Applying for and obtaining amendments to water use licences is an ongoing and often time-consuming process for most mines, even when the adjustments are relatively low-risk, according to SRK Consulting principal environmental scientist Jacky Burke, the leader of SRK’s water use licence application (WULA) Group.
Speaking recently at a WULA workshop hosted by SRK in Johannesburg, Burke said due to the dynamic nature of mining – which constantly adapts to changing conditions – amendments to existing water use licences and applications for additional new water uses are a regular requirement for mines. She highlighted that SRK’s experience in this field – including its constructive working relationships with the Department of Water and Sanitation (DWS) – positions it well to conduct the necessary specialist studies for mines, assist with applications, and also follow up actively where necessary with the DWS to facilitate an outcome in good time.
“Water is a complex field and everyone involved is on a steep learning curve with the stringent new licensing system,” said Burke. “But we are confident that by sharing our experiences in workshops like these – and continuing to receive guidance from DWS – we can help clients improve compliance and reduce operational and closure liability costs.”
The workshop focused on the new Electronic Water Use Licence Application and Authorisation System (EWULAAS), highlighting the value of making the financial and time investment early in a WUL application so that costs can be saved later. Experts also outlined how applications could benefit from the DWS’s more streamlined and manageable process – while also considering where challenges that delay the application process were being experienced.
SRK senior environmental scientist Avril Owens emphasised that the web-based EWULAAS system was user-friendly and followed a logical flow process in three key steps: a first, pre-application phase; a second phase in which supporting documents and water use forms are submitted on-line; and a third phase where a technical report and additional specialist information are uploaded for DWS decision making.
“EWULAAS certainly promises to be a great improvement on the original paper-based system,” said Owens. “Among the advantages is the ability to generate a summary of water uses per farm prior to phase one submission, to verify that all water uses have been correctly captured on the system and highlights any gaps in the application; also, the submission can be tracked on-line, providing more transparency on its progress.”
As with any new system, she said, there were going to be teething issues, so SRK maintained close working links with DWS to help ensure that the system worked optimally.
“There is no doubt that this is a better way to go – with applicants knowing that all the information is there, that nothing can get lost, and that the process can be tracked,” she said. “There is obviously also a human element to the system, and as users we also have to play a constructive role in keeping everyone to the deadlines.”
Owens emphasised the importance of the pre-application phase, in which applicants meet with DWS to clarify their way forward; in fact, most of the preparation work is required to be completed before the on-line submission process can begin.
Highlighting the type and scale of activity to be undertaken, SRK principal environmental scientist Didi Masoabi said it was important for applicants to be aware that site-specific environmental impact assessments and specialist studies may need to be conducted.
“Public participation is also an important element of a WULA, as interested and affected parties need to be informed about what you plan to do and how it may impact them,” said Masoabi. “Depending on the size of your project, the DWS may need more information on how you intend to communicate with the public about your project.”
The workshop included presentations by SRK environmental scientists Giulia Barr, Angelika Möhr and Björn Schroder, as well as Stephen van Staden, an accredited aquatic biomonitoring specialist at Scientific Aquatic Services (SAS).
Burke said it was vital for WUL applicants to have the findings of their studies thoroughly reviewed by experienced experts to minimise the potential for unreasonable conditions in the water use licence based on specific specialist findings, and that the SRK WULA team was geared to tackle complex projects within the evolving environmental legislative framework.
“We work with clients on projects from concept stage through to closure, providing services such as integrated WULAs, general authorisation applications, WUL amendment applications, and WUL audits,” she said.
