# Implement

# Step 3 - Implement

Stage Three of the Programme is implementation. Here, Participants are required to maintain their membership of WSAP, and implement the actions set out in their Water Stewardship Plan towards achieving water stewardship outcomes.

An internal review must be completed by Water Stewardship Asia Pacific to demonstrate compliance with the required indicators and criteria. Once approved the organisation can progress to Stage Four (Verify) of the Programme. Participants must complete an Annual Communication of Progress within 12 months of their internal review..

To maintain the Implement level of verification (if not continuing to Stage Four of the Programme), an Annual Communication of Progress must be submitted every 12 months.

# 3.1 Implement plan to participate positively in catchment governance

# 3.1.1 Provide copy of plan and evidence to demonstrate site has supported good catchment governance

For targets defined in Step 2 (Develop water stewardship strategy and plan), the organization should show what the targets and actions are and how it has progressed towards them. For this indicator, this would include how the organization has supported or contributed to good catchment governance. For example, it may have engaged with relevant authorities and can demonstrate support for improved water governance and water management policies. Where targets are not met or approached, then justification should be given.

# 3.1.2 Investigate and document measures to respect others’ water rights

This indicator refers to water rights not already covered by legal and regulatory mechanisms as captured in Indicator 3.2.2. Information on such rights may come from local governance groups or other stakeholders. Recognizing that some rights are not legal or regulatory requirements, but are still relevant, they are captured in this indicator regarding good governance. One possible source of this information could be local indigenous groups or organisations.

Where stakeholders have rights to the water resource, such as some local communities and indigenous peoples with traditional rights, their informed consent should be given in order to use the resource. Where these rights are not formally recognized by a government regulator, there remains a duty to identify and respect them where they exist. Engaging with such communities requires a long-term commitment to achieve meaningful dialogue and build trust between parties.

Additional guidance on the respect of human rights is given in the UN Guidance Principles on Business and Human Rights (2011), however it is important to note that the scope of the International Water Stewardship Standard is focused on water-related rights.

# 3.2.1 Provide evidence of process implemented to verify legal and regulatory compliance

Linking with Criterion 2.2 (Develop process to achieve and maintain legal and regulatory compliance), the organisation should provide, or reference, the documentation demonstrating legal compliance and provide documentation of any violations or corrective actions taken to address violations. Documentation may be in the form of authorizations, auditor records, compliance submissions, etc. Sites may reference documentation already gathered by regulatory bodies where appropriate, provided they are accessible to WSAP for verification.

# 3.2.2 Provide evidence of measures implemented to respect others’ legal water rights

The difference between Indicators 3.1.2 and 3.2.2 is that 3.2.2 specifically refers to rights captured in legal and regulatory requirements.

# 3.3 Implement plan to achieve site water balance targets

# 3.3.1 Document progress towards meeting planned water balance targets

For targets defined in Step 2 with regards to water balance, the organisation should show what the targets and actions are and how it has progressed towards them in a format that is clear and appropriate.

It's recognized that the site may not require improvement targets for all indicators and outcomes. Broadly, the organization's water stewardship plan and targets should seek to:

ENSURE legal compliance (minimum)
MAINTAIN good performance
IMPROVE on poor performance and priority shared water challenges, site risks and opportunities towards best practice. All water stewardship targets and actions (whether maintenance or improvement) should be documented and evidence of progress or achievement provided.

Where targets are not met or approached, then justification should be given and appropriate corrective actions provided.

# 3.3.2 Provide evidence of Implementation of targets to improve water use efficiency or total use where scarcity a challenge

Where water scarcity is a priority challenge (Criterion 1.6 Shared water challenges), the organization should implement particular actions to reduce total water use or consumtption or demonstrate that their total water use or consumption is sustainable (within the limits/constraints/balance of the catchment). This indicator relates mainly to site water use. Indicator 3.9.2 considers site and catchment best practices, investigated and described at Indicator 1.8.2. (See also guidance for Indicator 1.8.2 on water balance best practice).

# 3.3.3 Provide copies of legally-binding documentation for re-allocation to others non-economic needs (if applicable)

Where the organisation re-allocates water for external benefits or uses (e.g. social, cultural or environmental benefits or uses), then it should demonstrate this action is legally compliant and has appropriate regulatory approval, where applicable. Legal compliance is required to ensure approval and to avoid liabilities (e.g. black water events). The organisation should take such actions in consultation with catchment authorities and key stakeholders.

This is particularly important for water supplied for human use, but also for water bodies containing important biodiversity and cultural values, for which water quality is critical. There should also be confidence that re-allocated water does not create a risk of flooding, erosion or other damage or to third parties. Whatever the purpose, the organisation must be confident the water quality is safe and compliant for the intended use and should include water treatment if necessary to achieve this.

Examples include:

Transferring water to a sensitive IWRA, such as a biologically important wetland
Providing a drinking water supply to a small local community
Providing irrigation water to subsistence farmers
Aquifer recharge
Offering water to Indigenous groups disadvantaged by water markets.

It is also understood that in some cases, the organzation may have no mechanism, legal or otherwise, to reallocate water.

# 3.4 Implement plan to achieve site water quality targets

# 3.4.1 Document or provide evidence of progress towards meeting planned water quality targets

For targets defined in Step 2 with regards to water quality, the organisation should show what the targets and actions are and how it has progressed towards them in a format that is clear and appropriate. Where targets are not met or approached, then justification should be given and appropriate corrective actions provided.

For each water quality target, the evidence should show: the water body or feature it applies to, the target water quality, planned timescale, and progress towards achieving it.

It's recognized that the site may not require improvement targets for all indicators and outcomes. Broadly, the organization's water stewardship plan and targets should seek to:

ENSURE legal compliance (minimum)
MAINTAIN good performance
IMPROVE on poor performance and priority shared water challenges, site risks and opportunities towards best practice. All water stewardship targets and actions (whether maintenance or improvement) should be documented and evidence of progress or achievement provided.

# 3.4.2 Document or provide evidence that quantifies continual improvement to achieve best practice for effluent where water quality a challenge

As a minimum, effluent quality should be legally compliant. Best practice will mean ensuring it is of the highest quality feasible (beyond compliance) and fit for the downstream receiving bodies or uses. Where water quality is a shared challenge, then the quality concern should be identified (e.g. elevated levels of a particular chemical) and this taken into account in treatment and discharge location. This indicator relates mainly to site effluent treatment and quality. Indicator 3.9.3 considers site and catchment best practices, investigated and described at Indicator 1.8.3.

The plan is defined according to Criterion 2.3. It's recognized that the site may not require improvement targets for all indicators and outcomes. Broadly, the organization's water stewardship plan and targets should seek to:

ENSURE legal compliance (minimum)
MAINTAIN good performance
IMPROVE on poor performance and priority shared water challenges, site risks and opportunities towards best practice. All water stewardship targets and actions (whether maintenance or improvement) should be documented and evidence of progress or achievement provided.

Where no IWRAs are identified, no action is required.

Because of possible unique situations where the best that can be done is to prevent further degradation, maintaining the IWRA may be the only suitable solution for this requirement, however this should be considered a last resort.

Where an IWRA is to be restored or improved, the organisation should have a record of its status prior to interventions. Depending on what the feature is, this may include a biodiversity study, water level and/or flow data, water quality data, etc. This then forms the benchmark against which to monitor improvements. If the target is to conserve (assuming it is already in good status), then similar information can be used to demonstrate it remains in a good condition, and to highlight any negative changes in its condition – which of course, will require corrective action. Photographs and videos can also be valuable in showing condition and change.

# 3.6 Implement plan to provide worker access to WASH

# 3.6.1 Provide evidence of adequate WASH access

The site should provide a evidence of measures implemented to improve the level of access and adequacy of WASH at the site, developed as a result of the site WASH assessment completed at Indicator 1.3.8. The site is recommended to assess WASH provision by defining measures and indicators that enable it to determine any particular gaps in access or adequacy, in comparison to laws, independent standards and guidelines, and considering internal inputs from the workforce. This should take equitable account of gender, age, religion, mobility, and any other special needs.

This indicator relates mainly to site WASH. Indicator 3.9.5 considers site and catchment best practices, investigated and described at Indicator 1.8.5.

# 3.6.2 Provide evidence that that site not impinging on communities’ human right to WASH, traditional access rights are respected, and remedial actions in place

Examples of where an organisation could impinge on the human right to safe water and sanitation of communities:

Negative impacts on community water supplies such as pollution or excessive abstractions.
Land developments or exclusions that prevent Indigenous peoples from freely accessing their traditional water sources.
The costs associated with providing access to safe drinking water should not outweigh the human right.

# 3.7 Implement plan to maintain or improve indirect water use

# 3.7.1 Provide evidence that planned indirect water use targets are met

For targets defined in Step 2 with regards to indirect water use, the organisation should show what the targets and actions are and how it has progressed towards them in a format that is clear and appropriate.

As for all water stewardship plan targets, indirect water use targets and actions should be prioritized according to the urgency and level of risk, based on the information gathered at Criterion 1.4 (Indirect water use) in this instance.

For indirect water use, risks may be associated with goods or services sourced within the same catchment as the site, or catchments other than the site’s and at some distance from the site. In many cases, but not all, priority may be given to indirect water use within the site's same catchment where the site has greater ability to influence or work together with suppliers on shared risks/challenges. In other cases, priority might be given to other catchments that present greater risks or priority for the site.

Examples for reducing indirect water use include:

Engage with existing suppliers to encourage them to improve their practices.
Switch to a different service or product supplier that is known to use less water to provide the same level, quantity, and quality of primary inputs.

It is important to ensure that choices about switching suppliers are based on measurable water use/quality data and not on theory or modelling. For example, water footprint assessments are a means to raise awareness about how much water is typically used for a product or food item but may be unreliable for a specific case. A water footprint assessment of how much water is used to grow a certain crop in a certain region of the world relies on general data for that region and does not take account of water efficiency practice on individual farms. Any choices that can have an economic impact on a supplier should be based on verifiable data.

# 3.7.2 Provide evidence of engagement with third parties in relation to indirect water use

Achieving a reduction in indirect water use will often require engagement with suppliers to understand how they use water, and encouragement for them to modify their practices so as to make savings. Suppliers may do this directly, or they may rely on support from the organization.

In fact, many of the actions the organization applies itself as a water steward could be relevant. Once the organisation has achieved good water stewardship status, it is in a stronger position to advise its suppliers, and demonstrate to them the advantages and benefits, such as reduction of risks and costs.

# 3.8 Implement infrastructure owners’ notification and engagement plan

# 3.8.1 Provide evidence of engagement and document key messages

This crtierion and the site's plans to notify or engage with owners of water-related infrastructure links with Indicator 1.5.6 (describe and provide a map of or document water-related infrastructure), Criterion 1.6 (shared water challenges), Criterion 1.7 (site risks and opportunities), and 2.4 (demonstrate site’s responsiveness and resilience to external water risks). The intent of engagement with infrastructure owners is to address shared infrastructure-related risks.

# 3.9 Implement actions to achieve Water Stewardhsip best practice outcomes

# 3.9.1 Provide evidence of actions implemented to achieve best governance practice

In the spirit of continual improvement, Indicators 3.9.1 to 3.9.5 in this (Implementation) stage relate to actions implemented towards achieving best practice (investigated and described at Criterion 1.8), acknowledging that there may be some elapsed time before full implementation and achievement of best practice is realized.