TLU SA is concerned about the proposed notice of the Revision of Regulations regarding the Procedural Requirements for Water Use Licence Applications and Amendments in terms of section 69(1) of the National Water Act, 1998 (Act No. 36 of 1998), published for comments on 19 May 2023 by the Minister of Water and Sanitation.
The implications to the production process are of such a nature that the outcome of this if it is made applicable, will play a negative role in the sustainable availability of food for our country’s citizens.
- Right of Business
The Constitution stipulates it is citizens’ right to decide where and how they want to do business. With this proposed approach, this choice is taken away from entrepreneurs. - Production of food
The utilisation of water is an essential part of the production of food. The strategic value of food on our consumers’ tables is so significant that we can’t mess around with it. The allocation of water to land does have a history, and the present users of the water do have an invested right to that water and land used in the production process. - Employment and urbanisation
The agricultural sector, with around 37 000 commercial farmers producing food, utilises approximately 63% of the water in South Africa. That is to ensure that we have food on the table, especially for urbanised people, namely about 70%. This so-called empowering attempt will address a small portion of the population with no actual empowerment. Out of more than 60 million people in our country, of whom almost 50% are unemployed, that is not an honest way of creating the impression of empowering people.TLU SA states that this way of trying to empower people is not feasible. It is impossible to empower people by handing over some assets and thinking it is empowering. The government should instead teach people how to accept the responsibility that life demands from all of us. People should work for a better life and let go of this demanding culture that creates the impression that they are entitled to some benefits. - Economic market forces
Market forces always have the last say in sustaining an economy – it entails applying economic principles. The outcome of a socialist policy, the way these regulations were proposed, is bound to fail and cannot be supported.
Without going into the lack of sound procedural principles, the proposed revisions give the impression that this document was compiled in a hurry and with ulterior motives with many variables that cannot work.TLU SA, therefore, rejects these proposals regarding the transfer of ownership of the assets if applying for a water license.



