1.3.7 Environmental impact assessments, aspects and impacts

Environmental Impact Assessment (EIA) and Environmental Management Systems (EMSs) are both well-known and well used environmental management tools in South Africa. The tools are well used on their own but they are not often linked to the extent where they could effectively carry through important environmental information generated in one process(such as the EIA) and ensure that the lessons learned are implemented and systemised in the management structure (the EMS).

EIAs are a regulatory tool in South Africa but that is not yet the case for EMSs.

In the above model, the Environmental Impact Assessment evolves into an Environmental Management Plan, which then becomes the Environmental Management System.

Example

In some Off-Shore Drilling Projects in Mozambique, the project life cycle was Planning – Mobilisation – Execution – Demobilisation and the Environmental Management Strategy followed this sequence. Examples of how this was implemented are:

  • Procure to Destroy: A typical cycle where parts were purchased and became contaminated through use. These parts were identified during the planning stage and mitigation factors were designed to ensure that such parts were never recycled or sold to the local population;
  • Procure to Rehabilitate: This strategy was adapted for land where chemicals were stored. During demobilisation, a team of specialist rehabilitation workers were deployed and the land was restored to its original state. Part of the EMS was to store and handle chemicals in such a manner that contamination was minimised.

Environmental Impact Assessment

Environmental Impact Assessment, through the documents known as Scoping and Environmental Impact Reports, has formed part of the “EIA Regulations” promulgated in terms of the Environment Conservation Act No 73 of 1989, as amended, since 1997. (Environmental assessments have, however, been undertaken extensively, especially for larger projects, since the 1970’s. (Glazewski, 2000)

These documents have been the basis for authorisations that have been issued, along with “Records of Decision” (RoDs), by the national Department of Environmental Affairs and Tourism (DEAT) and the nine Provincial Departments, delegated to administer the EIA regulations in their various provinces.

When discussing some of the earliest Scoping and Environmental Impact Reports with applicants (also known as “proponents”), it becomes clear that in many cases, the reports were a means to an end and once authorisations were given by the authorities, the reports were filed and more often than not, forgotten. Any conditions that may have been associated with the authorisations were also often forgotten. The reasons for this are simple. At the time, the authorities had limited manpower and resources available to follow up on compliance with authorisation conditions. If the conditions were implemented, measurement and monitoring systems were rarely in place to track progress (for internal or external review), often making auditing of the conditions, very difficult and unenforceable.

In recent years, capacity within the various departments has developed with the result that enforcement and monitoring of RoDs has begun to increase. However, only in a few cases, would self-regulatory tools (such as conditions requiring annual, independent auditing of RoD conditions) be added to the authorisation requirements.

The benefits to the regulators of self-regulatory tools are that the proponents carry the cost of enforcement monitoring.

Outside of the mining sector, there is no evidence of authorities in South Africa formally requiring EMSs to be established after an EIA has been carried out. This may be because of a wariness of possible legal action from proponents who might suggest that the legal requirement for an EMS is ultra vires, or outside of the scope of the legislation at the current moment.

A conceptual framework, explaining the interaction between EIA and EMS is as follows:

Whilst having a formal environmental management system such as ISO 14001, which is a preferred option, other systems can also be used, if they include the necessary environmental prerequisites to meet minimum environmental requirements.

Those prerequisites should have long term objectives which include:-

  • Ensuring continuing compliance with legislation and company environmental policy
  • Achieving, enhancing and demonstrating sound environmental performance
  • Ensuring environmental issues continue to be integrated into business decisions
  • Rationalising and streamlining environmental activities throughout the lifetime of the development to add value and efficiency
  • Encouraging and achieving a high level of environmental performance and response from all employees, contractors and suppliers
  • Providing the standards for overall environmental planning, operation, audit and review
  • Enabling management to establish environmental priorities

In the absence of a formal system to integrate the results of the EIA, a plan should be developed to accommodate them which describes the following:-

  • The environmental objectives and commitments
  • The means by which this will be achieved
  • The responsibilities and accountabilities
  • The procedures for dealing with changes and modifications to the project
  • The corrective actions to be employed should the need arise
  • Review schedules and criteria

In the case where a formal EMS is in place, an Environmental Management Plan (EMP) can be used as the means to take the findings and recommendations of the EIA into the system, structure and procedures of the EMS.

Benefits of EIA and EMS

It is very important to “sell” the benefits of EIA, EMS, and integrate the two, to business management and decision makers. In the case of many business organisations, an EIA is undertaken simply to comply with legal requirements.

Lack of coordination and communication is probably the main reason why linkage between EIAs and EMSs has not occurred more effectively in the past. The improvements in the National Environmental Management Act No 107 of 1998, will enable better coordination of environmental and sustainability activities between the various tiers of government to emerge, as well as improved environmental management of the entire life cycle of projects, policies and programmes.

Greater focus on holistic environmental management thinking, which recognises the importance of effective information and data flows for environmental decision-making purposes, will see the natural benefits of integrating EIA and EMS.

South Africa is increasingly participating in the global marketplace where competition is more complex than simply giving the best price. EIAs and EMSs are common integrated components of international commerce and trade and there is no choice as to whether they are needed or not needed. They must form a part of the business process in any international trade in the 21st Century.

Conclusion

The tool below is an example of what a SHE practitioner can use to assess the effectiveness of Economic Sector Integration with Environmental Management Strategies.