For water use licences (WULs) to be successfully granted, the application process needs to be made simple and easy to understand by representatives from the Department of Water and Sanitation (DWS), according to Sibanye Gold water engineer Lauren Dell.
She presented on the topic ‘Water use licence application success and lessons learnt’, during the yearly Southern African Institute of Mining and Metallurgy (SAIMM) Water 2017 Conference, which was held from July 10 to 11 at Emperors Palace, east of Johannesburg. The event was hosted by the SAIMM and the Mine Metallurgical Managers Association.
She said water resources were regulated under the National Water Act, No 36 of 1998, which applies to consumptive and nonconsumptive use. Therefore, all mining activities involving water required a valid WUL, including metallurgical plants, making successful and timeous granting of such licences critical, she stressed.
However, there are several challenges in terms of obtaining a compliance certificate, including long application processing times of up to several years. In addition, issued licences may contain a number of inaccuracies or unachievable criteria, such as clerical errors, conditions not related to the applied-for applications and excessive monitoring requirements.
Negative impacts resulting from these challenges could be elevated costs and an increased administrative burden. However, in instances where unachievable criteria were set in issued WULs, Dell said the compliance auditing process would unearth issues of technical noncompliance, which would affect the miner’s reputation and stakeholder confidence, and could expose management to risk.
Therefore, much of the trouble could be mitigated by “getting it right the first time” when applying for and being granted an easy-to-abide-by WUL, she stated.
Key to “getting it right” is the incorporation of the WUL into the design of water-related projects.
Another key consideration is the relationship between WUL applicants and the DWS. “[Representatives from] the DWS are friends,” Dell said, adding that the relationship with the DWS needed to be nurtured and valued through continuous proactive engagement with case officer and prompt attention to requests for information from the DWS.
Dell concluded that the process of applying for a WUL should be made as easy as possible for a DWS case officer to decipher, and any questions posed by the DWS should be handled with urgency and transparency.