Rand Water’s progress reports in addressing the sewage pollution of the Vaal and the FSE’s comments

FSE’S COMMENTS ON THE VAAL INTERVENTION PLAN

The FSE is a member of the Vaal Intervention Steering Committee.  

The first attached Report was presented during a meeting with the Deputy Minister (DM) of Water and Sanitation, DM Mahlobo to the Vaal Intervention Steering Committee on the 4^th of February 2022 during the Section 63 Stakeholder Engagement meeting.  The second attachment is the Progress Report prepared by GIBB for the Department of Water and Sanitation (DWS).

The FSE raised the following concerns:

1. 1. The directives, which were issued by the SAHRC pursuant to the Commission’s investigation in loco in September 2018 and its “Final Report of the Gauteng Provincial Inquiry into the Sewage Problem of the Vaal River”, namely that officials in non-compliance with legislation be dismissed and that corruption be referred to the Public Protector and SAPS,  are not addressed in the Intervention Plan.
3. 2. Whilst the FSE is heartened by the proposed implementation of the Intervention Plan by Rand Water, the fact that Rand Water is operating without a water use licence for the last 8 or more years is a matter of serious concern.  Operating without a water use licence is unlawful.  
5. 3. In terms of the attached “Sedibeng Regional Sanitation Scheme Progress Report for the Department of Water and Sanitation for the Vaal River System Intervention (Refurbishment Works) – Period Ending 31 December 2021” prepared by GIBB (Document No: J39079-0-G1-MPR04, dated 13 January 2022) (“GIBB Report”) the required Capital Funding for the Short Term Intervention Programme is estimated at R1,012,802,219, that is, excluding the operational costs (OPEX).  Rand Water has received R100 million from the DWS with an additional promise of another R100 million.  No information has been provided regarding how additional funds will obtained.
7. 4. In terms of the GIBB’s Report there is a failure to appoint the much needed Civil, Mechanical and Electrical Contractors and the implementation programme has not been implemented as the appointment of the Civil Contractors, Mechanical and Electrical Contractors have not been finalised.  Service Level Agreements are still to be concluded with 7 civil contractors and the appointment of mechanical and electrical contractors is to be re-advertised due to an overall non-responsiveness in the first round of call for bids. 
9. 5. The Intervention Plan only addresses the upgrading of plants, unblocking of sewer pipes but fails to address the sewage pollution and other challenges within the Integrated Vaal River System (IVRS) since the Vaal Barrage falls within the IVRS and pollution upstream will impact on the Vaal Barrage.
11. 6. There is a need to also rehabilitate the polluted wetlands and eco-systems.  The Intervention Plan, according to the FSE’s understanding, does not address the rehabilitation of the polluted wetlands and eco-systems.
13. 7. In terms of the GIBB Report the existing sewers and pump stations in the region are overburdened, due to population growth and development. The Intervention Plan, according to the FSE’s understanding, does not address the disconnect between the growth in formal and informal housing and the provision of sanitation and treatment of sewage.
15. 8. In terms of the GIBB Report a fleet of 7 bakkies and 2 Jet Vac Truck are currently out of commission to undertake the Operational and Management (O&M) work. 
17. 9. In terms of the GIBB Report there are fuel shortages and this is a recurring issue. 
19. 10. In terms of the GIBB Report, the IMQS and Google Earth files are outdated or incomplete. 
21. 11. The Intervention Plan must be scientifically defensible. There is a need to understand the science which supports the Intervention Plan.  This is not provided in the Intervention Plan.

Relevant documents below.