Project developers will now have to invest in more upfront work to generate detailed engineering specifications for their water use licence applications (WULAs), before they make their submission.
This follows the development by the Department of Water and Sanitation (DWS) of a series of technical advisory notes (TANs) and design checklists to which applicants must adhere. This move aligns with the shift in global best practice to integrate engineering aspects with environmental, social and governance (ESG) issues and financial sustainability in all projects.
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According to SRK Consulting principal scientist Jacky Burke, this shift has long been embraced by SRK and is driven by various international bodies including the United Nations and the International Commission on Large Dams (ICOLD). The requirements outlined by the DWS were anticipated by SRK and are in line with regulations published in 2017, in Government Notice R267.
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“The DWS is following the global trend towards the sound engineering of all existing and proposed structures, including supporting facilities such as silt traps and water diversions,” said Burke.
“The higher level of detail is to assist DWS case officers in their initial assessment of submitted WULAs; more importantly, the TANs and checklists also assist applicants in meeting engineering requirements upfront rather than after their WULA submission.”
She noted that this will require more early-stage work by the applicant but will improve the efficiency of the WULA process and reduce the time taken to obtain approval. The principles underlying this latest move are water conservation and environmental protection, part of a constant evolution of practices toward ensuring that the proposed design will facilitate efficient use of water and minimise pollution.
Adriaan Meintjes, partner and principal geotechnical engineer at SRK Consulting, also highlighted the significance of the new requirements for the design of tailings storage facilities on mines.
“In addition to the need for protection of our water resources, there is the need to protect against the failure of structures – to save lives and to reduce the related impacts on the affected environment, stakeholders and communities,” said Meintjes.
The new approach by the DWS means that all WULAs involving engineering design work will now need to include a proof of concept, a design report with drawings to the required level, and a construction quality assurance (CQA) plan.
“The proof of concept may involve site specific investigations, field and laboratory testing, and the required engineering of all structures,” said Burke. “The feasibility of the concept or design must be proven, to give assurance to the DWS that the stability of the structure over its intended life is adequately engineered to minimise any potential risks of failure.” Any review by another stakeholder should then come to the same conclusions.
In terms of WULA submissions, this means that structural risk must be assessed and mitigated by suitable engineering works – and incorporated into the designs and CQA plan submitted with the WULA.
The design level acceptable to the DWS is outlined in the TANs, based on the Engineering Council of South Africa (ECSA) Board Notice 138 of 2015, which defines various stages of a project. This states that the Stage 2 level of design is generally inadequate for regulations requiring a quantified performance, but may be adequate in some projects.
“Stage 3 is the stage of design which is the basis of quantified performance assessment and subject to review by authorities,” she said. “Here, the concept must be developed to finalise the design and to outline specifications; the submission must incorporate a cost plan and define both the financial viability and a programme for the project.”
It is at this stage that the regulatory requirements must be built into the design and reflected in the design drawings – including draft technical details and specifications. The Stage 4 project elements – essentially the tender documentation and procurement of construction services – can be done once the WULA is approved and a water use licence is issued.
“The CQA Plan now also required in the WULA submission establishes the procedures to verify that construction is in accordance with the construction drawings and specifications,” she said. “It must also verify that construction will meet the appropriate regulatory requirements, with the necessary documentation for submission to the regulatory authority.”