BUSINESS UNITY SOUTH AFRICA [BUSA]

1 July 2006

TOWARDS A JOINT ACTION PLAN TO CONTINUE TO IMPROVE THE QUALITY OF LIFE OF SOUTH AFRICA's PEOPLE THROUGH IMPROVED WATER QUALITY

Attached as document D258/06 please find the BUSA submission to the Portfolio Committee on Water Affairs.

If you need clarification on anything contained in our document, please do not hesitate to give us a call.

Yours sincerely

JERRY VILAKAZI: Chief Executive Officer

(BUSA) BUSINESS UNITY SOUTH A,FRICA

BUSA SUBMISSION TO THE PORTFOLIO COMMITTEE ON WATER AFFAIRS AND FORESTRY: TOWARDS A JOINT ACTION PLAN TO CONTINUE TO IMPROVE THE QUALITY OF LIFE OF SOUTH AFRICA's PEOPLE THROUGH IMPROVED WATER QUALITY

SUBMISSION BY BUSINESS UNITY SOUTH AFRICA (BUSA)

JUNE 2006

BACKGROUND

Business Unity South Africa (BUSA) was created in October 2003 through the merger of the Black Business Council and Business South Africa. It began operating in January 2004. The merger created the first truly representative and unified organisation for business in South Africa.

BUSA is a confederation of chambers of commerce and industry, professional associations, corporate associations and unisectoral organisations.

BUSA represents South African business (See attached list of members) on macro- economic and high level issues that affect it at the national and international levels. BUSA's function is to ensure that business plays a constructive role in the country's economic growth, development and transformation and to create an environment in which businesses of all sizes and in all sectors can thrive, expand and be competitive.

As the principal representative of business in South Africa, BUSA represents the views of its members in a number of national structures and bodies, both statutory and, non-statutory. BUSA also represents businesses' interests in the National Economic Development and Labour Council (NEDLAC).'

Internationally, BUSA is a member of the International Organisation of Employers (IOE), the Pan-African Employers' Confederation (PEC) and the Southern African Development Community (SADC) Employers' Group. BUSA is also the official representative of business at the International Labour Organisation (lLO), African Union (AU) Social Affairs Commission and World Trade Organisation (WTO).

BUSA welcomes the opportunity to make a submission on the question of water allocation.

WATER CONSERVATION AND WATER DEMAND MANAGEMENT STRATEGY

Business recognizes the need for a water consideration and water demand strategy and the role that such a strategy can play in supporting the achievement of national objectives like:

· The development of key sectors of the economy; and

· Alleviating poverty and reducing unemployment.

In Business' view, implementation of this strategy requires greater attention to be paid to the following:

· Co-operative governance so that authorisations in terms of water and environmental legislation are integrated;

· Partnerships between the Department and water using sectors to achieve agreed objectives;

· Incentivisation of innovative water consideration measures introduced by industry; and

· Use of National Treasury's Framework for Environmental Market Instruments as a benchmark for the development of any economic tools to incentivize efficient use of water.

INDUSTRY AND MINING STRATEGY

BUSA notes the intention of the Department to require industrial users who require a licence to use water, to .develop and submit a water management plan (WMP) in accordance with Guidelines to be developed by the Department.

BUSA would like to work with the Department on these guidelines for industry.

BUSA welcomes the apparent intention to integrate the requirements of a WMP with an Environmental Management Plan that may be required in terms of other legislation.

Should the requirement for a WMP be required by local water services authorities or providers, consideration should be given to harmonized guidelines in this regard.

RESEARCH AND DATA

'BUSA welcomes the need for a comprehensive water quality monitoring network and proposes the inclusion of the following elements in the network:

· Build on existing reporting requirements:

· Public accessibility of verified information;

· Verification system for information to ensure accuracy and reliability;

· Harmonized format for data requirements by all spheres of government; and

· Elimination of duplicate reporting requirements.

CONCLUSION

BUSA looks forward to working with government in the implementation of this initiative.