The Governance of New Immigrants Inflow: from Emergency Management to Social Inclusion Policies. The...

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The Governance of New ImmigrantsInflow: from Emergency Managementto Social Inclusion Policies.The Case Study of the Municipalityof Rome

Andrea Calabrò, Valentina Ferraro, Silvia Testarmata

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University of Rome “Tor Vergata”Università degli Studi di Roma “Tor Vergata”

Department of Business Studies Dipartimento Studi sull’Impresa (DSI)

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Editor in ChiefRoberto Cafferata – University of Rome “Tor Vergata”, Italy[cafferata@economia.uniroma2.it; cafft2002@yahoo.it]

Scientific Committee Alessandro Carretta – University of Rome “Tor Vergata”, ItalyCorrado Cerruti – University of Rome “Tor Vergata”, ItalySergio Cherubini – University of Rome “Tor Vergata”, ItalyAlessandro Gaetano – University of Rome “Tor Vergata”, ItalyClaudia Maria Golinelli – University of Rome “Tor Vergata”, ItalyHans Hinterhuber – University of Innsbruck, AustriaJoanna Ho – University of California, Irvine, U.S.A.Anne Huff – Technische Universität München, GermanyMorten Huse - Norwegian School of Management BI, NorwayMarco Meneguzzo – University of Rome “Tor Vergata”, ItalyPaola Paniccia – University of Rome “Tor Vergata”, ItalyCosetta Pepe – University of Rome “Tor Vergata”, ItalyHarald Plamper – Zeppelin University in Friedrichshafen, GermanyFrancesco Ranalli – University of Rome “Tor Vergata”, ItalySalvatore Sarcone – University of Rome “Tor Vergata”, ItalyJohn Stanworth - University of Westminster, United KingdomJonathan Williams - Bangor Business School, United Kingdom

Managing EditorsEmiliano Di Carlo – University of Rome “Tor Vergata”, Italy[dicarloe@uniroma2.it]

Sara Poggesi – University of Rome “Tor Vergata”, Italy[sara.poggesi@uniroma2.it]

Mario Risso – University of Rome “Tor Vergata”, Italy[mario.risso@uniroma2.it]

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The Governance of New Immigrants Inflow: from Emergency Management to Social Inclusion Policies. The Case Study of the Municipality of Rome

Andrea Calabrò, Valentina Ferraro, Silvia Testarmata1

Abstract Recent studies and events on immigration highlight the strategic importance of an immigration management. The paper aims at emphasizing that a possible solution is to adopt a multilevel governance perspective which focuses on the main actors and processes involved in the immigration management. Starting from the structural characteristics of this phenomenon with its long-term im-plications, the paper reviews the relevant literature and analyses the legislation context, giving a detailed picture of the current situation in the area of the Mu-nicipality of Rome. We underline the roles played by actors at the central and the local organizational level. Particular attention is given to their areas of in-tervention. Our results show the existence of overlapping and/or missing ac-tions at the central level, while an important role is played by NGOs. JEL Classifications: L60, L25, L11, L15, M16 Keywords: Immigration; governance; emergency management; social inclusion.

________________ 1 Andrea Calabrò, PhD candidate in Public management and Governance - University of Rome “Tor Vergata”; Valentina Ferraro PhD candidate in Public management and Govern-ance – University of Rome “Tor Vergata”; Silvia Testarmata, PhD doctor in Public manage-ment and Governance – University of Rome “Tor Vergata”.

Contents 1. Foreword 3 2. Theoretical background 3 3. Research methods 6 4. Regulation of immigrants’ inflow 7 5. The Central Administration level and the role of Ministries: labour division vs duty avoidance 12 6. The local level: the Municipality of Rome 16 7. Results and findings 23 8. Conclusions 25 References 27 Tables and figures 31

Editorial notes A previous version of the paper was presented to the EGPA (European Group of Public Administration) – 2007 – Madrid, in the Seminar for Doctoral Stu-dents and Junior Researchers European, 14-17 September, Madrid, Spain.

1. Foreword A correct approach to the migration phenomenon postulates the necessity to be aware that this phenomenon has become “structural” rather than “tempo-rary”, so that we should cope with it, by assuming a long-term perspective. Moreover the presence of outlanders in western societies is not just a matter of law and order and emergency management; indeed, it has become one of the constitutive elements of the social context.

That is why it calls for social integration strategies, which have to be elabo-rated according to a contingency approach, in order to adapt the solutions to the peculiarity of each context. In this respect, a multilevel governance ap-proach to handle migration brings about several factors of innovation, which drive both a higher level of awareness of the territorial resources and a formal and informal network building promoting dialogue, knowledge exchange and a positive interaction among institutional and non-institutional territorial stakeholders. Only in this direction it would be possible to look at migrants as a strategic resource, according to the human capital perspective, in support of territorial strategies of development.

The paper is organized as follows: in sections two, three and four we review the main literature, show the methods and analyze the legislation context. In section five and six we analyze the role of central and local actors (the case study is on the Municipality of Rome). Our results and findings are showed in section seven. The paper ends with conclusion and implications.

2. Theoretical background

The issue of immigration policy represents a fairly recent field of study in Italy. Lawyers, sociologists and political scientists only started to analyze this subject in the early 1990s, and even nowadays, studies often focus more on legislation than on policy-making processes.

However, in front of the growing pressure (Monar, 2001) of the migratory phenomenon in the political agenda and the “emergence of ‘transnational so-cial spaces’ constituted by transnational migrants’ networks”, the civil society has called for a greater commitment of the Academics in this field. Thus, in a

4 A. CALABRÒ, V. FERRARO, S. TESTARMATA

functionalist perspective many authors (Monar, 2001; Stetter, 2000) accommo-date new models of governance for the migratory flow management, facing at first the lack of a multidimensional immigrants’ integration policy.

In Italy, many studies on the policy-making processes for immigration, ad-dresses the two classical issues: a) policy networks and local decision-making; b) implementation and the role of Public Administration (P.A.). The first one explains territorial differentiation in immigration policy as due to the degree of importance of the third sector and the level of conflict and fragmentation within the P.A..

Analysing the immigration flow management, as a complex and historical problem, we cannot use directly a network approach. We think that it is neces-sary to show-up the explicative framework of policy outputs studies, seeking to identify the main factors that explain either national or local policy outputs, justifying the choice, at the end, of a multilevel governance approach.

We identify some stages among the main studies on the topic. In the first stage there are studies focusing on the “demographic inflows”

and on the national composition and evolution of migration flows into and within European countries (Zincone, 2006a). In this stage we include the eco-nomic theory of migration determinants (Zimmermann, 2005; Kandel and Massey, 2002; Fuglerud and Engebrigtsen, 2006; Evergeti and Zontini, 2006).

In the second stage we highlight researches which focus primarily on immi-grants’ economic integration into the labour market, the assimilation of the mi-grants, and the effects of the immigrants on the natives (Constant and Zim-mermann, 2005; Chiswick and Hatton, 2002; Hatton and Williamson, 2002) the role and the structure of the labour market and the informal sector, which still plays a crucial role in the Italian economy, as strong ‘pull factors’ for for-eign immigrants (Constant and Zimmermann, 2005), the assimilation into the labour market (formal sector) as a determinant of social inclusion.

The third stage concerns the part of literature that deals mainly with integra-tion policies and political participation.

Studies have also been carried out in this context in order to assess the in-fluence of immigrant organisations on both national and local policy outputs. According to this literature policies aimed at providing financial and organisa-tional resources for immigrant associations are likely to have a positive impact

The Governance of New Immigrants Inflow 5

on foreigners’ civic participation and their associations (Horta 2003; Soysal 2004; Fennema and Tillie 2004). Other studies highlight that immigrant poli-cies are dependent on the patterns of relations between third-sector organisa-tions and local government (Lostia and Tomaino 1994).

The fourth stage literature has tackled the problem of understanding how immigration policies are decided upon and carried out. These studies represent a relevant research field in most of the new immigration countries, such as It-aly (Zincone and Caponio, 2004a; Di Gregorio, 2004), Spain (Morén-Alegret, 2004) and Greece (Apostolatou, 2004).

Even more recently, a sort of fourth and a half stage literature has emerged, addressing the issue of the multilevel governance of immigration by focusing on government levels, interrelations and decision-making processes (Zapata-Barrero, 2004; Geddes, 2000; 2003; Di Gregorio, 2004; Lahav 2004; Guirau-don, 2003).

Those studies looks to changing patterns of public-private relations, and to the redefinition of traditional hierarchical governing structures (Pierre, 2000) underlying the role played b NGOs, immigrant associations, social movements. because a variety of actors are involved in defining immigrant policies (Alexan-der, 2003; 2004). For better understanding the multilevel governance approach, it is necessary connecting it with the network one. Indeed, referring to the local level, we may identify policy-networks, within which cultural mediators play a crucial role, as means of innovation (Moore, 2004; Gaxie et al., 1999; Morel, 2002; de Wenden and Leveau, 2001).

Moreover, some studies (Zucchini, 1997; Caponio, 2004; Campomori, 2005; Bosswick and Will, 2002) highlight differences among local policy networks af-fecting immigrant inclusion policies at the local level and reflecting established models of public/third sector relations, in which the coordinating or integrat-ing role played by the city council appears to be essential (Caponio, 2004; Campomori, 2005) rather than being determined by general strategies at the national level (Zucchini, 1998; Fasano and Zucchini, 2001; Damay, 2002).

A multilevel governance approach to the immigration flows acquires its relevance in the light of a system analysis framework (Zincone and Di Grego-rio, 2004). It is in this perspective that we set our research question: who are the main actors involved in the management of immigration at the central

Administration level and in the local area of Rome and which are the connec-tions and overlapping functions among them?

3. Research methods

The research methods used in the paper underline the complexity of the im-migration phenomenon. Therefore, we proceed step by step, as it follows:

a) Literature review on the immigration topic. We set out from a literature review at both the national and the international levels, in order to have a comprehensive frame of the studies evolution. Therefore, we classify the main studies in stages, in order to justify our choice of a multilevel governance ap-proach to immigration.

b) Analysis of immigration regulatory framework at both the European and the national levels.

c) Stakeholders analysis (institutional and non-institutional actors). Firstly, identifying, according to a prescriptive model, the directions along which the immigration policies may be defined. Secondly focusing on what has been al-ready done by the Italian institutional actors (central administration, e.g. Minis-tries). Thirdly, analyzing the Municipality of Rome context (the local level) by a case study analysis (Yin, 2003).

d) Case study on the Municipality of Rome. We analyse the behaviours of the various actors, according to the policy implementation methodological ap-proach. The Municipality of Rome is one of the main immigration pole in It-aly, for this reason we have chosen it. However, some specifications are due: the case study approach seems to be uncompleted if it is circumscribed only to the Municipality of Rome. Therefore, we preferred extend it at the Province level, aware that for a multilevel approach to be adopted it is necessary to es-tablish connections among institutional territorial actors. Indeed, we have car-ried out the case study on two levels: the Province and the Municipality level. Moreover, the case study is supported by targeted interviews carried out in Rome and by the collection of direct testimonies of the main representative subjects involved in the phenomenon, which operate both in the central and in the local Administration, and in NGO’s. The interviews have been carried out using structured grids.

4. Regulation of immigrants’ inflow

The analysis of the actual regulation on the immigration issue takes into account firstly the European level and secondly the national one.

4.1. The European Level

This level was more consistently connected with the national level and, to a cer-tain extent, the local one (Zincone and Caponio, 2004b), but now the perspec-tive is reversing, delegating more competences at the local level.

Since the Treaty of Amsterdam, the European Union had the necessary legal basis for adopting measures relating to certain areas of immigration policy. From 2001 to 2006 several acts were adopted for the development of a common asy-lum and migration policy (Table 1).

The Commission guidelines underline the importance of a coordinated ap-proach to the immigration management at the national level. It is important to improve information available on legal possibilities for immigrants admission, reinforcing also the fight against illegal immigration. Moreover, considering a manpower shortages scenario for the next years, the fixed targets of the Lisbon Agenda (2000) require a complete acknowledgement of the immigration phe-nomenon as an economic opportunity.

A newly prepared EU Green Paper indicates how to manage the economic migration and put emphasis on the various harmonization options available. The definition of a “Community Preference” principle, the setting of a more strict and flexible admission system on the basis of recognized short-term and long-term labour market requirements of the receiving country, the necessity of sim-plifying existing procedures for residence and work permits are all elements which can improve immigration strategic management.

In spite of an overall emphasis in the Green paper on the focal role played by economic aspects, it may be criticized for a one-side utilitarian “win-to win” per-spective. Indeed, very little attention is paid to the key issue of integration and there is no reference to the important role that social partners and dialogue can play in assessing labour market needs. The focus of the Community on the eco-nomic integration issue is confirmed by the pilot studies, which have been un-

dertaken in the last few years by the European Migration Network (EMN), through its existing 17 national contact points (NCP). The Commission approach is part of a participative model which involves the institutional level as well as social partners, third countries and the civil society. However, the NGO’s have a consistent role in the implementation of the EU’s new integrated program for employment and social solidarity: PROGRESS (2007-2013). In continuity with the previous program (EQUAL) it establishes to give a financial support for the implementation of the objectives of the Euro-pean Union in the fields of employment and social affairs. This is a support strategy to the Lisbon strategy goals across five broad areas: employment, social inclusion, working conditions, equality and tackling discrimination. Whereas EQUAL focused on a partnership approach, promoting development partner-ships, as an essential component for financial aid, PROGRESS opens the access to the program to public and/or private bodies, players and institutions con-firming the tendency towards a governance approach, in which the local level finds a new strength and commitment.

4.2. The Italian regulatory system of immigrant inflow Italy is a relative late-comer among immigration countries. Inflows started after the 1973-74 oil shock, when Britain, Germany, and, in particular, neighboring France closed their borders. The legal treatment of foreigners as potential immi-grants started only in the late 1980s, despite the fundamental features of the legal framework on the acquisition and loss of nationality date far back, to the period immediately following the unification of the country.

The first Act that attempted to regulate the development of these immigra-tion flows was Statute no. 943/1986. This Act regarded immigrants as workers, and was designed to protect Italians against potentially ‘unfair’ competition on the labour market. Moreover, non-EU citizens were prevented from moving freely from one kind of job to another. The Act also introduced the first regu-larization of illegal in Italy, and granted basic civil and social rights to foreign workers. However, no financial resources were explicitly allocated for these poli-cies, thus producing a striking discrepancy between the noble principles underly-ing the Act and its actual implementation (Zincone, 2006b).

A few years later, the total inadequacy of this first Act was clearly demonstrated by the passing of a second Immigration Act, Statute no. 39/1990, under dra-matic events pressure which pushed immigration to the forefront of the political agenda.

Immigration was reconceptualised as an emergency issue. The new guiding principles were to give the immigrants who were already in Italy the opportu-nity to lead a good life, and drastically reduce immigration flows. Indeed, the Act allocated a specific budget to the construction of ‘initial reception centres’. As regards flow regulation, a Flow Committee was set up to decide how many workers from non-EU countries could enter in Italy every year. Finally, a new Act was approved, allowing the regularization of 234.841 illegal immi-grants. However, these provisions did not prevent the emergence of new ille-gal flows.

The early 1990s can be described as a period of emergency policy, as demon-strated by the ad hoc provisions adopted to host the influx of refugees from Al-bania, the former Yugoslavia and Somalia, with the grant of temporary stay per-mits ‘for humanitarian reasons’. In 1995, new legalization was passed, attached to Legislative Decree no. 489/1995, which allowed the settlement of these immi-grants on a more permanent basis, allowed the regularization of 248.501 illegal immigrants, and introduced more severe measures against smuggling and traf-ficking of immigrants.

The following act is the no. 40/1998 On the Regulation of Immigration and the Legal Status of Foreigners in Italy, known as the Turco-Napolitano Act, which is the first systematic Italian Immigration Act: it may be considered as the first reform regarding immigration and immigrants’ rights which was not conceived under emergency conditions, but rather it treated immigration as a permanent phenomenon and regulated the subject with a comprehensive act.

The Act was based on four pillars: 1) prevention and contrast of illegal entry; 2) regulation of new flows of foreign workers; 3) promotion of immigrants inte-gration; 4) improvement of basic individual rights to illegal immigrants (Zincone, 2006a).

As regards the first pillar, the Act established special ‘temporary accom-modation centres’ where undocumented immigrants were temporarily de-tained while waiting for the expulsion procedure. The second pillar provided

legal entries on the basis of annual quotas, facilitated by the introduction of ‘sponsorship’. In order to promote integration (the third pillar), the Act granted foreigners who had been in Italy legally for at least five years the right to apply for a permanent residence card. A special fund (National Fund for Migratory Policies) was also set up to finance the integration measures promoted by the regional and local authorities. A later corrective Decree (Decree no. 380 of 16 October 1998) introduced another amnesty for un-documented immigrants, which regularized 220.000 illegal stayers. The fourth pillar concerns the treatment of illegal stayers. In particular, as for health care, according to the Implementing Regulation (DPR no. 394/1999, art. 43), illegal immigrants in need of assistance are granted an anonymous card which entitles them to access to the services granted by the Act.

The Turco-Napolitano Act was partially reformed in 2002 by the right-wing government.

The Norms Concerning Immigration and Asylum (Statute no. 189/2002), known as Bossi-Fini Act has two main purposes:

1) linking the new residence permits more strictly to employment require-

ments and favoring temporary jobs, discouraging permanent settlement; 2) fighting illegal entry.

The first purpose is underlined by the abolition of sponsorship and the short-ening of the validity periods of the various residence permits. In particular, the ‘unified contract of employment and residence’ was introduced as a main change, apart from the other innovation which is represented by the institution of the Unique Counter for Immigration. The unified contract of employment and residence involved hiring a worker abroad, with the obligation for the em-ployer to guarantee accommodation and cover the cost of return to the worker’s country of origin in the event of dismissal. In addition, the length of stay required to apply for the permanent residence card has been increased to six years. The Act did not apparently change the policies included in the third pillar (integration) or the fourth pillar (illegal immigrants’ rights), the only real legal change in immigrants’ welfare concerned pensions and was not substan-tial.

As regards the second purpose, the Act introduced some particularly repressive measures, such as mandatory imprisonment of foreigners who fail to comply with an order to leave the country after being found without a residence permit or with an expired permit; and arrest and immediate escorting to the border following a simple endorsement by a judge, without any hearing or possibility of defense. Both these provisions were ruled to be unconstitutional by the Constitutional Court, and had to be considerably attenuated by the govern-ment (Corrective Decree converted to Statute no. 271/ 2004). Despite the re-strictive approach of the Bossi-Fini Act, a new amnesty was introduced which allowed the regularization of over 634.000 illegal immigrants. The turning point of that restrictive approach has been signed by a new proposal of law - “Amato-Ferrero” in 2007. This proposal of law suggestes changes to the mi-gration law in Italy. Among the normative innovations we mention the three-year “decree flows”, the opportunity of admission for job seeking, a facilitated admission for “talents”, and effective expulsion.

The modification of the “Bossi-Fini” law was necessary because the immigra-tion mechanisms brought about an overwhelming clandestine immigration. The Bossi-Fini law has not succeeded neither in channeling the illegal immigration into the legal area, nor in contrasting it.

In particular the permit of stay, which is temporary, de facto turned into peri-odical regularizations, favoring, in turn, the illegal migration phenomena, which it was supposed to countervail, according to the intention of the written law. Moreover, the permit of stay, strictly connected with the duration of the labor contract, revealed to be an inefficient tool, both for the immigrant and for the employer, whereas the mechanism of expulsion turned out to be ineffective. Consequently it came out the necessity of the reformation. Among the innova-tion there are:

• the duration of the “decreto flussi”, which establishes quotas of outland-ers as a superior limit for admissions to Italy, rather than being a one-year dura-tion will be a three-year duration, in order to ensure a medium/long run plan-ning. The definition of the numbers will involve associations and political pa-tronages, apart from territorial representatives;

• the reformation brings in a privileged channel for high-skilled workers admission, which are apart from the established flow quotas;

• the provision of a “sponsor”, who can obtain a permit of stay for immi-grants. The sponsor guarantees patrimonially for the immigrants' sustenance and for their eventual repatriation. Institutional organizations, enterprises and profes-sional associations may assume the role of “sponsor”;

• concerning the penal norms, the competence to judge immigrants’ crimes will be transferred to the ordinary judge instead of the peace officer, as a guarantee of personal rights;

• in order to make the expulsions effective, there are specific repatriation programs, both volunteer and assisted, as far as the immigrant is collaborative. It is also possible to obtain a reduction of the prohibition for returning in Italy;

• according to the Ministry of Home Affairs’s estimations, the new expul-sion system will have an effect of significant downsizing of the number of sub-jects destined to the Centres for Temporary and Assisted Stay (CPT), so facili-tating a progressive emptying of these structures.

The CPT won’t have to be anymore a prosecution of jail under another form. Indeed new procedures will be introduced to identify the outlanders and repa-triate them avoiding the Centers. The outlanders in specific conditions of need will be received in proper receiving Centres, for a limited period of time.

5. The Central Administration level and the role

of Ministries: labour division vs duty avoidance

We start up with a strategic analysis of the central Administration level, show-ing the competences and the involvement of each Ministry in the immigration policy-making. The central level is connected to the further implementation stage through its delegation mechanism to other institutions operating in dif-ferent territorial levels.

At the central level the distribution of policy functions seems to be very fragmented and the Ministries functions fall down in a grey area of overlapping

and confusion. This leads to ineffective resolution mechanisms which turn into a stagnant inactivity. The Ministries involved in the Immigration policies are: the Ministry of the Home Affairs, the Ministry of Labour, the Ministry of Wel-fare, the Ministry of Economics and Finance, the Ministry of External Af-fairs.

According to its role of strategic planning and directing, the central Admini-stration should firstly acknowledge that the problem does not need an emer-gency management orientation but a strategic and systemic planning of coordi-nated actions. The immigration policies may broadly be identified according to the following areas (directions):

1) planning and management of the migratory flow at both the national

and the local level; 2) promotion of inter-institutional cooperation; 3) socio-health assistance and social inclusion policies; 4) immigrants’ economic integration into the labour market; 5) law and order and contrast to illegal immigration.

For what concerns the first direction, the action is carried out basically at the normative and regulatory level, with a relevant impact on the responsiveness of the management system characterized by a high degree of rigidity. The number of institutional actors which operate at this level is outstanding. The Ministry of Home Affairs deals with the global definition of immigration policies in-cluding the admission requirements, through the Central Department for the im-migration policy and asylum. This function is also included in the mission of the Ministry of Welfare, which, apart from the declared duties of supervision of immigrants who enter for economic reason from a third country, actually annually plans their flows, through a General Direction, managing and moni-toring the quotas at the territorial level. The Ministry of External Affairs pro-motes the bilateral cooperation with the native Countries. Lastly, the Regional Directions referring to the Ministry of Labour investigate the emergent needs for the determination of immigration flows and the management of the re-gional quota. This allocation of planning activity shows two hierarchies of criti-cality. Firstly, there is no correspondence between the Ministries duties regard-

ing immigration management and their strategic focalization. Secondly, there is a high replication of functions.

The latter consideration is the starting point for the second analytical area of policy: the inter-institutional cooperation. In this direction three Ministries mainly operate: the Ministry of Labour for what concerns the coordination of the labour and employment policies; the Ministry of Welfare, coordinating the social integration policies; the Ministry of Economy and Finance realizing ac-tions and planning in cooperation with Regions, Provinces and Local Admini-strations, through a technical Agency, Italia Lavoro S.p.A., which serves the cen-tral Public Administration, in order to create opportunities for formal em-ployment and promoting the international cooperation.

The above described framework shows a significant absence of any institu-tional structure dedicated to inter-institutional cooperation at all levels of im-migration management. From a strategic perspective the key criticality of this setting is the difficulty in implementing an integrated system of planning and strategic control, which is meant to be suitable for the proposed actions.

A systemic approach is needed even more sharply in the context of the third category of Immigration policies. Those policies may be classified accord-ing to their time-horizon: short-run and long-run policies. Short-run policies include health and social assistance (provisioning), in particular first reception services, in which apart from the institutional actors also the associations and the non-profit sector have a commitment. In this group of policies the Minis-try of the Home Affairs creates complex Centres (Territorial Councils for Im-migration, Unique Counters of Immigration, Immigration Centres) on the na-tional territory displaying a strategic mechanism which is able to manage the first immigration inflow. Mission and articulation of those centres seem to be positive in themselves, but facts and statistics do not support an accord-ing evaluation of the implementation of the above declared intentions. On the contrary, there is a local activism of non-institutional actors in the “welcoming” field, which overcomes the inefficiencies of the central level.

Among the long-run policies we find the intervention for social integration and inclusion, referring to the action of the Ministry of Welfare and involving a broader spectrum of sectors (health, education, culture).

The systemic value of social integration policies is underlined by their impact on migratory flows planning, which refers to the first dimension of the policy above explored.

Indeed, among the duties of the Ministry of Welfare there is the regulation of inflows of job-seeker from third countries. The Ministry above mentioned annu-ally plans the conditions for the inflow and the further management and moni-toring of territorial quotas. Indeed it is essential taking into account social inte-gration policies when the quotas of immigrants are planned, in terms of a sys-tematic management of the immigration phenomenon.

The immigrants’ job concern is connected to the fourth category of policy at the central level. The latest point is connected to a strategic consideration of the economic “allocation” of immigrants: without an organic system for the integra-tion of immigrants in the formal labour market there is room left for a highly probable integration into the illegal sectors. In relation to this a further consid-eration should not be underestimated: given the provided annual quotas for the inflow of job-seekers, the residual flow turns into clandestinity, with the resulting negative implications. Once again it is at the source of central policies that we can find the reasons of the problem: if either the quota is not carefully fixed or there are not flexible criteria, which will make an ongoing adaptation feasible, the main implication would be a mismatching between the management tools and the phenomenon which has to be managed. The starting point for a policy de-sign should be the awareness of the dynamic nature of phenomenon, which calls for an adaptive process of management. On the opposite, though the above de-scribed system is meant to be at least idealistically integrated and immigrant-oriented, nevertheless it turns to be not only inadequate but also ineffective. As a result without a flexibility in the first stages of the management process of the new immigrants’ inflow, the flexibility of the whole system of policy is not able to avoid a managerial rigidity and the multiplication of problems to be managed (criminality and black labour). On this side the Ministry of Labour operates by developing and evaluating employment policies. Some of the projects for the economic integration of immigrants are also carried out by Italia Lavoro S.p.A. The ongoing devolution of administrative duties from the central to the local levels has had a remarkable relevance in management o of labour policies, bring-ing about, in particular, the assignment of a greater amount of functions to the

County level. To end up, the last category of policies has a decisive importance in the management of immigrants’ flow, mostly in contrasting the dispersion of this flow in the illegality. In this respect the Ministry of Home Affairs designs migratory policies, which are intended to guarantee law and order and to con-trast clandestinity. From an operative perspective this function is delegated to the central Department of the Police for immigrations and boundary control, through structured strategies of action. In order to integrate the entire policy dimension in a unique scheme we propose, here below, a conceptual frame-work in which the migratory policies are represented as connected rings of a chain (Figure 1).

6. The local level: the Municipality of Rome

The number of regular immigrants in Italy has almost reached the level of 3.035.144 at the end of 20062. Thus, Italy is approaching the position of the main European countries concerning immigration: Germany (7.287.980), Spain (3.371.394), France (3.263.186) and UK (2.857.000). In Italy, the in-creased stock of immigrants in 2006 is due both to new arrivals (187.000) and to the growth of the second generation of immigrants (52.000). Immigrants are spread out in all the country, although there is a territorial differentiation: North-East 27%, North- West 34%, Centre 27% and South 12% (Figure 2).

Referring to the national level, it is interesting to analyse which is the trend in the permits of stay (2003-2006) and the main reasons for it (Table 2).

Lazio is the second region (Lombardia is the first one) with more immi-grants: the two regions, so called “Capitals of Immigration” have almost ¼ and 1/6 of the total amount of outlanders in Italy, respectively. The settling mod-els shape depends on the different elements and behaviours, which vary ac-cording to the citizenship of origin. Among the 16 most numerous communi-ties at the regional level, making a selection of those which represent at least the 10% of immigrants residents we may identify the 10 countries which rep-resent the 56% of the outlander residents in the region, except from Lazio

________________ 2 Most data on immigration are provided by the Ministry of Home Affairs, which gathers the number of immigrants minors and the quota of permit of stay to be renewed.

(45%), where a higher presence of ethnicities downsizes the percentage rate of the single citizenships (Table 3). In all the regions there is a high presence of people from Albania, Morocco and Romania, but there is a different de-gree of concentration. In the Lazio region, Romanians are a consistent quota of the outlander residents (23,8%).

Given the specific relevance of the migratory phenomenon at the regional level and the peculiarity of the Lazio region, it seems to be interesting to extent the case study analysis both at the Province3 and the Municipality of Rome level. Some data may be necessary to shape the context of our analysis from a quantitative perspective. This seems to be a crucial step towards a further veri-fication of the coherence and the rationality between the dimension of the mi-gratory phenomenon and the actions undertaken on the territory.

The Province of Rome is composed by 120 Municipalities distributed in 17 Districts, apart from the Municipality of Rome. This Province includes the Municipality of Rome with a population of 2,547,677 inhabitants, of whom 156,833 outlanders (6.16% of the residents). Moreover, over the 120 remaining Municipalities, 62 have a population of no more than 5,000 inhabitants and 27 have less than 1,000 inhabitants. In the Province, each of the 17 Districts have a guiding (leader) Municipality with coordination and planning role. Indeed, the leader elaborates the socio-health plan and has a tight connection with the Region and the Province.

According to the Dossier Statistico Immigrazione Caritas/Migrantes (2006), out of the 3,035,144 outlander citizens at the beginning of 2006, 418,823 were lo-cated in Lazio and among them 365,274 in the Province of Rome (the Province had the 12% of regular immigrants’ population over the national amount).

During recent years, it is possible to observe some trends which focus on a more balanced distribution of immigrants in Italy, there is an increasing inter-est to the Province level. Indeed, immigrants are attracted by smaller Munici-palities because of the real-estate market accessibility. In respect of that, and with focus on the Roman metropolitan area, the Capital has still a strong at-

________________ 3 The on-going trend is an out-flow from the city centre to the metropolitan border areas (the Province of Rome). In Rome, this is proved by the house location bought by the immigrants in 2005 and in 2006.

tractive force, but there are changing directions and increasing flows towards all the other area around the city of Rome.

Giving a de-structured glance at the different municipalities we noted remarkable differences in the distribution of the immigrant population in the area of the province. On one hand it seems impossible to identify specific zones of immigrant concentration – so-called ghettos – but on the other some places are distinguished either by a higher presence of immigrants or by a terri-torial concentration of specific ethnicities.

Generally speaking, 181 ethnic communities exist in the province of Rome, and the first 10 community groups include about 60 per cent of the total num-ber of immigrants. The country of origin with the major number of resident immigrants is Rumania (53,093), followed by the Philippines (23,027) and Po-land (18,052) from Poland. Other relevant communities are the Ukrainian (11,801), Albanian (9,457) and Peruvian (9,371). With reference to the distribu-tion of countries of origin, 51.3 per cent or resident immigrants come from Europe, 22.7 per cent from Asia, 13 per cent from America and 12.8 per cent from Africa. Immigrants from east-central Europe are the numerical majority, at 36.7 per cent.

With regard to immigrants’ gender composition there is a remarkable pres-ence of women (54.3 per cent, or four per cent more than the national aver-age). Non-adult immigrants in the province number 54,063 (19.4 per cent), of which 75.4 per cent were born in Italy. Therefore, the Province of Rome, with 39,758 immigrants enrolled in public schools, is the second in Italy (after Mi-lan) in terms of foreign students. Rome itself attracts about 80.4 per cent of foreign students in the Region.

At both the province and the municipal level, it is necessary to paint a map of the actors involved in immigration management, classified by areas of inter-vention, in order to define the boundaries of the networks, the relations and missed linkage among the actors.

Thanks to the ongoing devolution of administrative duties, the Province of Rome has taken on the role of coordinating and promoting governmental ac-tors involved in immigrant policy management in order to build a path of citi-zenship and civil and political representation of immigrants therein.. Several initiatives have been carried out by the province taking into account the

specificities of the context instead of adopting top-down self-referential plan-ning for immigration management, which used to be mainly regulated by means of predetermined entrance quotas. The following map of the Province of Rome (Figure 3) shows the breakdown of areas, in order to give a measure of the territorial dimension of immigration in the province.

It is possible to find in the territory a network of immigrant communities. Indeed, in keeping with a participatory approach, the province establishes a direct connection with resident immigrants, identifying groups, associations and single representatives and promoting the construction of formal net-works. Starting from the investigation carried out at this level, the mapping of the actors involved in immigration management is summed up in Figure 4. The majority of the abovementioned actors (62 per cent) are NGOs, typically with the status of association. Furthermore, there is a significant presence of immigrant associations. Specific ethnic communities of immigrants establish NGOs in order to facilitate their members’ integration in aspects of social life in Rome. The governmental organisations are the Employment Centres (CPI), the Service Centres for Immigrants (CSI), and the offices through with trade unions offer services for immigrants.

Also, some considerations on the relationships amongst the province, the CPI and the CSI are necessary. The 23 CPI arise from a project aimed at pro-moting better labour policies, in accordance with a need for flexibility and ef-fectiveness in the local economy of Rome. The CSI, embedded in the structure of the CPI, offer assistance, welcoming and counselling services both to legal and illegal immigrants. These centres arise from a project of the province; for this reason they are not autonomous governmental organizations (the province is in charge of their funding and coordination).

From the analysis of CSI it emerges that professionals who work in these centres have a strategic role. The presence of these cultural mediators is due to the need to convert immigrant management policies from emergency tools into integration tools developing social cohesion. Moreover, the territorial position-ing of these Centres is another aspect to be emphasized: only two of them are located in the municipality of Rome; the others are spread throughout Rome Province. In this respect, the interviews pointed out the presence of a dichot-omy between the province and the municipality of Rome in immigration man-

agement. The reason could be sought in the metropolitan rank of the munici-pality of Rome, which has articulate networks of actors, involved at different levels in immigration management. The strong commitment of the province to strengthen its territorial control of the phenomenon is due to the tendency of immigrants to moving from the city-centre to the outskirts, given the lower cost of real estate, the lower cost of living and the guarantee of high mobility. Concerning the main areas of intervention of the 133 actors operating in the province, and focusing on the welcoming services, we classify these according to their area of competency, underlining the reception services provided by 20 NGOs and just two governmental bodies. There are also other groups of serv-ices provided by associations active in welcoming. The main weakness in the provincial NGOs intervention model is healthcare. This service is provided by a small number of structures, with specific operational areas for immigrants. Given the risk of epidemics in the arrival of immigrants in precarious condi-tions, the lack of health services is a matter of serious concern. In this respect governmental action is crucial, especially through the capillary presence in the territory of Health Care Agencies (ASL). However the rationale seems to be the recognition of the necessity of a public intervention for providing critical services. In the future the structured intervention of NGOs in this field could provide a more effective action for immigrants.

Concerning the housing problem, both the governmental and the non-governmental organizations seem to be irrelevant. This is a key point in the analysis of the territorial governance model for the immigration management, given its implications on the immigrants’ living conditions and the phenome-non of unauthorized building and nomadic camps, which, in turns, have a re-markable impact on the level of intolerance toward the immigrants.

In terms of labour policies, governmental intervention is well constructed. In this field the functions assigned to the different actors do not overlap: the CPI with the respective COL look toward integrating immigrants according to their skills and competences. The action in this field is particularly relevant in preventing criminality and black-market labour practices (Table 4).

In the training field, Permanent Territorial Centres are responsible for Ital-ian language and professional training courses. Also there is a variety of asso-ciations in charge of the socio-cultural integration of immigrants in the terri-

tory and associations of immigrants operating for the promotion of their cul-ture and traditions. An outstanding absence of both governmental organiza-tions and NGOs emerges in the promotion of cooperation and coordination actions, which are deeply connected to immigration management: the former type of cooperation fosters the exchange of knowledge and best-practices, whereas the latter seems to be a necessary and sufficient condition for the de-sign of well-targeted immigration policies. The last emerging and significant point from a multi-level governance perspective is the relationship between the province and the municipality of Rome, in the Region of Lazio. The distinct-iveness of the municipality of Rome has a strong impact on the models of in-tervention in the territory of the municipality.

Having examined the provincial intervention model, at this point we can shift our focus to the level of the municipality of Rome, looking for a further analysis of interaction in keeping with the multilevel governance approach.

At this level the progressive consolidation of immigrant communities and the increasing number of resident immigrants are accountable as important at-traction levers for inflow brought to the capital through often-informal aggre-gation channels. This phenomenon has been radicalized in the last few years, notwithstanding precarious labour and housing conditions.

From a territorial multi-level governance perspective, as the local level plays a key role in responding to grass-roots demands, it holds major opportunities for working out contingency strategies. We expect, therefore, the municipality to be the promoting actor for integrated territorial plans, given also the devolu-tion of competencies in the last years.

The mapping of the different actors confirms the consideration made at the provincial level and the governance relationship with the other territorial ac-tors. In fact the municipality is provided with an articulate structure of subjects in order to deal with the whole spectrum of management concerns. Given the relevance of the NGOs at this level, we have deemed it appropriate to start with an analysis of them. Table 5 synthesizes the results we came up with.

One notes the wide range of NGOs (associations, cooperatives, ONLUS), whose areas of intervention are shown in Table 6.

From the table above an interesting picture emerges: there are more than 40 associations in the social-assistance intervention area, which are meant to be

actions of first welcoming and first health care as well as of assistance to resi-dent immigrant. In this respect we have identified associations that are respon-sible of providing full healthcare. Overall we see a well-articulated welcoming structure at the municipal level.

The second most numerous associations are those acting for the promotion of immigrants’ rights, which often have an international derivation. The third is the educational and training area; the fourth is the cultural integra-tion area. Replicating the provincial model analysed above, the critical point in the municipality of Rome is the lack of cooperation and coordination among the main actors.

What emerges from the interviews with NGO representatives at this level is that the connection between the municipality of Rome and the NGOs has a formal nature, which is structured with formal conventions, in keeping with the logic of delegation, services outsourcing and ex-post monitoring. Besides, there are strong informal links between the managers of different formal and informal organizations, which are linked by personal contacts. Indeed ‘informal power based on interpersonal relations can be more important than formal power’. Only in some cases there are structured partnerships with shared stra-tegic goals and formal cooperation. The shape of this kind of connection widely varies across the different areas in which the municipality of Rome is involved and it is highly dependent on their number and complexity.

Our analysis of the municipal framework would not be complete if we did not take into account the governmental networks of wide-ranging services for immigrants and their connections to NGOs networks. In this respect the gov-ernmental organizations seem to have an exclusive competence in terms of la-bour policies. This consideration is supported by the fact that there are no NGOs in this field.

From a governmental point of view there are two Employment Centres in the municipality and there is a Centre for Job Guidance (COL) in several mu-nicipal departments, which is also in charge of the economic integration of immigrants; dedicated assistance points for immigration in the Unions. On the educational front, as we have seen at the provincial level, at the municipality there are Permanent Territorial Centres responsible for promoting training for immigrants through specially tailored language courses.

7. Results and findings

The paper aimed at systematically designing and highlighting the governance model for the immigration flows, which has been adopted in the province and municipality of Rome. The analytical model is centred on the local governmen-tal and non-governmental actors’ ability to promote territorial policies.

One of the most important results regards the variety of actors involved in the immigration governance.

However the central level remains crucial, because without a well-defined central strategy the implementation of coherent solutions for the immigration management at the local level seem to be not feasible. On the other side there is also a need of high degree of autonomy at the local level to foster a more contingent and coherent policy implementation favouring a bottom-up ap-proach.

The local governmental actors (region, province and municipality) should be in charge of translating policies into programs ensuring their implementa-tion trough coordinated action on the territory. In this respect there would be vertical networks among the different actors, even if in the reality there are not formal links between the province and the municipality.

The case-study analysis shows that it is possible to detect two networking systems at the local level: the province and the municipal one, which seem not to be interrelated.

In both the vertical and horizontal territorial governance networks, we show and localize who are the main actors involved in the immigration man-agement, according to their specific areas of intervention (health, education, labour, welcoming).

In Figure 5 and Figure 6, we show both the formal and the informal net-work, distinguishing them by using different colours: green (formal networks); red (informal networks); dashed grey (missing networks); dashed blue (non-profit networks).

Concerning the labour policies, at both the provincial and the municipal level the formal networking is limited to a spot connection with one of the ac-tors (respectively with the CPI and with the COL) and there is not either for-mal or informal connection with the non-profit sector. In this respect, the

horizontal networking does not seem to be able to overcome this limit. In fact, for both the institutional levels, there is just one informal horizontal connec-tion in this area (between CPI and COL). Thus, the overall picture of labour policies management seems to be weak from both the sides of the networking options, highlighting the lacking of a well-built implementing structure of the central strategies for the immigrants integration in the labour market.

Concerning the educational area, at both the institutional levels the CTPs and the non-profit associations operate. There is here a clear intersection between the two main actors, shown by the orange circle. In relation to the direction of the connections, a vertical networking emerges between on the one hand the County and the Municipality and on the other hand the CTPs.

However, for both the system of network governance, the horizontal net-working lacks communication between institutional actors and the non-profit sector (Marsh, 1998).

Indeed in the educational area there ought to be a more harmonic planning and promotion of actions of communication and cooperation, in order to fa-vour the operativity and the implementation process at the bottom level.

For both the Municipality and the County networks, in the welcoming area the presence of the non profit sector is dominant and its action creates an in-tersection with the health assistance area. Even in this field there are limited formal vertical connections (between the County and the CSI, whereas there is no vertical link at the Municipal level). On the other side the horizontal con-nections are guaranteed by the deep interaction between the associations oper-ating in this area, which are so much reciprocally conditioned to be almost merged in one organism, with the leadership attributed to CARITAS. The dominancy of the third sector seems to be justified by the nature of the wel-coming services, but at least a greater financial support should be given to the associations by the central administration.

Concerning the health assistance, what is different from the previous con-sideration of the dominancy of the non-profit actors, is that here the presence of another institutional actor must be empathized: the HEALTH CARE AGENCIES (ASL), which on the one hand are directly connected with the re-gional level (vertical formal link) whereas on the other hand they seem to be isolated by the rest of the network system. In this context a horizontal connec-

tion among the actors is totally missing. Concerning the relationship between the County/Municipality and the non-profit sector, we have noticed that whereas the County established a vertical formal connection with the third sec-tor, at the Municipality level this link has an informal nature. Moreover on the one hand the above mentioned vertical connection at the county level has an implication on the horizontal connection among the actors of the non-profit sector: the vertical link ensures the coordination of the formal networking in the third sector, through the so called “network of outlanders communities”. This is not the case of the Municipality network system, in which the main actions are carried out by promoting different project, according to a de-structured action model. Indeed the Municipality has established a strong formal link with the cul-tural associations, confirming the passage towards policies for the social cohe-sion, as a strategic choice.

In conclusion apart from an evaluation of the formal/informal networking at each level, the most outstanding absence is a connection between the County and the Municipality, demonstrating the existence of a sort of parallel strategies, not enough communicating, but perhaps justified by the particular nature and dimension of the Municipality of Rome.

8. Conclusion The paper has analyzed the importance of adopting a multilevel governance approach in the management of immigration. Our case study shows the diffi-culty to manage this phenomenon because of the high degree of functional overlapping at the central government level. Indeed it seems necessary to im-plement actions that promote both communication and cooperation among the various actors involved in the management of the phenomenon. Network structures may require separate actions on the part of the individual members, with the participants taking on broad tasks that reach beyond the simultaneous actions of independently operating organizations. Network structures may in-clude informal linkages, co-operation, coordination, task force action, or coali-tion activity.

The case study of the Roman area shows that even without a structured sys-tem of policies at both the central and the local level, the handling of immigrants

is sustained by the effective actions of many NGOs, which is certainly related to the actual process of hollowing out of the state. As a consequence it seems neces-sary to empower the local government, providing more financial aids to NGOs and ensuring the unity of the system by adequate coordination and cooperation policies, in keeping with a multilevel governance approach. Our analysis points out that a bottom-up approach to the management of immigration is more co-herent and, in turn, effective because of NGOs’ mission and their proximity to the real situation of immigrants (Rhodes 1996).

Focusing on governance can blur the distinction between state and civil so-ciety. The state becomes a collection of inter-organizational networks made up of governmental and societal actors with no sovereign actor able to steer or regulate. Governance as self-organizing networks is as distinct a governing structure as markets and hierarchies (Rhodes 1996). A key challenge for gov-ernment is to enable these networks and to seek out new forms of co-operation. In other words, network governance is expected to be conducive to technically more adequate and politically more realistic decisions.

The presence of overlapping competencies among multiple levels of gov-ernment, as well as the interaction between a variety of actors renders vertical and horizontal coordination critical. Such coordination, and coherence, is a ne-cessity, not an option.

Moreover research and innovation in immigration management following a multilevel governance approach needs to be improved, in order to achieve a public value management model (Reichard 2001).

Our effort to comprehend all the facets of the phenomenon is only the first step towards a deeper understanding of the issues at stake. More investigations must be carried out especially in order to better evaluate the features of the immigration network via a Social Network Analysis approach – an approach capable of determining the number of contact points and their density, and of casting light on the quality of interactions among the different actors (govern-mental and NGO) involved in immigration management.

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Tables and figures

Table 1: The regulatory framework

Council Decision 2006/688/EC

Establishment of a mutual information mechanism concerning Member States' measures in the areas of asylum and immigration

Council Directive 2005/71/EC

Specific procedure for admitting third-country nationals for the purposes of scientific research

Council Decision 2005/267/EC

Secure web-based Information and Coordination Network for Member States’ Migration Management Services

Conditions of admission of third-country nationals for the purposes of studies, pupil exchange, unremunerated training or voluntary service

Residence permit issued to third-country nationals who are victims of trafficking in human beings or who have been the subject of an action to facilitate illegal immigration, who cooperate with the competent authorities

Council Regulation (EC) No 377/2004

Creation of an immigration liaison officers network, collecting particular data about illegal immigration

Directive 2003/86/EC

Family reunification

Directive 2003/109/CE

Status of third country nationals who have been long-term residents

Council framework Decision 2002/946/JHA

Strengthening of the penal framework to prevent the facilitation of un-authorized entry, transit and residence

Mutual recognition of decisions on the expulsion of third country nationals

Harmonizing financial penalties imposed on carriers transporting into the Community third country nationals lacking the documents necessary for admission

Table 2: Permit to Stay for economic reasons 1° January - 2003-2007

stat d

The Governance of New Immigrants Inflow 33 Table 3: Immigrants for region of residence and country of origin at the 1°January 2007

stat d

A. CALABRÒ, V. FERRARO, S. TESTARMATA 34 Table 4: Areas of intervention on the Province territory

Welcoming 20 Education-Training 14

Institutional Welcoming 2 Cultural integration 19

Welcoming Services 14 Services to immigrants 11

Health Assistance 3 Services – Unions 7

Housing 1 International cooperation 3

Labour 16 Immigrants’ Associations 16

Legal Services 6 Coordination among actors 1

133 (Our elaboration)

Table 5: NGOs in the Municipality of Rome

Associations 14 Federations 4 Social Cooperative 8 ONLUS (Non-profit socially

useful organizations) 65

91 (Our elaboration)

Table 6: Intervention areas of the NGOs in the Municipality of Rome

(Our elaboration)

Socio-Assistance 40 International cooperation 4

Health 8 Cooperation among actors 1 Education and training 12 Rights Protection and promotion 16 Cultural integration 10

The Governance of new immigrants inflow 35

South Islands Centre North-East North-West

Figure 1: The policy system for immigration management

Figure 2: Territorial distribution of immigrants in Italy

(Our elaboration on Ministry of Interior data 2006)

A. CALABRÒ, V. FERRARO, S. TESTARMATA 36 Figure 3: The immigrant areas in the Province of Rome

(Our Elaboration on data of the Prov

Figure 4: Main actors in the Province of Rome

Sites of interaction

Institutions and services

51 Immigrants’ associations

Religious Associations

Associations 50

Map of Actors

The Governance of new immigrants inflow 37 Figure 5: The provincial network

(Our Elaboration)

(Our Elaboration) Figure 6: The municipal network

(Our Elaboration)

McGraw-Hill

DSI Essays Series

cop3.qxd 3-03-2010 15:39 Pagina 1

The Governance of New Immigrants Inflow: from Emergency Management to Social Inclusion Policies. The...

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ANNUAL REPORT - Lesedi Local Municipality

LEPELLE-NKUMPI LOCAL MUNICIPALITY

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adelaide-lingelethu - Raymond Mhlaba Municipality

Saldanha Bay Municipality

TARIFF POLICY - Overberg District Municipality

Indaka Municipality IDP

OVERSTRAND MUNICIPALITY - MFMA

IMMIGRANTS & URBANIZATION

KWADUKUZA LOCAL MUNICIPALITY SCHEME

CUMBUM MUNICIPALITY BDV-BPL List

alice - Raymond Mhlaba Municipality

EMALAHLENI LOCAL MUNICIPALITY - MFMA

SUN PEAKS MOUNTAIN RESORT MUNICIPALITY

Can online contacts between immigrants and veterans facilitate immigrants’ social integration?

ASSTT TEACHER - FINAL - Bansberia Municipality

Citizen's Charter | Municipality of Botolan

Infiltration and inflow to wastewater sewer systems

Annexure R - Saldanha Bay Municipality