1. Draft National Water Resource Strategy

2. Focus CAIA supports BUSA submission Water conservation Economic charge
Regulatory reform

3. 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

4. Water use efficiency in chemical industry

5. 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

6. 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

7. 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

8. 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