Draft National Water Resource Strategy

Focus CAIA supports BUSA submission Water conservation Economic charge Regulatory reform

Water conservation Joint project with DWA on development of water use audit protocols as basis for determination of a long term water use efficiency target Chemical Iron and steel Agro processing Paper and pulp Ferro alloys No reference to initiatives in draft

Water use efficiency in chemical industry

Economic charge No reference in draft strategy to Waste Discharge Charge Strategy (WDCS) Proposal in WDCS: Mitigation charge = user charge Incentive charge = tax Complementary to other regulatory measures

Economic charge (2) Challenges Chemical industry: Application to compliant and non compliant users Investment by compliant user therefore not recognised Only applies to point sources Tax cannot be imposed on municipalities Potential double charge on municipal users Chemical industry: Strives for high level of compliance Most discharges to sewer Possibility of offsetting

Regulatory reform Long delays in obtaining a license Lack of regional harmonisation in requirements License conditions ultimately unachievable Limits based on unrealistic Receiving Water Quality Objectives Focus on private sector dischargers

Conclusions Draft strategy not necessarily aligned with other developing sector strategies Water conservation should be aggressively pursued in partnership with industry Waste Discharge Charge System should be included and should be subject to impact assessment before finalisation Regulatory reform should be pursued using platforms for engagement with private sector