BASIC EDUCATION LAWS AMMENDMENT BILL – Letter to Parliament.

Attention: Mr L A Brown

Dear Mrs B P Mbinqo-Gigaba, Chairperson: Portfolio Committee on Basic Education

 

RE: BASIC EDUCATION LAWS AMMENDMENT BILL –

Concerns about home education sections.

The Gauteng Association for Homeschooling welcomes the opportunity to comment on the BELA Bill which is now before the Portfolio Committee of Basic Education.

A. Introduction and Background

The Gauteng Association for Homeschooling was established in 2013 and represent home educating parents and other parties with a (non-commercial) interest in home education.
One of the Association’s chief aims is to obtain the recognition of society and the protection of the law for the child’s right to receive education within the family, and to have their education individualized according to their specific needs. We also would like to achieve the same for the obligation and concomitant right of parents to educate and school their children in every respect and according to the child’s best interest. The Association has a special concern for families whose rights are typically in danger of being infringed upon, such as families who uses an individualized approach to education, and families with low or no income.

The Association is deeply concerned about the proposed amendments to the South African Schools Act, specifically to the amendments on the following sections:

a. The definition of home education;

b. Section 3; and
c. Section 51.

Our main concerns will be dealt with in two parts. In Part A we will address the uncertainty caused by the proposed changes to the definition of home education and section 51.

In Part B we will address further substantive concerns with the contents of the BELA Bill. Recommendations will be noted at the end of each part.

B. Part A: BELA Bill: Causing Clarity, or Causing Confusion?

 

1. Introduction

In the Socio-Economic Impact Assessment (SEIA) on the BELA Bill, the DBE identified the following socio-economic problem (see point 1.1.d): “Uncertainty pertaining to home education legislation and monitoring of this sector of education.” In point 1.2 they identify one of the root causes of this problem as follows:

“The current provision on the registration of home education learners is subject to different interpretation.”

Later on (point 2.2.a) the SEIA states: “The current law is not clear on this relatively new form of education in South Africa as well as what are the responsibilities of parents who choose to home educate their children.”

In summary, one of the main problems the BELA Bill seeks to address, according to the SEIA, is an uncertainty in the current law with regards to home education. It identifies the root cause of the problem as the fact that the current law may be interpreted in various ways. Unfortunately, the BELA Bill does not solve this problem at all. In fact, the BELA Bill creates far more confusion in far more areas than the current law does. If one of the main aims of the BELA Bill is to create clarity on the legislation surrounding home education, it fails miserably.

Although the following points are by no means an exhaustive list of all the points which create confusion in the home education community, they will hopefully serve as sufficient illustration:

2. The Definition of Home Education: Section (a)

“home education” means a purposeful programme of education for a learner, alternative to school attendance, which –
a) is provided under the direction of the learner’s parent, primarily in the environment of
the learner’s home;…
The phrase “the environment of the learner’s home” is unclear. Neither this phrase, nor the word “home” is defined in the Bill.

a. FIRST INTERPRETATION: The phrase could be interpreted to mean the environment around the physical home (i.e. the building where the child lives). It isn’t clear how far “environment” extends. Does it only include the physical building, or does it extend to the backyard? The street outside? How about the park next door, or the community hall down the road?

If this interpretation is used, we have to point out that some of our members and indeed homeschoolers across our country, do not always conform to this definition. Learners may use a library or employer’s office space or even sit in a park to study.
By the very nature of home education, families may choose to use venues other than their homes where it would be more convenient or more conducive to learning. It is difficult to see why families should be prohibited to make use of such alternative spaces, especially in cases where the alternative space would create a more favourable environment for learning.

There is also a percentage of home educators who are itinerant. They travel as a family across the country and learn as they travel. They work in the car or in their campervan or at their temporary accommodation. If BELA Bill was to be passed, these traveling homeschoolers will be deemed illegal, effectively ending a way of life for many families. This while the Policy on Home Education (2018) specifically mentions itinerancy as a reason families may choose to home educate.

 

b. SECOND INTERPRETATION: The phrase could be interpreted to mean the family environment, regardless of where the family physically find themselves. However, it is once again not clear how far this environment extends. Is a parent’s presence required to create a “family environment” or will the presence of siblings, grandparents, and extended family suffice?

Although still vague, this would solve the problems in the first interpretation, and align more closely to the reality of home education. The education site in home education should in general not be seen as a permanent fixture, but rather as one of the elements, like curriculum and other resources, that a parent and/or learner may change as necessary to facilitate better learning. However, if the home education
site is seen as fluid, it is difficult to see how a “home education site visit” (Section 51.3) will then be applied.

 

c. THIRD INTERPRETATION: The phrase could be interpreted as containing both interpretation A and B. This is the way the home education sector currently interprets this phrase. Both the physical home and the family environment is recognised as legitimate aspects of “the environment of the learner’s home”, and the presence of either will therefore classify a certain kind of education as “home education”.

This interpretation would align with the current practice in the home education environment and avoid the problems of the first interpretation. However, as this interpretation also sees the home education site as fluid, it isn’t quite clear how a “home education site visit” (Section 51.3) will then be applied.
Furthermore, the word “purposeful” is problematic, nebulous and vague. Is this the same standard that conventional schooling is required to meet? What is intended by requiring that home education should be purposeful? According to what predetermined definition?

 

3. The Definition of Home Education: Section (b)

“home education” means a purposeful programme of education for a learner, alternative to school attendance, which –

…

b) may include tutorial or other educational support, if necessary, secured by the parent on specific areas of the curriculum followed by the learner; and …
Firstly, it is unclear what the word “specific” is meant to convey.

a. Does it limit the number of subjects that may be tutored (in other words, a parent may appoint a tutor or other support only for x amount of subjects)?

b. Or does it limit the number of subjects that may be tutored by a single tutor (in other words, a parent may appoint a tutor for each subject, as long as the tutor is only appointed for one specific subject)?

c. Or does it perhaps limit the initiative that may be taken by a tutor (in other words, a parent may appoint a single tutor for all subjects, as long as they give specific instruction to the tutor on which subjects to cover)? The spectrum of interpretation of this phrase is so broad as to make it impossible to comment as an Association on the appropriateness or otherwise of this part of the definition.
Secondly, it is unclear how this would apply in the home education context.

 

Preliminary findings in a survey done by the Gauteng Association for Homeschooling indicated that only 36% of respondents covered subjects (or learning areas) separately and continuously in the traditional way. 

60% of respondents used a blended model for some or all of the subjects/learning areas. A “blended model” means that they will cover more than one subject or learning area at the same time (for example, cover language, history, and geography at the same time through reading and discussing a single book).

For 60% of respondents, “specific areas of the curriculum” are therefore not distinct from each other, and it is unclear how this part of the definition will practically apply to them and their tutorial (or other educational support) needs.

Thirdly, the phrase “other educational support” is vague and could be interpreted in any number of ways. As we understand it, other educational support would include, amongst other things, multimedia, online resources, and library books. These resources are used not only in the homeschooling sector but also in the conventional schooling system. Their use is very valuable and should not be limited.

 

This survey ran from the 11th to the 18th of May and gathered seven hunderd and sixty-one (761) responses from home educators across the country. The Gauteng Association for Homeschooling is still processing some of the results and all references to findings in relation to this survey is therefore only preliminary. Final results should be available later this year

4. Section 51(2)(a)(ii)
“… the parent understands what home education entails…”
It is unclear what exactly is expected under this phrase. The phrase does not limit or specify which aspects of home education this “understanding” should cover. The most straightforward reading of the phrase therefore would be to require a comprehensive understanding of home education.
However, anybody who knows the field also knows that to have a comprehensive understanding of what home education entails is a completely unreasonable expectation from a parent who is only starting home education. Home education “entails”, amongst other things, legal, educational, societal, familial, and psychological aspects. Some of these aspects are so broad as to be nearly impossible to master in a life-time (for example, the vast number of different approaches, philosophies, and methodologies used in home education). Other aspects are difficult to understand until you have experienced it yourself (such as certain societal, familial, and psychological aspects).
But if this phrase does not mean a comprehensive understanding, but rather a limited understanding, then it would be failing to achieve anything of substance.
Furthermore, this requirement raises the question of what yardstick is to be used to determined the parent’s understanding of home education. In other words, would there be a checklist against which the parent will be evaluated to determine if they understand home education?

 

5. Section 51(2)(a)(iii)
“… the proposed home education programme is suitable for the learner’s age, grade level and ability and predominantly covers the acquisition of content and skills at least comparable to the relevant national curriculum determined by the Minister.”
Both the word “predominantly” and the phrase “at least comparable” are imprecise and leave a lot of room for interpretation.
a. While one person may interpret “predominantly” as anything more than 50%, another may interpret it as “the same with only a few deviations”.
b. “At least comparable” does not specify in which respect it must compare. Must the content or skill be the same level of difficulty, or just the same kind of content or skill?
Or both?

 

6. Section 51(2)(a)(iii), Section 51(2)(b)(iii), Section 51(2)(b)(iv), Section 51(8)
The above-mentioned clauses all have one thing in common: they either explicitly or implicitly depend on the use of grades.
However, in the survey conducted by the Gauteng Association for Homeschooling, only 31% of respondents recognised grades in all of their subjects. 36% only recognised grades in core subjects (such as maths and language) and 26% did not recognise grades at all.
A follow-up question provided even more insight into the way home educators made use (or not) of grades. When asked whether they cover the same grades work in all subjects or learning areas, only 29% responded in the affirmative. 56% covered different grades in different subjects, while 12% indicated that they did not recognise grades at all.

In short, nearly three-quarters of respondents do not recognise grades in some or all of their subjects, or they cover work in more than one grade. The fact that such large percentages of home educators have a loose (or no) relationship with grades creates a unique interpretation problem in any clause which is dependent on the use of grades.

 

i. Section 51(2)(a)(iii)
“… the proposed home education programme is suitable for the learner’s age, grade level and ability…”
The requirement for the programme to be suitable for the learner’s “grade level” seems difficult to apply, as the majority of home learners either do not recognise grades, or have, not one, but several “grade levels”.

 

ii. Section 51(2)(b)(iii)
“(iii) [if the parent undertakes to] arrange for the learner’s educational attainment to be assessed by a competent assessor –
(aa) annually, up to the end of the year in which the learner reaches the age of 15 years or completes grade 9, whichever occurs first; and
(bb) against a standard not inferior to the standard determined in the National Curriculum Statement …”
Clause (bb) is actually misleading, as the National Curriculum Statement does not provide a single “standard”, but rather several “standards”. A learner in grade 9 is obviously measured against a different standard than a learner in grade 1.
In school it goes without saying that the grade 1 NCS standard will be used to measure the learner who is in grade 1.
However, where a learner is in more than one grade, or does not recognise grades at all, this creates a practical difficulty, namely, which NCS standard is the child supposed to be measured against? If a child is covering work in grades 2, 3, 4, and 5, do they need to be measured against a) four different standards, b) the lowest standard, c) the highest standard, or d) the average?
Not to forget that this uncertainty will be present in the case of nearly three-quarters of home learners.
Home education affords the learner time to master each concept and to work either faster or slower than their peers. The pace and mastery-approach of home learners means that they do not always complete grade levels in the space of a calendar year.

Simply put, home educated children are not on the same time schedule as school-going children and therefore cannot be assessed in the same manner.

 

iii. Section 51(2)(b)(iv)
“(iv) [if the parent undertakes to] submit to the Head of Department, at the end of each phase and as evidence of the learner’s attainment, the learner’s assessment report, signed by the competent assessor.”
The parent of a learner who covers work in grades 2, 3, 4, and 5 will have difficulty pinpointing the end of a phase. Should this parent send in four different reports in four different years for different subjects? Or should they send a report when the learner has moved beyond grade 3 with the last subject? Or perhaps with the first subject? Or when most subjects are beyond grade 3?
The question becomes even more difficult when one contemplates the case of children who do not use grades at all.
And once again – this uncertainty will likely crop up in nearly three-quarters of all home learner registrations.

 

iv. Section 51(8)
“The parent of a learner who has been registered as contemplated in subsection (1) or subsection (5) must notify the Head of Department at the end of the –

(a) Foundation Phase (Grades R to 3)
(b) Intermediate Phase (Grades 4 to 6), and
(c) Senior Phase (grades 7 to 9),
of his or her intention to continue educating the learner at home.”
Please refer to the comments on the previous section, as the interpretation problems in both sections are exactly the same.

 

7. Section 51(8), Section 51(9)

There seem to be a direct contradiction between these two sections. Subsection (8) reads:
“The parent of a learner who has been registered as contemplated in subsection (1) or (5) must notify the Head of Department at the end of the … Senior Phase (grades 7-9), of his or her intention to continue educating the learner at home.”
However, Subsection (9) reads:
“A parent who wishes to continue educating a learner at home after the learner has reached the age of 15 years or has completed grade 9, whichever occurs first, or who wishes to start educating such a learner at home at such time, is not required to apply for registration, as contemplated in subsections (1) and (5), or to notify the Head of Department, as contemplated in subsection (8).”

A plain reading of these two clauses seems to be directly contradictory and is sure to cause much confusion as to the obligations of a parents once a learner has finished grade 9.

 

8. Conclusion

From the above points it is clear that there are a great many terms, phrases, and subsections in Section 51 of the BELA Bill which can be interpreted in many different ways.
This means that the BELA Bill suffers from the same malady as the SASA: should this Bill become law, the uncertainty pertaining to home education legislation will simply continue.
And looking at the sheer number of unclear words, phrases and sections, the BELA Bill will create far more uncertainty than the SASA ever did.

The BELA Bill does not solve the problem it set out to solve. It makes it worse. Far worse. The Gauteng Association for Homeschooling therefore cannot recommend passing this section of the BELA Bill as is.
Some of the uncertainty may be removed by adding clear definitions to the SASA.
However, a large number of words, phrases, and clauses is unclear not because they lack definitions, but because they presuppose that home education is simply school at home with the use of separate subjects and the uniform use of grades – mechanisms which are only used by a minority of home learners. In order to clear up this confusion, no mere cosmetic exercise of changing a few words here and there will suffice. The use of subjects and grades is so fundamental to the system of regulation proposed in the BELA Bill that the whole section will have to be re-written, and a completely new system of regulation developed, in order for the law to be applicable to the lived reality of the majority of home learners. As it stands, the proposed S51 is fundamentally flawed, fails to achieve its purpose and breeds confusion.

Should the Bill be passed without fixing these uncertainties, at least the following can be expected:

 

a) Much conflict between parents and officials will arise due to differing interpretations, which will most likely also increase the incidences of litigation.
b) The registration numbers of home leaners will most likely continue to remain low and even decrease – not because home educators wish to break the law, but because the legislation is so far removed from their lived reality that they cannot even accurately fill in the registration form.

 

The Gauteng Association for Homeschooling would therefore like to ask the following:

a) That the current proposed Section 51 in the BELA Bill be removed.

b) That the DBE be requested to write new legislation pertaining to home education, which takes cognisance of the differences between school education and home education, which are applicable to the lived reality of home educators, and which is clear and precise.

C. Part B: Further Substantive Comments

 

1. Introduction

In Part A of this submission, the Association commented on the fact that the BELA Bill contains many unclear words, phrases, and subclauses causing uncertainty. This means that the BELA Bill does not solve the problem it sets out to solve. In Part B of the submission the Association would like to comment on several further clauses which is of concern to our membership.

2. Section 3(1)

“Subject to this Act and any applicable provincial law, every parent must cause every learner for whom he or she is responsible to attend school, starting from grade R on the first school day of the year in which such a learner reaches the age of six years…”

We are concerned that the link between a certain grade (R) to a certain age (6) will negatively impact learners who may not be ready for that specific grade at that specific age.
It does not allow learners whose brain development is delayed due to slower (but normal) function, to develop naturally without being forced to develop other parts of their brain unnaturally in order to “learn.” The school education curriculum prescribed for their age may cause more damage than it educates the learner, because that particular part of their brain has not developed enough to process the schoolwork in that part of the brain yet. This forces delay in their education and puts the learner in a disadvantaged position which in turn allows for more grade failures and or additional classes and therapies which would have been unnecessary if the natural process of learning was followed.

 

3. Section 51(1), Section 51(2)(a)(i), Section 51(4), Section 51(12)

“If the parent of a learner who is subject to compulsory school attendance as contemplated in section 3(1) chooses to educate the learner at home, such parent must apply to the Head of Department for the registration of the learner to receive home education.”
This section provides for a parent to apply for registration for home education. One of our concerns with this section, is the fact that the approval and retainment of the registration depends in part on whether the Head of Department deems home education to be in the best interest of the learner.

Subsection (2)(a)(i): “The Head of Department must approve the application and register the learner as contemplated in subsection (1) if he or she is satisfied that education at home, as provided for in this Act, is in the best interests of the learner…”
Subsection (4): “If the Head of Department is satisfied that the parent does not meet the requirements set out in subsection (2), or if the outcome of the process set out in subsection (3) fails to satisfy the Head of Department that home education is in the best interest of the learner, the Head of Department must decline to register a learner to receive home education.”

Subsection 12: “The Head of Department must cancel a learner’s registration to receive home education if, after investigation, the Head of Department is satisfied that home education is no longer in the best interests of the learner.”
The effect of these clauses is that a parent may make a decision to home educate a learner, but the Head of Department may overrule that decision based on his or her understanding of the learner’s best interest.

According to section 28(2), a child’s best interest must be of paramount concern in every matter concerning the child. The utmost care must be taken to uphold this right in every decision affecting the child. The question is therefore whether it is practically possible for the Head of Department to take such decisions on the best interest of the learner, and whether he or she are more capable of making such a decision than the parent.
a) When the application arrives at the Head of Department, the HOD knows nothing about the learner. In order to make a decision on the best interest of that learner, the HOD will have to become intimately acquainted with the details of that learner’s situation, personality, ability, history, environment etc. No mere cursory overview will give effect to the child’s right to have its best interest truly considered.

Furthermore, should the HOD wish to overrule the parental decision on the best interests of the learner, he or she should have to be as well or better acquainted with the learner’s situation than the parent is.

For the HOD to become this intimately acquainted with the learner’s situation will take many hours, much administrative work, and much investigation. Given the budgetary constraints of the PED’s, this is not practically possible.

b) Another consideration is that the educational best interest of the learner cannot be severed from other aspects of the learner’s best interest. A parent’s decision to home educate is rarely made only on the basis of whether the learner will receive a better education at home or not. Many other aspects are taken into account, such as the learner’s psychological state, his or her physical safety, the family’s financial position, the family’s cultural or religious convictions, etc.

The HOD’s jurisdiction is education, and they are not trained to make decisions on the best interest of a learner in these other matters. To obtain the opinion of other people trained on these matters for each learner who applies for home education will once again not be practically possible on the current budgetary constrictions. In light of the above points, the Association therefore holds that it is inappropriate to expect the Head of Department to rule on the best interest of the learner. For practical
considerations, the parent’s decision on the learner’s best interest should be taken as valid until and unless the contrary can be proven.

This means that instead of the intricate application process, a simple notification process should be substituted whereby the parent simply notify the Head of Department of their decision to home educate.

4. Section 51(2)(a)(iii)

“[The Head of Department must approve the application and register the learner as contemplated in subsection (1) if he or she is satisfied that] the proposed home education programme is suitable for the learner’s age, grade level, and ability and predominantly covers the acquisition of content and skills at least comparable to the relevant national curriculum determined by the Minister …”

In part A we have expressed concern about the vague terms used in this specific phrase to describe an acceptable home education programme. We pointed out that “predominantly” is open to a range of interpretation. However, no matter how you look at it, “predominantly” must at the very minimum mean more than 50%.

It is worth noting that the pass mark for learners following the NCS only requires the attainment of 50% in a single subject per grade. All other pass marks are below 50%. Some pass marks are even as low as 30%. Note that learners who pass a subject with 30% has only acquired 30% of the content and skills of the relevant national curriculum determined by the Minister. No learner in public schools is required to acquire more than 50% of the content and skills in any subject in order to pass that grade.
We therefore deem the requirement of home learners to use a program which “predominantly” (meaning more than 50%) covers the acquisition of content and skills “at least comparable to” to the relevant curriculum to be an unreasonable limitation on the curriculum choice of the learner. At the very least, home learners should not be expected to cover more of the relevant national curriculum (or content and skills comparable to it) than children in public schools does, if the State should be allowed to prescribe content in independent education at all.

5. Section 51(2)(b)(iii)

“(iii) [if the parent undertakes to] arrange for the learner’s educational attainment to be assessed by a competent assessor –
(aa) annually, up to the end of the year in which the learner reaches the age of 15 years or completes grade 9, whichever occurs first; and
(bb) against a standard not inferior to the standard determined in the National Curriculum Statement …”
The cost of annual assessments by a competent assessor is a major concern to a significant number of home educating families. As shown earlier in our submission, the majority of home learners does not cover subjects / learning areas separately and continuously in the traditional way, but rather uses a blended model. On the subject of grades, once again the majority does not use grades for all subjects, covers various grades in various subjects, or doesn’t make use of the grade-system at all.
Competent assessors, as defined in the BELA Bill, are not trained to assess in this environment. This creates two problems:
a) There is no logical reason why home educators should be required to make use of a person who has not been trained to do the specific task which they are forced to use them for.
b) If such competent assessors do attempt to assess in the home education environment, it takes a significant amount of time and effort, which rises the costs significantly.
Enforcing this requirement on the home education sector will mean disproportionate costs to the families, who are already sacrificing all or part of a second income to teach their children themselves. The Association would therefore recommend that assessment should only be done if necessary, that is, if there is reason to suspect that a child may be educationally neglected, and that a person who is trained in the specific approach, methodology or philosophy the learner is using be appointed as an assessor.

6. Section 51(3)
“In considering the application, the Head of Department may require a delegated official to conduct a pre-registration home education site visit and consultation with the parents and learner to verify the information supplied in the application documentation and to provide support, where necessary, with the application process.” Section 14 (a) of the Constitution states that “everyone has the right to privacy, which includes the right not to have their person or home searched.” The required entry by an
uninvited party into someone’s home in order to investigate that home therefore amounts to a limitation of the right to privacy of the parent, learner, and any other occupants of that home. It must therefore be shown that there is good cause for this limitation.
The subsection limits the delegated official to conduct the site visit for two reasons: to verify information supplied in the application, and to provide support with the application process.

 

In order to show that the site visit is a necessary limitation on the right to privacy, it must be shown that either the verification or the support, or both, cannot possibly take place at an alternative venue.
It must be noted that there are no requirements set for the site itself. The registration requirements that are set in the BELA Bill all apply to aspects which can relatively easily be moved to an alternative location, such as curriculum or educational resources. There is therefore no reason why the verification of information can not take place at an alternative site. For the same reason it is also difficult to see why support cannot be provided at an alternative site.
There seems to be no valid reason to place such a limitation on the right to privacy of the parent, learner, and other occupants of the home, and this subsection should therefore be removed.

1. Section 51(16)
“The Minister may make regulations relating to the registration for, and the administration of, home education.”
From Part A of our submission, it is very clear that the home education sections of this Bill were written by someone who has little to no understanding of the home education sector and the lived reality of home learners. Our many attempts to convey the reality to the Department of Basic Education over the years have fallen on deaf ears and our concerns has largely been ignored.

Under these circumstances, this clause gives us cause for major concern. If this is the pattern that has been established for writing law, it is expected that the pattern will simply continue with the writing of regulations, and that the regulations will enlarge the distance between legislation and reality rather than close the gap.

We would therefore like to ask that this subsection be amended so that the Minister may make regulations only in consultation with the home education sector.

 

2. Conclusion and Recommendations
Apart from the very unclear words, phrases, and subsections in the Bill, the Association also have substantial concerns with many of the subsections which are, in fact, clear. Based on the arguments presented in Part 2 of our submission, we would like to ask the following:

a. That the requirement to start grade R at age 6 be omitted;

b. That the intricate application process be removed and a simple notification process be substituted whereby the parent simply notifies the Head of Department of their decision to home educate;
c. That the prescription of content and skills for the home education sector be removed;
d. That the assessment requirement should be changed to only be done if necessary, that is, if there is reason to suspect that a child may be educationally neglected, and that a person who is trained in the specific approach, methodology or philosophy the learner is using be appointed as an assessor in such a case;
e. That the subsection authorising a home visit be omitted;
f. That subsection 16 be amended to allow the Minister to make regulations only in consultation with the home education sector.

 

D. Conclusion
Although we have more concerns with the changes to section 15 of the SASA proposed in the BELA Bill, it is our sincere wish that the two-part submission above will give some indication of the gravity of our concerns.
It is a great pity that the Bill has reached this stage without any meaningful change to accommodate the lived reality of home educators. Should it be passed in its current form, much confusion will be caused, and many problems will be experienced in the regulation and administration of home education. We hope that our recommendations and requests as presented at the end of Part A and Part B will assist in avoiding this.
We greatly appreciate the opportunity to comment on the proposed changes of the BELA Bill and would like to request the opportunity to make an oral submission to the Committee as well.

 

Sincerely yours,

 

Charlene Chauvet-Swart (Chairperson)
Martin Law (Deputy Chairperson)
Neeresh Badal (Secretary)
Uda de Wet (Secretary)
Lalie Moraba (Secretary)
Lebo Ngcobo (Treasurer)
Sikhumbuzo Dlomo
Tehillah Green
Janet Kieswetter
Karin van Oostrum

 

On behalf of the Gauteng Association for Homeschooling

 

We invite all Gauteng homeschooling members to join the Gauteng Association for Homeschooling, by completing this membership form below: https://forms.gle/Cfch2bfvsAFmHtdJ9

Together, we are strong!