1. Review of National Water Act BUSA submission to Portfolio Committee on Water and Forestry 22 October 2008

2. BUSA represents South African business on strategic issues at a national and international levelrepresents South African business on strategic issues at a national and international level ensures business plays a constructive role in South Africa’s economic growth and transformationensures business plays a constructive role in South Africa’s economic growth and transformation water resources must make a meaningful contribution to economic and social development imperativeswater resources must make a meaningful contribution to economic and social development imperatives

3. welcome opportunity to comment on NWA appreciate openness by the DWAF to engage with business: – –water for growth and sustainable development (WfGD) strategy development – –national water summit – –Water Sector Leadership Group (WSLG) – – business involved in various steering committees and ad-hoc activities review of National Water Act

4. water - a global challenge requiring local solutions the world has some serious water problems: – –growing demand, competition and backlog in basic water and sanitation services – –water pollution and ecosystem deterioration and climate change concerns – –inequitable benefit sharing

5. example - getting the Vaal system into sustainable balance will require various interventions: treating and re-using “excess” return flows (to particularly support future industrial growth)treating and re-using “excess” return flows (to particularly support future industrial growth) implementing water quality management measuresimplementing water quality management measures preparing for future augmentationpreparing for future augmentation implementing water conservation/ water demand management (WC/WDM) with a focus on loss management measures at mostly municipalitiesimplementing water conservation/ water demand management (WC/WDM) with a focus on loss management measures at mostly municipalities curbing unlawful water usecurbing unlawful water use

6. the NWA: management of water resources is an exclusive national competencymanagement of water resources is an exclusive national competency –critical to separate regulation/ enforcement from support and advisory work –the different roles of national, provincial and local government not always clearly defined the essence of water resource management lies with the establishment of CMA’sthe essence of water resource management lies with the establishment of CMA’s

7. challenges with the NWA striking the balance between water use and water resource protection – –ensure the right mix between economic growth, social equity and environmental sustainability controlling water use through regulation – –efficient and effective licensing planning, pricing and implementation of water resource infrastructure – –avoiding a similar situation to the current electricity supply crisis

8. water use - licensing support the registration and formal authorisation of water use it’s a difficult process – –long delays in issuing of licenses – –onerous and impractical license conditions – –lack of uniformity in licensing requirements (section 21) – –differing approaches to general authorisations capacity constraints contribute to delays

9. way forward - licensing there are various ways to streamline the license application process and to provide clarity and certainty – –stipulate an agreed time frame within which each phase of a water use license application needs to be finalised – –ensure uniformity amongst all regions as to the requirements and procedures for general authorisations – –place a greater emphasis on the verification of water use – –harmonize requirements with EIA process

10. catchment management agencies (CMA’s) can CMA’s really be functioning by 2018? – –CMA’s generally not functioning as intended by the Act – –don’t support reducing the number of Water Management Areas without good reason and consultation – –revisit CMA’s which includes undertaking a cost benefit analysis

11. Infrastructure and funding welcome efforts to improve infrastructure asset register water tariff increases have mostly been above inflation the past years – –longer term water pricing projections needs to be developed and shared with stakeholders complicated merger of DWAF water infrastructure branch with TCTA to establish NWRIA waste discharge charge system remains controversial

12. concluding remarks urge department to finalise WfGD strategy and commence revising the National Water Resources Strategy (due 2009) undertake an independent review of the implementation of the act – –Identify more streamlined and cost effective approaches to implementation require workable regulations that provide clarity and certainty – –water resource classification, water pricing, water allocation, etc.