DRAFT NATIONAL WATER RESOURCE STRATEGY 2ND EDITION

The Centre for Environmental Rights (CER) submitted comments on the Draft Second Edition of the National Water Resource Strategy (draft NWRS2) to the Portfolio Committee on Water and Environmental Affairs. The CER evaluates the draft against its own 2012 report, 'Stop Treading Water', highlighting areas of alignment and critical gaps in governance, institutional stability, and regulatory enforcement within South Africa's water sector.

• The CER identifies significant institutional instability within the Department of Water Affairs (DWA), noting a loss of "institutional knowledge, experience and competence" that hinders optimal performance. While the draft NWRS2 proposes capacity-building and the appointment of leadership and technical staff, the CER argues it lacks specificity on securing financial resources, managing the transfer of skills from private sector experts, and addressing staff turnover.
• The draft NWRS2 is criticized for being "thin on strategic actions" regarding cooperative governance. Specifically, the CER notes a lack of effective mechanisms to support local authorities—despite acknowledging that weak municipal performance in water and sanitation is a "key driver of change"—and a lack of detail on how the DWA will ensure its pivotal role in development decisions concerning mining and agriculture.
• The CER expresses concern over the proposed revision of the Reserve, stating that using "economic development" as a justification for revision may further complicate and delay its implementation. The document notes that the ecological Reserve is often not met in several water management areas (WMAs) because other users are prioritized, posing a "major threat to ecosystems and their resilience."
• Water use authorisation is described as a "critical business risk" due to severe backlogs and illegal use. The CER notes that only 10% of water is used under licences and 57% of water services authorities lacked appropriate licences for wastewater treatment works in 2007. While the draft NWRS2 aims to clear the WUL backlog by 2016, the CER warns that speeding up the process must not compromise the quality of authorisations.
• Compliance monitoring and enforcement (CME) are identified as major weaknesses, with national non-compliance levels at 88%. The CER recommends moving beyond a reliance on criminal penalties—which are described as an "undue burden" on the justice system—toward an administrative penalty system to create more consistent regulatory responses and disincentivise violations.
• The CER highlights critical failures in the Water Tribunal, including the appointment of non-lawyers to determine legal questions and the exclusion of affected parties' legal standing. The CER notes that the draft NWRS2 makes "no reference to the Water Tribunal," despite the institution's essential role in hearing administrative appeals under the National Water Act.

APA

Centre for Environmental Rights (2012). DRAFT NATIONAL WATER RESOURCE STRATEGY 2ND EDITION. https://cer.org.za/wp-content/uploads/2017/10/CER-Submissions-to-PC.pdf?x21779

Chicago

Centre for Environmental Rights. DRAFT NATIONAL WATER RESOURCE STRATEGY 2ND EDITION. 2012. https://cer.org.za/wp-content/uploads/2017/10/CER-Submissions-to-PC.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=DRAFT NATIONAL WATER RESOURCE STRATEGY 2ND EDITION |date=18 October 2012 |url=https://cer.org.za/wp-content/uploads/2017/10/CER-Submissions-to-PC.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2012draft, author = {{Centre for Environmental Rights}}, title = {{DRAFT NATIONAL WATER RESOURCE STRATEGY 2ND EDITION}}, publisher = {Centre for Environmental Rights}, year = {2012}, month = oct, url = {https://cer.org.za/wp-content/uploads/2017/10/CER-Submissions-to-PC.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }