WATER USE LICENSING AND AUDITING- South African National Water Act, 1998 (Act No. 36 of 1998)
The National Water Act, 1998 (Act No 36 of 1998) (NWA) defines various categories of permissible water use including Schedule 1 uses, generally authorised uses, existing lawful water uses, and water uses requiring licensing. Section 21 of the NWA identifies water uses activities including consumptive (for example the taking and storing of water) and non-consumptive water uses (for example disposing of waste in a manner which may detrimentally impact on a water resource or the altering of the beds, banks, course or characteristics of a watercourse). GCS has many years of experience in the compilation of Integrated Water Use Licence Applications (IWULA) which has been gained in a variety of sectors which include but are not limited to mining (coal, gold, platinum, iron mining, and prospecting activities), golf courses and residential developments, industry, municipal water supply and water bottling plants.
The company provides comprehensive services relating to water use licensing and the water use regulation process, including:
Integrated Water Use Licensing – GCS specialises in handling the water use licensing process on behalf of an organisation, allowing for maximum efficiency and minimal costs and delays. GCS have the expertise and experience to undertake IWULA processes and follow up and liaison with the Department of Water and Sanitation (DWS) to ensure the effective processing of the applications and the issuing of a correct Integrated Water Use License (IWUL) to authorise all water uses triggered.
Water Use License Auditing and Amendments – GCS have the skills to assess compliance with license conditions and compile and submit licence amendment applications. GCS undertakes detailed assessment audits of an organisation’s compliance with its water licence conditions and, where possible, advises the client how to achieve and sustain compliance.
Water Use Registration – Our in-house expertise includes application for water use registration in terms of the General Authorisations (GAs) in Government Notices published by the DWS. GCS assists organisations in identifying their specific water use registration requirements, completes the relevant application and registration forms and ensures that the water uses are properly registered and lawfully undertaken.
Transfer of water use entitlements – The transfer of water use entitlements has become an important process in the water stressed sectors of the country. GCS provides the necessary assistance with regard to such transfers, including the
identification of water sources and supply, the preparation and submission of the necessary documentation to the regulatory authorities.
GCS has the required expertise to develop Integrated Water and Waste Management Plans (IWWMPs) and has gained extensive experience in the compilation of IWWMPs across a variety of mining sectors, which includes but is not limited to coal, gold, iron and platinum mining. GCS is also able to provide IWWMPs for all industries, golf courses, residential developments, municipal water supply projects and water bottling plants should they be required by the DWS.
Authorisation and specialist report Review for appeal processes: GCS has a large set of in-house specialists who can independently
review authorisations and specialist studies undertaken to apply for water use licenses.

In support of the water authorisation services, the following actions are generally undertaken:
Site visits to identify Section 21 water uses (in terms of the NWA) and water users related to a project. Determination of the correct authorisation routes required in terms of the NWA.
Giving advice and recommendations to the client in terms of the water legislation and other guideline documents.
Compilation of IWULA Technical Reports and IWWMPs with the required technical detail to the satisfaction of the DWS. This includes the assessment of impacts and management measures associated with the various water uses; water and waste management; motivation for water uses and discussion of alternatives, Section 27 Motivation (related to socio-economic aspects, redressing of past racial and gender discrimination, upliftment of communities, etc.), monitoring
requirements and completion of the required application forms. Through these reports, GCS ensures that all requirements are met in order to obtain a license from the DWS.
Existing relationships and extensive liaison with DWS Regional Offices and Head Office prior to and during the project ensure the process run smoothly. Pro-active follow up of the application after submission is also undertaken with the DWS.
Site visits and information review to determine compliance of an operation to the license conditions. Compilation of an audit report showing percentage of compliance and provision of mitigation measures to correct identified non-compliances.
GCS has the necessary expertise, staff and equipment to undertake the required investigations and reporting within various sectors and over a wide range of situations.
GCS ensures that the most up to date legislation and guidelines are used in the application process. GCS has experience with the electronic Water Use Licence Application and Authorisation System (e-WULAAS) and the regulated timeframes as detailed in the Regulations regarding the procedural requirements for water use license applications and appeals (GN R 267).

YEARCLIENTOPERATIONPROJECT
2019Anglo Gold Ashanti (AGA)Kareerand TSFKareerand TSF Expansion IWULA and IWWMP
Technical report compilation and submission to the DWS
2018SARAONorthern CapeSquare Kilometre Array (SKA) IWULA and IWWMP
Technical report compilation and submission to the DWS
2018Skyline InvestmentsWestern CapeVigne d'Or Farm groundwater abstraction WULA
Technical report compilation and submission to the DWS
2017Centre for Environmental RightsMabloaMabola Protected Environment Appeal
Review of specialist reports and water tribunal appeal
2017Booysendal Platinum (Pty) LimitedBooysendal MineBooysendal North Mining IWULAs
Technical report compilation and submission to the DWS
2016Consol Glass (Pty) LtdPhilippiPhilippi Mine IWULA and IWWMP
Technical report compilation and submission to the DWS
2015Crowhurst House (Pty) LtdEvertonCrowhurst Waste Treatment Plant IWULA
Technical report compilation and submission to the DWS
2015Berry Select (Pty) LtdBronkhorstspruitIWULA Assistance and Government Liaison
2015Elements 227 (Pty) LtdGolf Course EstateElements IWULA & IWWMP
Technical report compilation and submission to the DWS
2015Samquarz (Pty) LtdDelmas DivisionSamquarz Mine IWULA Assistance 2015
Client assistance and liaison with the DWS
2014Zinoju Coal (Pty) LtdCoal MiningAviemore Mine IWULA Follow-up
Liaison with the DWS
2014Kangra CoalPiet RetiefMount Ngwibi Mine Closure IWULA
Technical report compilation and submission to the DWS
2014Booysendal Platinum (Pty) LtdBooysendal NorthBooysendal Mine IWULA Amendment
Technical report compilation and submission to the DWS
2014Kangra Coal (Pty) LtdPiet RetiefMaquasa Mine IWULA DWS Response
Liaison with the DWS
2014Airports Company South Africa (ACSA)DurbanACSA King Shaka Airport IWULA
Technical report compilation and submission to the DWS
2013Zululand Anthracite Colliery (Pty) LtdUlundiZAC Mine IWULA DWA Response
Liaison with the DWS
2013Northam Platinum LimitedZondereinde MineZondereinde Mine IWULA Amendment follow up
Zondereinde DivisionLiaison with the DWS