2. Objectives
1. Overview of the on-line WULA submission process
(eWULAAS)
2. Alignment of eWULAAS with the WULA time
frames and requirements of Regulation 267
3. Understanding the evolving water use licence
conditions
4. How to improve compliance to reduce operational
and closure liability costs
OPPORTUNITY TO DISCUSS & SHARE EXPERIENCES
3. The SRK WULA Team
Insert photos
MeganGovender
JackyBurke
BjĂśrnSchrĂśder
AvrilOwens
DidiMasoabi
GiuliaBarr
AngelikaMĂśhr
4. Agenda for Rest of the Day
09h15: eWULAAS
09h45: R267 requirements aligned with eWULAAS
10h15: Tea and coffee break
10h30: Licence conditions and compliance
⢠General conditions
⢠Section 21(a), (b) and (j)
⢠Section 21(c) and (i)
⢠Section 21 (e), (f) and (g)
⢠Compliance approach
13h00: Closure and light lunch
5. VERY IMPORTANT
Ask Questions, share
experiences â good & bad
We are all on the WATER
learning curve and will climb
much higher if we work
together
Possibility of SACNASP CPD points
6. Water Use Licensing Workshop
Overview of the eWULAAS
Avril Owens
27 March 2018
8. What is eWULAAS
Electronic Water Use Licence Application and Authorisation
System
On-line WULA submissions
9. Three Key Steps
Pre-application meeting / consultation
Phase 1
⢠Pre-application
phase
Phase 2
⢠Supporting
documents and
water use
forms
Phase 3
⢠Technical
report and
DWS decision
10. Phase 1: Pre-Application
⢠Establish consultant-client (applicant) link (per
client)
⢠Applicant and signatory details
⢠Initial water use(s) and location/map identification
⢠Property and property owner information
⢠Applicant review & sign off (sms)
⢠Submit application
⢠DWS determines type of authorisation e.g. WULA
or GA
⢠DWS site visit, if required
⢠Receive letter from DWS with requirements for
technical report & other information needed
(specialist requirements)
11. Phase 2: Supporting
Documents and WULA
Forms
⢠Applicant information - ID, business registration,
BEE (equity & gender status of the prospective
beneficiaries, Broad Based Black Economic
Empowerment Status)
⢠Pay licence application fee
⢠Complete WULA forms (Section 21 uses)
⢠Applicant review of information
⢠Applicant sign off
⢠Submit to DWS
12. Challenges
⢠Beneficiaries should relate to SLP implementation and other
socio-economic developments related to the water user.
⢠Beneficiaries include
o those directly employed by the water user
o third party water supply should be included
⢠Number of beneficiaries requires a specific breakdown
o demographic group
o gender
o adult/youth
The numbers need to be confirmed upfront and will support the
Section 27 motivation.
If a parallel EIA/EMP process with supporting Socio-Economic
specialist study is not being followed or this detail is not in the latest
SLP, it may pose a challenge to source these numbers.
13. Phase 3: Technical Report
⢠Compile the required technical report/s (R267)
(WUL report, specialist reports, designs)
⢠Applicant review
⢠Upload and submit
⢠DWS assessment
⢠Decision on technical information
⢠Decision on application
15. eWULAAS Features
⢠Follow the progress of your application (status
section)
⢠Request assistance (support section)
⢠Withdraw your application (withdrawal section)
⢠View the correspondence history with the
department (correspondence section)
⢠Will not allow you to submit if all information is not
included
⢠Logical step-by-step approach and ensures all
relevant information is captured
16. Important to Note
⢠Decide/confirm/agree up front on
o water uses
o important information e.g. volumes, co-ordinates,
footprints
o specialist studies required and scope of work for
studies (R267) â not enough time to complete at
phase 3
⢠Not all provinces are using eWULAAS currently e.g.
KZN
17. What Works Well?
⢠System is user friendly and follows a logical flow
process
⢠The mapping of water uses on the system allows a
check to be done on the co-ordinates in the WULA
report
⢠The summary of water uses per farm prior to
Phase 1 submission provides a check and highlights
gaps
⢠Submission can be tracked
18. What is a Concern?
⢠Linking the signatory to the application for review
and sign off
⢠The mapping system has the functionality to include
polygons and lines to show water use areas e.g.
irrigation, however, the map only saves the last
polygon/line entered with previous entries âlostâ after
each water use update
20. Water Use Licensing Workshop
R267 Requirements for Phase 3 of
eWULAAS
Jacky Burke
27 March 2018
21. R267 Overview
GN R267, Government Gazette 40713, 24 Mar 2017
1. Regulates the WULA process as per eWULAAS
2. Contains checklists of the information
requirements for phase 1, 2 and 3 of eWULAAS in
Annexures B to H â some annexure content is
missing
3. Annexures C & D provide requirements per water
use
4. Annexure D specifies technical report contents
with the exception of surface water â guided by
Section 21(c) and (i) and IWWMP requirements
22. REPORT Purpose of report
1 WASTE WATER TREATMENT / WATER
TREATMENT PLANTS TECHNICAL REPORT
Water uses for water treatment and
wastewater treatment plants
2 AGRICULTURE TECHNICAL REPORT OR
BUSINESS PLAN
Agricultural water use
3 STREAM FLOW REDUCTION ACTIVITY
REPORT
Stream Flow Reduction Activity
4 INTEGRATED WATER AND
WASTEWATER MANAGEMENT REPORT
Main technical supporting report for
mining and industrial operations; collates
specialist study information and provides
water and waste management plan.
5 GEOHYDROLOGY REPORT All groundwater related uses and impacts
6 WETLAND DELINEATION REPORT All surface water related uses and
impacts; to include aquatic ecology
assessment.
7 MINE CLOSURE/REHABILITATION PLAN Plan for the closure of a mine and
rehabilitation
8 PUBLIC PARTICIPATION REPORT Consultation of interested and affected
parties
9 CIVIL DESIGN - MINIMUM INFORMATION
REQUIREMENTS
Meet regulatory & environmental
protection requirements
Technical Reports
23. Section 21 (a): Taking water from a water resource
Description Applicable Submitted
*Taking water from a water resource Form (DW 773) Yes No Yes No
*Pump Technical Data Form (DW784)
*Canal Technical Data Form (DW 786)
*Irrigation Field and Crop Details (DW 787)
*Supplementary Info: Power Generation, Industrial or Mining (DW 788)
*Supplementary Info: Domestic, Urban, Commercial or Industrial (DW
789)
Soil Suitability Report (for irrigation from Dept. Agriculture)
Viability Confirmation (for permanent transfers from Dept. Agriculture)
Confirmation of no Land Claims (for permanent transfers
from Rural Development and Land Reform)
Recommendation from CCAW (for reserved water)
Recommendation from WUA or (for scheme related water use)
Stakeholder Consultation with Interested and Affected Parties
Pump Test Certificate (Groundwater)
Geo-hydrological Study (Groundwater)
Checklist in Terms of R267
24. Checklist in Terms of R267
Section 21(j): Removal of water found underground
Description
Applicable Submitted
Yes No Yes No
Removing, discharging or disposing of water found
underground if it is necessary for the efficient
continuation of an activity or for the safety of people
form (DW 780)
Water Balance
Geohydrological report
Stakeholder consultation with interested and affected
parties
Other information as requested inthe
acknowledgement of receipt and where applicable
the site visit and meeting:
25. Section 21(c) &(i)
Presentation Checklist
There are 22 items â key ones to be aware of not
necessarily covered in other studies:
5. Stormwater management plan - drawing
6. Hierarchy of impact mitigation
16. Flow drivers
(i) Contribution of groundwater (geohydrology), surface water (hydrology) and
interflows (hydropedology) into the watercourse, losses, treatment, discharge back to
the system
(ii) Level of modification to flow drivers
17. Eco-hydrological perspective from all specialists involved
18. Rehabilitation plan
19. Landscape maintenance plan
20. Plant species plan
22. For underground mines: Confirmation from Rock Engineer about possibility of
subsidence and safety factor of the underground workings
Minimisation pollution prevention water reuse and reclamation treatment
26. Specialist Study Timing
Concept
Pre-feasibility
& feasibility
1. How much background
technical information is there?
2. What is the likelihood of fatal
flaws/no go areas?
Design
Concept
May be accepted for
authorisation - depends on risk
to water resources as perceived
by DWS.
Detailed May be required for authorisation
For
construction
During/after authorisation
As-built Required by WUL
OR???
Timing is project
dependent but for
larger projects
specialist input
earlier rather than
later can identify
likely authority
concerns upfront
and avoid costly
lessons learnt &
avoidable âback to
the drawing board
scenariosâ
27. Specialist Integration
⢠Critical for larger projects
⢠Key for initial site work: geohydrologist, hydrologist,
aquatic specialist, heritage/archaeology & GIS
⢠Combined site assessment and/or as a minimum pre-
and post integration session including the project
engineers, designers, project manager & geologist
⢠At draft report stage an integration workshop with all
environmental specialists is key to ensure alignment
and avoidance of impractical and unrealistic WUL
conditions based on specialist report findings and
recommendations
⢠Appropriate motivation for proposed alternative to
anticipated WUL conditions â mostly related to Section
21(c) and (i) conditions
29. Water Use Licensing Workshop
Technical reporting â Mapping and
Verification
BjĂśrn SchĂśder
27 March 2018
30. Geographic Information
Systems (GIS)
⢠GIS is a collection of computer hardware, software,
and geographic/spatial data for capturing,
managing, analysing, and displaying all forms of
geographically referenced information.
⢠With GIS, you can link information (attributes) to
location data, such as water uses to areas where
these uses occur in this case.
⢠You can then layer that information to give you a
better understanding of how it all works together and
achieve a visual overview of uses based on
geographical extent.
32. Geographic Information
Systems (GIS)
⢠Spatial data is the basis of almost every project
undertaken by SRK within the GIS environment, but
it is often misunderstood in terms of coordinate
systems, positional accuracy
⢠Issues and effects of misused/misunderstood spatial
data are the following
o Uncertainty with the coordinate system being
used
o Inaccuracies when transforming datumâs
o Data supplied with/without a projection
33. Geographic Information
Systems (GIS)
Data verification therefore becomes an important exercise. This
entails
⢠The coordinate system needs to be defined from the on-set,
existing data and the coordinate system of the country where
the project is taking place. Wherever possible, WGS84
ellipsoid should be used and recommended
⢠Plotting of data as a check to see if location is as expected or
experienced on the site or based on layout received.
⢠Google Earth is a useful tool to verify where access to GIS
software is limited
⢠When plotted information doesnât fall in the correct place this
should be rectified straight away to avoid issues down the line
⢠The correct coordinate information needs to be entered into
the EWULAAS database, so the correct information is
reflected on the issued water use licence
36. VERY IMPORTANT
Ask Questions, share
experiences â good & bad
We are all on the WATER
learning curve and will climb
much higher if we work
together