Die ATR se kommentaar op die konseptaalbeleid vir Hoër Onderwys

Die ATR het kommentaar en insette ingewin van lidorganisasies en individue met betrekking tot die konseptaalbeleid vir hoër onderwys.


U kan die kommentaar, soos gerig aan die direkteur-generaal van die department vir hoër onderwys, Mnr. Mabizela, hier lees:



13 April 2013


The Director-General
Department of Higher Education and Training


Dear Mr Mabizela,




Thank you for the opportunity to comment on the Draft Language Policy for Higher Education (the policy), published in the Government Gazette on 23 February 2018.  The ATR (Afrikaanse Taalraad or Afrikaans Language Council) is a civil society organisation constituted in terms of article 185 of the Constitution. It promotes Afrikaans and all its varieties within a multilingual context and has a strong focus on basic and higher education. For these reasons we consider the policy as extremely important.


The ATR finds much that is positive and well-intended in the Draft Language Policy for Higher Education (the policy). We welcome the commitment in the policy to multilingualism and the promotion of the indigenous languages of South Africa, as well as the recognition of Afrikaans as an indigenous language. We also welcome the implicit recognition of the value of mother tongue education.


We would like to emphasise that Afrikaans belongs to an extremely wide and diverse range of people, cutting across all the boundaries that divide us as a nation. We also hope that the policy will promote the mutual support and synergies needed to advance the collective cause of the country’s indigenous languages. Most Afrikaans language organisations and structures would welcome such an approach and the opportunity to support such a mutually beneficial process. We further hope the policy will help to halt the precipitous slide towards English monolingualism and hegemony that has been taking place at most of our tertiary institutions. The use and status of Afrikaans declined dramatically at most of the historically Afrikaans universities and other tertiary institutions – to the point where its survival as an academic language is at stake. Simultaneously, extremely little progress has been made in the development of the other, previously disadvantaged, indigenous languages. This damage needs to be undone as part of a linguistic turn-around strategy at academic institutions.


The authors of the policy have obviously put much thought to the context within which the policy has to be implemented, and are without a doubt aware of several complicating factors and matters. However, we respectfully note that a number of key elements of the policy need to be clarified and strengthened for the policy to get traction.


The lack of clarity or detail in respect of some critical issues result in a troubling degree of fuzziness about the intent and implementation of the policy. Left unchanged, these risk would undermine the effectiveness of the policy while enhancing the risk of undesirable unintended consequences – such as actually strengthening the hegemony of English versus the indigenous languages.

Please refer to the attached document for a more detailed consideration of these issues.


Kind regards,
Conrad Steenkamp






The ATR welcomes the draft language policy for Higher Education as a major improvement on the existing policy, one that places the development of multilingualism and the indigenous languages of South Africa in the foreground. The mechanisms proposed for the implementation of the policy are particularly important. We also
welcome the recognition of Afrikaans as an indigenous African language for the purposes of the policy.


However, we are concerned about aspects of the policy.
 The policy needs a clear long term vision to give the policy direction. The point of departure used can be extended to include language as a resource, rather than language as an obstacle, cost, or right – a prerequisite for full democracy and economic development of the country.


 The policy needs a much clearer set of objectives. Also the meaning of the term multilingualism has to be defined more clearly. There can be big differences between developing multilingualism and developing the indigenous languages.


 The scope of the policy needs to be restricted to public universities. Including private tertiary institutions within the scope could enhance monolingualism and harbours a host of possible negative consequences.


 There appears to be a mismatch between important aspects of the policy and international best practice, on the one hand, and recent court decisions, on the other. The policy has to consider ways of addressing this.


 Linkages with Basic Education should include consideration of a structured pipeline approach for each of the indigenous African languages: incremental development from primary through to tertiary level.


 More clarity is needed on the financial mechanisms proposed by the policy and the resources that might be made available. Without this implementation will be difficult. The ATR hopes that the shortcomings identified can be addressed so as to enhance the effectiveness of the policy and to reduce the likelihood that may generate negative unintended consequences, such as the promotion of English linguistic dominance.



Preamble of the policy
The Preamble of the policy rightly highlights the linkages between the language and the ability to participate in the social, cultural, intellectual, economic and political life of South African society. This could be improved by highlighting the full development of our indigenous languages as a prerequisite for a truly democratic South Africa, one in which a small linguistic elite does not control all the levers of power and economy.


This point of departure could further be strengthened by including consideration of language as an economic resource, rather than an obstacle or language as right. Language is thereby converted from a cost and a compliance nuisance to an underutilised resource without which a country cannot achieve its full economic potential.


The rationale for the development of the indigenous languages given in the Preamble constitutes a welcome contribution to the debate about the value of language to society and economy. However, this rationale has to compete with a strong narrative about the internationalisation of the institution, the benefits of English as an “international” language, and the indigenous languages as a cost and nuisance factor. In consequence, the policy has to promote a much stronger narrative of its own – one with an unassailable rationale for the underutilised value of language for the institutions themselves.



Purpose of the policy
The Policy’s statement of purpose (article 13), seems to mix up policy’s overall aim or development objective with three sets of activities or subsidiary outcomes and objectives. For instance, to “guide HE institutions to evolve relevant strategies, policies and implementations plans”, represents a means to an end, which is to “strengthen indigenous official languages as languages of teaching, learning, research, innovation and science” (article 13.1). It should not be part of the purpose. The resulting lack of clarity is exacerbated by the subsidiary statement on what the policy seeks to address (article 14).


This is unfortunate, for one is left to deduce what the policy’s purpose might be. One could, of course, fall back on the purpose as described in the Preamble, namely to want to: “address the challenge of underdevelopment and underutilisation of indigenous official South African languages in higher education and at the same time sustaining the standard and utilisation of languages that have already progressed.”


The success of the policy depends on the formulation of a brief and clear statement of purpose:
What are the concrete outcomes being strived at? Everything else flows from that. A vision that describes the long term development objective of the policy could be another way of providing such focus.


By all means define subsidiary objectives such as using language to transform higher education, enhancing the status of indigenous languages, their use in communication, the inclusion of the Khoe and San languages, and so forth, but first clarify the main statement of purpose. Guidance provided to educational institutions appears to be a means to an end (i.e. belonging to the Policy Framework, article 25 onwards), which risks becoming an end itself if included in the purpose of the policy. Used in this context, words like “guide” and “evolve” (article 13.1) belies the active enforcement of the policy. In this regard, we respectfully draw attention to the fact that Afrikaansmedium instruction has been rolled back or eliminated at practically all the historically Afrikaans
universities – despite the fairly strong wording of the 2002 language policy.


A policy that has being a “guideline” as its purpose, is unlikely to make a dent in the increasingly unilingual practice at most tertiary institutions. If taken to its logical conclusion, this policy will require academic institutions to substantially update their language policies. For this to happen, a measure of forcefulness will be required.


In conclusion, without a clearly stated purpose and subsidiary objectives, the policy will remain open to different interpretation, make it difficult to set in place the best practice principles, standards and frameworks so urgently needed as a reference point for university language policies. The lack of clarity also increases the likelihood that the policy might generate undesirable unintended consequences.



Scope of the policy (Article 15)
The inclusion of private institutions of higher education in the scope of this policy is of great concern, especially in respect of those already providing a service in an indigenous language. This concern is amplified by the already noted lack of clarity regarding the policy’s purpose and other issues mentioned further below.


Such private institutions play a critical role in meeting the demand for Afrikaans-medium instruction to the extent that it is no longer catered for by public institutions. Forcing these to become “multilingual” would probably result in the introduction of English, contradicting the rationale behind their existence and exposing them to the same pressures towards monolingualism experienced by the public institutions.


In addition, many of these institutions are small and specialised, which makes them vulnerable to the financial stress. In the case of English-medium institutions it could jeopardise the international investment on which these often depend. Would the DHE, furthermore, also fund “multilingualism” at such private institutions? Would it have the budget to do so and if not, what might the funding priorities be? What does such funding mean for the distinction between public and private institutions?


It is highly likely that the inclusion of private institutions in the scope of the policy would generate much unhappiness, and that some might regard this as a measure aimed specifically at Afrikaans. The ATR therefore strongly advises that the scope of the policy should be restricted to public institutions only.



Policy and legislative context (Article 16 – 22).
The policy makes no mention of recent decisions by the Constitutional Court regarding language and higher education. In the recent case regarding the language policy of the University of the Free State, the Court’s contested majority decision effectively made it impossible to use Afrikaans as language of instruction, as this would divide students on a racial basis.


Arguments regarding the university’s responsibility to recruit a wider diversity of Afrikaans-speakers aside, there appears to be a gap between international best practice regarding multilingualism and the attitudes towards language reflected by our courts. This mismatch is highly unfortunate. It also has significant implications for the meaningful development of the other indigenous languages. We hope that the draft policy would help to create a new and more balanced context for the courts to take into consideration in language cases. However, it is necessary to address the possible gaps between the policy and the legal environment at least in principle. The policy also needs to address the need for pro-active engagement of the justice system as a means to close the abovementioned gap, if at all possible.



The policy speaks of promoting multilingualism and the “inclusion” of our indigenous languages, specifying various domains in which they should be developed: e.g. instruction, scholarship, communication etc. (Articles 31 – 33). This expands the scope of the language debate at a tertiary level and evokes a general sense of excitement. However, exactly what is meant with multilingualism?


Multilingualism is defined formally in a rather generic fashion as “the effective use and promotion of multiple languages either by an individual speaker or by a community of speakers.” However, given the frequency of its use, this is too vague for the purposes of the policy, creating substantial risk that the term could be interpreted differently by various interest groups. For instance:

Would the distribution of lecture notes in an Indigenous African Language mean that the language concerned has now been “included” and that that particular lecture is now “multilingual”? At least one university is satisfied with this perspective.


  • Or, would the policy aim at multilingual pedagogies, i.e. methods in which multiple languages are used simultaneously within the same lecture? And, if such pedagogies are appropriate in one context, are they appropriate in all contexts? Should multilingual pedagogies therefore replace single-medium instruction in all instances?
  • Or, would a lecture in which only one Indigenous African language is used be positively viewed as an example of how to promote multilingualism at the relevant institution as a whole? Or would that lecture have to become “double medium” to qualify?
  • Or, would the objective be to develop the language skills of students, possibly following the international best practice example of at least two local/national languages plus an international language (e.g. English)?


Depending on what the exact purpose of the policy is and the way its subsidiary objectives are formulated, there could exist a gigantic and material gap between the development of multilingualism, on the one hand, and the development of the indigenous languages, on the other. Without a clear statement as to what multilingualism means in practice and how it relates to the development of the indigenous languages, the policy could conceivably achieve the opposite to what it sets out to do: namely, promote English monolingualism.




Policy Framework (Article 25 – 44)
The Policy Framework contains much meat and a host of potentially useful mechanisms, to note the submission of annual plans, progress reports by Vice-Chancellors, and active monitoring and evaluation by the DHE. The protection of language departments is crucial, though this cannot take place in a vacuum. Also the idea of a long term planning framework for the development of all the indigenous languages is an excellent one as it might help to set in place a clearer long term vision for the development of the indigenous languages.


Of critical importance is the allocation of responsibility for specific languages to specific institutions. Without this little is likely to happen. However, most institutions would find it difficult to develop or maintain more than three languages as a full medium of instruction, communication, etc. – especially if doing so required a substantial investment in language development. However, narrowing the responsibilities in this manner, does not preclude the use of more languages for ancillary purposes.


However, the policy covers the proposed management framework in only the briefest of terms. For instance, one would at the very least expect the policy to explicitly allow the DHE to determine basic standards or best practice frameworks for university language policies, strategies and plans. Looking at some university policies, such standards are clearly needed, also in respect of student and staff recruitment. Without such standards and frameworks, language policies are likely to remain the slippery beasts that they currently are, greatly complicating monitoring and evaluation, never mind provide a standardised measure to be used for the fair allocation of resources.


The policy mentions linkages with Basic Education, a matter that lies at the heart of meaningful implementation of the policy. However, it should be clarified much more forcefully that the development of indigenous African languages on a tertiary level cannot be done in isolation, but has to be linked with the development of these languages for Basic Education.


The policy should consider the introduction of a systematic pipeline approach to language development, in which development on a primary level and secondary levels is linked with development on a tertiary level. This presupposes a strong link between the development of language departments and faculties of education for the training of educators. One cannot expect universities to take responsibility for the development of indigenous languages in isolation. Such a structured approach is a prerequisite for effective resource use and requires substantial coordination between universities, colleges and various provincial and national government  departments. These issues need to be considered in the policy in much more detail.


We note with concern the statement that universities should translate all communication into four languages (article 33), which would be difficult to achieve in practice and may ironically enhance the hegemony of English. We suggest that all universities are required to develop communication in at least two languages in the short term, followed by the longer term development of a third language for this and other purposes.The extremely brief treatment of the financial aspects of the policy creates the unfortunate  impression that insufficient thought has gone into the implementation side of the policy. To start with, the policy framework should at the very least contain some thoughts about the wider funding environment, and a statement about the principles according to which funding might be allocated. If meaningful incentives are not offered to academic institutions to develop true multilingualism, the policy is unlikely to take effect.


What, for instance, would be used as the datum line for funding allocations? Would universities be able to ask for resources for new multilingual activities only, or would existing use of indigenous African languages also be covered? How does one promote collaboration and synergy between languages, as opposed to competition for resources? What are the implications for the organisation of language departments and faculties of education? How much in the way of resources might there be to allocate in the first place? Within the framework of this policy, inadequate funding could do much harm to Afrikaans and the other indigenous African languages.