State Comptroller Matanyahu Englman published today (16.7.24) to the public the annual local government audit report – July 2024
State Comptroller and Ombudsman, Matanyahu Englman:
On the surveillance cameras in public spaces:
"During the past twenty years, there has been a surge in the number of surveillance cameras in the streets of Israel which were installed by the local authorities in order to contribute to the sense of security. The audit found that no competent authority knows how many cameras there are and what their technological features are. These cameras are designed to maintain public order – but some penetrate residents' private homes. The Swords of Iron War and the cyber dangers sharpen even more so the State of Israel's obligation to protect the privacy of its citizens. The Ministry of Justice and the local authorities must regulate the use of the cameras and protect the residents' privacy".
On the integration of Ethiopian immigrants in society:
"First Sergeant Assi Sama z"l, who fought bravely and fell in the Swords of Iron War, was not accepted into first grade in his childhood at the school in his hometown because he was an Ethiopian immigrant. It is inconceivable that in the year 2024 – more than 40 years after the waves of immigration from Ethiopia – significant gaps still exist between Ethiopian immigrants and the rest of the population. The Prime Minister's Office must strictly observe the implementation of the plan to integrate Ethiopian immigrants".
"It is sad to state the obvious, but whoever is good enough to sacrifice his life for the state – the state must protect his rights".
On the information security of the collection system in the local authorities:
"A connection has been found between the privacy violations raised in the report on cameras in public spaces and cyber threats to information concerning residents and held by the local authorities. Cyber threats increased during the Swords of Iron War – around 100 cyber incidents occurred in the local authorities during just three months. This notwithstanding, the Sectoral Unit at the Ministry of Interior, entrusted with the regulation of the matter, has not been in operation for some time and the Ministry of Interior is not formulating a solution for the matter".
"The Ministry of Interior, in conjunction with the Israel National Cyber Directorate, must rectify the defects in order to ensure that the residents' information is protected".
The operation of surveillance cameras by the local authorities in public spaces
"Big Brother": There has been a surge in the use of surveillance cameras by local authorities during the past twenty years, but the law does not regulate their use – and no party has any centralized information about the number, type and technological features of the cameras in public spaces. The Comptroller found that the examined authorities are not properly protecting the residents' privacy: Surveillance cameras that allow close-ups to private spaces were found and also surveillance cameras allowing automatic identification of license plates, without any explicit authorization in law.
The use of surveillance cameras by local authorities has gathered momentum during the past two decades, following initiatives by the government alongside initiatives by the authorities themselves.
Thus, for example, in Jerusalem's public spaces the number of surveillance cameras increased 47 times from 2011 to 2024 – from 80 cameras to 3,800; in Beer-Sheva's public spaces the number of cameras increased 271 times from 2011 to 2024 – from 14 cameras to 3,800; and in Petach Tikva's public spaces their number increased during the same years 67 times from 42 cameras to 2,820.
A residents' opinions survey, conducted by the Office of the State Comptroller, found that most of the respondents (80%) thought that the local authority should install surveillance cameras in public spaces. The main reasons for this, in their opinion, are to provide the residents with security (39%); prevent crime (16%); and for the purpose of preventing offenses and following up on them (16%).
Despite the upward trend in the number of surveillance cameras installed by the local authorities in the streets of Israel, the State Comptroller found that no public party in Israel keeps a concentration of data concerning their number, type and technological features.
There is no reference in the law in Israel to the issue of the installation of surveillance cameras in public spaces, and the use of these cameras has been regulated only by means of the general provisions of the Protection of Privacy Law and the directives of the Privacy Protection Authority. The State Comptroller found that the examined local authorities – Bnei Brak, Daliyat al-Karmel, Nesher, Haifa and Rishon LeZion – are not operating using all the tools at their disposal for the protection of the residents' privacy and compliance with the Privacy Protection Authority's directive in relation to surveillance cameras.
In all the examined authorities it was found that the sampled surveillance cameras were able to make close-ups into private spaces, which is liable to cause a tangible infringement of the residents' privacy. Starting with 25% of the cameras (11 cameras) examined in the Bnei Brak Municipality, and ending with 45% of the cameras (16 cameras) examined in the Rishon LeZion Municipality; in the Haifa Municipality 33% (15) of the examined cameras; in the Nesher Municipality 43% (17) of the examined cameras; and in the Daliyat al-Karmel Local Authority 30% (6) of the examined cameras. The Bnei Brak, Haifa and Nesher Municipalities and the Daliyat al-Karmel Local Authority did not examine, prior to the installation of the cameras, the need to camouflage the private spaces within the shooting range of the cameras.
All the examined authorities installed surveillance cameras for the automatic identification of license plates, without obtaining explicit authorization to do so beyond the general authority in the municipalities' ordinance. None of the examined authorities had held a public hearing prior to the installation of the surveillance cameras in order to hear relevant public views on the matter.
Four of the examined authorities, Bnei Brak, Haifa, Nesher and Rishon LeZion, had not collected complete and detailed data from the Israel Police in relation to the location of the offenses within their territory over a period of time, so that they could make a data-based decision in relation to the required location for the installation of the cameras in their territory and the determination of priorities for the sites of the cameras.
The audit found that the Haifa, Nesher and Rishon LeZion Municipalities had not installed surveillance cameras in neighborhoods where the crime rate was higher than average in the city neighborhoods in 2022. The Bnei Brank and Haifa Municipalities did not install cameras at all in the streets leading in the number of offenses committed in the aforesaid year.
Contrary to the Privacy Protection Authority's directive, the Bnei Brak and Nesher Municipalities and the Daliyat al-Karmel Local Authority did not mention on their websites the locations of the cameras and the area covered by them; the Rishon LeZion Municipality did not publish the shooting area covered by each of the cameras; and the Haifa Municipality published the layout of the cameras in the city on a map without noting additional details, including the shooting area covered by the cameras and how long the recordings are kept.
For comparison, the BCP Council in Great Britain published on its website comprehensive information regarding the surveillance cameras in its territory, including a list of cameras installed in public spaces, including the type of camera and the names of the streets or sites shot by each camera. Their website allows each resident to submit a request to receive a copy of the material shot where they appear. The authorities examined in Israel have no uniform policy in the matter: The Bnei Brak Municipality has no written policy in the matter of transferring photographed materials, and contrary to the Privacy Protection Authority's directive, the Municipality transferred to applicants for information shots of events without blurring other people appearing in them; the Haifa Municipality and the Daliyat al-Karmel Local Authority do not deliver photographed material to residents; the Nesher Municipality has not implemented the procedure stipulated in the mater, and residents requesting to receive information from the photo database are answered negatively.
The examined local authorities did not conduct an orderly procedure where they examined from time to time whether the circumstances that originally justified the installation of the cameras are still valid, and whether it is necessary to continue to operate them in order to fulfill their purpose, as required by the Privacy Protection Authority's directive, and as is acceptable in the British authority.
This and more: In the penetration test conducted by the Office of the State Comptroller in one of the local authorities in Israel, 11 findings on various levels of risk were identified: 2 at the critical risk level, 4 at the high-risk level and 5 at a medium risk level.
Comptroller Englman recommends that the Ministry of Justice consider regulating in legislation the issue of the use of surveillance cameras in public spaces by the local authorities. The examined local authorities must rectify the defects and preserve the principle of transparency and the residents' fundamental right to privacy.
Freedom of information in the local authorities
25 years since the Freedom of Information Law was enacted, the local authorities do not have any regulatory body to ensure that they are operating for its optimum implementation. The powers of the Freedom of Information Unit do not apply to the local authorities and the procedures it wrote do not bind them. From 2021 to 2022 there was an increase of 24% in the number of requests for information from the local authorities. The ongoing difficulty in enforcing the reporting obligation is particularly felt in the authorities in Arab society, where many are not fulfilling their statutory obligation to strive for transparency of the information and to share it.
25 years since the Freedom of Information Law was enacted, and 11 years since the Freedom of Information Unit was established, 95% of the public authorities in the state to whom the Freedom of Information Law applies, including the local authorities, do not have any regulatory body to ensure that they are operating for its optimum implementation: The State Comptroller found that the powers of the Unit apply to only 91 (5%) of all the public authorities (31 government ministries and 60 auxiliary units), and not even to one local authority.
Transparency of the activity in the local authorities and the fulfillment of their obligations pursuant to the Freedom of Information Law must be a paramount interest of the Ministry of Interior as the one responsible for their proper functioning. However, in its opposition to the fulfillment of the role itself, and even to the appointment of another party to fulfill it, the Ministry of Interior is single-handedly contributing to the continuation of the existing situation, where there is no body that regulates the activity of the local authorities in this field.
The persistent difficulty in enforcing the obligation to report on the implementation of the law in the local authorities is all the more discernible among the authorities in Arab society, where many are not fulfilling their statutory obligation to strive for transparency of the information and to share it with the public.
The Comptroller found that only 23% (20) of the authorities in Arab society had reported on requests for information in each of the years 2019-2022; 16% (14) had not reported at all on requests for information during these years; 24% (20) had not reported during three of the four years; 37% (31) had not reported in one or two of the four years.
The audit findings also show that the local authorities should expand their activity to promote transparency, including the publication of substantive information of public interest on their own initiative – in order to allow the general public, and not just the person requesting the information, access to information. Regarding the sharing of the information, the audit findings show the difference in the local authorities' manner of response and attitude to transverse requests for information.
While from 2019 to 2021 there was a continuous increase in the public demand for information from the government ministries and auxiliary units (12,549 requests, 13,390 and 14,838 respectively) the trend in the local government grinded to a halt (6,285 requests, 7,117 and 7,139 respectively). Nevertheless, there was an increase in the use of the Freedom of Information Law in local government in 2022 (8,847 requests), while it decreased in central government (13,028 requests). During the past four years, the number of petitions filed in court against the local authorities by applicants for information (1,081) is higher than the number of petitions filed against the government (674).
In the absence of orderly tools and directives in the field, the audit findings show the differences in the actions of the examined authorities – the Ashdod, Haifa, Netanya and Rosh HaAyin Municipalities and the Mateh Yehuda Regional Council – in the field of freedom of information, both in the matter of transparency of the information contained in the authorities' websites; and in the matter of the sharing of the information – including management of the requests for information array, the manner of responding to requests (including the model of delivering the information and a specification of the information) and the handling of the requests for photographed information; and concerning the reporting of the implementation of the law to the Unit. This difference in the actions of the local authorities is generally undesirable.
The Comptroller found that over the years, there had been an improvement trend, and the acknowledgement of the importance of government transparency has come a long way. Nevertheless, it was also found that not enough has been done – on the level of local government and on the level of central government – in order to encourage the public to take advantage of its right to receive information pursuant to the Freedom of Information Law. In practice, the implementation of the law is dependent to a great extent on the policies outlined in the matter by the professional parties in the local authority and those at its helm.
Comptroller Englman recommends appointing a regulatory party that can direct the authorities in the field, supervise them and enforce the implementation of procedures. It is recommended to examine the possibility of expanding the powers of the Freedom of Information Unit, which is the professional party proficient in this field and which has a broad systemic viewpoint on the matter, so that they will also apply to the local authorities. As long as no regulatory party has been appointed for the local authorities in the field, it is recommended that the Ministry of Interior be more involved in all matters pertaining to the reinforcement of the transparency of the local government.
Promotion of gender equality in local government
74% of the local authorities' employees are women – but the Comptroller found that in 2021 they earned only around 69% of the salary of the men who worked alongside them. Only around 6% of local authorities were headed by women. Women hold only about one quarter of the senior positions in the local authorities. After the latest municipal elections: Only 20% of the public officials are women. The Ministry of Interior and the Authority for the Advancement of the Status of Women have not done enough to promote gender equality in the local authorities.
The findings of the audit conducted by the State Comptroller indicate the depth of the gender disparities that still exist in the salary of the male and female employees of the local government (the average salary per month of female employees in relation to male employees in 2021 totaled around 69%); in the number of women among elected officials (724 out of 3,647, around 20%) and among the holders of senior positions in the local authorities (379 out of 1,431, around 26%). These disparities are even higher compared to the ratio of women among all employees in local government (approximately 123,000 out of approximately 166,000, around 74%) – and not only among the whole population (around 50%). These disparities are even higher in local authorities belonging to low socioeconomic indicator, peripheral authorities, non-Jewish, ultra-Orthodox and weak or unstable authorities. Against this background, and against the background of Israel's declining global gender gap ranking (in the 83rd place out of 146 countries; the country ranked in the 1st place is the nearest to achieving gender equality), the essentiality and importance of proactive initiatives to advance gender equality and to reduce gender gaps in local authorities is increasing.
An analysis of the data regarding the results of the elections to the local authorities in 2024 showed that only 6% of local authorities (15 out of 257) were headed by women. Even though there had been a certain increase in the number of women heading a local authority, their number remains low, and this is also the case in comparison with other democratic countries. Likewise, according to the data regarding the results of the elections to the local authorities in 2024, the number of women among members of the local authority council was around 19% in the municipalities and local councils (493 out of 2,655) and around 23% in the regional councils (231 out of 992). The number of women among council members in all types of local authorities was around 20% (724 out of 3,647), as opposed to around 18% in 2018, around 13% in 2013 and around 11% in 2008. In about one third of the examined authorities (83 out of 238) not one single woman was elected to hold office in the local authority council.
As aforesaid, even though the number of women among all employees of the local authority is around 74%, their number among the holders of senior positions is around 26%. A low number as aforesaid is especially noticeable in local authorities belonging to low socioeconomic indicator (around 10%), in peripheral authorities (around 21%), in non-Jewish authorities (around 8%) or in authorities that are part of recovery or streamlining programs or those where an accompanying accountant has been appointed (around 12%). In around one third of the local authorities (72 out of 252) there are no women at all holding office at senior management level, including the Rahat Municipality, and in a similar number of local authorities (67 of them) one woman holds office at senior management level, including the Nahariya Municipality. Furthermore, the audit found that in one third of the local authorities (79 out of 240) there was no representation of women at all among the holders of senior positions and among elected officials or there was only symbolic representation (up to 10%).
The Comptroller found that the Ministry of Interior had not implemented the recommendations of the Public Committee for the Advancement of Women in Local Government since 2018 and of the policy team it had formed in the matter of "Identifying, recruiting and promoting women to senior management positions in the local authorities" in 2021, including not publishing any directives for the local authorities regarding the need to formulate an internal policy within the authority for the advancement of the appropriate representation of members of both sexes, in particular at the middle management level and at the senior management level, and including the proactive head-hunting of female candidates for positions or jobs where significant under-representation had been found. Neither had the Ministry of Interior determined an outline for supervision and control over compliance with the statutory provisions, including not stipulating any reporting obligations that would allow it to conduct effective follow-up and control over the extent of gender equality promotion at the middle management level and at the senior management level in the local authority.
The audit showed that in each of the years 2015 to 2023 on average no female advisor for the advancement of the status of women had held office in 20 out of the 257 local authorities (around 8% of them). Furthermore, in 13 local authorities no female advisor had held office in the accumulative of four years during these years. As of September 2023, it was found that 24 of 257 local authorities (around 9% of them) had not appointed a female advisor, and in 12 of them no female advisor had held office for at least two consecutive years. Even though by law, the Ministry of Interior is under an obligation to appoint a female advisor after it has ordered the local authority to appoint her and it has not done so, the audit found that the Ministry of Interior had not fulfilled this obligation nor is it using the other more moderate tools to encourage local authorities to fulfill the position of the female advisor.
The scope of the position of around 80% of the female advisors who replied to the questionnaire of the Office of the State Comptroller (148 out of 184) has not been defined at all. The replies also showed that the absolute majority of the female advisors who replied (169 out of 184) have another job in the local authority, around 36% of them (61 out of 169) hold their other job as division directors or as department directors in the local authority. This state of affairs gives rise to concern regarding the female advisor's ability to dedicate appropriate time to her tasks and realize all the opportunities involved in the position.
During the course of the audit, the Central Bureau of Statistics, in conjunction with the Authority for the Advancement of the Status of Women, began to formulate a set of indicators that could describe gender distribution and at the local authority level, gender disparities in the various fields of life, including in the employment market; in the fields of education, welfare, health and leisure; in the fields of housing, demographics and transportation; and also in the aspects of resilience and public activity. These indicators could also be integrated into the Central Bureau of Statistics' periodical publications about the local authorities, and thus they can be used for examining the gender implications of the authorities' decisions in the various fields of activity; as a comparative tool for the examination of the unique phenomena of gender inequality in the authorities or their success in reducing gender disparities; and also as a decision supportive tool for the government regulatory bodies, among other things with regard to decisions in matters of decentralization of powers or budgeting.
Comptroller Englman recommends to local government bodies to develop a strategic plan to reduce gender disparities among their employees, from which work plans will be derived containing measurable outcome-based goals and timelines for execution – all with the involvement and leadership of the Advancement of the Status of Women advisors serving in them. The Ministry of Interior, in collaboration with the Authority for the Advancement of the Status of Women and the Union of Mayoral Advisors, must complete the formulation of the concept of the role of the female advisors and examine ways in which it will be possible to ensure that they fulfill their duties optimally.
The activities of local authorities for the integration and inclusion of Ethiopian immigrants into society
Significant disparities persist in all aspects of life between Ethiopian immigrants and the rest of the Jewish population. In 2021 the average gross financial income per household in the entire population was higher by around 30% than the average income per household among Ethiopian immigrants. The rate of students among Ethiopian immigrants who are studying 5 units in mathematics is about one quarter of the rate of students who are studying 5 units in mathematics in the general population (4.8% out of around 20%). Around 77% of Ethiopian immigrants who work in the local authority are employed at a very low rank. The local authorities have utilized only 67% of the budget allocated to them from the government ministries for following the "New Way" program for the integration of Ethiopian immigrants.
At the time of writing the audit report concerning the integration of Ethiopian immigrants, First Sergeant Assi Sama z"l fell in the Swords of Iron War, alongside other Ethiopian immigrant fallen soldiers. Assi was a brave combat soldier in the Nahal brigade and fell in battle in the north of the Gaza Strip. After the death of First Sergeant Assi Sama, it was discovered that he was the boy Aschalwu Sama, who in 2009 became the face of the fight of Ethiopian immigrant children who had been discriminated against in the educational system in his hometown, Petach Tikva, after the school in the city refused to accept him into the first grade due to his being an Ethiopian immigrant, with the excuse of "cultural gaps".
14 years later, his grieving compatriots said: "Assi z"l was good enough to fight and die for us and for our leadership – but he wasn't good enough for the blind Israeli educational system, which for years discriminated against him and his friends". Assi z"l, in his and his family's brave fight for equality in education, generated a change and will forever be remembered thanks to his and his family's great sacrifice. Assi will also be remembered by virtue of the the phrase he coined and which he acted on as a child and as a soldier: "Be stronger than your excuse". May his memory be for a blessing.
More than 40 years after the large waves of immigration of Ethiopian Jews, significant disparities still persist in all aspects of life between Ethiopian immigrants and the rest of the Jewish population in Israel. At the end of 2016 "New Way", the new government program for the integration of Ethiopian immigrants, which is based upon several government decisions in the matter, began to operate. In order to implement the program in all aspects of life, the government ministries, and the local authorities in particular, are required to demonstrate deep involvement in the issue, including conducting mapping, determining and implementing action plans, allocating budgets and maximizing their utilization, and conducting continuous monitoring and control – lead by the implementation staff of the program for the integration of Ethiopian immigrants established by the Prime Minister's Office.
The State Comptroller found that from 2016 to 2022 the Ministry of Education, the Ministry of Welfare and Social Affairs, the Ministry of National Security, the Ministry of Culture and Sports and the Prime Minister's Office had budgeted the local authorities participating in the "New Way" program in an inclusive sum of NIS 203 million, however in practice the transfers to them had totaled about only NIS 136 million, and accordingly the local authorities utilized only 67% of the budget allocated to them by the government ministries for implementation of the program.
The goals of "New Way" for the reduction of salary disparities between Ethiopian immigrants and the rest of the population have not been achieved: In 2021 the average gross financial income per household in the entire population was higher by around 30% than the average income per household among Ethiopian immigrants (NIS 19,916 in the general population as opposed to NIS 15,285 among Ethiopian immigrants).
In 2021 the average monthly salary of Ethiopian immigrants who were born from 1978 to 1983 was NIS 4,595, a salary that was about 33% lower than the average salary of other Jewish Israeli residents who were born in those years who were examined, namely NIS 6,916.
The Comptroller also indicated significant disparities in education: In the September 2021-August 2022 school year, only 54% of 12th grade Ethiopian immigrant students received a Matriculation Certificate complying with the universities' threshold requirements, as opposed to 75.1% of all the Jewish education students.
The number of students who studied five units in mathematics among Ethiopian immigrants is considerably lower than the number of Ethiopian immigrants in the general population: In 2022 the number of students who studied five units in mathematics in Yavne was about 17% of the students in all the educational frameworks in the city, as opposed to only 8.5% among Ethiopian immigrants; in Kiryat Malakhi about 10% of the students in all the educational frameworks in the city studied five units in mathematics as opposed to 0% among Ethiopian immigrants; in 2021, 0% of Ethiopian immigrant students in Netivot studied five units in mathematics, and in Rehovot 7.7% Ethiopian immigrants studied five units in mathematics. This is as opposed to 21% in the general population. The number of Ethiopian immigrants nationwide who were examined in five units in mathematics was 4.8%. It was further found that the number of Ethiopian immigrant outstanding students out of all the 12th grade students in Netivot and in Kiryat Malakhi who had completed their studies in 2021 was 0%; in Yavne and Rehovot the number of outstanding students was 2%. The number of outstanding students among all the Ethiopian immigrants in this year group was 2.32% out of all the 12th grade Ethiopian immigrant students, while the number of outstanding students among all the 12th grade students around the country was about 10%.
The Comptroller found that the number of Ethiopian immigrant female students (23.2%) and male students (12.2%) holding certificates of completion from higher education institutions – universities and colleges – is the smallest relative to their number among all ethnic groups of Jewish students (which ranges from about 28% among men of Mizrahi origin and 64% among women of Ashkenazi origin).
It was further found that the Ministry of Interior and the local authorities had not adopted a measurable goal for the representation of Ethiopian immigrants. Around 77% of the Ethiopian immigrant employees were employed in the local authorities in very low-ranking positions (up to Grade 7). The representative rate of Ethiopian immigrant employees in high-ranking positions (1%) is considerably lower than the representative rebate of the employees in the general population in the high-ranking positions (around 3.6%). The Ministry of Interior does not conduct any audit in the matter of the quality of the employment and positions filled by Ethiopian immigrants, and it does not demand that the authorities comply with the representative goal in all ranks. Only five out of the 253 authorities that sent reports to the Ministry of Interior noted in their reports that they had published designated tenders for Ethiopian immigrants (Bat Yam, Givat Shmuel, Netanya, Kiryat Malakhi and Ra'anana). The authorities were not required to specify in their reports which designated positions they had published.
Comptroller Englman recommends that the staff implementing the program for the integration of Ethiopian immigrants at the Prime Minister's Office take care to exercise the control over the program's goals and the utilization of the budgets and enhance the Ministry of Interior's involvement in harnessing the authorities to implement the program.
Parent-child communication centers in the local authorities
66 communication centers that were operating in local authorities all over the country in 2023 found it difficult to provide an available and accessible response. Many families were required to wait for assistance, sometimes for many months. About one third of the parents involved were not happy with the location of the communication centers. From 2021 to 2023, more than half of the social workers in the communication centers experienced violence. In 2023, there were communication centers in only 9% of the non-Jewish authorities, as opposed to 32% in the authorities in Jewish society.
The parent-child communication centers (the communication centers) are operated by the local authorities and are designed to act as a safe place for holding meetings between parents and children against the background of separation, divorce or violence and risk. In 2023, 66 communication centers were scattered in 64 local authorities around the country, for about 6.3 million residents. The centers are supposed to act as regional centers. About one third of the families treated there in 2022 were residents of other local authorities.
The State Comptroller examined and found that 66 communication centers found it difficult to provide an available and accessible response for the population requiring their services, and many families were required to wait, sometimes for many months, before receiving assistance in reinforcing the relationship between the parents and their children.
In 26 out of the 59 communication centers that replied to the questionnaire of the Office of the State Comptroller, it was found that 111 families had been compelled to wait for periods of time ranging from two weeks to more than 30 weeks before receiving services. Thus, for example, in the Nesher Municipality, they were compelled to wait more than 30 weeks for the start of the meetings in the communication center. Another example of the waiting times required – a father who lives in Petach Tikva and his children who in 2022 were staying with their mother in a shelter for battered women in the Jerusalem area were compelled to wait about eight months before it was possible for them to meet in the communication center in Betar Illit (a distance of about 70 kilometers from the father's home) – since throughout that period no vacant place had been found in a communication center near the shelter for holding the meetings.
About one third (90 out of 280) of the respondents to the satisfaction questionnaire among the patients in the communication centers replied that they are not satisfied with the location of the communication center and with its accessibility.
It was found that the budgetary mechanism determined by the Ministry of Welfare and Social Affairs – a mechanism that includes participation in the salaries of the communication center's employees only (75% of the rate that in November 2023 totaled about NIS 650 for every family treated) and which leaves the local authority operating the center to bear the cost of the other expenses involved therein – makes it difficult to give incentives to local authorities to establish communication centers. As of the date of the audit, the establishment of the centers is based for the most part upon the willingness of local authorities to bear the costs involved in the operation of the center and not on early and informed planning based upon an examination of the needs. The Comptroller found that as of 2023, only 9% of the non-Jewish authorities had established communication centers, as opposed to 32% of the authorities in Jewish society.
It was further found that more than half of the social workers in the communication centers that had replied to the questionnaire had experienced violence during the past three years (2021-2023). In 35% of the cases, the social workers replied that the event had been reported to the police, in 17% of the cases the event was reported to the Non-Violent Committee at the Ministry of Welfare and Social Affairs. 12 (20%) of the social workers replied in the communication centers that from 2021 to 2023 violent events had occurred on the part of parents against their children during the meetings at the center where they were employed. The police was only involved in seven out of the 22 cases (31%) where violent events occurred.
Even though the treatment at the communication center is designed to last for about six months in practice, according to Ministry of Welfare and Social Affairs data, from 2020 to 2022 about 15% of the families treated at the communication center were treated for a period of more than two years. The questionnaire showed that in the 59 centers that replied in August 2023 251 families had been treated for more than two years, out of which, for example, there were 21 families in Beer-Sheva, 20 families in Bnei Brak, 17 families in Or Yehuda, 15 families in Tel Aviv-Yafo, 13 in Haifa and nine families in Bet Shemesh.
Less than half of the families who had completed treatment in 2022 (598 families) went on to independent visitation arrangements. Alongside the decline in the number of families completing treatment that went on to independent visitation arrangements, there was a rise in the number of families that returned to receive treatment at the communication center after the meetings had ended, 206 families in 2022 as opposed to 147 families in 2020.
Data from the Ministry of Welfare and Social Affairs show that in all four districts, the number of families treated in relation to the number of staff members at the communication center is higher than the fixed standard (an average of 48 families are treated as opposed to the fixed standard of 23 families). In response to the questionnaire, 75% of the respondents said that they are experiencing emotional overload within the framework of their work at the communication center, and only 66% replied that the local authorities are providing a response to the aforesaid emotional overload.
75% of social workers who replied to the questionnaire thought that it was necessary to hold training sessions for treating designated populations at the communication center. 27% replied that training sessions were necessary in order to treat the Arab society and members of the Ethiopian community.
Comptroller Englman recommends that the Ministry of Welfare and Social Affairs examine the correlation between the needs in all the local authorities for the services of the communication centers and the present geographic dispersal of the centers – and determine on the basis of this examination standards regarding the maximum occupancies and distances that families are compelled to travel in order to reach the communication center.
Employment of workers in the local authorities via manpower contractors
In 2022, approximately 19,000 wage violations involving contractor employees were discovered, worth approximately 886,000 NIS. By the end of June 2023, 11,700 additional violations had been discovered, with a total financial scope of approximately NIS 521,000. The examined authorities had not enforced the rectification of the defects on the service contractors and had contented themselves with merely follow-up by the wage inspector, without any intervention and discussion with the contractor concerning the violations discovered. The telephone numbers published by the Ministry of Labor and the Audit Division at the Accountant General Department at the Ministry of Finance are not active, so that it is impossible to use them to file a complaint.
Many local authorities in Israel and worldwide avail themselves of external suppliers, including service contractors, for the purpose of providing services to their residents. In 2023, around 105,000 service contract workers were employed in Israel, according to data from the Ministry of Labor: Around 55,000 were employed in the cleaning field, and around 50,000 in the guarding and security field. Some of the engagements by the local authorities were conducted via joint tenders by the Local Government Economic Services Ltd. (Mashcal). The service contractor is the one who employs the workers, enters into a contract with them, and takes care of their conditions and rights – but this form of employment exposes the workers to the danger of exploitation, especially in jobs where many working hands are required and the wage is low, such as cleaning, guarding and security. These jobs are characterized by poor employment conditions and a lack of employment security, and those working in them are especially vulnerable and require protection and enforcement of the labor laws by the employer.
The findings of the audit conducted by the State Comptroller indicated defects in the controls made by the examined local authorities (Bnei Brak, Netanya, Afula, and Kiryat Yam Municipalities and Misgav Regional Council) concerning the employment conditions of the service contract workers employed within their jurisdictions – some even expose the workers to a substantive infringement of their rights.
The Department for Enforcement of Employee Rights at Mashcal performs periodic sample wage inspections and operates a telephone wage hotline to provide a direct response for workers. Thus, for example, 819 wage inspections were made in 2022, and 354 wage inspections were made in 2023 (January-June). Around 19,000 violations were discovered in 2022, most of them financial violations, at an inclusive financial scope of around NIS 886,000. Likewise, until the end of June 2023, 11,700 violations at an inclusive financial scope of around NIS 521,000 were discovered. The damage caused to workers as a result of these wage violations, and all the more so when low salaried workers in the fields of guarding and security and cleaning are concerned, enhances the need to perform the wage inspections by Mashcal. Mashcal's computerized database has not been used in order to direct its wage inspectors to focus on the frequent violations that were discovered in the inspections.
The examined local authorities did not enforce on the service contractors the rectification of the defects and had contented themselves with merely follow-up by the wage inspector, without any intervention and discussion with the contractor concerning the violations discovered.
In five of the examined authorities no documents documenting the circumstances leading to the decision about the transition to indirect employment were found, including the performance of a calculation for a feasibility study of the employment of workers via service contractors. As a result, the financial effectiveness of the course of action was not a consideration in the decision to engage with the service contractors.
In a public sharing process conducted by the Office of the State Comptroller in the examined local authorities, most of the contract workers interviewed complained about the amount of their wage and expressed a desire to be employed directly by the local authority. About one third of the interviewees were unaware of all the rights they are entitled to, and few of them had received an explanation regarding their rights from the employer or person in charge at the local authority.
The Comptroller also examined the telephone hotline for inquiries from contract workers, and found that the telephone numbers published by the Ministry of Labor and the Audit Division at the Accountant General Department at the Ministry of Finance are not active, so that it is impossible to use them to file a complaint.
Comptroller Englman recommends that the examined local authorities conduct wage inspections in accordance with the law and maintain close control over these inspections. They must use all the tools at their disposal by law in order to enforce the obligation of the service contractors to provide their workers with the rights they are entitled to.
Making buildings and services accessible for persons with disabilities
Around 92% of the local authorities have not fully complied with the requirements of the Accessibility of Buildings, Infrastructures and Environment Law in 2020. The Comptroller found disparities between the examined authorities in accessibility of the buildings and services within their jurisdiction. Defects were found on the websites of all the local authorities examined.
One in every nine residents in Israel (approximately 1.017 million persons) is a person with a disability. The local authority plays a key part in the integration of persons with disabilities as full and equal members of the community and as active partners therein.
According to a survey by the Federation of Local Authorities, as of September 2020 237 local authorities (around 92% out of the 256 authorities) have not fully complied with the requirements of the Accessibility of Buildings, Infrastructures and Environment Law.
The State Comptroller found disparities between the local authorities examined – El'ad, Yokne'am Illit, Kfar Saba, Nahariya and Arraba, and the Drom HaSharon and Merom HaGalil Regional Councils – in the promotion of the accessibility of the buildings and services within their jurisdiction. It was found that in the aspects examined, the local authorities that had adapted their organizational building and the authority's work in the matter of accessibility, including the appointment of an accessibility coordinator, the establishment of an accessibility committee, the adaptation of internal procedures and the provision of designated training sessions for employees, had a better accessibility situation than that in the authorities that did not do so.
The audit found defects in the local authorities examined – non-compliance with the outline for the dispersal of the facilitation of accessibility for additional four years, the absence of facilitating accessibility and availability for use of public buildings and places that are not a building, the non-completion of the general facilitating of accessibility of the educational institutions, defects in the accessibility of the service including the digital service on the authorities' websites and defects in the supervision and enforcement of facilitating the accessibility of businesses. Nevertheless, in three of the local authorities examined (the Municipalities of Yokne'am Illit and Kfar Saba and the Drom HaSharon Regional Council) initiatives and demonstrations of excellence in the inclusion and integration of persons with disabilities were found.
The audit staff found, among other things, defects in facilitating the accessibility of the local authority building in six of the local authorities examined (the El'ad, Yokne'am Illit, Kfar Saba, Nahariya and Arraba Municipalities, and the Merom HaGalil Regional Council). In the El'ad Municipality building there is no disabled parking and no accessibility for the visually impaired in the elevator and stairs; in the Yokne'am Illit Municipality building there is no accessibility for the visually impaired in the elevator and stairs and the disabled bathrooms there were locked and it was not possible to use them for about six months; in the Kfar Saba Municipality building there is no accessibility for the visually impaired in the stairs, the entrance door does not close slowly as required, and accessories are missing in the disabled bathrooms; in the Nahariya Municipality building there is no accessibility for the visually impaired in the elevator and stairs, and the chairlift in the entrance was out of operation for a period of time; in the Arraba Municipality building there is no disabled parking and the entrance route is blocked by parked vehicles, nor is there any accessibility for the visually impaired in the elevator and stairs; and in the Merom HaGalil Regional Council building there is no accessibility for the visually impaired in the elevator and stairs. Defects in the accessibility of additional buildings owned by the local authority were found in all the local authorities examined.
Four years after the date fixed in the law for the completion of the facilitation of accessibility (May 2019), in five of the local authorities examined – El'ad, Yokne'am Illit, Arraba, Drom HaSharon and Merom HaGalil – there are still educational institutions that are not accessible by general accessibility, which includes an elevator shaft, accessible toilet cubicle and accessible entrance and route. An examination of the criteria concerning accessible documents and the level of contrast found defects in all the websites of the authorities examined.
Comptroller Englman recommends that all local authorities, including the seven local authorities examined, continue to promote the matter of accessibility in their jurisdiction. It is recommended that the Commission for Equal Rights of Persons with Disabilities follow up on the matter of accessibility in the local authorities and continue to enforce all the local authorities to make their jurisdiction accessible.
Information security of collection systems in local authorities
Following the Swords of Iron War there was an increase in the risks of the occurrence of cyberattacks in all the bodies in the state, including the local authorities: 96 cyberattacks occurred from October to the end of December 2023. The Comptroller found that the Sectoral Unit at the Ministry of Interior, which is supposed to direct the local authorities in cyber protection aspects, had stopped operating. The annual financial cost of the cyber damages is estimated at at least NIS 12 billion per annum.
The local authority's collection system is a central system through which the authority collects payments from the residents, allowing it to perform its ongoing activity. Personal information about the residents accumulates at the local authorities, compelling them to adopt measures for the safekeeping and security of the information collected by them.
As of the end of 2021, there were approximately 9.4 million residents within the jurisdiction of all the local authorities in the state, and their independent income totaled approximately NIS 44 billion. In 2022, 9,108 cyberattacks were reported to the National Cyber Directorate. In 2023, the Directorate received reports regarding 13,040 cyberattacks.
In 2021, the cost of the cyber damages worldwide was 6 trillion dollars and in Israel the annual financial cost is estimated at at least NIS 12 billion per annum.
The State Comptroller found that from January 2021 to October 2023, the National Cyber Directorate received reports of 164 cyberattacks in the local authorities. Following the Swords of Iron War, there was an increase in the risks of the occurrence of cyberattacks in all the bodies in the state, including the local authorities: 96 cyberattacks occurred from October to the end of December 2023.
From May to December 2023 the State Comptroller examined the matter of information security of the collection system in the Or Akiva, Rishon LeZion, Rahat, and Rehovot Municipalities, in the Even Yehuda Local Council and in the Emek Hefer Regional Council. The Comptroller found defects in the implementation of the requirements, some of which appear in the Protection of Privacy Law, in the regulations thereunder and in the National Cyber Directorate directives, and these defects are liable to expose the local authorities to cyberattacks.
Among the defects that were found in the audit: The absence of a body acting as a sectoral unit of the local authorities that guides them from the professional viewpoint in cyber protection aspects. At the end of 2023, no outline had still been agreed upon between the Ministry of Interior and the National Cyber Directorate regarding the continuation of the activity of the Sectoral Unit at the Ministry of Interior, which was established following a government decision in 2015 with the aim of guiding the local authorities in the field of cyber protection – and the Unit stopped guiding the local authorities sector. Therefore, there is no body acting as a sectoral unit of the local authorities that is responsible for guiding them regarding their preparation for dealing with cyberattacks. In the absence of an official party there can be no accompaniment, direction and control in the matter of preparation for dealing with cyberattacks and in the matter of the readiness to deal with cyberattacks, especially in view of the increase in cyberattacks that have occurred against various state bodies during the course of the Swords of Iron War and the evacuation of the local authorities in the south and north of the country, which is liable to expose their computerized systems to information security risks.
The audit also found defects in the local authorities' management of the information database of the collection system. Likewise, it was found that the local authorities had not conducted any risks surveys and penetration tests for the collection system, and they are not conducting an ongoing monitoring of the service providers holding their databases nor have they received from the service providers periodical reports regarding the extent of their compliance with the obligations pursuant to the Protection of Privacy Regulations.
Comptroller Englman recommends to the Ministry of Interior and the National Cyber Directorate to act to determine a party that will serve as a sectoral unit for the local authorities. Furthermore, the local authorities should rectify the defects raised in the report.
Computerization of small local authorities
No government party nor the Federation of Local Authorities has any status report concerning the information systems, software and hardware infrastructures, contact channels and the network of the local authorities' online services. In the Swords of Iron War, 28 local authorities, including 20 small authorities, did not operate an emergency hotline at all hours of the day.
The State Comptroller found that the field of computerization in the local authorities is not regulated. The Ministry of Interior has not published binding directives for the local authorities and has not defined a standard for the level of computerization there, so every authority operates as it sees fit. Despite two attempts at mapping by the Ministry of Interior in 2020 and 2021, no government party nor the Federation of Local Authorities has any status report concerning the information systems existing in the local authorities, software and hardware infrastructures, contact channels and the network of the local authorities' online services. The Ministry of Interior and the National Cyber Directorate did not determine what are the recommended systems for managing a local authority, and in practice every local authority is required to decide for itself which systems to purchase.
As of July 2023, only about 80 local authorities out of the 259 local authorities employ primary information systems managers, and out of them about 30 are employed via outsourcing. The audit findings show that not a single local authority of those examined properly handles the matter of its information security.
Only 12 small local authorities, constituting about 10% of all the small local authorities, participated in the Ministry of Interior's Digital Leaders program since its commencement in 2017 (69 local authorities out of the 259 local authorities – about 27%). Not a single local authority of those examined – Elyakhin, Beit Dagan, Jaljulia, Merhavim, Fureidis and Kiryat Ye'arim – did not train employees within the framework of the Digital Leaders program.
During the Swords of Iron War, 28 local authorities, of them 20 small local authorities, did not operate an emergency hotline available at all hours of the day; 19 local authorities, of them 13 small local authorities, provided their residents with just an online response, via contact on its website or text message. These response methods were unfitting for a time of emergency, which entailed the existence of an immediate human response for the residents.
There was no authority among the those examined that had the option of holding a chat on its website; the authorities examined do not provide a computerized information station (kiosk) for residents who do not have private access to a computer or to the internet.
It was further found that 231 authorities had received a deed of undertaking from the Israel National Digital Agency within the framework of an RFP for the updating of infrastructures, but about NIS 24.5 million (approximately 56%) of the sum of the undertakings were not realized. The low realization percentage indicates, among other things, the lack of correct accompaniment in the submission process of the RFP and the realization and reporting process, as well as a less than optimum budgeting model.
Comptroller Englman recommends that the local authorities examined rectify the defects raised in this report in the field of protection of the information systems and data security they possess. In view of the difficulty of the small local authorities in employing an information systems manager, it is recommended that they appoint a professional body, from the authority's administrative echelon, to manage and promote the field or to avail itself of the services of an information systems manager in the regional clusters.
The collection of betterment levies and their use
The State Comptroller found that the present format of the betterment levies causes an increase in the financial disparities between local authorities in the center of the country and those in the periphery, and between local authorities of a higher socioeconomic ranking than those of a low ranking (up to disparities of 15 times the revenue to the resident from the levies). In 55% of the cases an appeal led to a change in the assessment in favor of the debtor or its cancelation. According to a sample, in 95% of cases decisive appraisers reduced the charge determined by the local planning and building committees – sometimes this concerned a reduction of an overcharge of millions of shekels.
The State Comptroller examined and found that in 2021 the local authorities had collected approximately NIS 8.7 billion from betterment levies; at the end of this year, the balances that had accrued in the funds designated for the levy monies totaled approximately NIS 7.5 billion. The audit found that the present format of the betterment levies causes an increase in the financial disparities between local authorities in the center of the country and those in the periphery, and between local authorities of a higher socioeconomic ranking than those of a low ranking.
The financial statements of all the local authorities were analyzed as part of the audit and an in-depth audit was conducted in four municipalities: Herzliya, Jerusalem, Ramat Gan and Ramat HaSharon.
The revenues from betterment levies in the local authorities in the more peripheral clusters and those ranked in the low clusters (1-4) on the socioeconomic index were an average of NIS 559 per resident, while the revenues from the betterment levies in the local authorities nearer to the center of the country and those ranked in the high clusters (8-10) on the socioeconomic index were an average of NIS 8,476 per resident – namely, a 15-fold disparity. The amount of the revenues from the betterment levies in the local authorities nearer to the center of the country and those ranked in the high clusters (8-10) on the socioeconomic index total approximately 40% of all the revenues, while 13.5% of the population resides within their jurisdiction.
There are considerable disparities between the authorities in terms of the total balance of the betterment levy fund, where at the end of 2021 approximately NIS 7.5 billion accrued: In the local authorities ranked in the high clusters (8-10) on the socioeconomic index, in whose jurisdiction about 20% of the population resides, the fund balance totaled approximately NIS 4.5 billion, and its rate was about 60% of the total fund balance in all the local authorities. In the remaining local authorities, in whose jurisdiction about 80% of the population in Israel resides, the fund balance totaled approximately NIS 3 billion, and its rate was about 40% of the total betterment levy fund balance in all the local authorities.
The Comptroller found that the average time period for completion of the handling of the appeals in all the districts was 429 days – three times longer than the standard time for completion of the process (140 days). The longest time period was measured in the Tel Aviv District – about two years, almost five times longer than the standard time. In the Jerusalem District the time period for completion of the handling was 1.3 years – almost 3.5 times longer than the standard time. In the Southern, Haifa and Northern Districts the average time period for completion of the handling is longer than 282 days – two times longer than the standard time.
The audit found that in 55% of the appeal proceedings commencing from 2018 to 2022 against assessments prepared by the local committees (1,305 proceedings out of 2,353), the appeal was accepted in full or in part or ended with the parties' consent or in a compromise settlement between them. In other words, in about half of the cases the appeal led to a change in the assessment or its cancellation. As to the disputes regarding assessments that had been brought before decisive appraisers, in 57 (95%) of the 60 final assessments randomly sampled, the decisive appraisers reduced the local planning and building committee's assessment and on average the reduction rate totaled 36%; in 70% of the cases the reduction was at a substantial rate of more than 25/%.
The findings relating to the disparities in the betterment levies charges after the decisions of the decisive appraisers indicate an overcharge of large sums of money, sometimes hundreds of thousands of shekels and even millions of shekels – sums that are liable to substantially undermine the feasibility of a venture or of a real estate deal. In three of the municipalities examined – Herzliya, Ramat Gan and Ramat HaSharon – the average sums of the change in the charge sum following the decisions of the decisive appraisers ranged from approximately NIS 320,000 to approximately NIS 1.42 million. The median sum of the disparity in the charges ranged from NIS 83,000 to approximately NIS 105,000. This is liable to adversely affect the public's trust in the way in which the authorities fix the betterment levy sums, and it reflects the extent of uncertainty latent in the charging system regarding the sums that will ultimately be collected.
The Comptroller found that the examined municipalities do not publish to the public the betterment assessments they have prepared, the final assessments and the levy sums collected from property owners. Consequently, this adversely affects the public's ability to make informed decisions, examine the betterment assessments and the payment demands, and examine, as necessary, whether they are justified and reflect an equalitarian and fair charge.
It was further found that the government decision regarding the formation of a public committee for the examination of the betterment levies mechanism has not been implemented, and in practice no committee has been formed by the Ministers of Interior who held office from August 2021 to October 2023 (the date of the audit).
Comptroller Englman recommends that the Minister of Interior establish a public committee to examine the mechanism of the betterment levy, in accordance with the government decision, in order to rectify the defects.
The handling of noise nuisances in the public space
From January 2021 to June 2023 the Israel Police received more than 650,000 inquiries regarding noise – the second most common inquiry subject after traffic offenses. The Comptroller found that the police and the local authorities examined had not sufficiently enforced the laws and regulations concerning noise offenses. Contrary to the standard practice in Europe, the local authorities in Israel are not obliged to map the noise nuisances and act to reduce them – and the Ministry of Environmental Protection has no written policy for dealing with them.
There are about 400 cases of death per year in Israel as a result of indirect damage caused by noise nuisances, according to a calculation made by the Ministry of Environmental Protection.
The parties responsible for dealing with noise nuisances in Israel are the Ministry of Environmental Protection, the Israel Police and the local authorities. The State Comptroller examined and found that from January 2021 to June 2023 the Israel Police received 656,813 inquiries regarding noise – the second most common inquiry subject after traffic offenses.
Among the local authorities examined (Netanya, Afula, Petach Tikva and Zefat), the number of inquiries received by the municipal hotlines on noise matters, out of all the inquiries regarding environmental protection matters from 2019 to 2023, reached approximately 64% (about 94,000 inquiries regarding noise out of a total of about 154,000 inquiries regarding environmental protection matters). The number of inquiries regarding noise matters in Netanya (approximately 99%) and in Afula (approximately 87%) was especially high.
The Comptroller found that the Israel Police and the examined local authorities had not sufficiently enforced the laws and regulations concerning noise offenses, despite the tools at the disposal of the local authorities. Thus, in the first three quarters of 2022, only 15% of the inquiries to the Israel Police regarding causing noise concluded in the imposition of a fine (about 35,000 fines). The Petach Tikva Municipality has authorized only one environmental inspector, and the Afula and Zefat Municipalities have not authorized any environmental inspectors at all. The failure to authorize any environmental inspectors adversely affects the local authorities' ability to enforce the laws and regulations concerning noise offenses in their jurisdiction.
The audit showed a difference between the number of reports issued by the municipal inspectors in Netanya and Petach Tikva, where the authority's inspectors issued an average of 38-44 reports for noise offenses every month, and the Afula and Zefat Municipalities, where no reports for noise offenses have been issued at all.
As of the date of the audit, the Zefat Municipality had not established an environmental unit, and so it could not take advantage of the financial resources made available by the Ministry of Environmental Protection within the framework of the RFPs it published. The environmental units in the Afula and Petach Tikva Municipalities did not utilize all the support sums approved for them by the Ministry of Environmental Protection: The utilization rate of the supports approved by the Ministry from 2017 to 2023 for the Afula Municipality was approximately 40% (about NIS 767,000 out of about NIS 1.9 million), and in the Petach Tikva Municipality – approximately 44% (about NIS 1.34 million out of about NIS 3.03 million). A larger utilization rate of the supports would have assisted the aforesaid local authorities in dealing effectively with the environmental nuisances in the municipal space in general, and with noise nuisances in particular.
The audit findings show that the Ministry of Environmental Protection has no written policy for dealing with noise nuisances on the national level. While the European Union demands that the European countries surveyed map the noise nuisances and act to reduce them – there is no obligation in Israel to map the noise nuisances, and the local authorities are not bound to prepare any plans of action to reduce them.
The examined municipalities did not conduct any spatial mapping of the noise nuisances in their jurisdiction and needless to say they have not learned any lessons as to how to deal with the noise nuisances.
Comptroller Englman recommends that the Ministry of Environmental Protection determine a national policy to deal with noise nuisances, and that the local authorities exhaust the tools at their disposal to reduce and even prevent this wide scope nuisance. The authorities must raise the residents' awareness of the damage that they are liable to incur from the noise nuisances.
The local authorities' handling of the public playgrounds in their jurisdiction
From 2013 to 2023 ten children were killed, and about 14,000 children attended the emergency rooms due to an injury caused in playgrounds. The decisive majority (approximately 81%) were injured following a fall, blow or wound. A survey by the Office of the State Comptroller: Only approximately 55% of the respondents to the residents' opinions survey stated that the playground nearest their home is safe.
From 2013 to 2023 ten children were killed, and about 14,000 children attended the emergency rooms due to an injury caused in playgrounds. The decisive majority (approximately 81%) were injured following a fall, blow or wound. The State Comptroller found that despite the requirement in the Israel standard, five of the six local authorities examined (Hadera, Tiberias, Rehovot, Shefar'am and Ramat Yishai) had not recorded on a detailed form the information about the accidents that had occurred in the playgrounds in their jurisdiction; the local authorities examined had third party insurance, but there are disparities between them, such as the ceiling of the insurance cover.
It transpires from the audit that in Hadera, Rehovot and Shefar'am the number of residents for each public playground is relatively high, 1,322, 1,374 and 4,838 respectively, while in Tiberias the number of residents for every playground is 808, in Ramat Yishai – 738, and in Hof HaCarmel – 553. It further transpired that the number of children for every playground on average in Rehovot and Shefar'am was 358 and 1,146 respectively, while in Hof HaCarmel and Ramat Yishai the number of children for every playground was 147 and 176 respectively. Insofar as the number of children for every playground in a particular area is higher, this is liable to adversely affect their enjoyment and use of the playgrounds and their taking full advantage of the public space. It further transpired from the residents' opinions survey conducted by the Office of the State Comptroller that in Hadera, Rehovot and Ramat Yishai the decisive majority of the respondents stated that the walking time to the nearest playground is less than ten minutes. Contrarily, in Tiberias about one quarter of the respondents (11) stated that it is necessary to walk for more than ten minutes to the playground nearest their home; and in Shefar'am 51% of the respondents (31) stated that there is not even one playground near their home, and that they are required to travel by car to the nearest playground. Only approximately 55% of the respondents to the residents' opinions survey stated that the playground nearest their home is safe.
The Comptroller found that only 37 local authorities out of the 257 authorities have a maintenance permit in their name, as required by the Standards Institution of Israel's Standards Mark Administrative Decision from May 2020. More than 50% of the playgrounds in the jurisdiction of two of the local authorities examined – Shefar'am and Hof HaCarmel – did not have maintenance permits from the Standards Institution of Israel for 2023. In Shefar'am there was no maintenance permit for any playground.
Comptroller Englman recommends that the local authorities examined rectify the defects in the report. The Standardization Commissioner at the Ministry of Economy and Industry must enforce the statutory provisions and the Standards Mark in the field of playground maintenance, and the Standards Institution of Israel must supervise the playgrounds under its supervision, in order to ascertain that they have been adapted to the requirements of the Standards Mark.
The local authorities' contending with the processes of destruction of the coastal cliff – follow-up audit
13 years after the government decision, there is still no agreed upon outline for assisting the local authorities in finding sources of funding for land protection. The Ministry of Interior has no updated estimate of the required land protection costs, and the estimates are considerably higher than the sum budgeted by the state for land protection. In 14 out of 27 land units, no work had been performed for land protection on the cliff at all, even though this is necessary. The Israel Nature and Parks Authority has not completed the protection of the land units of the cliff under its responsibility. The Ashkelon and Herzliya Municipalities have not yet begun to perform land protection on the cliff.
During the past decades, the cliff along the Israeli shoreline has been collapsing and retreating eastward at a pace of dozens of centimeters a year. In 2010 and 2020 the State Comptroller examined the matter of the coastal cliff destruction. In this audit, which is a follow-up audit on the rectification of the main defects that arose in the 2020 audit, it was found that some of the defects from the previous report in the matter had been rectified, some had been partially rectified, and some had not been rectified at all.
Thus, the Ministry of Interior still has no updated estimate of the land protections costs required. Neither has the Ministry of Interior requested since 2019 that the local authorities send it estimates of the expected costs of planning and establishing the land protection.
13 years after the government decision, the government ministries – including the Prime Minister's Office, the Ministry of Environmental Protection and the Ministry of Interior – have still not succeeded in finding a solution for the disputes concerning the responsibility for financing and establishing the land protection, and no assistance mechanism for the local authorities for this purpose has been agreed upon. This is despite the inquiries that were sent in the matter to the Prime Minister's Office by the Coastal Authorities Forum and the Cliff Preservation Company, inquiries that did not receive any response, and discussions that were held in the matter in the Interior and Environmental Protection Committee. An attempt to promote this matter has not yet led to a solution to the question of responsibility for the financing of the land protection.
In 2022, the cost of establishing the required land protection was estimated at NIS 670.5 million. In 2022, the maintenance costs of the entire land protection for ten years were estimated at NIS 300 million, and the costs of maritime protection measures in Stage B have been estimated at NIS 360 million – in addition to the budget of a similar amount fixed for Stage A. The Comptroller found that the state had budgeted only NIS 90 million for the land protection in Stage A.
As of July 2023, four out of the nine local authorities that had received allocations and budgetary authorizations for the promotion of the planning and execution of the land protection as far back as 2019, had not filed any demands for payment at all for the realization of the aforesaid budget. The Tel Aviv-Yafo Municipality and the Emek Hefer Regional Council had realized the entire budget that had been allocated to them. Likewise, the total budget utilized by the nine authorities was approximately 35% (about NIS 21 million) of the budget allocated (NIS 60 million). The Ministry of Interior has updated that as of February 2024 the total budget utilized had increased to 40%.
Since the previous audit, apart from five local authorities, where the partial land or maritime protection required pursuant to the national outline plans was performed, no protection had been performed in the other segments. As of August 2023, in 14 land units out of 27, no land protection had been performed at all, and in one additional land unit partial protection had been performed. Likewise, it transpired that in 10 out of 18 land units no maritime protection had been performed at all, and in one additional land unit partial protection had been performed.
A document prepared for the Cliff Preservation Company in August 2023 shows that as of such date maritime protection had been performed on segments along about only 5 kilometers out of the 13 kilometers where it had been decided that maritime protection should be performed. The failure to perform the protection work in the land units where it had been decided that protection should be performed is liable to endanger human life, cause damage to property and lead to a reduction in the coastal areas and even to the disappearance of some of them.
The Israel Nature and Parks Authority has not completed the protection of the land units of the cliff that are located within its area of responsibility; and the Ashkelon and Herzliya Municipalities have not yet begun the performance of the land protection for the cliff.
Comptroller Englman recommends that the Prime Minister's Office, the Ministries of Interior, Environmental Protection and Finance, and the Israel Lands Authority, promote the deciding parties' proposal which will ensure the continuation of the measures required for the land and maritime protection of the coastal cliff and the budget required therefor. The Office of the State Comptroller further recommends that the Ministry of Environmental Protection and the Cliff Preservation Company examine the need to update the policy for the protection of the cliff in view of the updated scenarios for the increase in the sea level and the potential for damage to the coastal cliff.
Selected issues in the water sector in Samaria – follow-up audit
The water depreciation rates in the authorities examined have dropped in recent years, yet they were still high (12%-15.3%), as opposed to all the local authorities in the country that are unincorporated into water corporations (9.4%). In recent years, the Alfei Menashe, Elkana and Kedumim Local Councils did not conduct surveys to examine the reasons for the water depreciation. The Oranit, Alfei Menashe and Elkana Local Councils still have no information about the age of the water piping and the sections that have not been replaced for many years.
In 2020, the State Comptroller published a report that indicated substantive defects in the provision of municipal services in the field of water to the residents of the local authorities in Samaria. The follow-up audit found that there were defects that had been rectified in full or to a great extent: The water deprecation rates in the authorities examined have dropped in recent years, but they were still high (12%-15.3%), as opposed to all the local authorities in the country that have not been incorporated into water corporations (9.4%); the majority of the water meters in the jurisdictions of the Alfei Menashe, Elkana and Kedumim Local Councils are new; the Oranit, Alfei Menashe and Elkana Local Councils are managing a water rehabilitation fund.
Nevertheless, the Comptroller found that other defects had been rectified to a small extent: The Alfei Menashe and Elkana Local Councils had no master plans for the water sector; the Oranit and Elkana Local Councils issued part of the water charges according to estimates – thus, for example, 30% of the water charges in Oranit from 2020 to 2022 were according to estimates and not according to measurement. There are no central water meters within the jurisdictions of Oranit, Alfei Menashe and Elkana.
The follow-up audit found that there were defects that had not been rectified at all: In the Alfei Menashe, Elkana and Kedumim Local Councils no surveys for examining the reasons for the water depreciation had been conducted. The Oranit, Alfei Menashe and Elkana Local Councils still have no information about the age of the water piping and the sections that have not been replaced for many years; the Kedumim Local Council reported that since the previous audit it has replaced piping in several neighborhoods.
The Comptroller also found that the number of consumers who did not receive discounts in the water payments out of all those eligible during 2022 in all the local authorities, namely about 125,458 consumers, totaled 18%. In the authorities examined, the number of people receiving discounts in the water payments out of all those eligible during 2022 totaled 62%-85%.
Comptroller Englman recommends that the Water Authority and the authorities examined continue to rectify the defects presented in this follow-up report.


