3.1.1. Principles of the National Water Resource Strategy Relevant to Eskom
The NWRS provides the implementation framework for the National Water Act (no. 36 of 1998) (NWA), which states that the nation’s water resources must be protected, used, developed, conserved, managed and controlled in accordance
with the NWRS. The NWRS was first adopted in 2004, and is scheduled for review every 5 years after mandatory consultation with stakeholders. The next iteration is scheduled for 2010, and a draft which will be available early in 2009 is currently being compiled by DWA. The ultimate objective of the NWRS is to allow strategic management of national water resources.
The NWRS is a comprehensive document, and our aim is not to repeat it. Rather, discussions will review aspects of the NWRS that are considered to be relevant to Eskom’s Water Supply Strategy in the Lephalale region.
3.1.2. Protection of water resources
The NWRS highlights the fact that South Africa is a country with scarce and unevenly distributed water resources. Protection of this resource should therefore be the priority of all users. Protection of water resources in terms of the NWA refers to maintaining both water quality and quantity at desired levels through two fundamental approaches:
• Resource-directed Measures measure the condition of the resource itself, including in-stream and riparian habitats and the condition of aquatic biota • Source-directed Controls seek to manage water use activities at the source of impact through tools such as standards and conditions included in water use authorisations.
This applies to both surface water and groundwater, which could both be impacted upon by Eskom’s Medupi operations. In particular, migration of mobile species from Medupi’s ash dumps (which may include disposed Gypsum) is a matter requiring consideration in this regard.
3.1.3. The “polluter pays” principle
Where the resource is polluted through accident, negligence or deliberate actions, the NWA holds the polluter responsible for clean-up and rehabilitation of the resource. This applies to both point source and diffuse source pollution, the latter being the primary mode through which Medupi could impact on water resource quality.
Risks to Medupi arise from the potential co–disposal or single disposal of gypsum and ash. DWA’s stance is that pollution of water resources is to be avoided as
far as possible. Where avoidance cannot be achieved, the aim is to avoid irreversible damage and to ensure that other users of the resource do not bear the costs of the pollution i.e. costs are to be internalised by the generator of the pollution.
It is therefore important that in the absence of appropriate gypsum markets, clear consideration is provided for the additional liabilities that Medupi could be required to manage.
3.1.4. Authorisation of water use
The use of water for power generation has to be authorised. Such authorisation must be current, and the conditions attached to each authorised water use must be met by the user. Water Use Authorisation gives DWA significant leverage through the conditions attached to each licence. Systems should be in place from Eskom’s point of view to enable routine monitoring and measurement of compliance to licence conditions. Non-compliance is an offence in terms of the NWA.
3.1.5. Water Conservation and Water Demand Management
Due to the spatial distribution of surface water resources across South Africa, water transfers are an unavoidable reality. Dams are also a necessary part of water resource infrastructure in the country, due to the seasonality of rainfall patterns. The NWRS seeks to complement these supply-side options with demand-side initiatives, the most important of which from Eskom’s perspective would be a focus on water conservation and water demand management (WC/WDM). Medupi Power station therefore cannot assume that it is the responsibility of DWA to ensure security of supply. Eskom, and indeed the Medupi Power Station, needs to carefully manage its demand for water.
3.1.6. Power generation as a strategic water use
In terms of the NWRS, operational responsibilities for water management will be devolved from DWA to Catchment Management Agencies (CMA’s) which will be responsible for these matters in each of the nineteen Water Management Areas (WMA’s) in South Africa. The NWRS assesses water resources in each of these WMA’s against demand, and identifies development opportunities and constraints. Water demand is considered for various sectors, specifically irrigation, urban, rural, mining and bulk industrial, power generation and aforestation. Of these, power generation is officially recognised as a strategic user of national importance, subject to authorisation by the Minister of Water Affairs and Forestry rather than a CMA. This means that water transfers between WMA’s (the other strategic use recognised in the NWRS) to supply Eskom’s needs are supported by DWA and that there is a commitment to a secure supply for the sector. Strategic users do not however receive the highest water use priority, and are preceded by provisions for the water reserve, international obligations and agreements, and water requirements for social needs.
The fact that Eskom enjoys strategic user status imbues the organisation with unique responsibilities, not by law, but through the required sense of social responsibility expected from corporate citizens of the scale of Eskom. It would be unacceptable for the organisation to use as much water as it does (1.5% of SA’s annual fresh water consumption) without considering other users, particularly given the need for social redress in South Africa. This responsibility is fundamental to the evaluation of the need for FGD in the context of water demand and supply in the Lephalale region
3.1.7. Integrated Water Resource Management (IWRM)
A fundamental principle of the NWRS is that of integrated water resource management (IWRM). The IWRM philosophy recognises that various competing objectives associated with water use have to be considered in a holistic fashion in order to achieve the best overall outcome. It recognises that water use efficiency and water quality are indivisible, and that environmental, social and economic issues are best considered as an integrated whole where water use is concerned. IWRM recognises further that surface water and groundwater are both components of the resource and have to be managed as an integrated whole.
These principles apply at the national level, but they apply equally to local environments as well. Consequently, Medupi Power station represents an integrated water management system, which receives raw water and will produce effluents which can impact on surface and groundwater resource quality. The securing of water supplies to the power station requires consideration in concert with water conservation plans for that power station, and with careful review of the network of power stations, and other water users that may be sharing the resource and infrastructure with the station concerned. Water use for the power generation should not compromise social redress, economic growth opportunities of other users, the environment or South Africa’s international obligations.
3.1.8. A Summary of Implications of the NWRS for Eskom
As a water-intensive industry, Eskom has to secure water supplies to the organisation’s various power stations, including Medupi.
In the long term, unresolved water management issues will ultimately be reflected in the price of water, or the cost of compliance to specific water use authorisation conditions which DWA may impose on Eskom. Water management issues run deeper than commercial considerations only, however. Water is a national asset with social value, and Eskom is in the unique position, as identified by the NWRS, of being the only organisation recognised by DWA as a strategic water user. With this comes a level of responsibility towards water use that transcends that of other users in South Africa.