Evaluating the quality of water use licence application technical reports for solar power plants in the Free State Province

Abstract

Globally, water resources are under pressure due to anthropogenic activities. One of the major contributors is the energy sector, driven by the increasing need for reliable electricity generation. In response to the environmental degradation of traditional electricity generation, renewable energy initiatives such as solar power plants are increasingly proposed in many countries, including South Africa. Semi-arid provinces in South Africa, such as the Free State province, have attracted solar power plant development due to abundant solar radiation resources. However, the province is known for threatened endemic biodiversity, protected areas, and stressed water resources. Despite the sustainable nature of solar power plants, they are not developed without environmental impacts, especially on water resources. The National Water Act (Act 36 of 1998) provides for the licensing of activities that may have negative impacts on water resources. This licensing process entails the submission of a Water Use Licence Application (WULA) technical report that is subjected to the scrutiny of the competent authority before the licensing of water uses. However, recently, the completeness and substantive quality of report content have been questioned. Therefore, this research aimed to evaluate the quality of WULA technical reports for solar power plants in the Free State province and to offer recommendations to improve their quality. The evaluation followed a case study approach in which a sample of eight WULA technical reports was evaluated against the criteria of an adapted review package. The evaluation results revealed an overall satisfactory performance (A-C=51%; D-F=49%) with omissions identified in certain subcategories. Review area 1 (description of the development) and review area 2 (specialist assessment of impacts) performed predominantly satisfactorily in their sub-categories. Whereas review area 3 (alternatives and impacts) performed average, and review area 4 (communication of results) displayed unsatisfactory performance. Overall, subcategories that performed unsatisfactorily include the baseline conditions, waste, alternatives, public participation, the inclusion of non-technical summaries, assessment of impact significance, commitment to mitigation, report layout, presentation, and emphasis of information. The satisfactory performing categories are site description, environmental description, definition of impacts, identification of impacts, prediction of impact magnitude, scope and effectiveness of mitigation, and report emphasis. To address the gaps in quality of the WULA technical reports, it is recommended that Environmental Assessment Practitioners (EAPs) be provided with the final project designs to understand the project holistically and scope in all possible potential impacts into the WULA for all relevant specialist studies to be submitted. The appointed EAPs and specialists should adopt a project life cycle approach in their assessments of water-related impacts. The Department of Water and Sanitation (DWS) should continually conduct workshops in the water sector related legislation for applicants to include all legal requirements, climate change, and emergencies in their WULAs. The required DWS Risk Assessment Matrix must be templated to include wasterelated impacts and impacts on Interested and Affected Parties.