The City of Cape Town’s Draft Water Strategy is out for comment until the 15th March. This post provides a quick and opinionated précis of what it contains and the comments I’ve sent to the City. Even if you don’t agree with me, I encourage you to write to the City and have your say.
The Strategy in brief
The document is structured around 5 “Commitments”, which are defined as “A willingness to give our time and energy to something that we believe in, a promise, a firm decision to do something”
The Commitments (no, not the 1990’s Irish movie band) are guided by the Vision that “Cape Town will be a water sensitive city by 2040 that optimizes and integrates the management of water resources to improve resilience, competitiveness and liveability for the prosperity of its people.”
They are also guided by ten principles:
- Value water
- Grow inclusivity and trust
- Build capability
- Work together and across boundaries
- Design for adaptation
- Live with water
- Work with nature
- When it rains, slow, store and repurpose
- Ready for shocks
- Stimulate the green economy
If you want more detail on these principles, refer to the document.
As for the 5 Commitments, these are:
Safe access to water and sanitation (1 page of the document)
- mostly focused on improving access and quality of service to informal settlements and low-income areas.
Wise use (3 pages)
- concerning itself with reducing water losses through the City’s network, encouraging water savings by residents, and pricing water to cover the costs of the augmentation schemes.
Sufficient, reliable water from diverse sources (12 pages)
- predominantly the “Build programme” for schemes to bring new water to the City. They are largely the groundwater, water reuse and desalination schemes that are already underway as the City’s emergency response to the drought. It does give some detail on costs – namely a capital expenditure of R5.4 billion over the next 10 years. It also indicates an alien vegetation clearing budget of R20 to R40 million per annum. This range spans from no change in budget allocation for alien clearing since before the drought to a doubling in budget. It also does not indicate that the money will be spent on clearing in the catchments, which seems unlikely to be implicit, since very little of the catchment areas are within the City’s municipal boundaries. Either way, it is too little to effectively address the issue (and reap the benefits) even if it were all spent in the catchments.
Shared benefits from regional water resources (3 pages)
- proposes using undefined “collaborative processes” to optimise the economic, social and ecological benefits of regional water resources, and to reduce the risks.
A water sensitive city (2 pages)
- aims at moving the City towards one that makes optimal use of stormwater and urban waterways for the purposes of flood control, aquifer recharge, water reuse and recreation, and is based on sound ecological principles.
Translating the plan into action
This is the bit where the document gets a little thin…
It mostly outlines a list of what are essentially key performance areas (KPAs) for the City’s Department of Water and Sanitation. These do not appear to be novel, and I’d expect are basic KPAs for any water facility anywhere in the world. If anything, outlining them here is great cause for concern as it suggests that these have not been the focus for Cape Town thus far. I’d love to know what has?
As one would expect, the only area of any detail is the section on “Financing Capital Costs and Setting Tariffs”, which is the usual fluff to soften the blow of “The build programme is gonna cost a lot and you guys have to pay”.
Perhaps my biggest cause for concern is the lack of suggested key performance indicators (KPIs) to assess progress towards the KPAs. While the details of any KPIs would only come into play in the THREE(!!!) proposed implementation plans, without any indication of what the KPIs would be here it is difficult to gauge what actions the City actually envisages taking.
Which brings us to the 3 proposed…
Implementation plans
The Cape Town Water transition plan
“will be developed and implemented to achieve the transformation of Cape Town water into a modern fit-for purpose water service provider that will lead key elements of the implementation of this strategy”
- Essentially aimed at taking stock of the current state of things, the drought, and where the City needs to go from here.
The Water services development plan
- This is the only plan with any teeth, as it feeds into the City’s Integrated Development Plan and budgeting, but seems focused on capital expenditure (i.e. the “engineering solution”)
The Collaborative resilience action plan
- To create “a multi-stakeholder platform to coordinate efforts and improve governance and decision making during any period of crisis” - building on the Section 80 Water Resilience Advisory Committee
Since no justification is given for having 3 separate plans (and a strategy), the conspiracy theorist in me is suspicious that this is an attempt at divide and conquer. “We’ll let people have their say through the Collaborative resilience action plan”, but then that plan either never gets off the ground, or is written (most likely by a verbose consultant), filed and ignored.
Annexures
Finally, there are a series of annexures to support some of the content reported in the body of the document. These are not without flaws, but I’m going to hold back, other than to say that the interpretation of changes in Perth’s runoff into dams (Figure A1) as a massive a step change in rainfall driven by climate change impact creating is disingenuous.
The figure is presented as a step change in rainfall and evidence for climate change, yet the data shown are for runoff, which depend on a variety of other factors too. In fact, the book Ludwig et al. 2012. Climate Change Adaptation in the Water Sector presents the same data (up to ~2007), citing catchment management and pressures on groundwater sources as equally important drivers of the change, but the relative importance of the various drivers is yet to be quantified.
This interpretation is key as the City has made no clear commitment to addressing catchment health (including clearing invasive alien plants), but is investing over a billion Rands into abstracting groundwater from catchment areas…
My comments to the City
The City forces you to provide comments by section. I submitted all of these under the section “Translating the strategy into action”, but also submitted Comment 1 to Commitments 1, 4 and 5.
Suggestion:
One approach would be to commit to a reassessment of the existing build programme (and/or committed capital expenditure) in the context of Commitments 1, 4 and 5 and the 10 guiding principles. This build programme commits the City to a course of action that will unfold over the next 10 years. It is key that it aligns with the Strategy, otherwise the City delays beginning to deliver on its commitments for a decade or more…
Comment 2:
No justification is given for having 3 separate implementation plans (in addition to this Strategy). A conspiracy theorist may be suspicious that this is an attempt at divide and conquer, with the City thinking “We’ll let people have their say through the Collaborative resilience action plan”, but then that plan is either never given enough support to get off the ground, or is written (most likely by a verbose consultant), filed and ignored.
Suggestion:
Provide a clear justification of why three separate implementation plans are required and how they support each other, or revise to have only one implementation plan. A single plan makes more sense, since you would need to address trade-offs and conflicts between goals explicitly a priori. Taking this action at a higher level is key, as the strategic overview is lost once it is devolved to individuals to implement the plan(s) on the ground as isolated entities.
Comment 3:
More generally, it seems inconceivable that any strategy aimed at providing a large number of people sufficient access to a scarce resource does not put more emphasis on protecting the source of that resource. While the strategy discusses this under Commitment 4 “Shared benefits from regional water sources”, it is far too brief and vague. Protection of the source should be step 1 of any resource-provisioning programme.
The current document makes much of climate uncertainty, and glosses over or ignores other threats to the source, including a number of drivers that have large impacts on surface water resources such as land cover change and groundwater abstraction. A case in point is Figure A1, which the City presents to make the case that there has been a climate change induced step change in rainfall in Perth in the past ~50 years. The City suggests that the data presented are rainfall, yet they are actually for runoff into Perth’s dams, which depend on a variety of other factors too. In fact, the book Ludwig et al. 2012. Climate Change Adaptation in the Water Sector presents the same data (up to ~2007), citing catchment management (predominantly pine plantations) and pressures on groundwater resources as equally important drivers of the change, but indicating that the relative importance of the various drivers is yet to be quantified. This interpretation of climate change vs change in climate and catchment health is key as the City has made no clear commitment to addressing catchment health (including clearing invasive alien plants) or protection (e.g. restrictions on land-use activities), but is investing over a billion Rand into abstracting groundwater from these areas.
Table 1 indicates an alien vegetation clearing budget of R20 to R40 million per annum. This range spans from no change in budget allocation since before the drought to a doubling in budget. It also does not indicate that the money will be spent in the catchments, which seems unlikely to be implicit, since very little of the WCWSS catchment area is within the City’s municipal boundaries. While the City indicates constraints on spending outside its municipal boundaries, it has done so in the past, including large water projects like building the Berg River dam. Either way, the City’s suggested budget allocation is too little to effectively address the issue of water losses from alien plants in the catchments (and reap the benefits) even if it were all spent in the catchments.
Suggestion:
The City needs to lead by example among regional water users/municipalities and show a clear and on-going commitment to water source protection. As the biggest role player it stands the most to gain. Potential avenues inter alia are:
A large and sustained investment in clearing of alien vegetation, such as R150 million or more per annum over the next 10 years. This would release more water than any of the proposed built infrastructure in Table 1, at a fraction of the cost. If it is easier to spend Capex than increase operating costs then this could be done, e.g. by buying equipment to support the operations of existing alien clearing programmes (e.g. Working for Water, The Nature Conservancy), such as chainsaws, rope access gear, or vehicles (even helicopters).
Aid in the measurement and management of groundwater resource abstraction. There are currently many users and few records, prohibiting adequate measurement, modelling and monitoring of the resource and risking a “Tragedy of the Commons” scenario. The City should take a leading role in coordinating users and role players in this sphere. Beyond being a finite resource, groundwater abstraction is very likely to have large impacts on biodiversity (through surface developments and draw-down impacts). Abstraction is also likely to affect stream flow, as many rivers in the Cape depend on groundwater to sustain summer “low flows”. These flows are key for ecological function, but also for services to the City, such as effluent transport by rivers that have been canalized or integrated into storm or wastewater networks.
Comment 1:
While there is much information on the build programme (Commitment 3) and Wise Use (Commitment 2), the document lacks clear indication of actual commitment to Commitments 1, 4 and 5. As it stands, it is very thin on what actions will be taken and what key performance indicators would be used to gauge progress towards these commitments.