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© 1999 DWAF.
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Last updated: 18 March 2004. 
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In South Africa, afforestation has been declared as a stream flow reduction activity (SFRA)  regulated by means of a licensing system in terms of Chapter 4, Section 36 of the National Water Act (No. 36 of 1998). This licensing system has replaced a permit system that has been in use since 1972 and which was regulated under the Forestry Act. The licensing system is required because:

  • Industrial forestry is concentrated on 10% of the land area that produces 60% of this country’s water resources.
  • Industrial afforestation is, to all intents and purposes, a permanent change of land use from relatively low water use veld, to a higher water use crop. The main exception to this is some rotation between forestry and agriculture governed by changing economics. The land use can be changed, albeit with considerable difficulty, but not back to the natural state. However, it is very rare that forest lands are converted back to their natural condition. The effectively permanent change to a higher water use (= runoff reduction) therefore demands a conservative approach in a water-scarce country.

The original Afforestation Permit System (APS) instituted in 1972, was geared towards determining areas available for afforestation, based on the calculation of the percentage reduction in flow regimes caused by tree planting at primary catchment scale, without the consideration of the detail of impact on other water users, for example, low flows or in smaller catchments. The 1972 classifications of  0%, 5% and 10% reductions in Mean Annual Runoff (MAR) from whole or part of primary catchments, guided decisions on determining areas to be planted. This was average annual runoff, which had no concern for low flows: perennial streams could be converted to seasonal streams, with concomitant effects on those relying on the run of the river.

As a result of the various shortcomings, especially local participation in decision–making in the original (1972) system, the previous Minister of Water Affairs and Forestry (1994 - 1999), Prof. Kader Asmal, made an announcement in January 1995 which heralded the development of a new procedure for the APS. This new, more comprehensive procedure was developed in consultation with major role-players in the forestry sector of the country, as well as affected parties, and embodies the Department’s commitment to openness, transparency and accountability in all its activities. The new procedure is subject to rigorous and continual auditing, both internally and externally, in conjunction with interested and affected parties. Since 1 October 1999, when Chapter 4 of the National Water Act (No. 36 of 1998) was promulgated, the Afforestation Review Panels (established in 1995) became known as Stream Flow Reduction Activity Advisory Committees.

Decision–making has widened in scope due to the multi-disciplinary nature of the provincial decision–making bodies, which have adopted responsibility for ensuring good practice forestry in term of both society and environment.

The SFRA Licensing system as it looks today:

The licensing system remains flexible and receptive to practical and meaningful inputs in the application of new procedures. Areas of concern and contentious issues in the original pre-1995 system have been addressed, but the system is still continually being updated and changes include the following:

  • The old APS was previously overseen by the Forestry Chief Directorate – considered to be a conflict of interests as the function of promotion is incompatible with that of self-regulation. A new division has been created within the Water Affairs Branch, called Stream Flow Reduction Allocations (previously Afforestation Permit Control), that, in conjunction with Regional Water Affairs Offices, deals with the protection of water resources that could potentially be affected by afforestation and other SFRAs;
  • The APS originally lacked transparency in that there was no public accountability, no procedures for appeal by affected parties and no effective monitoring, control or audit of compliance with permit conditions or expiry of permits. The body, which considered, granted or denied permits was also not representative of all interests. The Minister has constituted an Afforestation Permit Review Panel (subsequently known as Stream Flow Reduction Activity Advisory Panel) in each province affected by forestry to deal with the above in a rational, fair and consultative manner. Re-inspection consultants have been appointed in almost all affected provinces, and it is their job, in conjunction with the relevant Regional Water Affairs Office, to carry out re-inspections of permitted farms ensuring that permit conditions have been complied with;
  • Greater attention will also be paid to addressing historic illegal afforestation in certain catchments by undertaking regular and systematic re-inspections;
  • More thorough consideration of the effect of afforestation on low flows (and possibly the drought cycle);
  • Greater consideration is now being given to environmental issues such as the effect of afforestation on rare or endangered flora and fauna, bio-diversity, and the visual impact on the landscape. Where necessary, Environmental Impact Assessments (EIAs) are required of forestry developers;
  • A start has now been made, in collaboration with provincial departments, on evaluation of the economic viability of proposed forestry developments, and to compare its value with that from alternative uses of water; and,
  • Provision is now also being made for limited-term permits.

It is clear that the regulation and control of forestry has come a long way. This is not to say that the Department’s homework is now finished – it has only just begun. One must, however, bear in mind that all these measures take time to implement, thus calling for continued care and patience.

With the promulgation of the National Water Act (No. 36 of 1998), all commercial afforestation plantations (those planted before and after 1972) have to be registered.

The forestry industry has also shown that it would like to manage its existing plantations in an environmentally sustainable and socially responsible manner and the Department will do all it can to work with the industry in achieving this.

Although afforestation is the only declared SFRA at present, it is now accepted that all crops should be considered in a similar way and new legislation will ensure some form of compliance.

Last updated: 18 March 2004.

© 1999 Department of Water Affairs & Forestry.
All rights reserved.
Comments: webmaster