SUBMISSION BY RAND WATER TO PORTFOLIO COMMITTEE FOR WATER AFFAIRS AND FORESTRY NATIONAL WATER RESOURCES STRATEGY, 12 OCTOBER 2004

1. Introduction

Rand Water welcomes the publication of the first draft of the NationalWater Resources Strategy ("the Strategy") The Strategy describes how water resources of South Africa will be: Protected; Used; Developed; Conserved; Managed; and Controlled in accordance with the requirements of policy and law.

Rand Water fully agrees that water is essential for human life and that the first priority is to ensure that water resources management supports the provision of water services - potable water and safe sanitation – to all people, but especially to the poor and previously disadvantaged. Further, it should contribute to the economic viability of all the provinces of South Africa.

The Strategy is a positive step towards a more effective process for the management of water resources within South Africa. This Strategy will have a direct impact on Rand Water's operations because Rand Water, as an organisation, has been involved in the management of water resources at a regional level for many years. Rand Water aligns itself to the spirit of the Strategy and intends to continue to play a significant and active role in its implementation.

The Strategy's emphasis on the importance of water conservation, water demand management and measures to promote greater efficiency in the water use is welcome and implementation is urgently needed.

The Strategy's articulation of the importance for the protection of water resources, water use, water pricing, monitoring and information systems for water resources and disaster management is indeed very positive. The practical and successful implementation of all these processes will ensure that South Africa's National Water Resources Strategy is progressive.

2. Rand Water's Activities - in respect of the Strategy

It is crucial for us to align ourselves with the processes set out in the Strategy and to play a very active role. We have been involved in the process since it started and we are currently involved in the process of establishing Catchment Management Agencies and the implementation of the Strategy. This involvement goes beyond Rand Water's immediate business areas (abstraction, purification and distribution) but focuses on long term issues to ensure sustainability of water as a resource.

Rand Water is by far the biggest role player in the entire Upper Vaal Water Management Area - making us not only a "user" but also a key stakeholder and role player. This factor also highlights our need for involvement in the process. We need to be involved to ensure that water quality is managed at a level most suitable for our operations. The boundaries of the Upper Vaal Water Management Area extend downstream of the Barrage to include the Kromdraai sub-catchment. This is important because Rand Water "exports" water to that area, and this needs to be factored into any resource management Strategy.

Re-use of water will have a positive impact if done in conjunction with an education drive - if consumers realise that they are using their own effluent, they might be more considerate in respect of what they discharge. Currently consumers are in a comfort zone, knowing that Rand Water only abstracts from the Vaal Dam, thus all the pollution on the reef has no impact on potable water quality.

Rand Water has huge successes with its Working for Water programme, which is a programme that seeks to control alien vegetation. This programme needs to be sustained, or else the problems will be worse in future, which may result in severe financial losses. The programme can even be extended to other types of vegetation such as water hyacinth control and the control of alien fish species - this could be important in stabilizing the "Ecological Reserve".

Rand Water has been highly successful in contributing to control of alien invasive vegetation, and has even received environmental awards for its programme. Rand Water can therefore continue to be an implementing agent for DWAF, irrespective of the area where a project needs to be implemented.

In addition to the water conservation value of this programme, Rand Water will continue to contribute to poverty relief, capacity building, training, and the general uplifting of local communities, thus living out its values through social responsibility involvement.

Rand Water's current approach to catchment management is one of managing the water quality to sets of catchment specific objectives. This ties in perfectly with the interventions in respect of providing water of a quality that is acceptable to the specific users. Our information system is set up to report in a colour coded fashion according to criteria. This not only allows for Rand Water's operational requirements but also to cater for all other users.

Rand Water's involvement in the "River Health Programme" which involves biological monitoring has been significant. We are the only organisation conducting biomonitoring as a routine activity.

All catchments in the Upper Vaal Water Management Agency already have quality objectives set, through forum activities, where Rand Water again took the lead in defining a scientific process to establish these objectives. Although the determination of the Reserve might influence some of these objectives, the process of Catchment Management Agency establishment was not stalled as a result.

It is not clear what role DWAF or the Catchment Management Agency will play in flood management. The Disaster Management Centre will develop policies, and it can probably safely be assumed that DWAF will be responsible for its implementation. Rand Water already implements the Vaal River Structure plan, which also includes development of the floodplain etc. in fact Rand Water's management of the Barrage reservoir can serve as a model for other Water Management Agencies.

However there are some practical concerns that we would like to bring to the attention of the portfolio committee.

3. The draft National Water Resource Strategy

1. Legal enforceable s7 of the National Water Act No 36 of 1998 ("the National Water Act") provides that:

The fact that the Strategy document is a draft document can be interpreted to be that the Strategy is not finalised and therefore not applicable. We intend to clarify this with our executive authority, DWAF.

2. DWAF as regulator The need to spell out the role of DWAF as a regulator needs to be spelled out clearly. Rand Water believes that this will have the following advantages:
Clarity of roles; Enhance the ability for DWAF to police pollution as set out in the act and Strategy; DWAF will be in a position to retain the current water levy that is charged to assist in funding the proposed Catchment Management Agencies, and this may obviate the need to charge

an additional water levy for the establishment of Catchment Management Agencies; and DWAF will be seen to be fair in its pronouncements, by all role players in the water sector.

3. Practicality of implementation The National Water Act has been in place since 1998, with provisions to implement and enforce what is largely set out in the National Water Resources Strategy. The Strategy provides for implementation over a number of years, this may be indicative of the difficulty to practically implement what is envisaged in the National Water Act. Many catchment role players are losing interest in the Catchment Management Agency process because they feel that it is too slow. DWAF may consider the delegation of certain functions to either catchment forums or institutions such as Water Boards to ensure that the momentum in respect of implementation is not lost.

4. Unintended consequencies There might be unintended consequencies as a result of the implementation of this Strategy in that catchment management areas will tend to want to look after their own interests as opposed to the national interests and equity. This may result in further levies on raw water, and in turn on Water Boards, because historically it has proven to be the easiest form of collecting levies in respect of water. Rand Water, in its tariff structure has to account for such levies and pass it on to its consumers. Inevitably the cost of setting up and running the Catchment Management Agency's is just going to be eventually borne by the consumers.

5. Viability of Catchment Management Agencies Some Catchment Management Agencies may not be viable because there may not be enough viable water users in the area. Therefore, the requirement that they be self sustaining may not be feasible. It is Rand Water's submission that subsidies are inevitable.

6. Duplication of capacity/capacity problems The work that is envisaged to be done by Catchment Management Agencies is work that the provincial departments of Water Affairs should be doing. As a result there may be some duplication of outputs, whilst there may be capacity challenges. There are skills challenges existing in the Water Sector in the country and on the continent. Therefore, there might be limitations and uncertainties relating to the "pool" of skills available in South Africa to implement and operate 19 fully functional Catchment Management Agencies.

7. National Agency

In the foreword of the Strategy mention is made of a national agency to manage nationally important or multi-sector infrastructure. Within the water board environment there has been a lot of debate about wall to wall water boards and this has been difficult to implement partly because some areas are not viable and infrastructure development is very expensive and needs a lot of expertise to manage. In this regard. Rand Water has recently had its area of supply extended to assist with the management of the extension of the Cullinan pipeline. Annexure "A" hereto is a copy of Government Gazette No 25993 published on 06 February 2004.

4. Rand Water's service area/capacity

Rand Water has a history of supplying bulk water spanning over a period of 101 years. Rand Water supplies potable water in bulk to a growing population of the order of 11 011 000 million people in its 31 463 km2 service area.

Rand Water's customers comprise 3 Metropolitan Municipalities, 13 Local Municipalities, 45 Mines and approximately 330 industries and 570 private customers.

Annexure "B" hereto depicts Rand Water's services area and how it has increased over the years. Annexure "C" depicts Rand Water's Infrastructure.

Rand Water has currently been engaged by both DWAF and some of its customers, i.e. municipalities, in both capacity building management as well as assisting with retail water services and other water services related activities. This illustrates capacity problems within the water sector as it is currently structured.

To repeat what was in our previous submission last week, Rand Water's capacity with regard to water demand management is of such a nature that organisations like UNHABITAT programme have partnered with us to formulate appropriated approaches to address non-revenue water in various parts of the developing world. Rand Water firmly believes that this capacity will go a long way in contributing to the socio-political and economic development of Africa and if used to support NEPAD initiatives and to achieve the Millennium Development Goals.

E. Conclusion

Rand Water welcomes the draft National Water Resources Strategy and its various areas of emphasis. It is important for all stakeholders to co-operate both in ensuring the practicality of the Strategy and in co-operating in respect of its implementation for the greater good of the water sector and the country. Further, it is important that current capabilities be retained and leveraged to ensure the progress of our economy and the extension of access to water services for all.