Water Use and Water Resource Impacts:  How will an auditor evaluate these practices?

Taking water from a resource

This includes abstraction from rivers, dams, springs, groundwater through boreholes or water allocation from CMAs, Water Schemes or Irrigation boards. 

In such situations, an auditor can verify the following:

• Existence of a valid Water Use Licence (WUL) or lawful water use registration where applicable. The auditor will be guided by what they can observe during the site tour and the site’s management system.
• Alignment between allocated license volumes and actual abstraction volumes.
• Evidence that the site has installed and maintained flow meters (calibration records).
• Water allocation documentation from the relevant authority (e.g., CMA or irrigation board).
• Records demonstrating abstraction do not exceed permitted limits.
• A contingency plan during drought restrictions. The risk focus in situations like this will be over-abstraction, unlawful water use, inaccurate measurement, and adverse cumulative catchment impacts.  

Storing water

Storage of more than 10 000 cubic metres of water requires registration with the DWS. A dam with a capacity of more than 50 000 cubic metres and a dam wall height of >5 metres must additionally be registered with the Dam Safety Office.

An auditor will verify the following:

• Registration certificates with the DWS.
• Dam Safety Office registration (if thresholds are exceeded).
• Dam wall safety inspection reports and engineer certifications (where applicable).
• Maintenance plans and structural integrity records can also be requested.
• Emergency preparedness plans (particularly for large dams).
• Confirmation that stored volumes match registered capacities. 

The risk focus here is failure risk with the dam, unregistered storage infrastructure, and downstream safety liabilities.  

Impeding or diverting the flow of water in a watercourse

Includes weirs, culverts, canalisation or altering a river’s course.

The auditor will verify the following:

• Approved water use authorisation for impeding/diverting flow.
• Engineering plans and environmental authorisations (if applicable).
• Evidence that structures do not cause unintended upstream flooding or downstream deprivation.
• Maintenance records of culverts and weirs.
• Evidence that ecological flow requirements are considered.

If we look at the risks here, illegal alteration of watercourses, ecological damage, flooding risks, and community impacts are issues that can result in high-risk ratings during audits.  

Engaging in a controlled activity

Includes activities such as irrigation with waste or water containing waste. Auditors will look at the following:

• Authorisation for controlled activity under the WUL, meaning what is allowed in terms of the licence.
• Water quality testing results and monitoring frequency (i.e., annually for irrigation).
• Soil monitoring results (salinity, heavy metals, nutrient loading).
• Evidence of application rates aligned with licence conditions.
• Risk mitigation measures to prevent groundwater contamination.

This is important because of soil degradation, groundwater contamination, and non-compliance with licence conditions.    

Discharging water or water containing waste into a water resource

Includes the releasing of wastewater into a water resource, auditors will ask for a:

• Valid discharge licence or General Authorisation compliance.
• Effluent quality monitoring results (vs licence limits).
• Calibration of monitoring equipment.
• Records of incidents, exceedances, and corrective actions.
• Stormwater management systems which separate clean and dirty water.

Pollution incidents, non-compliant effluent discharge, reputational and legal risks are the focus point here.  

Disposing of waste in a manner which may detrimentally impact a water resource

Includes the disposal of waste on-site, which may cause seepage that impacts a water resource.

Auditors will tend to ask for:

• Waste management plan and disposal methods.
• Location of disposal sites relative to watercourses and boreholes.
• Evidence of lining, containment, or seepage control measures.
• Groundwater monitoring results (where applicable).
• Compliance with waste classification and disposal regulations.

These factors are important due to leachate contamination, groundwater pollution, and perhaps inadequate containment systems.

Altering the bed, banks, course or characteristic of a watercourse includes excavation or development within a watercourse. 

Authorisation can be included in an approved River Maintenance Plan.

Auditors will focus on the following:

• Approved River Maintenance Plan (if applicable).
• Environmental authorisation (if required).
• Proof that work remains within the approved footprint.
• Rehabilitation plans and evidence of implementation.
• Measures to prevent erosion and sedimentation.

The risks here include habitat destruction, erosion, sediment loading, and unlawful development.    

Engaging in a stream flow reduction activity is typically associated with commercial forest plantations. 

Auditors will therefore verify:

• Registration of stream flow reduction activity.
• Mapping of plantation areas relative to watercourses.
• Compliance with species and planting restrictions.
• Evidence of water balance assessments where required.

Complying with the above reduces catchment yield and cumulative water scarcity impact risks.