Water-use
licences
Despite the laborious process around obtaining
a water-use licence, once obtained, it is an
opportunity and tool to raise your game..
By Jacky Burke
S
outh African industry is fast
coming to terms with the country’s
water-scarce status and is making
marked shifts in both technology and
culture to become more water-wise;
the application for and compliance to
water-use licences (WULs) should be
embraced as part of these efforts.
It is true that obtaining WULs is seldom
an easy or straightforward process,
and SRK has many years of experience
in working with clients to achieve their
goals in this regard; but there is definite
headway in the form of an online
application system now being put in
place by the Department of Water and
Sanitation (DWS) — with which SRK
is working closely to help facilitate
effective implementation.
Far from being simply an onerous
regulation to be met, the WUL needs
to be recognised as a valuable tool for
professionals to obtain the necessary
internal budget approval for water
management and monitoring at their
operations; the licence also provides
useful benchmarks against which the
operation can assess its performance.
It is worth remembering that water
management is a complex field,
and everyone involved is on a steep
learning curve with the new licensing
system. For this reason, SRK’s Water
Use Licence Application (WULA) Group
in Johannesburg recently brought
together clients, colleagues, and other
professionals in this field to share their
experiences and gain some guidance
from DWS — with the aim of helping
users improve compliance with the
ultimate benefit of protecting the water
resource, while reducing operational
and closure liability costs.
The workshop focused on the
new Electronic Water Use Licence
Application and Authorisation System
(EWULAAS), highlighting the value
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of making the financial and time
investment early in a WUL application
so that costs can be saved later.
Experts also outlined how applications
could benefit from the DWS’s more
streamlined and manageable process
— while also considering where
challenges were being experienced.
There was general agreement on the
fact that EWULAAS is certainly going
to be a great improvement on the old
paper-based system, with advantages
like being able to generate a summary
of water uses per farm prior to phase
one submission — which provides
a check and highlights gaps in the
application. Also, applicants can track
their submissions online to get updates
on administrative progress.
It was also clear that — as with
any new system — there are teething
problems, and SRK is making sure
that it maintains close working links
with DWS to give input that can help
the system work optimally. EWULAAS
gives confidence that all the submitted
information is safely stored, and that
the process can be tracked; as users
we also have a constructive role to play
in fine-tuning the human element of the
system, so that everyone keeps to their
deadlines.
The system is essentially user-friendly
and follows a logical flow process in
three key steps: a first, pre-application
phase; a second phase in which
supporting documents and water-use
forms are submitted online; and a third
phase where a technical report and
additional specialist information are
uploaded for DWS decision-making.
For a WUL applicant to gain the full
benefit of what the process demands
of them, however, we advise clients
to take a proactive approach towards
ensuring compliance — which can be
practically applied using EWULAAS
Water Sewage & Effluent May/June 2018
while providing operational systems
that can be easily managed and tracked
in-house.
Among our interventions with clients
is to assist them with the development
of a Licence Implementation Plan (LIP),
which can range from a simple Excel
system to a SMART tool that helps
distinguish monitoring requirements,
all deliverables, and measures to
address auditable conditions. A LIP
also records the commitments and
recommendations contained in WULA
documents that may be referenced in
WUL deliverables; this is important in
terms of risk management, as these
commitments are legally binding.
The plan then contains the clarity
required to gain management approval,
a budget, and an implementation
schedule that details timeframes
and responsibilities. In terms of a
quantitative contribution, the LIP makes
it easier to submit required data to DWS