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Using good governance, stewardship to ensure water security

Using good governance,

stewardship to ensure water security

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Major water users can adopt a globally applicable framework to understand their own water use and impacts

As South Africa confronts reality as a water-scarce country, more is being demanded of water users by the authorities. Water users face the challenge of ensuring water security in the face of changing requirements and expectations. By Giulia Barr

The answer lies beyond compliance, in an approach that embraces good governance of water resources not only on-site but in the broader catchment.

Recent regulatory changes have seen the Department of Water and Sanitation taking steps to reduce the 300-day period for processing water-use licences (WULs) to just 90 days. This has been welcomed by water users as a valuable contribution to speeding up the planning and implementation of projects. At the same time, though, we have seen that there are often further requirements specified by the regulator – such as additional technical studies. Many of these studies highlight the potential impact of the project site on water resources – and vice versa – but some may not be applicable to the conditions pertaining to the site. They may not even be applicable to the requirements in the National Water Act (No. 36 of 1998). It is seemingly becoming more difficult for sites to successfully apply for a WUL, or to fully comply with the licence once it has been issued, as a result of the continual increase in studies. The cost and time involved in conducting such studies therefore deserve further consideration, as these may be deterring sites from obtaining or fully implementing their WULs.

Stewardship

The responsible route to water security in a water-constrained system is to avoid the ‘tick-box approach’ and rather to embrace water stewardship as a strategic principle. The regulations must, of course, cater for every type of site and eventuality, but not all these requirements will be relevant to every site.

While a large, complex site might require five studies to cover the vital aspects of its WUL, a smaller site with less complexity may be able to accomplish this goal with one integrated study. There may also be very specific risks associated with a particular site, which are not covered by the standard, generalised conditions – and which could thus be overlooked, to the detriment of the environment.

A stewardship approach begins with understanding the particulars of each site and goes on to investigate the catchment in which it is located and its stakeholders. This avoids the danger of being awarded a WUL based on standard conditions that may be difficult to meet, or do not apply to the site itself. Officials may even be unable to later change the terms of the licence when it comes to the standard conditions, during a licence amendment application process. Remember that a business’s compliance to the WUL conditions must be internally and externally audited each year, so the requirements must be suited to the site or they could become overly onerous and impossible to fully comply with.

Action plan Among the useful strategies we have applied in our interaction with clients is a WUL implementation plan, where we

Giulia Barr, senior environmental scientist, SRK Consulting

extract the deliverables from the licence conditions. This could be described as a form of action plan – a living document that is continually adapted over time. Timeframes are identified for each of the deliverables to be submitted to the Department of Water and Sanitation, and these are assessed in terms of time and cost. Where it is not realistic to meet the required deadlines, a motivation is prepared and presented to departmental officials. We have found that there is a willingness by the department to consider alternatives as long as the client can demonstrate their intention to comply.

This is particularly useful for water users with limited resources, who may not have a dedicated environmental manager, for instance. The implementation plan also sets out a clear framework for what needs to be done, by whom and by when. Tasks would generally include surface water and groundwater quality monitoring, stormwater management plans, hydrogeology studies and the annual water balance.

As a practical intervention, such a plan goes some way towards the next strategic goal – which is to understand more clearly the water-related risks that the site may be facing. Too often, the adherence to a WUL is not accompanied by a broader appreciation of how the compliance conditions may reflect real risks to the sustainability of the business. Water risks A water stewardship approach can help to achieve this. To fully understand water risks, site management and staff need insight into the catchments in which they operate. Economic growth and urbanisation are among the factors raising water consumption levels, and this trend will inevitably create more competition for water. Being better stewards of water resources means communicating and collaborating with other stakeholders within the catchment – as water security for the business cannot be sustainably achieved if it excludes other users.

Water stewardship does not place the onus on any individual water user to gather information or ensure water management by other users; rather, it gives insight into the water status of the catchment. This helps users understand their site’s impact on surrounding water resources and can also mitigate the possibility of over-allocations in the catchment’s WULs.

The water stewardship approach is not completely new, having been incorporated in certain studies such as the Integrated Water and Waste Management Plan (IWWMP) – which includes catchment information, water quality, water balance and other studies. There is exciting potential to include water stewardship training in the workshops where we present the draft IWWMP. This will assist the client to fully understand the importance of water management at the site, the site’s impact on the catchment, and the potential impacts from neighbouring sites on the shared water resources within the catchment.

It is significant that the IWWMP be a standard condition of a WUL and an annual deliverable in terms of compliance. Its value can be well leveraged as a focus for the business to consider internal and external factors related to water, while raising the awareness of all employees about water stewardship.

Credentials To strengthen the expertise of SRK in this regard, a number of water specialists in the network have attended the Standard System training courses designed and conducted by the Alliance for Water Stewardship (AWS). By joining the AWS Professional Credentialing Programme, we are part of an international organisation of water stewardship professionals across industry sectors. In this position, we ensure credibility in the dissemination and adoption of water stewardship knowledge and expertise.

In turn, major water users can adopt a globally applicable framework to understand their own water use and impacts, and to work collaboratively and transparently with others for sustainable water management within the wider water catchment context. More systematic governance can therefore reduce water-related risk and lead to better water security.

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