EHLANZENI
DISTRICT MUNICIPALITY
PROFILE
1
TABLE OF CONTENTS
1.
1.1
1.2
1.3
1.4
2.
2.1
2.2
2.3
2.4
2.5
2.6
3.
4.
4.1
4.1.1
4.1.2
4.1.3
5.
6.
7.
EXECUTIVE SUMMARY
INTRODUCTION
Overview
Municipalities within the District
Political and Administrative Leadership and Seat of District
Political Representation
SERVICE DELIVERY
Household Infrastructure
Sanitation
Water
Electricity
Refuse Removal
Service Provider
AUDIT OPINIONS
STATE OF LOCAL GOVERNMENT ASSESSMENT
Overview of findings on assessment in the Municipality
Governance
Financial Management and Viability
Service Delivery
INFRASTRUCTURE PRIORITIES IN TERMS OF THE MUNICIPAL
TURN-AROUND STRATEGY
MIG PROJECTS
3
4
4
5
5
6
7
7
7
7
8
8
8
8
9
9
9
9
9
10
VULNERABILITY CLASSIFICATION
14
2
11
EXECUTIVE SUMMARY
Ehlanzeni District has the highest population density in Mpumalanga. The majority of
the population lives in formal urban areas, or in villages in the tribal areas. The
estimated population density varies substantially between the five municipalities with
Mbombela and Bushbuckridge having the highest densities and Umjindi and Thaba
Chweu the lowest. There are five local municipalities within the district.
Ehlanzeni has the lowest access to infrastructure amongst the districts in the province.
Access to infrastructure in the municipality increased from 49% in 1996 to a higher level
of 60% in 2009. The main contributor to the increase in access is electricity
infrastructure and to a certain extent sanitation.
The audit outcomes of the District and two of the local municipalities have improved
over time and reached financial unqualified status, while the two other local
municipalities have remained poor.
The State of Local Government Assessment found that water provision within the
district is generally inadequate. In certain areas water is not purified and this results in
communities being provided with unclean water. Theft of water through illegal
connections is eminent within the municipality. Installed pipes are of low quality thus
leakages are often experienced. Several roads in the district are not surfaced.
In terms of its Municipal Turn-Around Strategy the District identified the need for bulk
water infrastructure, as well as improving refuse removal.
None of the five local municipalities in the Ehlanzeni District have been classified as in
the category of most vulnerable by DCoG in terms of functionality, socio-economic
profile and backlog status, but two municipalities are classified in the second most
vulnerable group. This profile confirms that infrastructure prioritisation in Ehalnzeni
District should focus on the provision of bulk water.
3
1.
INTRODUCTION
1.1
Overview1
Ehlanzeni District Municipality is the most eastern district of the province of
Mpumalanga. It is bordered by Swaziland and Mozambique in the east, Limpopo
Province in the north, Gert Sibanda District in the south and Nkangala District in the
west. It consists of five local municipalities: Mbombela, Thaba Chweu, Nkomazi, Umjindi
and Bushbuckridge, which became part of the district after the government decision to
phase out cross-boundary municipalities in 2006.
The majority of the population lives in formal urban areas, or in villages in the tribal
areas. Ehlanzeni District has the highest population density in Mpumalanga. The
estimated population density varies substantially between the five municipalities with
Mbombela and Bushbuckridge having the highest densities and Umjindi and Thaba
Chweu the lowest. Ehlanzeni District includes both Lowveld and escarpment country.
Agriculturally, the area has much to offer. An abundance of citrus fruit and other
subtropical fruits ‑ mangoes, avocados, guavas, paw-paws, litchis, bananas and
granadillas ‑ as well as sugar-cane, pecan and macadamia nuts and many types of
vegetables are cultivated. Nelspruit, the Provincial capital, is the second largest citrusproducing area of South Africa and is responsible for a third of the country’s export of
oranges. The Institute for Tropical and Subtropical Crops is situated on the outskirts of
the city.
The Maputo Corridor, linking Gauteng with Maputo harbour, traverses the district along
the N4 national road, offering easy access to the area as well as providing export
opportunities for companies operating in the area. The Kruger Mpumalanga
International Airport (KMIA), near White River provides further accessibility to this
district. The airport, which has direct flights to and from Europe, is a benefit to both
tourism and export businesses. The Kruger National Park was re-demarcated in 2006.
Previously it formed the now disestablished cross-border Bohlabela District Municipality.
The northern portion of the park is now a District Management Area (DMA) of the
Mopani District Municipality in Limpopo while the southern portion of the Park is a DMA
of the Ehlanzeni District Municipality.
Source: Gaffney’s, November 2009: Local Government in South Africa 2009 – 2011, Official Yearbook:
p 985 - 986.
1
4
1.2
Local Municipalities in the Ehlanzeni District
The details of the five local municipalities within the District is tabled below:
Table 1: Statistics of the Ehlanzeni District and Local Municipalities
Municipalities
within the
District
Ehlanzeni
District
Municipality
Bushbuckridge
Local
Municipality
Mbombela
Local
Municipality
Nkomazi Local
Municipality
Thaba Chweu
Local
Municipality
Umjindi Local
Municipality
Ehlanzeni
District
Management
Area (Kruger
Park)
1.3
Area
Area (km2) after 2011
(km2)
Local Government
in 2009
Elections & % change
27,895.57
27,895.57
-
Population
Poverty
Rate
1,549,666
393,260
57.00%
2,589.39
10,249.70
295.83%
517,807
126,506
79.84%
3,411.96
5,394.43
58.10%
535,290
139,461
58.55%
3,240.49
4,786.99
47.72%
343,288
79,456
65.73%
5,719.06
5,719.06
-
88,888
28,691
38.30%
1,745.39
1,745.39
-
61,405
19,054
43.48%
To be incorporated into
the local municipalities.
2,989
91
57.00%
11,189.29
Political and Administrative Leadership and Seat of District2
Political Leadership: Executive Mayor: Ms L Shongwe
Administrative Leadership: Municipal Manager: Adv H Mbatha
The head office of the District is located in Nelspruit.
2
No. of
Households
Source: Ehlanzeni DM; August 2011
5
1.4
Political representation3
Table 2: Local Government Election 2006 / Provincial & National Elections 2009
comparison:
Leading
Parties
in the
Election
1st
2nd
3rd
4th
Totals
Local Government Elections 2006
Party
Party Votes and
Ward Votes and %
%
Councillor Seats
Party
Seats
ANC
DA
PAC
ACDP
Other
ANC
DA
APC
PAC
OTHER
243,335
20,079
8,121
3,244
7,451
282,230
86.2%
7.1%
2.9%
1.1%
2.6%
100%
237,072
19,473
7,252
3,257
20,601
287,655
82.4%
6.8%
2.5%
1.1%
7.2%
100%
54
6
1
1
62
Provincial Elections 2009
Party
Votes and %
National Elections 2009
Party
Votes and %
ANC
DA
COPE
APC
Other
ANC
DA
COPE
APC
Other
%
87.1%
9.7%
1.6%
1.6%
100%
477,778
25,950
14,876
3,283
10,778
532,665
89%
4.9%
2.8%
0.6%
2.0%
100%
489,782
29,007
15,132
2,805
11,378
548,104
Figure 1: 2011 Local Government Election results and seat allocations:
The ANC is the leading party in terms of proportional DC40 Seats in Ehlanzeni, with 24
seats of 28 seats.
3
UPDATE Aug’09: DC40 seats - ANC (88%) 22 seats, DA (8%) 2 seats, PAC (4%) 1 seat, Total 25 DC40 seats
6
89.4%
5.3%
2.8%
0.5%
2.1%
100%
2.
SERVICE DELIVERY4
2.1
Ehlanzeni District Municipality Household Infrastructure
Household Infrastructure Overview
MP - DC32 Ehlanzeni District Municipality
0.80
0.70
0.60
0.50
Index
0.40
0.30
0.20
MP - DC32…
0.10
0.00
19961997199819992000200120022003200420052006200720082009
Source: IHS Global Insight Regional eXplorer version
Ehlanzeni has the lowest access to infrastructure amongst the districts in the province.
The graph above shows that access to infrastructure in the municipality increased from
49% in 1996 to a higher level of 60% in 2009. The main contributor to the increase in
access is electricity infrastructure and to a certain extent sanitation.
2.2
Sanitation
With regard to access to sanitation, the district municipality’s household access to
hygienic toilets has gone up from 24% in 1996 to 42% in 2009. The improvement in
access to sanitation in general in the Municipality is mainly due to the increase in the
use of pit latrines with ventilation which went up from 5% in 1996 to 20% in 2009. About
45% of the households use pit toilets.
2.3
Water
In terms of water infrastructure, there has been a decrease in the number of households
having access to piped water above RDP level in the municipality from 71% in 1996 to
67% in 2009. While this is the case, households’ access to water below RDP level
4
Sources: IHS Global Insight Regional eXplorer version 574 and Municipal Demarcation Board, 2008:
National Report on Local Government Capacity, District and Local Municipalities, MDB Capacity
Assessment, 2007/2008.
7
increased from 10% in 1996 to more than 20% in 2009. Still, there are more than 10%
households without piped water in the municipality.
2.4
Electricity
In 1996, household access to electricity connections was at 42%. Since then, access
has increased drastically reaching 81% by 2009. The increase in electricity connections
is the biggest infrastructure achievement in the municipality.
2.5
Refuse removal
There has been an increase in access to formal refuse removal service from 1996 to
2009 in the Municipality. Access has gone up from 21% in 1996 to 34% in 2009.
Personal refuse removal which stands at around 60% remained the same over the
years. The high levels of personal refuse removal must be taken in the context of low
settlement densities, where on-site disposal or backyard burning of waste is sometimes
appropriate.
2.6
Service provider
Ehlanzeni District does have authority and does perform potable water function. There
is however, limited capacity available to perform refuse removal function.
3.
AUDIT OPINIONS
Table 3: Audit Opinions of the District and Local Municipalities
Municipality
Audit
Opinion
2005/6
Ehlanzeni DM
Financially
unqualified
with other
matters
Bushbuckridge Adverse
LM
Audit
Opinion
2006/7
Qualified
Disclaimer
Audit
Opinion
2007/8
Financially
unqualified
with other
matters
Qualified
Mbombela LM
Qualified
Disclaimer
Qualified
Financially
unqualified
with findings
Qualified
Nkomazi LM
Thaba Chweu
LM
Umjindi LM
Qualified
Disclaimer
Qualified
Disclaimer
Disclaimer
Qualified
Qualified
Disclaimer
Audit
Opinion
2009/10
Financially
unqualified
with no
findings
Financially
unqualified
with findings
Financially
unqualified
with findings
Qualified
Disclaimer
Qualified
Disclaimer
Qualified
Financially
Financially
unqualified
unqualified
with other
with other
matters
matters
Source: Auditor-General 2009 and 2011, see. www.agsa.co.za
8
Audit
Opinion
2008/9
Financially
unqualified
with findings
The trend of audit outcomes from 2005/6 to 2009/10 for Ehlanzeni places the district
municipality at an outstanding position. For instance, only in 2006/7 Ehlanzeni district
failed to obtain an unqualified audit outcome. In the case of Nkomazi and Thaba
Chweu, their audit opinions from 2005/6 to 2009/10 indicates a short fall in the
management of resources as the two municipalities had not improved to financially
unqualified audit outcomes.
4.
STATE OF LOCAL GOVERNMENT ASSESSMENT
4.1
Overview of findings on assessment in the municipality
4.1.1 Governance
Poor interaction between the Executive Mayor and the Speaker impacts on the
business of the municipality. The Executive Mayoral Committee is divided along the
regional lines Bushbuckridge, Nkomazi and Nsikasi. These divisions results in the
budget processes being driven along regional lines while allocation is influenced by
those who are more articulate than influenced by developmental priorities. More often
the municipality deviates from the IDP and budget without the approval of the Council.
The capacity of councilors is a concern to the municipality as majority of them do not
perform according to expectations thus they require to undertake some capacity
building programmes. The Council has a very limited oversight role.
4.1.2 Financial Management and Viability
The database of creditors is not yet computerized. There is a tendency to implement
most projects towards the end of the financial year so as to meet legislative
requirements this however puts pressure on managers. The Fraud prevention plan is
not fully implemented.
4.1.3 Service Delivery
Water provision within the district is generally inadequate. In certain areas water is not
purified and this results in communities being provided with unclean water. Theft of
water through illegal connections is eminent within the municipality. Installed pipes are
of low quality thus leakages are often experienced. In view of roads several roads in the
district are not surfaced. Considering LED there is no official in province that deals with
LED and the district does not have Tourism Strategy. The district believes that an
informal border post at Nkomazi could improve tourism in the area if it is formalized.
Lack of a tertiary institution in the province is held responsible for semi skilled and
unskilled number of people within the district as well as in the entire province. Local
businesses are said to be appointing service providers from outside the district area
therefore there is no skills development happening within the district.
9
5.
INFRASTRUCTURE PRIORITIES OF THE MUNICIPAL TURN-AROUND
STRATEGY
The Ehlanzeni District Municipality identified a number of priorities for basic service
delivery in the Ehlanzeni Municipal Turn-Around Strategy.
Table 4: Infrastructure delivery in terms of the MTAS
Challenges
Access to water and
sanitation
There is no baseline data,
updated status quo for the
District in terms of Bulk
Water Master Plan &
Source Development
based on approved
engineering principles.
Access to
Electricity
No data base at
District level in terms
of determining the
backlogs as well as
other sources of
energy
No service level
agreements for provision
of bulk with all five (5)
LMs
New sites to be
established.
Determine financial
models for cost recovery
and funding as well.
Make provision in FY
2010/11 and appoint
specialist Service
Provider to undertake
study
Certain sites needs
to be closed,
upgraded,
decommissioned or
start operation.
No sites comply to
the minimum
requirements.
No budget for funding
bulk provision to support
municipalities
Municipal
Actions
Integrated waste
management
WMPs to be
upgraded of all 5
L.M.s EDM to
develop an IWMP.
Total break-down
of waste
management in
most areas.
Develop energy
master plan by 30
June 2010 in FY
2010/11
L.M.s to appoint
service providers
for WMP and EDM
for IWMP. Make
provision for R
100m on FY
2010/11 budget .
Data required from
LMs to take
SLAs to be developed to
provide support to LMs for
bulk
development/insufficient
source
Develop Bulk BPs and
submit to DWA and other
funding agencies
Other support
Funding from BIG, (DWA)
10
and
interventions
6.
the Dept of Energy
and Eskom and LMs
ownership of plans
and to budget.
MIG PROJECTS
Table 5: MIG projects
Municipality
Project name
Bushbuckrid
ge LM
Acornhoek Brenda water
reticulation
Inyaka water and
bulkdistribution system
Extension of hoxani water
water treatement works
module 6 & 7
Acornhoek
Sewerage plant
Thaba
Chweu LM
Registered MIG
funds
Total actual
expenditure in
the 2010/11
financial year
Project
status
(Registered/
design/tende
r/constructio
n)
Project
category (e.g.
water,
sanitation,
PMU)
R 1,000,000
R 2,283,856.31
Tender
Water
R 274,581,741
R 89,632,167.79
Construction
Water
R 44,300,000
R 17,983,318.60
Construction
Water
R 24,700,000
R 10,189,848.93
Sanitation
Project management unit
Construction of VIP toilets at
Bushbuckrudge, rural
sanitation for all regions
R 3,500,000
R 4,088,634.35
Tender
Awaiting
approvals
R 72,536,490
R 54,721,624.56
Moremela: Bus Route
Coromadel: Refurbishment of
Entrance Road and Lower
Bridge
Coromandel: Lower Water
Bridge
Upgrading of Voortrekker
Street - Lydenburg
Stasie; Construction of Bulk
water Supply
R 1,560,000.00
R 1,294,641.31
Construction
Construction~
Completed.
Sanitation
Roads and
Stormwater
R 4,532,732.00
R 7,539,868.40
Roads and
Stormwater
R 7,415,684.00
R 0.00
R 15,671,580.00
R 4,987,026.09
R 2,200,000.00
R 192,389.96
Provision of boreholes pumps
and rising main in Mashishing
Resevoirs
R 2,133,658.00
R 74,651.76
Provision of bulk water supply
and reticulation to Kanana ;
Moremela
R 6,188,633.00
R 0.00
Provision of water reticulation
to Leroro
R 2,923,479.00
R 167,063.44
Construction~
Completed.
Construction~
Completed.
Construction~
Completed.
Construction~
Completed.
Ajdudicated,
report with
the Municipal
Manager for
consideration
for
appointment.
To be
advertised for
Contractors
on 14-072011
Ajdudicated,
report with
the Municipal
Manager for
consideration
for
appointment.
11
PMU
Bridge
Roads and
Stormwater
Water
Water
Water
Water
Coromandel : Installation of
Streetlights
Umjindi LM
Mbombela
LM
Mashishing and Ext
2:Installation of Streetlights
Sabie Rehabilitation of Main
Road.
PMU Unit
Replacement of AC pipes with
PVC at Emjindini
Roads and Storm water
Infrastructure
Water and sanitation for ward 1
VIP toilets for rural areas
Sports Infrastructure
Street lights and High Mast
Lights
Backdoor taxi & bus route
phase 2
Project Management Unit
Construction of Clau-Clau
bridge
Kabokweni waste water
treatment works
Zwelishe phakane water
supply
Zwelisha zomba water supply
Construction of Elijah Mango
bus route phase 2
Construction of Msogwaba
tshuma bus road
Construction of Gutshwa Kop
bus route
Mamelodi water supply
R 174,344.00
R 0.00
R 194,835.00
R 0.00
R 11,600,000.00
R 1,109,600.00
R 184,219.45
R 526,102.42
R 2,134,294.90
Registered
with MIG.
Quotes will be
done to start
with
implementatio
n.
Contractor on
site (01-062011)
Retention
Amount
PMU
Electricity
Electricity
PMU Unit
Water
R 49,060.83
Construction
Operational
cost
0
0
0
0
Construction
Registration
Registration
Registration
Roads
Sanitation
Sanitation
Sports
0
Registration
Street lights
R11,210,000.00
R2,419,898.23
Completed
Completed
Construction
75%
Construction
65%
Construction
98%
Design
R 5,701,755.00
R348,371.13
R 62,084,400.00
R14,407,727.48
R 4,382,160.00
R 3,597,840.00
R2,786,962.08
R0.00
R 5,074,000.00
R868,135.28
R 4,765,256.00
R2,200,030.56
R 29,598,800.00
R 3,775,680.00
R2,777,296.47
R0.00
Matsulu Mashonamini bus road
Zwelisha B/Mluti/Aldie water
supply phase 3
TV Enkomeni: Bus route phase
3
Nsikazi North household
sanitation
Matsulu, Mpakeni, Portia &
Luphishi household sanitation
VIP
R 3,292,177.50
R1,611,148.43
R 9,773,000.00
R0.00
R 4,859,000.00
R4,812,294.45
R189,195,600.00
R7,870,687.24
R 49,407,600.00
R3,775,380.36
Nsikazi South house sanitation
Matsulu Hambavangeli bus
route
Construction of water
reticulation for zola matsulu
Entokozweni Kanyamazane
extension of water supply
Reconstruction of Clau-
R237,996,000.00
R4,684,236.51
R 4,748,400.00
R1,149,061.72
Construction
20%
Construction
20%
Construction
5%
R 6,460,000.00
R395,538.59
Construction
R 1,339,250.00
R 7,212,210.00
R1,303,142.59
R2,030,610.86
Construction
Completed
12
Electricity
Completed
Construction
25%
Construction
15%
Completed
Construction
5%
Design
Construction
98%
Construction
20%
PMU
Nkomazi LM
clau/Zwelis HA bridge
(destroyed by storm)
Reconstruction of
Kanyamazane/Pienaar bridge
(destroyed by storm)
Mataffin trust internal water
and sewerage
Tekwane to Entokozweni bus
route
Pedestrian bridges (Mbombela
2)
Upgrading of sandriver to
Nkambeni bus route
Construction of Phathwa
access road
Construction of Kabokweni to
Gutswa road
Elandshoek bus route
Tekwane north bus route
phase 1a
Matsula “B” Frank emoyeni bus
route
Clau-clau bus route and
related stormwater drainage:
phase 5 -7
Tonga C Mafambisa Water
reticulation Phase 2
(Mafambisa)
Tonga East Water Treatment
Works
Nyathi Water Treatment Works
Mbekisburg Water Connection
+ Reticulation
(Mbekisburg)
Sibange Bulk Supply
(Sibange)
Tonga WTW Phase 1B
(Tonga)
Mbuzini Bulk Water Supply
Augmentation
(Mbuzini)
Mangweni Water Reticulation
(Mangweni)
Steenbok Reticulation
(Steenbok)
Madadeni Elevated Tank And
Booster Pumps (Madadeni)
Masibekela Link Pipeline
(Masibekela)
Masibekela Water Treatment
Plant
(Masibekela)
Ntunda Bus Route
(Ntunda)
Tonga C Bus Route Phase 2
(Tonga)
Nyathi Bus Route
(Nyathi)
Magogeni Bus Ring Road
(Magogeni)
Schulzendal Bus Route
(Schulzendal)
Kamhlushwa(Eastgate)Bus
R 6,750,000.00
R3,512,100.56
Completed
R 32,560,547.57
R0.00
Design
R 9,107,679.00
R4,960,512.94
Construction
R 16,986,000.00
R2,424,000.22
R 8,716,743.65
R6,449,582.08
Construction
Construction
75%
R 6,850,392.00
R378,500.00
Design
R 4,863,637.00
R 2,497,100.00
R474,376.28
R584,348.45
Tender
Construction
R 24,736,106.46
R13,957,132.98
Construction
R 2,853,830.40
R200,761.80
Design
R 13,199,534.46
Completed
R 13,073,771.00
R 3,922,418.59
Completed
R 23,020,000.00
R 37,850,000.00
R 105,931.15
R 539,930.02
Completed
Completed
R 3,000,000.00
R 3,046,658.03
R 3,000,000.00
R 2,343,656.68
Completed
Construction
90%
R 51,000,000.00
R 2,576,319.63
R 61,933,300.00
R 6,596,867.67
R 5,244,128.00
R 3,496,727.31
R 5,244,128.00
R 1,660,057.00
R 2,944,700.00
R 2,917,464.00
R 17,100,000.00
R 4,222,773.81
R 33,085,137.00
R 1,802,380.25
R 9,500,000.00
R 6,611,740.35
R 6,000,000.00
R 3,589,515.84
R 8,000,000.00
R 2,818,071.79
R 9,500,000.00
R 4,311,408.93
R 8,200,000.00
R 5,500,000.00
R 5,641,666.00
R 2,016,486.75
13
Design
Construction
15%
Construction
87%
Construction
98%
Construction
100%
Consruction
80%
Construction
95%
Construction
75%
Constructionn
450%
Construction
50%
Construction
40%
Construction
80%
Construction
Route
(Kamhlushwa)
Kamaqekeza(Abdul
Section)Bus Route
(Kamaqekeza)
Langeloop Ring Road Phase 2
(Langeloop)
Construction of Vip Sanitation
at Nkomazi Rural Area Old
Village
Construction of Vip Sanitation
at Nkomazi Rural Area New
Village
Schoemansdal Community
Hall
PMU Operational Cost (2,7%)
Source: All MIG projects, 2011 June
50%
R 4,500,000.00
R 713,624.03
R 3,000,000.00
Construction1
0%
Design
R 58,500,582.00
R 5,568,604.01
R 81,105,300.00
R 3,208,576.05
R 5,000,000
R 4,665,770.01
R 2,470,014.00
Construction
100%
Construction
50%
Construction
55%
As shown in table 6, local municipalities in Ehlanzeni district have a mix of MIG projects
in their jurisdictions. Most of the projects in the local municipalities are still under
construction. As stated in the 2010/11 monthly non-financial report on MIG, Ehlanzeni
and its locals submitted their MIG 2011 June reports. However, none of these reports
were signed by the accounting officers as required.
7.
VULNERABILITY CLASSIFICATION
The DCoG Municipal Spatial Classification System was designed to develop municipal
profiles according to spatial location, based upon results from indicator sets on
functionality, socio-economic profile and backlog status. Its purpose is to inform a
differentiated approach to municipalities.
The four municipal classifications developed by DCoG are:
Class 1: Most vulnerable (57 local municipalities)
Class 2: Second most vulnerable (58 local municipalities)
Class 3: Second highest performing (58 local municipalities)
Class 4: Highest performing (58 local municipalities)
The five local municipalities in the Ehlanzeni District can be classified as follow:
Table 6: Vulnerability Classification
Local Municipality
Bushbuckridge
Mbombela
Nkomazi
Thaba Chweu
Classification
Second most
vulnerable
Second highest
performing
Second most
vulnerable
Highest performing
14
Umjindi
Highest performing
From this table it is evident that none of the five local municipalities in the Ehlanzeni
District fall into the most vulnerable category, but two municipalities are classified in the
second most vulnerable group.
15