striving for equity, justice and accountability.

Healthy environment: ensuring that the right of all South Africans to an environment that is not damaging to their health and well-being, as defined in the Constitution, is protected. Protecting the environment: ensuring our environment is protected through preserving biodiversity and our cultural heritage, reducing waste, and preventing pollution. Legal compliance: complying or exceeding the requirements of all local, provincial, national and international legislation, and those conventions and protocols to which South Africa is a signatory. The NMBM is also accountable for enforcement of its local legislation. Efficient use of natural resources: ensuring that our natural resources are used in a sustainable manner which protects them for future generations. Holistic approach: considering all aspects of the environment, including all potential impacts of our actions, be they cumulative, direct or indirect. Precautionary approach: applying a risk averse and cautious approach which recognises the limits of current knowledge regarding environmental impacts and the consequences thereof. Polluter pays: ensuring that the cost of environmental pollution, including all remediation, is borne by those responsible for causing the pollution. Public participation: involving civil society in the decision-making process with regards to the environment in NMBM, and partnering with the public to realise appropriate management thereof.


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Environmental awareness: furthering awareness of NMBM employees and the general public regarding all environmental management issues. Integrated planning and decision making : ensuring integrated environmental management is part of NMBM’s decision-making and planning at all levels, including policies, plans, programmes, and operational functions, in and across all sectors. All sectoral strategies or plans should consider the IEP and adopt it. Continual improvement: ensuring that we are continuously looking for better ways of doing things, and that our environmental performance continuously improves as a result thereof. Best Practical Environmental Option: ensuring that in decision making, the Best Practical Environmental Option (BPEO) is considered.


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4 SECTORS SPECIFIC COMMITMENTS

Different sectors of environmental management have different challenges and different management needs in the NMBM. Hence the NMBM’s goals and commitments to environmental management are presented below on a sector by sector basis.

4.1 Biodiversity and conservation Goal: To ensure biodiversity within the NMBM is conserved in a sustainable manner, for present and future generations. Hence the NMBM is committed to:

• Developing, maintaining and implementing a Biodiversity Management Plan, and the NMMOSS action plan for the NMBM.

• Recognising the value of the services provided by the many facets of the natural environment.

• Protecting terrestrial biodiversity and key habitats and ecological processes.

• Protecting the marine and coastal environment.

• Addressing the challenge of alien invasive species in the NMBM.

• Maintaining, increasing, and continually improving municipal designated conservation areas.

• Ensuring NMBM’s operational activities meet appropriate environmental management standards.

• Ensuring private land owner conservation through stewardship programmes.

• Implementing legal tools such as the Bioregional Plan (currently in the processes of being gazetted).

• Mainstreaming planning tools such as the EMF and EIA processes into land use planning.

• Partnering with civil society and academic institutions in research and conservation action.

Implementing Directorate: Environmental Management Sub-Directorate.

4.2 Water resources Goal: To ensure that water resources in NMBM are sustainable in terms of the biodiversity, and their use as a source of water for human needs.


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Hence the NMBM is committed to:

• The long term provision of clean, potable water for all.

• Protecting surface and groundwater resources.

• Protecting the ecological integrity of natural aquatic systems.

• Minimising all forms of water wastage so as to ensure water use efficiency is maximised.

• Provision of a basic sanitation services to all.

• Managing Waste Water Systems such that they operate effectively, and ensuring discharges meet legal requirements.

Implementing Directorate: Infrastructure and Engineering.

4.3 Air quality & noise Goal: To minimise the impact of air and noise pollution on people and the natural environment. Hence the NMBM is committed to:

• Developing the appropriate structures, systems, and capacity within the NMBM to manage air quality and noise issues.

• Maintaining and implementing the NMBM’s Air Quality Management Plan in line with the requirements of the National Environmental Management: Air Quality Act (39 of 2004).

• Combating noise pollution and its impact on developed areas.

• Ensuring our air quality and noise by-laws are relevant, up to date and enforced.

• Undertaking meaningful meteorological and air quality monitoring.

• Developing and managing a system for enforcing the legal air quality requirements.

Implementing Directorate: Environmental Health Sub-Directorate.

4.4 Energy and climate change Goal: To proactively respond to the challenge of climate change by implementing appropriate mitigation and adaptation measures.


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Hence the NMBM is committed to:

• Developing the appropriate structures and capacity within the NMBM to manage the challenge of climate change.

• Developing, maintaining, and implementing a Climate Change and Response Management Strategy for the NMBM and subsequent mitigation and adaptation response plans.

• Improve public awareness of energy and climate change issues in the NMBM.

• Fulfilling the local obligations which South Africa has committed to as signatories of international agreements such as the United Nations Framework Convention on Climate Change and the Kyoto Protocol.

• Encouraging efficient energy generation through facilitation of renewable energy projects, for example, wind, solar and landfill gas initiatives.

• Encouraging efficient energy use and “low carbon” practices wherever possible and practical.

• Encouraging technologies which minimise the release of greenhouse gasses harmful to the atmosphere.

• Responding to the challenge of sea level rise through informed coastal planning.


4.5 Waste Goal: To realise an effective waste management system, which, in line with the national waste management hierarchy, achieves waste reduction and minimisation. Hence the NMBM is committed to:

• Implementing our objectives as highlighted in the Integrated Waste Management Plan.

• Realising a clean municipality.

• Waste prevention and minimisation through initiatives such as the NMBM waste exchange.

• Recycling, including within the operations of the municipality itself.

• Preventing illegal dumping.

• Promoting public awareness campaigns with NMBM civil society on the dangers of illegal dumping.

• Ensuring our waste by-laws are up to date, relevant and enforced.

• The enforcement of appropriate waste management practices and the polluter pays principle.


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• Working with other levels of government, NGOs and the private sector to realise the above.

Implementing Directorate: Waste Management Sub-Directorate.

4.6 Heritage Goal: To ensure that the heritage of NMBM, including cultural heritage and living heritage, built heritage and historical townscapes, paleontological and archaeological heritage, and significant landscapes, are both preserved and celebrated in an accessible manner. Hence the NMBM is committed to:

• Developing, maintaining and implementing a Heritage Management Plan for NMBM.

• Recognising our diverse cultural practices.

• Protecting and maintaining existing heritage sites and areas, and improving these where appropriate.

• Raising public awareness regarding the heritage value of NMBM.

• Considering areas of heritage value in our decision making.

Implementing Directorate: Economic Development & Recreational Services.

4.7 Land use and housing Goal: To ensure that land is used and managed optimally in a manner which improves the quality of life for all residents, and that housing is provided for all. Hence the NMBM is committed to:

• Spatial planning that reduces urban sprawl, promotes densification, mixed use development, and corridor developments.

• Land use planning that promotes integrated communities and addresses the legacy of race-based segregation.

• Sustainable community planning which strives for poverty alleviation, satisfaction of basic needs, and focuses on special needs groups.

• Proactive community education regarding the importance of the above principles.

• Integrating open spaces into planning and developing and maintaining quality open spaces in all areas, and the greening of urban areas.


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• Eliminating the housing delivery backlog and providing quality housing for all in sustainable human settlements.

• Addressing land invasion.

• Inner-city rejuvenation of our main centres of Port Elizabeth, Uitenhage and Dispatch.

• Encouraging green buildings and sustainable design and development practices.

Implementing Directorate: Housing and Land Directorate.

4.8 Transportation Goal: To realise a sustainable transportation system that is safe and accessible, and which minimises environmental impact. Hence the NMBM is committed to:

• Considering sustainability and environmental factors when planning, implementing and managing all facets of transportation.

• The development of effective public transport systems which are energy efficient, and in which carbon and greenhouse gas emissions are minimised.

• Public transport that is safe, affordable and accessible to all.

• Encouraging commuting by non-motorised means through the development of bicycle and pedestrian routes were feasible.

Implementing Directorate: Infrastructure and Engineering.

4.9 Environmental education & awareness Goal: To facilitate environmental education throughout all levels of society and within the municipality itself. Hence the NMBM is committed to:

• Building a culture of learning about our environment.

• Raising environmental awareness through NMBM education initiatives.

• Developing environmental management capacity within the municipal staff, as needed, through formal training programmes.

• Building partnerships with government and the private sector and supporting the environmental education initiatives of other organisations as appropriate.

• Mobilizing community involvement through environmental education initiatives in the combating of environmental degradation.



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4.10 Economic development Goal: To realise a vibrant and sustainable local economy in NMBM resulting in increased wealth in the area and improved lives of its residents. Hence the NMBM is committed to:

• Poverty eradication through supporting job creation initiatives.

• Encouraging entrepreneurial activities through supporting emerging businesses and SMMEs.

• Prioritising empowerment of local communities.

• Ensuring NMBM is an internationally preferred destination for investors.

• Fostering an enabling environment for growth by, for example, providing the required infrastructure for growth.

• Encouraging sustainable businesses practices and environmental performance.

Implementing Directorate: Economic Development & Recreational Services.

4.11 Environmental governance Goal: To achieve effective environmental governance in all areas within the jurisdiction of the NMBM. Hence the NMBM is committed to:

• Transparent and accountable governance.

• Availing the required resources, both human and financial, for the appropriate management of our environment and implementation of this policy.

• Collection and management of environmental data and information in a manner which facilitates the effective management of the environment.

• Partnering with communities to realize environmental benefits.

• Clear, transparent communication with stakeholders and communities and ensuring inclusive decision making.

• Enforcing environmental legislation, including the development, implementation and enforcement of by-laws.

• Working together with other local authorities and levels of government, as well as the private sector, to ensure knowledge and skills transfer into and out of the NMBM.

Implementing Directorate: All Directorates.


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5 IMPLEMENTATION AND REVIEW

5.1 Implementation The NMBM is committed to implementing this policy by applying the principles contained therein in all decision making. The NMBM will respond to the sectoral commitments by developing and implementing sectoral strategies and plans which will address the relevant environmental issues. This sector strategies and plans approach will be rendered effective by:

• Ensuring that this policy and its commitment to sectoral strategies and plans are adopted at all management levels of the NMBM.

• Ensuring that appropriate resources, including financial and human resources, are made available for its implementation.

• Ensuring this policy is implemented across all NMBM Directorates. Implementation is not only the responsibility of the Environmental Management Sub-Directorate.

• Ensuring this policy is communicated to all stakeholders in NMBM including civil society, business and industry.

• Ensuring this policy is aligned with all other municipal strategies.

• Ensuring sectoral strategies and plans are developed within five years of the adoption of this policy. Where these already exist, they will be updated similarly.

• Ensuring the appropriate environmental management tools are utilised to achieve implementation.

5.2 Tools The following tools will be used in the implementation of this policy:

• Communication tools:

• Policy implementation team : A team including senior management representatives of all service delivery units will be established to ensure that the requirements of this policy are implemented.

• Inter-Directorate forums : These forums will be established where there is a need for addressing cross-cutting issues in a coordinated manner. The Corporate Environmental Task Team (CETT) which reviews EIA applications is an example o such a forum.

• Monitoring and reporting tools:

• Annual performance reporting : All relevant NMBM sectors will report on an annual basis regarding the degree to which they have implemented this policy.

• Monitoring: In order to understand environmental performance in the NMBM, regular environmental monitoring will be undertaken from which meaningful data will allow evaluation of performance.


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• Environmental Info Management system : The relevant Directorate will establish a system for collecting, storing and accessing environmental information and reports.

• State of the Environment Report : The SoER, which describes the environment and performance indicators under various “themes”, will be updated on a five-yearly basis.

• Legislative tools:

• By-laws : Up-to-date bylaws will be developed, implemented and enforced.

• Guidelines: Where specific activities and environmental issues warrant it, best practice guidelines will be compiled so as to provide clarity, guidance and direction for NMBM. Where guidelines from other organisations are relevant to the functioning of NMBM, these will be adhered to.

• Planning tools: The NMBM will develop and implement plans to address and realise the commitments detailed under Section 4 “Sector Specific Commitments”. The NMBM has completed, or is busy completing the following key environmental plans:

• Spatial Frameworks at both the municipal level, through the Spatial Development Framework, and at the local level through Local Spatial Development Frameworks and Sustainable Community Unit Plans.

• Integrated Waste Management Plan (2005, currently under review).

• Water Master Plan and Water Services Development Plan (2006).

• Sanitation Master Plan (complete).

• Air Quality Management Plan, 2010 (currently in draft).

• Metropolitan Open Space System (completed and revised).

• Bioregional Plan (in the process of being gazetted).

• Coastal Management Programme (2008).

• Greening policy (2007).

• Heritage Management Plan (to be commenced).

• Energy & Climate change strategy (to be commenced).

• Management & Decision Making Tools:

• Strategic Environmental Assessments (SEAs) will be undertaken to determine the degree to which key plans, such as the SDF, have considered the environmental needs of the area. The last SEA for NMBM was undertaken in 2007, prior to the revision of the SDF.

• Environmental Impact Assessments (EIA) will be undertaken to evaluate impacts on a project by project basis.

• Environmental Management Framework (EMF) is a tool whereby certain administrative permitting requirements and conservation requirements are defined for different geographical areas. The NMBM EMF is currently being developed.

• Environmental Management Systems (EMSs) will be used, where appropriate, by NMBM to manage its operational impacts.


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• Green Procurement Strategy and Implementation Plan: The NMBM is in the process of developing this.

5.3 Roles and responsibilities The NMBM acknowledges the following senior management responsibilities regarding this policy:

• Council: to review and approve the IEP, and ensure all new proposals are aligned with the IEP.

• Executive Mayor: to facilitate the implementation of the IEP by fostering relationships with over levels of government, and internationally, so as to achieve knowledge transfer, and to evaluate progress of IEP implementation.

• Municipal Manager: to ensure implementation of IEP across all Directorates of the NMBM.

• Executive Director, Public Health: as director for the unit responsible for drafting the IEP, the director of Public Health remains responsible for developing the policy; reviewing the IEP; reviewing implementation thereof; for communicating and implementing programmes for its implementation; and for allocating resources for the above.

• Directors (all): to ensure awareness of the IEP in their Directorates, to ensure its implementation in their Directorates, and to ensure that significant IEP issues are communicated to the Environmental Management Sub-Directorate.

5.4 Access & Review This policy will be reviewed at regular intervals, namely every five years. This will include a review of the success of implementation of the existing policy, and appropriate changes to the policy to ensure it continues to respond to our changing environment. This policy will be placed in appropriate locations, including the NMBM website, and will be available to all municipal employees and the general public.


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Envisaged use of Environmental Policy Implementation Tools for the NMBM

IEP & GENERAL PRINCIPLES

Integrated Environmental Management

Legal compliance

Best practical environmental option

Polluter pays Precautionary approach

Public participation

Integrated planning

Sustainable development Local Agenda 21

MONITORING AND REPORTING TOOLS

State of the Environment Reporting

PLANNING TOOLS (SECTORS)

Air Quality Management Plan

Coastal Management Programme

Energy and Climate Change Strategy

Heritage Management Plan

Integrated Waste Management Plan

Environmental Management Framework

Biodiversity Conservation Plan

MANAGEMENT & DECISION-MAKING TOOLS

Environmental Impact Assessment

(EIA)

Environmental Management

System (EMS)

Environmental Management

Framework (EMF)

Environmental Auditing

Guidelines Monitoring

Forums By-laws

Integrated Development

Plan

Annual Performance Reporting

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