Forestry South Africa
Major achievements with regard to Water Use Licence amendments
During the period 2000-2001, landowners were required to register the extent of plantations, in hectares, on their farms; this included state-owned and privately-owned plantations.
The Department of Water and Sanitation (DWS), in due course, issued every property a National Register of Water Use Registration Record, each with its unique registration number. There were, however, discrepancies. In some cases, the registration record solely reflected the area in hectares under plantations, in others, the genus and the area planted were specified. This inconsistency created much uncertainty and confusion among landowners.
At the time of the registration process, DWS and FSA agreed that Water Use Licenses (WUL) would be issued using water use figures established at the time for Eucalyptus.
However, Water Use Licences issued by the DWS after this agreement did not reflect the authorisation using these figures. Accompanying each WUL were a set of general conditions, as well as conditions specific to a Stream Flow Reduction Activity (SFRA). Over the period in which WULs were issued for new SFRA authorisations, these conditions were regularly changed to the extent that one landowner had two WUL’s on the same title deed, each with a different set of conditions.
The disparities between WULs are highlighted when comparing the number of General Conditions, which can vary from 20 to 25 depending on when the licence was issued. With many of the General Conditions being impossible to audit and many of the Standard Conditions for SFRA being vague, contradictory, unclear, impossible to implement and monitor, but most notably exceeding the DWS mandate.
Negotiations between the DWS and FSA on the conditions attached to WULs has been a lengthy, drawn-out and costly exercise. However, after years of engagements, the DWS has released an amended WUL template, which negates many of the issues associated with the initial licence.
Notable amendments include:
- Genus exchange can occur without seeking authority;
- New WUL has 12 General Conditions – down from 25;
- New WUL has seven Standard Conditions for an SFRA, the most important being: distance from a watercourse will be licence specific;
- Internal audits will be required after first planting and then every five years, rather than annually;
- Independent compliance audits will be required within five years of first planting, then every ten years, rather than annually; and
- The authorized area is the Planted Area Record.
Once again, the value of the Forestry Sector inclusion in the PPGI cannot be overstated. The inclusion of WUL as one of the Sector’s main inhibitors in the PPGI process resulted in an intervention by the Presidency and the rapid finalisation of this new WUL template. A template agreed upon by both Industry and DWS.
We would also like to acknowledge the lengthy efforts of the FSA Environmental Management Committee and their inputs into this process.