Water, Sewage & Effluent May-June 2018 | Page 28

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 26 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