Navigating the water use licencing minefield

Jacky Burke, SRK Consulting principal environmental scientist

Water is a complex field

Applying for and obtaining amendments to water use licences is an ongoing and often time-consuming process for most mines, even when the adjustments are relatively low-risk, said Jacky Burke SRK Consulting principal environmental scientist and the leader of SRK’s water use licence application (Wula) group.

“Water is a complex field and everyone involved is on a steep learning curve with the stringent new licensing system,” she said.

Burke was speaking recently at a Wula workshop hosted by SRK in Johannesburg, which focused on the new electronic water use licence application and authorisation system (Ewulaas), highlighting the value 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 that delay the application process were being experienced.

New electronic system

Web-based Ewulaas system was user-friendly and followed 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 on-line; and a third phase where a technical report and additional specialist information are uploaded for DWS decision making, said Avril Owens, SRK senior environmental scientist.

“Ewulaas certainly promises to be a great improvement on the original paper-based system. Among the advantages is the ability to generate a summary of water uses per farm prior to phase one submission, to verify that all water uses have been correctly captured on the system and highlights any gaps in the application; also, the submission can be tracked on-line, providing more transparency on its progress.

“There is no doubt that this is a better way to go – with applicants knowing that all the information is there, that nothing can get lost, and that the process can be tracked,” she said. “There is obviously also a human element to the system, and as users we also have to play a constructive role in keeping everyone to the deadlines.”

Public participation

Owens emphasised the importance of the pre-application phase, in which applicants meet with DWS to clarify their way forward; in fact, most of the preparation work is required to be completed before the on-line submission process can begin.

Highlighting the type and scale of activity to be undertaken, SRK principal environmental scientist, Didi Masoabi, said it was important for applicants to be aware that site-specific environmental impact assessments and specialist studies may need to be conducted.

“Public participation is also an important element of a Wula as interested and affected parties need to be informed about what you plan to do and how it may impact them. Depending on the size of your project, the DWS may need more information on how you intend to communicate with the public about your project," said Masoabi.