15 OCTOBER 2012

Ms Tyhileka Madubela

Committee Section,

Parliament of RSA

Dear Ms Madubela

National Water Resource Strategy [NWRS-2]: Managing water for an equitable and sustainable future

Please note that owing to time constraints this submission borrows heavily from the one prepared by Victor Munnik on behalf of the South African water Caucus.

WESSA South Africa’s oldest and largest membership based environmental organisation, operating across all regions of South Africa, and our mission is to promote public participation in caring for the earth.

In response to the National Water Resource Strategy [NWRS-2]: Managing water for an equitable and sustainable future, WESSA would like to make the following comments:

We acknowledge the department’s shift of thinking from the NWRS-1 which set out a ‘blueprint’ for water resource management in South Africa for the first time, whilst this document aims to set-out a ‘strategic direction for water resource management in the country for the next 20 years, with a particular focus on priorities and objectives for the period 2013-2017’.

WESSA also acknowledges the fundamental shift in thinking from a centralised democratic state approach to a developmental democratic state with all the ramifications that that brings. Please note the specific points raised in the following bullets:

  • The new NWRS2 framework is expressly pro-poor, and in favour of civil society participation, especially with an emphasis on marginalised communities. It is important that these good intentions carry through into the technical strategies. Examples are water conservation, demand management and allocation of water resources to ensure that interventions are genuinely and constructively pro-poor as well as participatory.
  • It is regrettable that the reduction in the number of catchment management areas and agencies places them even further from ordinary people. Thus we need to ensure that the catchment forums have teeth in terms of regulation and that these are inviting and accessible spaces for civil society to work in.
  • Job creation is a priority within the scope of this Strategy, but it’s imperative that highly focussed and professional capacity building with regards to those jobs is done.
  • The issue of Climate change and the national response to this challenging phenomenon has not been dealt with in enough a detail
  • The links between the strategy and proposed implementation of the S.A. version of the green economy should be more explicit owing to the cross-cutting relevance of water in all sectors..
  • While the role of civil society is acknowledged, in practice there is more engagement foreseen with the big water users in the SA Strategic Water Partners Network. Caution must be exercised in whose interests are most attended to.
  • Change in the way DWA officials do their work is also seen as necessary, so that they will do their duties with integrity, transparency, energy and commitment.

The 10 core strategies are dealt with in more detail below:

  1. Water policy in a democratic developmental state

Putting water at the centre of integrated development planning and decision making

This is a core strategy which necessitates the sector, under DWA leadership, communicating water priorities to the planners in all other sectors. The strategy document makes a start by relating water issues to current planning frameworks including National Spatial Development Perspective, National Planning Commission, New Growth Plan (paying special attention to jobs), the 12 national outcomes concerning 5 priority areas (decent work and sustainable livelihoods, education, health, rural development, food security and land reform, and the fight against crime and corruption), Industrial Policy Action Plan2, Rural Development Strategy, National Biodiversity Management Strategy, Irrigation Strategy, National Energy Efficiency Strategy, Tourism Strategy, Mineral Beneficiation Strategy. The implication is that the priorities of all these strategies should include deliberate undertaking to involve people in better overall decision-making processes so that more can share the benefits and responsibilities regarding water and its pervasive influence in all human activities. This must emphasise the need to align growth aspirations with natural constraints such as water availability.

  1. Ensuring water for equitable growth and development

Supporting growth includes intergovernmental co-operation, better monitoring and data collection, water use planning, stretching water resources (a recurring theme pointing to the need for recycling water, desalination, conservation and demand management), improved efficiencies in water user licensing, establishing functional and society-representative Catchment Management Agencies and the necessity for an economy embedded in a functioning ecological system. Unfortunately we cannot balance a finite amount of water with an ever growing economy unless a large proportion of this shifts non-consumptive growth. Implementing this core strategy will have to include:

  1. Combating the negative mining legacies like acid mine drainage and avoiding future impacts
  2. Regaining public credibility around the establishment of CMAs and supporting capacity building and participation.
  3. Linking sustainability and clean energy technologies to stretching water resources and redressing social injustices of the past.
  4. Emphasising water conservation measures such as rainwater harvesting practices and more efficient irrigation systems
  1. Contributing to a just and equitable South Africa

Meeting basic needs, creating jobs, and empowering citizens in water governance are all good objectives as are some specific actions like improving bulk infrastructure, implementing this core strategy should include intentions to:

  1. Align integrated planning by local government, DWA, Agriculture and other departments
  2. Land reform that leads to job creation and livelihoods built around access to water.
  3. Involve civil society in interrogating who bulk infrastructure is built for, what form it takes and how responsibly water is used by different role players
  1. Protecting water ecosystems

We fully endorse this section that deals with water quality (including acid mine drainage and failing waste water works), overuse of ground water, alien plants, habitat destruction, destructive coastal developments, catchment care, the determination of ecological reserves, catchment management strategies, freshwater ecosystem priorities, better monitoring and compliance, stronger water quality institutions and monitoring, better compliance enforcement. Keys to success in this aspect of the strategy are:

  1. Effectively dealing with acid mine drainage
  2. Very careful review of all activities such as proposed hydraulic fracturing in terms of water resource impact before the green light is given for them to proceed.
  3. Massively improving the hundreds of failing municipal wastewater works.
  4. Comprehensive assessments and pilot implementation of dry composting technologies that could be harnessed at all levels of society to reduce pressure on water resources and reuse nutrients beneficially
  5. Empowering local citizens to help with monitoring and compliance around water quality and legal use.
  6. The protection of water for eco-systems so that the rightful place of biodiversity in rendering ecosystem services is properly acknowledged and included in decision making.
  1. Implementing water use efficiency, conservation and demand management

This core strategy emphasises the need for water conservation and demand strategies. The strategy foresees water savings in commercial agriculture to be reallocated to emerging and household farmers, including women. This will necessitate:

  1. Civil society participation in the design, implementation and monitoring of water conservation and demand strategies to ensure that pro-poor demand management takes place with penalty tariffs escalating indefinitely to discourage high-end wastage.
  2. Support allocation of productive water especially to rural communities and rural women and urban subsistence initiatives.
  3. Resources for training in subsistence farming, access to mulching and local storage
  4. Training in basic plumbing and leak fixing as part of the general curriculum
  1. Optimising and stretching our water resources

It is commendable that there is a clear signal that South Africa is operating at the limit of our water resources availability by covering the implications of use of groundwater, reuse of dirty water and desalination but the following must be attended to in achieving the desired outcomes by:

  1. Adopting a precautionary approach to the exploitation of “new water“ resources.
  2. Ensuring that the respectful use of current water resources is accompanied by enhanced compliance work with informed buy-in going right down to street level.
  1. Achieving effective and smarter water governance

A key objective of the NWRS, the sector-wide approach under DWA leadership with multi stakeholders is an important topic for the strengthening of institutions like water boards and interdepartmental co-operation. It will have to reverse a few current trends and:

  1. Ensure that civil society is ready and able to support people’s participation in creating catchment management structures and catchment management strategies over a broad front in the CMA roll-out.
  2. Deliberately re-assert authority when it comes to the expectations and use (and abuse) of water by other government departments
  3. Fore ground responsibility and accountability for all water users.
  1. Embedding sustainable business principles and practices

It is fitting that there is scrutiny of the water value chain from source to tap and back as this will help inform the implementation of the whole strategy including life cycle planning, asset management, operations and maintenance, ring-fencing of water revenue and investment in skills. Success here will depend on inter alia:

  1. how costs are allocated across the water value chain how water is priced especially when expensive technologies are introduced
  2. the ring-fencing of water revenue including the question of ring-fencing the Equitable Share from treasury which currently can be spent by local governments on items that are not basic services
  3. Considering an equitable share for non-human species living outside of the money economy.
  4. Addressing backlogs and loss of services owing to insufficient maintenance
  5. Elevating infrastructure maintenance to a high priority
  1. Implementing a water sector investment framework

The fact that this has been initiated already is evidence of its importance but

  1. Since budgets are the most sincere form of communication, civil society needs to be able to track these by having them put in layman’s language.
  2. The matter of non-revenue water even where this far exceeds basic free water allocation will have to be sorted out before it leads to a pattern of unsustainable water use.
  3. Pragmatic and realistic amounts have to be allocated to particular priority tasks like solving the Acid Mine Drainage problem so that objectives can be reached.
  1. Engage the private sector

The UN CEO Water Mandate and the SA Strategic Water Partners Network have established themselves as close partners of government, as advisers and are well placed to secure their interests in terms of raw water requirements, and water quality regulation. In order for this engagement not to conflict with the democratic intentions and language of the NWRS:

  1. Civil society must have a clear understanding of the partnership and be able to share in the information and decision making.
  2. There will need to be a comprehensive explanation of other countries’ experiences of the UN CEO Water Mandate and strategic partners’ networks which consist of big water users in close communication with government decision makers.

Yours faithfully

Pp Garth Barnes (Conservation Director)