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SRK – media release on navigating complexity of WULAs

Effective engagement eases WULAs in South Africa

As South Africa pays closer attention to managing its scarce water resources, it has inevitably become more complex to apply for water use licences; however, there are experts providing support through this process.

“For the best results, the water use licence application (WULA) process really needs close and constant engagement with the Department of Water and Sanitation (DWS), as well as the various technical specialists who conduct studies for the application,” said Avril Owens, principal environmental scientist and associate partner at SRK Consulting. “Specialised consultants can help applicants to streamline this process.”

For instance, there is often insufficient information at the early stages of a project to meet application requirements, but the process is generally initiated early because it can be lengthy. To deal with this challenge, environmental experts can be consulted in the concept phase, and can start the WULA process with detailed information gathering and review. This assessment of available data helps determine the best way forward, including detailed schedules with clear permitting milestones, roles and responsibilities and action plans to close identified information gaps.

Owens noted that the DWS Electronic Water Use Licence Application and Authorisation System (e-WULAAS) has been a significant step forward in streamlining the application process.

“This online system allows for uploading of documentation and assists DWS with tracking and reviewing the application,” she said. “It also allows vital communication to be conveyed to and from applicants.”

She highlights that structured communication protocols with DWS officials are important throughout the application process. These protocols may vary between the different case officers and therefore agreed upon channels of communication at the beginning of the process is vital. The officials manage multiple applications, which may impact on their availability to address ad hoc queries regarding specific project requirements. There may also be slightly different technical requirements between the various DWS regional offices, making it crucial for these to be outlined early on.

It can happen that the DWS case officer changes during the application, pointed out Giulia Barr, senior environmental scientist at SRK Consulting, therefore communication is key to bring the new case officer up to speed.

“This provides context to assist with the application review – facilitating decision making within the timeframe,” said Barr. “It is also a good idea to select one person per project or site to engage with DWS – so that there is continuity in communication.”

A WULA hinges on scientific specialist assessments and/or engineering designs. A consultants’ assistance is invaluable in terms of integrating and sharing this information with the project team. Integration and sharing information takes considerable time and effort, often requiring technical integration workshops at key stages of the project where the needs and challenges of specific disciplines can be addressed to meet the DWS WULA requirements

Owens noted that a common complication in WULAs is when there are project changes, after the application process has commenced, affecting water uses and associated mitigation measures –.

“These changes can affect the specialist assessments, incur extra cost and cause schedule delays,” she said. “It is advisable that a scope freeze be agreed upon upfront and signed off as the impact of scope changes may be challenging to mitigate.”

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