National Water Resources Strategy draft August 2002






Civil Society comments for input into parliamentary hearings of October 2004. Please note that this input is the exact input submitted in January 2003.






October 2004



1. What is the National Water Resources Strategy?

2. Why is it important?

3. Does the NWRS further the agenda of poverty eradication and ecological sustainability?

3.1 Chapter 1: Water Policy, Law and Resource Management

3.2 Chapter 2: South Africa's water situation and strategies to balance supply and demand.

3.2.1 Section 2.4 water requirements.

3.2.2 The human need reserve:

3.2.3 Alternatives to increasing the supply:

3.2.4 The Ecological reserve:

3.3 Chapter 3: Strategies for Water Resource Management

3.3.1 part 1: Protection of Resources

3.3.2 Public participation:

3.3.3 Compulsory licensing

3.3.4 Further comments:

3.4 Chapter 4: Water pricing and financial assistance

3.4.1 Catchment Management Areas (CMA's):

3.4.2 Forums:

3.4.3 Privatisation of water infrastructure development - section

3.4.4 Pg. 86: section monitoring institutional performance

3.4.5 Part 6: monitoring and information:

3.4.6 public safety- Chapter 3, part 7

3.4.7 Programme of implementation section 3.8

3.4.8 Financial implications section 3.9:

3.5 Chapter 4: Complementary Strategies

3.6 Chapter 5: National Planning and co-ordination, and international co-operation in water management.

4. Conclusion:

Sections in italics indicate where DWAF has addressed our concerns at least in part

  1. What is the National Water Resources Strategy?
  2. In 1997, the National Water Policy was adopted by cabinet. This policy set out guidelines for ensuring that South Africa's water resources be managed in such a way as to achieve long term sustainability.

    The National Water Act of 1998 deals with the management of water resources. Its purpose is to ensure that there will be water for basic human needs and environmental sustainability. The National Water Act states that a national water resource strategy must be established but that it may be phased in and in separate components over time.

    The National Water Resources Strategy will provide the framework within which water resources will be managed everywhere in the country. It will cover the proper management of water resources, the classification of water resources, the provision for the reserve for basic human needs and for the ecological sustainability of the various water resources. It will also assist with the establishment of catchment management agencies.


  3. Why is it important?
  4. The National Water Act (NWA) states that there a National Water Resources Strategy (NWRS) must be established. The strategy is legally binding and anyone exercising any power within the NWA must do so according to the NWRS.

    The NWRS gives effect to the NWA and should direct the way in which our water resources are managed into the future. It is therefore important that there is a good quality strategy and reflects the needs of the majority of South Africans.


  5. Does the NWRS further the agenda of poverty eradication and ecological sustainability?

The new Water policy, national Water Act and the NWRS should ensure that the way in which water is distributed and used brings maximum benefit to all South Africans.

If we look at the National Water Policy, there are 28 fundamental principles which were approved by cabinet. These principles include:

These principles are given legal weight through the National Water Act (NWA) and through the National Environmental Management Act (NEMA).

Civil Society's vision for water resource management is based on the principles outlined above. In order to assist the reader, we provide a brief contextual statement at the beginning of each chapter.


    1. Chapter 1: Water Policy, Law and Resource Management
    2. Civil Society position:

      We believe that our legal rights and responsibilities derive from the Constitution, RDP and various laws enacted since 1994, as well as international norms and standards such as the World Commission on Dams (WCD) findings. Our position is that the NWRS must seek to build on the current legal instruments and not undermine them through lack of vision or negligence.

      Access to water is a fundamental human right. We would like to emphasise NEMA principle " ...all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured.." This principle must be applied to the NWRS. We do not feel that adequate attention has been paid to consultation and we are concerned that those communities who are most affected by the NWRS have not had an opportunity to comment.

      Detailed comments:

      We support the department of Water Affairs and Forestry (DWAF) in their identification of the principles of equity, sustainability and efficiency as the pillars of the NWRS, in particular their acknowledgement that women bear the burden of inequities of the system.

      However the sustainability definition on pg. 2 is a little unclear and we recommend that the paragraph is rewritten to present the internationally agreed view of environmental sustainability, which promotes human development within the limits of ecological systems and which ensure that future generations will have similar development options.

      On Page 3 , the minister states that South Africa has sufficient water to meet its needs. However, he then goes on to say that 11 out of 19 water management areas were facing a water deficit. These statements appear to contradict each other.

      The minister then lists the tools to address such deficits and includes water demand management and development of infrastructure such as storage dams and inter-basin transfers. While acknowledging that efficient use of water must be improved, the vast bulk of the NWRS focuses on the development of infrastructure.

      Page 4 speaks about the importance of protecting the ecosystems of South Africa but throughout the NWRS, little understanding is expressed of the devastating ecological impacts of tampering with the healthy river by transferring large quantities of water into or out of it. Our perception is that there seems to be little understanding of ecological systems - that generally if left to their own devices, each system is unique and in balance and should not exploited to the point where there is only the bare minimum of water left. Pages 12,16, and 37 all contain references to the transfer of water from one catchment area to another with no mention of the negative environmental impacts.


    3. Chapter 2: South Africa's water situation and strategies to balance supply and demand.

Civil Society position:

Civil Society acknowledges that there must be limits to growth. We do not support the current export led economic growth model as we believe that it is socially and environmental not sustainable. There is a finite amount of water available to South Africa to meet all needs. This water must be used for the public good and the ownership and management thereof must stay in public hands. Development options should be prioritised according to the most productive benefit per unit of water (efficiency), rather than the profit motive.

We support the concept of a reserve for human need and ecological functioning with the following reservations:

Detailed comments:

This critical chapter should provide options for meeting our future water needs. While considerable efforts have gone into identifying increasing supplies of water, little is said of water demand management. This chapter contains detailed data of the future water needs for South Africa and how to meet them. But the entire chapter is biased towards the supply side. There are no tables highlighting the scenarios for future water use taking into account the application of water demand management measures. There are no scenarios which see increasing efficiency of use and resulting impacts on the water requirements for the future. We recommend that such scenarios by developed as part of the NWRS.

The NWRS is disappointing in that it takes a 25 year view, an extremely short-sighted one from an ecological viewpoint. A longer term scenario should be included that incorporates the implications of the finite lifespan of dams; financial, ecological as well as the need to develop alternative options.

During a dam's productive life, provision should be made for decommissioning of dams.

Pg. 16 raises the problematic attitude of the NWRS towards water as a national asset. While acknowledging that a national asset is held in public trust for the benefit of all people, the NWRS adds a strange twist - that a national asset implies that it can be transferred all over the country. The NWRS commends itself for such an attitude, remaining blind to the ecological damage of such a policy. We find that the definition of national asset as something than can be transported to where it is needed is problematic and recommend that the NWRS adopt the more usual definition (an improved version is given on page 38).

Page 17 proposes a general expectation of increasing industrialisation and urbanisation for the foreseeable future. It appears to support a development model which focuses on capital investment in large infrastructure and relies on increasing heavy industry (mostly export led). The SA civil society water caucus (referred to as the water caucus in the remainder of this document) does not regard such a definition as sustainable in the long term and has accordingly also rejected NEPAD as an unsustainable development model for Africa.

The NWRS fails to take into consideration that there is a finite amount of water in South Africa and that a NWRS should plan for a situation where there is long term sustainable use of water i.e. the water requirements of the country must reach a stable state beyond which they cannot increase ever. Paragraph 4 suggests that the NWRS focus is to provide whatever amount of water is needed, and to continue to do so forever. However, within water supply strategies, we would like to see the narrow focus on large dams broadened.

The NWRS should contain reference to alternative supply options and projections of water quantities which could be gained as well as water savings from such sources as water recycling and rainwater harvesting. The introduction of greywater systems should also be outlined.

Page 20 states that 5 600 million cubic metres per year can be made available which will meet projected water requirements for the next 25 years. This figure is arrived by increasing the supply of water through increasing IBT's and the construction of storage dams. While this might be the dreams of engineers and financial institutions, it is the nightmare of local communities (who will have to foot the bill through water charges, and will be moved to make way for the dams, or will find a decrease in their available water downstream of the dam) and environmentalists (the large scale interference with all river systems in the country will have devastating consequences for the ecosystem).

Further the WCD sets out seven strategic priorities as part of the decision-making process around new dams. It is noted that these strategic priorities are not mentioned in the NWRS and the water supply strategy outlined in the NWRS appears to largely ignore strategic outcomes such as:

The NWRS is very positive on the government's international responsibilities but we would strongly recommend that the NWRS contain a section on how the international responsibilities and recommendations from the WCD are to be integrated into the NWRS. For example, page 32 explicitly refers to the " ...substantial potential for resource development, principally through the construction of new storage dams ...".

this is despite the WCD finding that "increasing the effectiveness and sustainability of existing water, irrigation, and energy systems are given priority" in any decision about whether to build a dam or not.

We do not support the building of more large dams but would emphasise a comprehensive options assessment, and further recommend that the focus should be on maximising existing infrastructure. This emphasis should be reflected in the document.

It is worth noting that few if any examples are available of thorough options assessment being undertaken in South Africa. This has been realised in the preparations for the Dams and Development project of UNEP (DDP) forth-coming workshop to be held in May 2003.

Another critical issue concerns reparations. Reparations for existing dams has emerged as a key issue from the WCD, particularly with respect to loss of land, loss of homes and loss of graves. We appreciate the token gesture of the memorial but there is a need to address reparations linked to sustainable livelihoods in depth.

There are about 600 large dams in South Africa. Communities such as Gariep and Inanda have been waiting 40 years and 17 years respectively for reparations.

We strongly recommend that the NWRS prioritise a process of reparations for existing dams, and that DWAF links to the reparations multi-stakeholder task team. Refer to the report - Southern African hearings for communities affected by large dams.

      1. Section 2.4 water requirements.

Again an overall comment that throughout this section there is no assessment of how inefficient the current use of water is except some broad statements about agricultural irrigation on page 25. While it might be possible to compare profits gained from industry, mining and export driven agriculture, it is not possible to compare them with the water use for subsistence agriculture which feeds families but does not directly impact on GDP.

Emerging farmers are also to obtain subsidies to enable them to use water for irrigated agriculture. There is no scenario of how water use might be reduced or how the resulting savings might impact on the future need for dams. Page 28 states that no adjustments were made for reflecting the impacts of increasing water efficiency but fails to provide an explanation for such a fatal flaw.

Each sector should have its own water conservation strategy with a timeframe for implementation. We give some illustrative examples:


      1. The human need reserve:
      2. The NWRS sets a compulsory reserve aside for the meeting of basic human needs. These figures are included in the calculations of water requirements for the future. However, the figure allowed by the NWRS is 25 litres per person per day, significantly less that the WHO basic recommendation of 50 litres per person per day.

        Accordingly, we would like to see the Appendix D scenarios revised to reflect the WHO standards. These revisions will have particular impact on the Crocodile West and Marico rivers where the NWRS predicts a large increase in water use due to domestic requirements of an increased population.

        pg. 39 maintains that irrigation is of no importance to national food security or food sufficiency. It appears that little attention has been paid to the millions of people who rely on agriculture for subsistence and livelihood. Some quantification and use of appropriate expertise would no doubt find that access to irrigation would greatly improve these people's quality of life. Those affected would most likely be rural women - a group which the NWRS names as a specific target. The Water Caucus position is that communities are entitled to water for productive use to sustain their livelihoods.

        The productive use of water should be aimed at household security. The productive use must be non-polluting and effective and efficient

        The productive use of water strategy should link to other government urban and rural strategies as well as de-urbanisation strategies.


      3. Alternatives to increasing the supply:

Page 37 contains a whole paragraph on water demand management. Although it provides some data for a 10% water savings, it fails to elaborate how this could achieved or the detailed implications for each water management area. There is not even an accompanying table. This is one of the most striking examples of the less than objective approach that we perceive that the NWRS has unfortunately adopted

Similarly page 38 contains reference to the re-use of water but while acknowledging that return flows will have qualitative impacts on the WMA's, this is not quantified. Mention is made of the increased costs of treating such returns but no detail is provided.

Pg. 42 mentions afforestation as one of the stream reduction activities. However, the NWRS fails to quantify the impact of commercial forestry plantations on the water resource. We support the submission of the South African Water Crisis Network, and in particular would reiterate the following points:

Pg. 42 provides information of a forecast of a 10% reduction in streamflow over the next 12 years due to climate change but fails to provide any tables of scenarios reflecting this. The precautionary principle as outlined in NEMA should be applied here.

It is extremely difficult to assess the costs and benefits of water conservation measures against the proposed construction of new dams without relevant comparative data. For illustrative purposes, we include Appendix A, a "back of the envelope" calculation of the impacts of a 12% savings in water use. It is interesting to note that the deficit situation overall changes from one in which 11 out of 19 WMA are in deficit to one in which only 5 are in deficit. A couple of case studies are unpacked for illustration.

The Olifants/Doring river example:

Using Appendix D 17 figures as the base data. Refer also to appendix A of this document. The total available yield (2000 level) is 335 units. According to D.17, the water requirements are greater than the current yield and the balance is -35. The maximum requirements calculated for the worst case scenario in 2025 is 380 units. This makes no allowance for any water savings. DWAF uses this figure as justification for both the raising of the Clanwilliam dam wall and the construction of a dam on the Doring River in the near future. The Doring river is regarded as of high ecological value yet DWAF still propose to dam it.

However, as appendix A shows, a 12% savings of water in the worst case scenario of 2025 results in a positive balance of 4. (A 12% savings over 25 years is an extremely conservative figure). This assumes no increase in the year 2000 yield and nullifies the justification for the construction of any dams for the next 22 years. This would result in a capital saving of over R800 million.(according to the NWRS table on pg. 114.

A small refinement is that the IBT from the Breede river (3 units) could be stopped and there would still be a positive balance in the WMA in 2025.

The Crocodile West/Marico example:

The yield of this river is only 693 units (year 2000) but the current requirements are 1328 and the future worst case scenario for 2025 is 2144 units. The reason for this increase is given as the rise in water requirements for the urban needs of the increasing population of Pretoria/Johannesburg. Even with a 12% savings in water requirements, the 2025 requirements are still 1887. This is a river in dire trouble.

However, according to the NWRS, in 2025, under the worst case scenario, the balance in the Crocodile WMA will be positive 170 units. How do they do this?

The Crocodile river receives almost half its current yield through IBT indirectly from the Lesotho water Highlands Project (LWHP). The Upper Vaal acting as a pipe, receiving water from the LWHP as well as the Thukela WMA, and then pumping over into the crocodile (sometimes indirectly).

According to DWAF, to find the water from the LWHP and the Thukela, they assume the building of the Mohale dam and the construction of a further 3 dams on the Thukela catchment. The impact of this is that the Thukela WMA loses 70% of its water (yield) to provide for the Pretora/Johburg citizens' water needs. The river is given as having a deficit as a result and this would imply that no further abstraction of this resource can occur for the benefit of riparian communities along the Thukela river.

Obviously water demand measures are critical and there is an urgent need for action-orientated strategies to reduce water requirements particularly in urban areas such as Gauteng.. However, the manipulation of figures to reflect a positive balance for the Crocodile WMA in the NWRS allays any alarms that concerned decision-makers may have and reinforces a belief that further water inefficient practices are okay as there is no crisis at the moment!


      1. The Ecological reserve:

Section 2.7 recognises the reserve. We believe that the compulsory implementation of an ecological reserve is an important step towards achieving sustainable use of water resources, bearing in mind our concerns raised under 3.2 of this document regarding the extraction of any water on the functioning of the river and the need for some rivers to be conserved in a pristine state.

However, according to the NWRS the ecological reserve is provisional until such time that DWAF has sufficient resources to provide a more precise measurement. While this is understandable, we feel that the implementation of an accurate reserve is of vital/primary importance and should receive the highest priority in terms of budget and capacity allocation. We would like to see the budgetary estimate in chapter 3, part 9 and the timetable for implementation (chapter 3, part 8) reflect this.

Concerns have also been raised regarding the seemingly arbitrary nature of the interim 20%, with a proposed lower and upper boundary of 12 and 30 percent respectively. Dryland rivers are particularly sensitive and many would not function with a 12% ecological reserve. We must emphasise that each river is unique and it is extremely important that accurate scientific information inform the management options in each individual case.

It is of concern that page 29 refers to rivers which show a deficit and provides an explanation which states that actual use does not exceed supply if you don't count the ecological reserve. The unfortunate impression is created that the reserve is somehow less important and we are concerned that delays in the implementation of the reserve could lead to continued wasteful and over-exploitation of rivers and their continuing degradation. We recommend that the wording be changed to ensure that there is no possible misunderstanding about the importance of the reserve. .

The apparent lack of importance prevalent throughout the document regarding the understanding of ecological functioning of rivers raises itself again here. There is mention on page 29 that water quality should be considered but has not been. We would ask why not? An integrated NWRS should strive to incorporate all relevant factors to ensure that, after considering all the options, the best available solution is taken.

With regard to water quality and contaminants, we recommend that the following points are emphasised in the NWRS text:

Again the findings of the WCD have not been integrated.

Page 31 refers to transferring water from one catchment to another to meet the ecological reserve. This shows total lack of understanding for the rationale behind the ecological reserve. The NWRS fails to address the WCD recommendation that a policy is developed to maintain rivers "with high ecosystem functions and values in their natural state". As an example, , pg. D17.5 of appendix D while acknowledging that the Doring river is in a relatively pristine state, still proposes to dam it.

We would strongly recommend that the ecological importance of rivers be reflected in the NWRS and emphasise that some rivers such as the Doring river should be left in their natural state.

International experts have documented the biological dangers of IBTs. However, this is not reflected in the NWRS. We feel that NWRS should make use of international science as part of the development of options for future water resources.

    1. Chapter 3: Strategies for Water Resource Management
    2. Civil Society position:

      In order to determine the amounts of water available for economic development, priority must be given to research and monitoring. Sufficient resources must be made available from the fiscus over a fixed timeframe to implement an effective, reliable system of monitoring and research.

      With reference to the precautionary principle (legally binding on DWAF as per NEMA) no further dams or, large water infrastructure likely to have significant impact on river systems, should be constructed until adequate data collection and monitoring systems are in place. This will ensure some accuracy in the calculation of the reserve.

      Water demand measures and water conservation which will aim to reduce water usage by fixed targets over fixed short timeframes should be developed and implemented.

      These measures should be applied to all sectors of water usage, including domestic, industrial and agriculture.

      Institutional mechanisms which ensure that local communities participate in decisions that affect them, including reparations, must be implemented. ( WCD, NEMA, caucus statement, DWAF guidelines on public participation).

      CMA's should be modified to ensure community involvement and include women and youth as specific sectors. South Africa's water belongs to its people, therefore communities living around those catchment areas must be capacitated in technical skills as well as management skills to enable them to preserve their resources.

      Privatisation/commercialisation: Water belongs to the state. The State should therefore maintain and fund in full, any infrastructure which is necessary to ensure that all people will have access to water to meet basic human needs. This is a right irrespective of people's ability to pay.

      During discussion, we were informed that DWAF does not have the power to compel local authorities to implement the right to access to water (the free allocation). DWAF must engage local authorities and should clearly spell out the powers of national government to set norms and standards. This should be clearly reflected in this document. If local authorities fail to comply with the provisions of the NWRS, the strategy will fail as it is dependent on implementation at a local level.

      Detailed comments:

      1. part 1: Protection of Resources
      2. The basic foundation of this section has our support: i.e. that resource demand management and source-directed controls should be implemented to ensure sufficient water to meet human needs and sustain ecological functioning. However, our concerns are with the timeframes for implementation and the allocation of resources to complete the classification accurately and timeously. The NWRS overall currently appears to focus on water supply and we would like assurance within the strategy that water demand will become the priority focus within the dept, and that no water supply options will begin prior to the provisions of this section having been completed.

        We believe that decisions should be made once all the relevant information is available. DWAF has clearly admitted that this section has not received attention and this section of the NWRS is extremely poor in the provision of data. This is of grave concern.

        pg. 50 speaks of a phased approach. This raises the danger that existing overexploitative practice could continue until such time that a reserve is defined. Similarly pg. 48, last paragraph "realistic" provides a loophole for business as usual to continue. Page 50 also mentions capacity limitations. We would emphasise the need for this section to be given priority and for the precautionary approach to be followed until such time that adequate data is available.

        pg. 53/54 suggest conditions for the relaxation of standards. We would propose that the current wording leaves the provision open to abuse and that the wording be tightened.

        Pg. 54 is supported in not allowing rivers to be downgraded. However, if a river is rehabilitated to a particular standard, surely provision should be made for an upgraded classification.


      3. Public participation:
      4. WCD principles speak to gaining public acceptance. We believe that those affected and interested should be part of making the decision. We would therefore suggest that where there is reference to "after public consultation" as in pg. 56, the phrase will changed to "in consultation with" which will reflect a greater degree of participatory decision-making in line with international standards.

        A particular emphasis should be placed on ensuring the participation of ALL affected communities as this is a national strategy. Appropriate measures that will be effective in communication with different target audiences must be developed.


      5. Compulsory licensing
      6. Pg. 58 describes processes for compulsory licensing. We believe that all applications should be considered together to ensure equitable allocation. We support the provisions of allocation which are specially to support previously marginalised users.

        The compensation provisions within section are supported, and in particular their implications for the reserve. Failure to limit the compensation would have hamstrung the department and we could envisage situations where rivers are overexploited because the govt was unable to compensate a water user.


      7. Further comments:

      Pg. 63 provides for Eskom to be able to store water in terms of its use as strategically important. However, we would note that the provision of national grid electricity is only one option for social and economic development. Other more water efficient measures of providing energy should be investigated and it should not be assumed that high water use options are inevitable. The Water caucus rejects large scale hydropower as an option for power generation.

      We support and applaud DWAF for emphasising the education and communication role which is an essential part of the NWRS. However, on pg. 66, it would be useful if this section contained an introduction which emphasised the fact that water is a limited resource and should be used wisely, rather than taking an approach that big dams are inevitable. We are left with the impression that Water Demand Management (WDM) is merely an add-on. Given that the document is supposed to be an integrated strategy to water resource management, it is inconceivable that the NWRS section on water conservation is still in a incomplete phase.

      The water resources of the country are in crisis.

      However, Pg. 67 appears to support the idea that water supplies must be ever increasing. The need for dams to "postponed" rather than "prevented" is weak and shows short-sighted planning. WDM should not focus on short time horizons of 25 years but be looking to 100 years or more.

      While we agree with the theory outlined on pg. 67 that currently available water should be used before further IBT's are contemplated, there is little data provided to motivate for this, or to show the savings which would result from the implementation of water conservation measures. We feel that the NWRS would be strengthened and our perceptions of bias could be addressed in part, if such details are provided.

      The strategies outlined on page 68 are useful and supported. However, further detail is required, including some scenarios regarding the targets for water saving, the long term benefits etc. We would also raise concern over phrases such as "consideration will be given" which does not guarantee any action. It is also of concern to see that although the reserve has, in theory, the highest priority in allocations, the mining/industrial sector appears to claim given highest priority - pg. 68 ".. it requires a high degree of certainty that its water needs will be satisfied..." This section could be rewritten to reflect an understanding that the reserve is paramount.

      Chapter 3, part 3 is totally inadequate and without it , the NWRS becomes merely a strategy of augmenting supply. Failure to complete this section adequately is regarded as a fatal flaw in the NWRS, and we urge DWAF to amend the NWRS accordingly.

      It is important to stress that effort-based water demand measures are more equitable than financial measures.

    3. Chapter 4: Water pricing and financial assistance
    4. While some mention is made of the option of variable or fixed rates and the intention is made to make polluters internalise the costs of pollution, the section is disappointing for its lack of incentives to use less water.

      While the NWRS is not meant to provide a definitive answer on pricing, it is important that some strategic direction is given. The costs of infrastructure such as dams and IBT's is to be passed on to the end users (pg. 67). This is not happening transparently. For example, in the case of Skuifraam, the broader Cape Town public were not told how much extra they would have to pay. There are less costly options to dams and IBT's and these should be given priority and incentivised. For example water sourced from IBT's should have a surcharge added to it, and those water users who implement 10 or 20% savings in water use should be rewarded.

      However, we would again reiterate that potable water is a basic right and all communities should be able to access their allocation regardless of their ability to pay. The position of the Water Caucus is that it rejects commodification and privatisation of water services and sanitation and water resources.

      Water trading is extremely dangerous. It takes us into uncharted territory and similar experiences within the fishing sectors raise alarm bells.

      Water trading (pg. 76) appears to allow for a similar situation of paper quotas to develop as occurs in the fishing industry. Those small users or previously marginalised can be tempted to sell their water rights. It is possible that large commercial concerns could offer more money for the small user's water rights than the small user could make as emerging farmers using irrigation fore example. . Despite assurances of tight controls, we believe this is commodification of water, removing control from public hands and therefore we reject water trading. If water savings are the stated objective, these could be realised through other means.


      1. Catchment Management Areas (CMA's):
      2. We believe that national standards are preferable to each CMA setting its own water tariff structure. The national standards must be developed through a meaningful public participation process.

        We support a decentralised system of water management but would raise a concern about the financial dependence of CMAs. If they are to be financially independent, they will need to raise revenue. If this is done by selling water, the CMA will experience a conflict of interest with its objective of managing water resources sustainably (including the need to conserve water). Similarly, some arrangements should be made to prevent municipalities buying bulk water cheaply and selling it to communities as a revenue generating exercise as this will undermine any role that local authorities should be playing in advocating water conservation.


      3. Forums:
      4. pg. 84 section

        Forums are an important means of involving communities directly in water management. We support section and believe that forums must continue to exist. However, people's abilities to participate are limited by their own resources (e.g. time, transport, communication) and poorer communities will find it difficult to participate without support. The DEPT should make sure that forums are given adequate resources to enable each member to participate meaningfully as per NEMA.


      5. Privatisation of water infrastructure development - section
      6. There are two options put forward. We believe that the state should take responsibility for the provision of a water supply and are concerned that the creation of state enterprises is the first step to privatisation. While we appreciate the pressure the Dept is under to follow the current outsourcing national trend, we believe that water as a national resource which is limited and vital to survival, should remain firmly within the ambit of the state.

        The privatisation of a structure such as a dam or treatment works, would we believe compromise safety standards and water quality as companies strive to increase profits and look to reduce short term costs.

        Governments must be accountable. Privatisation is not accepted at all. We acknowledge that the state is not able to provide adequate safety monitoring at the moment but the solution is to increase the government's capacity not to remove the function from government.


      7. Pg. 86: section monitoring institutional performance
      8. We support the idea that CMAs should be accountable and provide information in a transparent manner, but it is not clear from this section what sanctions will be applied should the CMA fail to deliver. We think that appropriate sanctions should be spelled out as part of the strategy.


      9. Part 6: monitoring and information:
      10. An adequate reliable monitoring system is the backbone of the NWRS as it will provide scientific evidence on which to make decisions. However, in the surface water flow monitoring subsection, a lack of capacity is raised and proposals are made to address this but only over the next 25 years. There is no timeframe for the improvement of the surface water quality monitoring. However, it is important that groundwater be assessed urgently and we are pleased to see a timeframe of 2006.

        The State of Rivers Reporting programme is supported and the timeframe of 2008 appears reasonable. However, we would strongly recommend that no further dams be built until such a programme is complete. We wish to emphasis that we are not advocating that providing water to those without stops but that alternative sources of water are found.

        There is also no clarity on how local knowledge will be incorporated into the programme nor of how communities will receive feedback. It would be logical that it be provided through forums and the CMA.

        This section should contain reference to community driven research, the importance of training researchers and the involvement of the communities in research projects.

      11. public safety- Chapter 3, part 7
      12. pg. 96. As a strategy document, options should be presented for dealing with disasters such as floods. However, pg. 96 speaks of proposals, guidelines etc. for sustainable use of floodplains but stops short of a real strategy. For example, local planning regulations should preclude further development in the floodplain. (1in 100 year line).

        Pg. 97, section droughts.

        We need to raise a concern here - in times of drought the NWRS states that human need will continue to be a priority. However, this is followed by strategically important uses "such as power generation and key industries". There is no mention of the ecological reserve - surely that should continue to be a priority otherwise it makes a mockery of the system. In times of drought, river ecosystems will also be severely stressed. We believe that DWAF has made the reserve paramount but the above perception needs to be addressed.

        Pg. 98 section disaster management: this section is weak, there is no strategic intervention, purely an attempt to absolve the Dept of blame by providing information. Poor communities most at risk do not have the luxury of choosing where to live - it is government responsibility to ensure their safety.

        Data collection is identified as a weakness and we support the strengthening of this function as the increasing uncertainty of weather events due to climate change requires a comprehensive data collection system.

        We strongly recommend that DWAF integrates the WCD findings particularly in regard to accessing information, and informed decision making.


      13. Programme of implementation section 3.8
      14. The provision of proposed timeframes is supported as it provides a transparent means of evaluating progress towards meeting the objectives.

        Pg. 109: This table's heading implies that these dams are to provide for irrigation yet in appendix D, water requirement scenarios generally state that no further provision is to be made for irrigation requirements to increase. Some clarity is needed here.

        The contents of the table reflect a haste to build dams without adequate data and we do not feel that these dates are useful at all. Data collection and monitoring systems will only be complete around 2012. The state of the river report for all rivers is predicted to be finished by 2008. Without these data systems, the reserve cannot be calculated, nor can water quality or other measurements which are needed to contribute towards the decision-making process of water supply options. Yet the table proposes that various dams be completed by as early as 2005 or 2007.

        A particular example is the Doring river, a pristine river with a high ecological value. A dam is proposed to be built by 2011 a year before the proposed date for completion of the data monitoring systems. This is inconceivable.

        This section contains no timeframe for water demand measures to be implemented and the approach appears to assume that the proposed dams are inevitable. We would rather recommend that a comprehensive water audit be completed to see how much water is being lost through poor maintenance.


      15. Financial implications section 3.9:

      We appreciate the work that has gone into the compilation of these figures. It is useful to have some understanding of the costing estimates of various aspects of the NWRS. However, it is again disappointing to note the lack of priority given to water conservation measures compared to the comprehensive cost estimates for the building of dams and associated infrastructure. The total costs of water demand management are put together with all other functions of catchment management - there is no breakdown and we only know that it is a portion of R209 million, and that there is a deficit of R150 million.

      The expansion of the monitoring networks will cost approx. R60 million a year over 25 years but there are no estimates for such vital functions as treatment of waste water before discharging it into the resource etc.

      As indicated earlier in this commentary, we would query the need for the either the raising of the Clanwilliam dam or the construction of the Melkboom dam. If one applies a rigorous approach to water requirements and includes water savings, then theoretically, the R819 million allocated for the two afore-mentioned dams could be put to better use e.g. catchment management functions. This would balance books of R150 million.

      That would still leave over R600 million which could be put towards improving the monitoring systems.

      There is also the need for reparations for the impact of existing dams as detailed earlier in this submission.

      We must emphasis that we realise that the costing of the above infrastructure does not balance in such a simplistic fashion but we use the example to demonstrate the benefits of allocating resources in an integrated manner, rather than focusing huge sums of money on unnecessary infrastructure.

      Pg. 116/117: The proposed system relies on the ability of water users to pay. While it is possible that all water can be allocated to those users who can afford the high costs (without government subsidy and having to pay back for dams which were not needed), it could also result in those users that cannot afford to pay being marginalised and cut off. The current cut-off policies of local authorities in this regard are an uncomfortable reminder of the future possibilities in this regard.

      It is important to note the acknowledgement that Govt funding may be required for infrastructure projects where consumers can't afford to pay but we would recommend that the "may" be changed to "will".

      Pg. 118. We raise a note of caution. The practice of forming private institutions for the construction of dams, who then raise the finance privately, build the dam and then recoup the costs from the users appears to very unfair. This appears to be a way of govt. making costly decisions for which it is not liable because the costs are passed on to the water users including the public. Within the present system, these people who do have to foot the bill, are inadequately consulted and do not participate meaningfully in the decision.

      We would also reject the idea of World Bank or WTO mechanisms being involved in the financing of the water supply.


    5. Chapter 4: Complementary Strategies
    6. Civil Society position:

      We believe that the fundamental basis for all decision-making should be a process which allows the inclusion of all interested and affected people where they are capacitated to participate meaningfully. Those people most affected should be given priority. Consultation should be decentralised and there is a need for education of communities in issues of health and safety.

      Water management must be accountable to communities at a local level.

      Detailed comments:

      This chapter is one of the most important chapters as it provides the strategy for engaging with the public, including interested and affected communities. However, it is of concern that there is no budget allocation given to this section.

      We support the creation of a capacity building task team but without a budget, it is unlikely to implement much. The tasks of the task team appear a little worrying - it is tasked with "the development of skills, knowledge and attitudes required to support the development of infrastructure.....". Nowhere is water conservation or water demand management mentioned. We could be forgiven for thinking that the task team's role is to ensure that people support the construction of dams! If this is not the intention, the NWRS should be amended to reflect its true purpose.

      We support the initiation of the public participation guidelines but would ask that the process for their completion and adoption be a participatory one, involving the public.

      We need clarity regarding the doing away with the requirement to consult if the waterworks will be in operation for less than 5 years. We accept that in cases of emergency, consultation processes may be curtailed but fail to see any circumstance where it is not necessary to consult when the waterworks will be in place for less than 5 years.

      We repeat the importance of integrating the findings of the WCD and highlight the following message ".. joint negotiations with adversely affected people result in mutually agreed and legally enforceable mitigation and development provisions".

      Pg. 124 - The last paragraph on this page is very telling and in our view could be applied to the entire NWRS. We would welcome an updated draft NWRS where all aspects of water management were given priorities in terms of international norms, i.e. water demand strategies higher priority than water supply.


    7. Chapter 5: National Planning and co-ordination, and international co-operation in water management.

We have no specific comments on this chapter but would reiterate the need to integrate the findings of the WCD into the NWRS.

  1. Conclusion:

The NWRS should provide reliable and progressive choices for decision-makers to enable them to make decisions on how South Africa protects and manages its water resources for the future.


We support DWAF in its aims to see water resources managed for the benefit of all but believe that this is only possible through a NWRS which has, as it highest priority, a concentrated focus on water conservation and water demand management.

In light of the above statement, We believe that NWRS has some merit but does not contain sufficient detail or data to enable decision-makers to use it as a strategy to guide water management in this country.

During the process which led to the drafting of these comments, it was apparent that many affected groups did not feel that they had been adequately consulted. We would therefore, strongly recommend that the second draft of the NWRS be published for comment. This is an extremely important document and its success will depend on its acceptance by the public.