Civil Society comments updated:

October 2004


In our fledgling democracy, the Dept of Water Affairs is to be commended in general for the policies and legislation it has put in place, and for creative and strategic implementation programmes which have been initiated.

In the National Water Resources Strategy, again, we see considered efforts to integrate various aspects of Water Resource Management. As civil society, we would like commend the Department, in this first edition NWRS, for its acknowledgement of water demand management and for its inclusion of groundwater and wetlands. It is also clear that some thinking has been put into pollution controls and the emphasis on emerging farmers, the acknowledgement of the need for productive livelihoods in rural areas particularly is applauded.

However, in 2003, civil society brought representatives from various civil society groupings together in order to meaningfully input into the NWRS.

In 2003, we raised serious concerns with some aspects of the strategy and provided approximately 20 pages of detailed commentary. We attach the same detailed commentary and express our profound disquiet that in the main, the views of civil society have been ignored.

In order to assist decision-makers, we have compiled a summary list of the highest priorities which the NWRS has failed to address:

  1. Short term emphasis
  2. NWRS focus on 2025 planning horizon. Longer term planning - 100years needs to take into account functional life of existing dams.

  3. Human needs reserve understated
  4. World Health Organisation states 50 litres per person per day. NWRS only allows for 25 litres per day. Future projects of availability of water based on flawed human needs.

  5. Related international processes ignored
  6. No meaningful integration of SA World Commission on Dams process. No reparations process, Little emphasis on comprehensive options assessment, Little mention of SADC water sector (Global water Partnership), Africa Water Task Force (AMCOW).

  7. Ecological reserve?
  8. Mixed messages within NWRS. Phased in approach undermines value of ecological reserve. Reserve is sacrosanct but other strategic uses can be authorized.


  9. Reliance on Inter Basin Transfer
  10. No comprehension of ecological damage of IBT. IBT used to lull decision-makers into false sense of water security.

  11. Failure to prioritise Water Demand Management
  12. Nearly 2 years after first draft of NWRS, no further development of demand side strategies. No resources/capacity for monitoring. Not priority - continual emphasis on meeting an ever increasing supply.

  13. Dam building bias
  14. NWRS entire emphasis on building more dams and use of IBT to move water, rather than applying water conservation measures to use water sustainably.

  15. Outsourcing of DWAF functions

Concerns regarding water pricing and dam safety. Water as absolute right not subject to ability to pay. Concern that Water management being privatized

In conclusion, the lack of public participation in the drafting of this NWRS undermines the policies and legislation of the very same Dept.

It was our expectation that these key issues would have been addressed in the second version of the NWRS entitled "NWRS first edition, September 2004". It is of grave concern that our concerns have been minimally addressed by the drafters. It further raises doubts and misgivings regarding the role of civil society and the importance given to civil society inputs.

We therefore appeal to parliament to hear us and to ensure that our concerns are addressed. The failure to do so undermines the very laws that the DWAF has put in place supposedly to encourage public participation and cooperation.


Contact: Liz McDaid

c/o Lianne Greef

Environmental Monitoring Group

Tel: 021-4482881

Cell: 082 731 5643