Written by Abigail Oellermann, July 2025
The following website article raises critical questions about the process of groundwater development, especially in a water-scarce country like South Africa. It highlights the complexity of groundwater authorisation, the importance of accurate monitoring, and the need for robust management systems. While groundwater offers a potential solution for water security, the current regulatory and infrastructural challenges need to be addressed to ensure sustainable and equitable use. Thus, the feasibility of groundwater development hinges on comprehensive management and stringent regulation, making it a conditional rather than an outright solution.
Before anyone invests in drilling, the following points discussed in the article should be considered.
Recent droughts have highlighted the vulnerabilities associated with relying solely on surface water systems. Consequently, groundwater exploration has become increasingly popular to augment water supply as a more reliable resource. When selling land, a business or acquiring property, the question, “Do you have water rights?” frequently arises, highlighting the increasing value of water. In South Africa, all water is managed by the government Department of Water and Sanitation, with regulations and requirements continually evolving to protect the nation’s scarce water resources. The number of groundwater users has increased, especially following the various droughts that have affected various part of the country during the past decade. Additionally, municipalities normally do not provide services to rural areas within their jurisdiction, due to a constraints in infrastructure and capacity, prompting many to seek alternative resources such as rainwater harvesting, reusing treated effluent and greywater, and utilising groundwater.
Rising Demand for Groundwater
In regions like Johannesburg and Tshwane, inadequate water infrastructure and frequent power outages have led many to adopt off-grid solutions, installing their own water, electricity, and treatment systems. The increase in applications and the broader scope of water uses raise questions about protecting water resources. Moreover, there is an observed insufficiency of monitoring for both authorised and unauthorised groundwater users, underscoring the urgent need for a robust system to manage current groundwater resources, predict future usage, and ensure water security.
DWS has conducted a reserve study which essentially is the water “set aside” for basic human needs (BHN) and ecological needs. The Reserve has priority over all other water uses and must be met before water resources can be allocated to other uses. This is a critical consideration when assessing future water use allocations.
The Complex Process of Groundwater Authorisation
The process of obtaining authorisation to drill for groundwater in South Africa can be complex and varies between municipalities. For example, in Cape Town, one must notify the municipality and submit a formal application before drilling can begin. Ideally, a hydrogeologist should be on site to oversee the borehole construction and log relevant details.
In Gauteng, especially in areas underlain by dolomite, municipal by-laws impose strict controls. In the City of Johannesburg, Section 72(1) of the applicable municipal by-law prohibits borehole drilling on dolomitic land without assessment and potential enforcement action by the Council. Furthermore, the Dolomite Risk Management By-law (2022) requires written consent from the Dolomite Risk Management Section for any groundwater abstraction on dolomitic land (Section 13(9)). Existing boreholes must be registered, and licences may be revoked if safety is compromised (Section 13(10)).
While an Environmental Impact Assessment (EIA) is not usually a requirement for borehole drilling, it may be triggered in certain areas or contexts. This underscores the importance of reviewing relevant legislation including environmental Law, water law, municipal by-laws and site-specific requirements.
Groundwater use may be authorised in terms of Schedule 1 (for basic domestic use and small-scale irrigation), as an Existing Lawful Use (ELU) predating the NWA of 1998, under a General Authorisation (GA), or through a Water Use Licence (WUL), depending on the volume of abstraction and intended use.
Risk of Drilling Without Approval and Understanding the Availability of Groundwater
Investing in drilling for groundwater without prior approval from the municipality and a proper understanding and certainty about the water’s availability can be risky. The financial implications of drilling are significant, and if the required authorisations are not obtained or the water is not found in sufficient quantities, the investment could be lost. There is also a dependence on DWS who are the custodians of the water resource. It is crucial to conduct thorough feasibility studies and obtain all necessary permits before commencing any drilling activities.
The availability of groundwater for abstraction is not always guaranteed. South Africa is divided into water management areas, each managed by a regulatory authority. Recent studies reveal that within these water management areas, many catchments are over-allocated, a fact not always known to the public. One might meet all the requirements and submit an application, only to have it approved for a reduced volume or declined altogether.
Importance of Yield Tests
Yield tests (according to SANS standards), are required for licence applications but not for general authorisations. These studies, help quantify the volume of groundwater available and provide a rate at which groundwater can be sustainably abstracted from a local aquifer. Long-term monitoring of the resource is required to ensure sustainability.
Given South Africa’s water scarcity, there is growing debate about whether yield tests should be mandatory even for use of groundwater in terms of the general authorisations. This would provide relevant information which could help manage groundwater, address concerns about long-term abstraction effects, and would inform monitoring endeavours.
Geohydrological Assessments and Monitoring
For Water Use Licence applications, a geohydrological report is mandatory, which incorporates the findings of the yield test. The geohydrological assessment is required to be thorough, including consideration of proximal users, surface water features, and modelling of the proposed abstraction impacts.
Groundwater Use and Allocation Challenges in South Africa
During authorisation applications, it has been observed that registered, lawful users (from DWS Water use Authorization & Registration Management System (WARMS) database) are sometimes not actively using their groundwater. Conversely, others use groundwater without an authorisation. This introduces uncertainty into evaluations of available groundwater in catchments and raises a question about how much water is being utilised. There is therefore a greater need for groundwater monitoring information to be collected by users and submitted to DWS. If this data were to be collated in a usable format, that would greatly assist in future groundwater management and allocation within South Africa.
The Need for Numerical Models
One of the requirements for a geohydrological assessment is the compilation of a model. For smaller and simpler applications, analytical models can suffice. However, for larger or more complicated applications, DWS often require the licensee to develop and build numerical models, a fairly costly undertaking. This leads to questions about whether numerical models should be developed for all catchments before any applications are approved or even before drilling commences in catchments which are over-allocated. Additionally, the question arises, “Who should bear this responsibility?”. By imposing this responsibility on the water user, the result is that a disaggregate collection of models are compiled by various entities, in some instances for the same resource. It may therefore be preferable for the regulator, and custodian of the resource, to build and use the requisite numerical models to assist in managing the resource. This would also reduce the burden of smaller scale applicants from gaining access to water. Several countries, such as Denmark, Germany, Australia, the United States and the Netherlands, have developed numerical models before drilling takes place, as part of their water resource management. The capacity limitations of the regulator are likely the reason why South Africa has not been able to adopt this approach.
Conclusion
It is crucial to understand the scientific aspects of hydrogeology and the legislation. When investigating if groundwater is feasible, a holistic approach should be taken, not just focusing on the geology, flow paths and the sustainable yield of the borehole, but also the availability of groundwater in a catchment which takes into consideration the recharge to the area, the lawful-registered active users, the lawful-registered inactive users, the unlawful usage, reserve, the groundwater dependent eco-systems and climate change. This holistic approach can be informed through the use of numerical models, the question is when should these models be developed, provide the purpose in and by whom.
DON’T JUST DRILL, UNDERSTAND THE BIGGER PICTURE.
