Comment on Water Strategy

While mining is an important contributor to the SA economy it is has the potential for significant negative impacts on the environment.  In South Africa the psychological dependence on the mining industry seems to extend beyond cost/benefit, a phenomenon evidenced in the metaphors used to describe the industry’s significance. The recently developed National Development Programme, however, does not state that mining investment and production is “urgent”, but rather that “[i]t is urgent to stimulate mining investment and production in a way that is environmentally sound…”.  

Comments on behalf of the Federation for Sustainable Environment (FSE) pursuant to the provincial multi-sectorial engagement workshop which was held in Rustenburg are available to download.  Here extracts follow.

The FSE submits that it is unfair and unpalatable that ordinary taxpayers, who have no connection whatsoever to the harm of contaminated water, and derived no benefit from it, will through the clean-up activities of the State, be compelled to pay for the treatment of acid mine water through increased water tariffs.
We call upon the Department of Water and Sanitation (DWS), in its implementation of the National Water Resource Strategy (NWR2), to diligently enforce Section 19 of the NWA, namely direct “an owner of land, a person in control of land or a person who occupies or uses the land…which causes, has caused or is likely to cause pollution of a water resources … to remedy the effects of the pollution.”
In terms of the Summary of Challenges in the WMA (Ref. DWS Business Case for the Limpopo CMA, September 2013) it was found that:
Water resources are nearly fully developed with all available water being highly utilized
Limited options for further resource development exists – attributable to the arid climate, unfavourable topography, sandy rivers as well as important conservation areas
Implementation of the Reserve is expected to result in serious deficits in some of the main river catchments
Planning has been made for large new mining developments for which additional water will be required
Urban and industrial growth will mainly be concentrated in areas where local water resources already are in short supply and need to be augmented by transfers from other WMAs
There are severe eutrophication problems at dams in the WMA.
Possibility for new power stations and/or petrochemical industries to be developed around the coalfields
Water pollution owing to large quantities of effluent discharged into the rivers in urban and industrial areas in the WMA.

While the right of the mining industry to sufficient water is prioritized, the right of the ecological reserve, tourism-, eco-tourism- and conservation sectors within the above-mentioned area to sufficient water is not afforded the same priority. It is the NWA’s purpose is to give effect to two types of constitutional rights that South Africans have. The first is their right to an environment sufficiently protected by legislative and other measures to secure socioeconomic development that is also ecologically sustainable while the second is their right to enough water to meet their basic needs.  
The Limpopo River Basin, already over-allocated by about 120%, has an extremely high Water Crowding Index (i.e. 2000 persons per flow unit per year), and is facing a 241% increase in demand by 2025, that is more than 2.5 times the global norm for social cohesion.
Minister’s Molewa’s Briefing to the PPC on Recommendations by the Business Processing Re-Engineering Committee on the 16 April 2013 stated that 52 villages in Limpopo had no water.

Another critical issue, besides the water challenges, is post-mining land use.  The extractive industry is by its very definition unsustainable since it depletes a non-renewable resource.  Mineral exploitation furthermore causes significant land use changes, generally irreversible destruction of ecosystems and loss in land capability.  
Tourism and eco-tourism, on the other hand, are sustainable land uses and provide opportunities for sustainable job creation and economic growth in the post closure phase of the mines but unless the extent of cumulative and regional mining-related impacts on inter alia water resources, sense of place, biodiversity, air quality and soil within the Pilanesberg Area are factored in, in the approval of new mining rights and authorisation of environmental impact assessments and environmental management programmes, sustainable land use with associated water use in the post mine closure scenario will not be possible.  The outcomes will result in economic and job stagnation, which will worsen poverty, and which will result in social decay.

In the National Assembly’s written reply to Question No 17158, we were informed that the Department of Water Affairs authorised three (3) river pans, ten (10) wetlands and forty one (41) rivers to be mined since the 1st of January 2004.  
Some of the rivers fall within areas of critical biodiversity such as national parks and national freshwater eco-system priority areas (NFEPA).  With over half of South Africa’s river and wetland ecosystems types considered threatened in the National Biodiversity Assessment 2011, mining in particular poses high levels of threat to freshwater ecosystems since mining has a profound often irreversible impact on ecosystems. This widespread degradation of freshwater ecosystems compromises ecosystem service delivery and results in costly management interventions and the loss of resilience to changing circumstances, including climate change.
We call upon the DWS to give urgent attention in the implementation of the NWRS-2 in order to ensure that mining is not authorized in NFEPA and areas of critical biodiversity.  Keeping these rivers and wetlands in the catchments in a natural or good condition serves a dual purpose of conserving South Africa’s freshwater biodiversity, while promoting the sustainable use of water resources in the catchment.
The FSE calls upon the DWS to, in the implementation of the NWRS-2 to, with reference to the cost/benefit analysis, consider the costs associated with the life-time of the impacts and not only the costs associated with the impacts during the life-time of the mine, since the impacts may continue for hundreds of years after mine closure.  In the absence of government interventions to compel mining companies to internalize their negative impacts, the social and environmental costs will be absorbed by the surrounding communities and other stakeholders.  The externalization of costs to communities, particularly to the poor and disadvantaged, is conceived as unfair, inequitable and unpalatable, and in contravention of the polluter pays principle.

Water Forums are voluntary initiatives with no decision-making power.  Civil society and NGOs, since they are not reimbursed for expenses incurred in participation in these Forums, including opportunity costs, have difficulty to justify their participation.  The result is civil society apathy.  
In South Africa, the representatives of the industry, including the mining industry, have greater capacity to negotiate and influence decision-making pertaining to water needs than NGOs and civil society groups with financial, technical and human resource constraints.  Greater care needs to be taken to ensure environmental justice through stakeholder engagement processes. In addition, it is problematic to assume that all stakeholders can be engaged and informed in a uniform way. Stakeholders vary widely in their ability to understand and adopt governance processes or instruments that they are not familiar with and therefore an ideal governance system needs to ensure that the participation of stakeholders at all levels is carefully balanced and integrated. 

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