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FSE's comments on the National Eutrophication Strategy: Draft Inception Report

Written by  Friday, 05 June 2020 11:42
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The following comments are submitted – with diffidence and deference - on behalf of the Federation for Sustainable Environment (FSE). The FSE is a member of a number of theDepartment of Water and Sanitation’s Steering-, Project- and Strategy Steering Committees, Implementation Task Teams; Expert Steering Committees; the WSSLG’s SDG6 Task Teamand a number of Catchment Management Forums.

From a reading of the Inception Report in terms of the Development of the National Eutrophication Strategy we deduce that the Scope of Work will include inter alia a report on eutrophication challenges in South Africa and their causes; the development of the National Eutrophication Strategy; putting the Strategy into Practice detailing the actions, the roles and timeframes; developing a monitoring and reporting system; stakeholder involvement; etc. The estimate timeframes from the 1st component to the implementation of the Strategy (“putting the Strategy into Practice”) will be approximately 20 months.

While we welcome the development of actions that would provide the detail necessary to turnthe National Eutrophication Strategy into action (s 2.4 of the Inception Report, titled “Strategyinto Practice”), such as the assignment of roles and responsibilities and the timeframes for undertaking the actions, it is the FSE’s considered opinion that it is not necessary to wait forthe development of the National Eutrophication Strategy to immediately implement a number of actions to address the challenges of eutrophication. Analogous to the FSE’srecommendation, the IWQM Policy identified eutrophication already in 2016 as one of the five aspects of water pollution as being priorities for immediate regulatory action at the national level.

The following challenges were identified by the DWS, which require immediate action:

1. The lethargy in completing the roll-out and delegations to catchment management agencies


The Inception Report on page 1 informs us that “this project is entirely reliant on activities performed within the Department, the CMAs, together with other institutions within the watersector”.

It is common cause that the number of WMAs was reduced from nineteen (19) to nine (9) in 2013 and that the establishment of the CMAs has been slow. By the end of 2016, only two of the nine CMAs were established in terms of the National Water Act, 36 of 1998 and functional. No functions have been delegated to these bodies which are therefore currently only responsible for the limited initial functions of a CMAs as set out in the Act. DWS acts as CMAs in most of the country.

The National Water and Sanitation Master Plan, 2018 called for the establishment of financially sustainable CMAs across the country and transfer of staff and budget1 and delegate functions including licensing of water use and monitoring and evaluation of water resources by 2020.

Atthetimeofwritingweareunawareofanyprogressinthisregard. ThedevelopmentoftheNational Eutrophication Strategy (“the project”) is at risk to be aborted unless CMAs becomefunctional.

2. Dysfunctional Waste Water Treatment Works

A key contributor to the deterioration of water quality of South Africa’s water resources and the marked increase in nutrients and microbiological contaminants with associated health risks is the result of untreated or partially treated municipal wastewater discharges from sewage treatment works.

To exemplify:

The recent instream water quality results of the Rietspruit@Sebokeng within the Rietspruit Catchment Management Area as provided by Rand Water show an e-coli count of 9,188,000 per 100ml for the period January to March 2020.

The resulting eutrophication in major dams has caused health threats to livestock and humans.

We are of the considered opinion that the most important driver of eutrophication is dysfunctional waste water treatment works, dense informal settlements without proper sanitation, vandalism of sewage reticulation systems, and sewage spills over many years into receiving steams2. The tipping point has already been reached, beyond which, our ecosystems can no longer absorb and process the nutrients and other pollutants being passed on to it.

The actions proposed by the National Water and Sanitation Master Plan is to, by 2020: “Identify and prosecute big polluters across the country (including municipalities), with a national

1 There are substantial financial shortfalls if Catchment Management Agencies are to be fully implemented and operationalized.

2 The state of our waste water treatment works (56% of waste water treatment works and 44% of water treatment works are in a poor of critical condition; 11% are dysfunctional) has significantly impacted upon the ability of downstream ecosystems to operate effectively with nutrient build-up and a general drop in water quality. This has resulted in a nutrient build up in our rivers and wetlands. According to the NW&S Master Plan between 1999 and 2011 the extent of main rivers in South Africa classified as having a poor ecological condition increased by 500% with some rivers pushed beyond the point of recovery. South Africa has lost over 50% of its wetlands and of the remaining 3.2 hectares, that is, one third are already in a poor condition.


communication campaign to accompany the action inclusive of reviving the Blue Scorpions”(1.4.8).

The above-mentioned actions, we respectfully suggest, must be implemented concurrently with the development of the National Eutrophication Strategy. Failure to prosecute municipalities and other polluters will render the objectives of the National Eutrophication Strategy impotent.

3. Eutrophication challenges in South Africa and their causes

As a deliverable in terms of s 2.2 of the Inception Report, a Report on eutrophication challenges in South Africa and their causes is envisioned.

Mining, in particular platinum mining, can result in increased nitrogen levels in groundwater through the use of nitrogen-based explosives. These various nitrate sources can contribute to mining-related impacts on the water resources.

Most commercial explosives contain between 70% and 90% ammonium nitrate – which is highly soluble in water. Spillages, dissolution in wet holes and incomplete detonation during blasting activities will result in soil and water contamination with nitrates, nitrites and ammonia. Nitrogen-rich water is typically pumped from the underground workings and then circulates through process water dams, the tailings dam return water and the concentrator plant. If not contained in the mine water circuit, surface spills or seepage through unlined facilities may pose a risk to groundwater. (Reference: https://www.srk.co.za/en/za-helping-mines-find- real-source-nitrates-water.)

Since algae and other plants use nitrates as a source of food, it may result if unchecked, in eutrophication.

In view of the aforesaid, the FSE recommends that the Report also includes the impacts of mining in the eutrophication challenges.

4. National Eutrophication Monitoring Programme

Finally, kindly advise regarding the status of the National Eutrophication Monitoring Programme which assesses trophic status, risks and trends of single impoundments, river reaches or canals.

Mariette Liefferink.

Comments attached for download.



The FSE, in association with Gold Fields’ South Deep Mine, donated 40 white Karee Trees (Searsia penduline) during Arbor Week to the mining affected community of Simunye in the West Rand and participated in the tree planting ceremony with the community of Simunye, the local Municipality and officials from South Deep Mine.  The FSE also delivered a presentation during the ceremony.

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Article also available for download as an attachment.

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The Sustainable Development Goals (SDGs) are a universal call to action to end poverty, protect the planet and ensure that all people enjoy peace and prosperity. The SDGs are spearheaded by the United Nations through a deliberative process involving its 193 Member States. The SDGs are a set of 17 “Global Goals” with 169 targets between them, covering a broad range of sustainable development issues.  These include ending poverty and hunger, improving health and education, making cities more sustainable, combating climate change and protecting oceans and forests. The SDGs were endorsed by all Heads of State, including South Africa, who authorized it “without any reservations” on 25 September 2015. The commitment was reconfirmed by the former President during World Water Week (March 2017),  which took place in South Africa, and he also called for urgent action. Goal 6 is to ensure availability and sustainable management of water and sanitation for all by 2030. The FSE is a member of the Water and Sanitation Sector Leadership Group (WSSLG) Sustainable Development Goal 6 Task Team. The attached presentation, which was presented by the Leader of the SDG6 Task team, Mr Mark Bannister has identified significant gaps. A summary of the gaps is attached hereto. The SDG Programme informs relevant ‘vehicles’ such as the National Water and Sanitation Master Plan (NW&SMP) to translate these Gaps into Actions that can be implemented by the Sector, towards the 2030 objectives.  However, although these actions have been identified in the NW&SMP, most of these Actions have not been implemented.  It is doubtful that South Africa will achieve the 8 targets of the SDG6 by 2030. View the SDG 6_Consolidated Gap_Action_2020 document here.View the FSE SUMMARY OF GAPS SDG6 TARGETS document here.