Environmental Impact Assessment Regime: public hearings (day 2)

Water and Sanitation

31 July 2013
Chairperson: Adv J De Lange (ANC)
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Meeting Summary

The Committee proceeded with the second day of public hearings on the efficacy of South Africa’s environmental impact assessment (EIA) regime. The general tone of the submissions was that whilst the current regime had its strength and impeccable legislation to support it, there was certainly room for improvement to make the system more efficient and reliable.

The Chamber of Mines said that the EIA system showed some strengths, but there was a need to improve the monitoring strategies, avoid duplication, cut down on the delays, and achieve greater harmonisation to avoid conflict in the processes. Similar comments were repeated fairly consistently also by other commentators. The Chamber urged the need for adequate resources and capacity in government to improve effectiveness, and pointed to the need for simultaneous amendments of the National Environmental Management Act (NEMA) and the Mineral and Petroleum Resources Development Act (MPRDA), as well as ongoing engagement with the mining industry. Members asked about the extent to which the Chambers’ members engaged with the Department of Environmental Affairs (DEA).

The Chemical and Allied Industries Association said it saw the EIA as an impediment to investment and suggested that there were a number of other routes that could be followed, in view of its several challenges, to achieve the results needed, including other frameworks, assessment methods and norms and standards. It particularly said the delays in authorisation needed to be addressed and urged that structures work together.

Paarderberg Sustainability Initiative proposed that the current “one size fits all” approach to EIA be changed to an economic approach based on the rand value, where listed activities, costs, job creation and contribution to the national economy would all be taken into account. Decisions were needed on environmental law enforcement departments, who should sit regularly to review applications with a more streamlined process. More effective public engagement was also needed. However, another submission later said that sometimes the public participation process was blamed for delays.

The Centre for Applied Legal Studies brought up the  role of Environmental Assessment Practitioners, recommending more formal regulation and monitoring, and saying that the quality of information had a direct impact on the manner and the timing of decision-making. Overall, the Centre made a number of recommendations for improvements to the process, stressing that although the background was good it must be recognised that this was an area requiring constant review and improvement.

Association of Cementitious Material Producers commended the work done on spatial applications and tools and was encouraged by efforts to improve systems across all spheres of government. This Association also recommended that a number of other options could be considered, and said that development of sectoral norms and standards should include best available technologies and processes, and industrial sectoral policies should look into the “best practical environmental option”.  Sustainable development should remain the key focus.

The AfriForum proposed definitions for 'Natural Capital’ and ‘Natural Capital Accounting’, which should inform decision making on consumption or use of natural resources. Afriforum was adamant that the environmental authorisation process should remain with DEA, to avoid monopolies in departments that were more interested in pursuing economic development. Afriforum criticised the current public participation processes, saying that proper translation and interpretation services should be provided to ensure that all relevant information was obtained.  It agreed with more regulation and control of EAPs, as also with the need to upscale capacity and expertise in the DEA. It urged a legislative process that would prevent companies, who tended to be unfazed by paying a fine if their proposed developments would engender substantial profits, from exploiting the country, and wanted more accountability from developers. It was emphatic that, given that there was only one chance to protect the environment, there must be proper integrity and enforcement of all efforts to ensure that protection actually happened, including holding the State liable if it failed to protect these resources. Members asked questions around the integrity of decision makers, and emphasised the need for a balanced board.

Agri-SA Western Cape noted that farming was resource-dependent but that it had already been recognised that biodiversity was inadequately reflected in the EIA process. Three possible solutions were presented; the first to set up Agri-Environmental Management Frameworks, to identify spatial opportunities to expand agriculture, and better planning; the second to have strategic river maintenance plans; and the third to follow one process for multiple projects in similar settings. Collaboration was vital. Other recommendations taking the specific needs of this sector into account were proposed, and it was emphasised that all options must be critically examined, since the current regulations were not achieving the desired results.

The Free State Provincial Department of Economic Development, Tourism and Environmental Affairs echoed sentiments that although there were merits to the process, the effectiveness was often diluted both by intrinsic challenges on capacity, quality and implementation, but also because it was advocated as a mere tool to achieve sustainable development, and the necessary conviction to safeguard the environment was not present. This province supported the proposal of a recent conference for formulation of a management strategy.

The International Association for Impact Assessment (IAIAsa) pointed out that the National Development Plan envisaged substantial infrastructure development, which could impact significantly on the environment. Its core submission related to the need to have quality and ethical EAPs, as well as competent decision makers in government. IAIAsa urged the setting up of a registration authority (RA) for Environmental Assessment Practitioners, and although the Environmental Assessment Practitioners Association of South Africa (EAPASA) had been set up in 2011, there had been no official recognition of this body as an RA. The continuance of unregulated poor practices would hinder efficiency. Once an RA was set up, IAIAsa believed that there was no longer any necessity to insist upon “independence” of EAPs, as it was not a requirement in other countries, and this would be overseen by the RA. Members questioned this assertion and asked the Association to re-think the issue, saying that EAPs could become employees of developers and be pressurised to approve EIAs for them. The DEA put the matter in context by noting that the regime differed. The IAIAsa also proposed adoption of a single EIA regime for all sectors, with DEA as independent assessor. Monitoring processes, and the independent review must be strengthened, and the process streamlined. In addition, there was a need to introduce a requirement for follow-up on whether predicted impacts had occurred. Inconsistencies between provinces had to be addressed, and more flexibility was required to focus on sustainability.

The South African Wind and Energy Association repeated strengths and weakness of the process, and cited the enormous workload that the DEA faced, which caused delays and frustrations, as well as criticising the review process. It was also noted that other departments could impose restrictions that conflicted with EIAs. Mitigation measures for birds and bats were often based on misunderstanding of wind farms and related technology. This organisation therefore recommended that DEA needed additional resources to deal specifically with wind and solar farm applications, and that more effort was need to integrate various permit processes. Where project impacts were low, it was suggested that a full EIA should not be required, although there was a need to be careful on Strategic Environmental Assessments to selected Renewable Energy Development Zones. Overall, greater collaboration was needed, and more follow-up on progress. Appeals must be established, and various processes should be done online. The DEA responded that although there had admittedly been some delays in appeals, the majority of wind and solar applications had been completed well within legislated time frames, and that the DEA had received 600 applications, rather than the 400 anticipated. More than 25 gigawatts had been approved, although the first phase allowed for less.

The Western Cape Property Development Forum urged a more practical understanding of the industry, and suggested that the pendulum of emphasis swung between considering, more favourably, environmental, societal and economic factors at certain times. The Forum was primarily concerned with the delays and uncertainty around the current appeals process, which could affect the seven-year property cycle, and urged for reduced timelines, and increased accountability of officials and spurious or professional objectors. Members took issue with the suggestion of favouring one principle and said that a balance was needed at all times. They urged the Forum to read the state of the environment report and to consider carefully where this profession stood. 

Mr Gideon Erasmus, in his personal capacity, said that the present system did not work and agreed that there was a need to find the appropriate balance between environment and development. The EIA process never resulted in recommendations that authorisation be denied, because EAPs were paid service providers, and could not undertake objective assessments. He suggested that differentiated listings were a waste of time, that it was impossible to determine impacts in advance and said that every proposed activity must be assessed on its contextually specific merits. He proposed the need for a single, suitably-flexible regime, with three main phases, similar to what had been in place under the 1998 regulations, but with amendments. He maintained that most delays were attributable not to the DEA but to applicants’ failure to meet requirements, and the Chairperson suggested that perhaps cut-off dates could be included to prevent applicants dragging out the matter indefinitely.

Treasure Karoo Action Group suggested that below 400 metres, there was not yet a good enough understanding of geology. It was concerned that drilling was not a listed activity and suggested that EIAs were needed for every drilling location, and there was a need in particular for protection of ground-water, as well as stronger systems for ecosystem services and agricultural issues. The disconnect between licensing processes in NEMA and MPRDA should be standardised, and strict rule and processes were needed for hydraulics. The Group agreed with earlier comments on timeframes, integration and the need to have more independence of EAPs.

Terry Bengis, in his personal capacity, agreed that practical difficulties watered down the EIA process, and agreed that this was because EAPs were paid by developers. He proposed the setting up of a central fund, from which EAPs appointed by the Department would be paid, and that additional practitioners must be appointed to check on protection of the publics’ needs. He also noted that too much emphasis was often placed on creation of jobs by developers, in support of their applications, yet nobody was checking that they did in fact comply with the figures, and therefore this needed to be tracked, and sanctioned where there was inconsistency. The Chairperson said that this was a useful suggestion and asked the DEA to think further and comment on it.

Dube Tradeport sought to be a catalyst in the global business and trade environment, concentrating on integrated supply chains. It agreed with other submissions and said that there was a particular need to look into land development processes and their integration across the spheres of government, to avoid duplication and delays, and the need for standardisation of approvals. The DEA pointed out that the King Shaka Airport developments were a prime example of processes that took into account sustainable development, rather than purely environmental considerations, and comments were made on the necessity to hold developers to account for meeting deadlines also.

South African Property Owners Association made some proposals for more efficient processes, including the idea that public participation processes should run concurrently rather than being held after each stage. The need for the appropriate balance should be explicitly stated in regulations, so that projects with large environmental costs and minimal economic benefits should not be allowed, whereas the opposite situation should not be unduly burdened. Institutional mechanisms were needed for appeals, and the consultation process should be streamlined.
Susie Brownlie, Ingrid Coetzee and Mary-Jane Morris made submissions in their personal capacity. They maintained that economic growth rather than sustainable and environmental considerations, seemed to have been afforded more weight in the past, and minimising impacts was the focus, rather than refusing detrimental projects. The fragmentation of the current process, and the “tick-box” approach, were hindrances, and there was no robust or explicit criteria statements, nor trade-off rules. All this should be changed. EAPs should be assessing projects against the NEMA principles, and better alignment was needed. Environmental costs had to be taken into full consideration. Members noted the need for a debate on, and agreed definition for “sustainable development”, and said that all these submissions would be considered and responded to by the DEA.

Meeting report

Efficacy of South Africa’s EIA regime: Public Hearings: Day 2
Chamber of Mines’ submission

Ms Stephanie Mudau, Head of Environmental Affairs, Chamber of Mines, said that the Chamber (CoM) and its members played a pivotal role in the evolution of the National Environmental Management Act (NEMA) and NEMA Environmental Impact Assessment (EIA) regulations and subsequent amendments. The CoM was participating in a project to formulate the Environmental Impact Assessment and Management Strategy for the country, led by the Department of Environmental Affairs (DEA or the Department), had always cooperated with the DEA in all policy developments, and, where appropriate, provided industry inputs.

The EIA system had many strengths, including the fact that there were well established proven methods for assessment and impacts prediction. It had generated better information about environmental conditions, and the system injected environmental accountability into decision-making and good governance. EIA had tremendously improved environmental performance in planning and management of environmental issues. It provided for a formal public space for debate about development impacts and how best to mitigate them, thus embodying the participatory approach.

Key challenges facing the regime included:
-uncertainty and duplication of Environmental requirements
-delays in decision making
-capacity constraints to regulate EIAs
- the lack of strategic approach and sustainable development thinking

Ms Mudau stressed the need for adequate resources and capacity in government to improve effectiveness and ensure efficiency in the EIA system, and to strengthen monitoring of compliance and enforcement with EIA recommendations. furthermore, because it was undesirable for the industry to follow a duplicate licensing procedure, CoM pleaded for a single harmonised integrated system for regulating mining and related activities, for simultaneous amendment of both NEMA and Minerals and Petroleum Resources Development Act (MPRDA) and for ongoing engagement with the mining industry on these imperative legislative changes.

Mr K Skosana (ANC) said the Chamber of Mines always addressed the issue of compliance, which was an obvious matter.

The Chairperson asked the extent to which that the CoM assisted the Department.

Mr Nikisi Lesuti, Senior Executive, CoM, said the Chamber took comments and developed guidelines, and also evaluated the readiness and planning for projects.

The Chairperson said he was impressed as it was not often that industry spoke on the strengths of EIAs, and urged the CoM to continue in the role and to support the Department where possible.

Chemical and Allied Industries Association submission
Dr L Lotter, representative for Chemical and Allied Industries Association, said that this body (CAIA) saw the EIA as an impediment to investment, as it was not always the most appropriate instrument. Its various challenges included the fact that timeframes were not met, and setting targets made no difference as there were delays in the authorisation process, which meant that significant costs were incurred. The system also reduced competitiveness, additional conditions caused delay, and there was no feasible emergency action.

The CAIA proposed some alternative instruments to counter the challenges in the current EIA process. These were;

-Environmental management frameworks
-Strategic environmental assessments
-Environmental management programmes
-Environmental risk assessments
-Environmental feasibility assessments
-Spatial development tools
-Norms and standards

To improve the EIA the CAIA proposed that the delays with authorisation be reduced, that the alternative instruments be used and that alignment of environmental management plan and conditions.

Dr Lotter said there was no reason to allow the unsatisfactory status quo to remain, it was possible to  initiate immediate steps to improve the situation and establish structures to work together to develop and implement an action plan.

Paardeberg Sustainability Initiative submission
Dr Bridget Johnsen, Representative, Paardeberg Sustainability Initiative, said that her organisation (PSI) was a non-profit company that was established to address environmental and social threats as a result of mining on the South African coastline.

Dr Johnsen proposed three main recommendations for consideration. First was an economic approach to applications based on the rand value. This would mean that, at initial application each proposed development would cite not only the number of listed activities but also the proposed costs of the development, including the valuation of job creation, actual physical costs and contribution to the National Economy. The cost of the proposed development, together with the number of listed activities would be used to categorise the application, in contrast to the “one size fits all” current EIA process, which had been criticised.

The second recommendation was to place a responsibility on government to instruct key personnel immediately within the legislation to apply their minds and make decisions especially with Environmental Law Enforcement departments.  Departmental committees should have regular sittings to review applications in a streamlined process which would ensure records of decision were issued more efficiently.

The third recommendation was to engage the public more effectively.

Centre for Applied Legal Studies submission
Professor Louis Synman, Centre for Applied Legal Studies, Wits University, recognised the importance of the initial construction of the EIA system, but said that it should be recognised as a dynamic system whose achievements and shortcomings could only be seen only over time, when they should be addressed for continuous improvement. The EIA regime had an admirable legislative and guideline backing, but implementation was a challenge that diluted this. Delivering on what the system promised was a difficult task, as environmental management was a complex area requiring the integration of many disciplines and the balancing of many values. However it was felt that the difficulties could be overcome or at least minimised. The goal was to have a system which would promote equitable development and environmental protection that would then give effect to the principles enshrined in section 2 of NEMA.

The EIA reports were the most central aspect of the environmental management framework, as considering and reporting on impacts was at the core of the system. Thus the quality of reports was imperative to sound decision making, and the decision makers must have had accurate information. Producing correct and complete reports would mean that decisions were based on sound scientific findings. Accuracy could reduce the administrative burdens and delays associated with submissions of incomplete or inferior reports.

Professor Synman said that it was vital there be a just balance between socio-economic biophysical factors when preparing the reports, and that the links between the physical environment and human needs must be brought to the fore. Cumulative impacts were too seldom adequately addressed; this was especially problematic in relation to large scale or particularly invasive projects with far reaching impacts. The EIA process should be considered an integral part of the regional planning process.

Again, Professor Synman emphasised that the quality of a decision was as good as the quality of the report on the decision maker’s desk which then hinged on the calibre of the Environmental Assessment Practitioner (EAP) work. Currently the calibre of EAPs varied greatly, and he recommended that this profession needed to be regulated.

Professor Synman said that as primary sources of information for relevant authorities, the information and thus the decision must be based on verifiable scientific environmental findings that would be able to withstand critical analysis and scrutiny.

The EIA process placed more emphasis on the stages leading up to the record decision and less concern on the mechanism’s periodical monitoring of the implementation. There was a need for a transparent review process, for all aspects of environmental management with comprehensive feedback mechanisms.

In recent years there had been increased enforcement activities including the imposition of sanctions and the work of the Green Scorpions, but more creative enforcement mechanisms were required. Enforcement mechanisms should be strong enough to deter crimes and to result in the reduction of environmental harm.

There needed to be collaboration between government departments, as proposed in NEMA, in order to align organs of state operating in different spheres of government. Though the regulatory framework was well-developed, South Africa seemed to lack the capacity to fully implement the regulations.

Professor Synman also reiterated the need for public participation to ensure that development met the socio-economic needs and was consistent with the environmental well-being of all sectors of society. In the current regime, public participation was a key weakness as there was no sufficient dissemination of information and thus effective participation. Opening up participation would create a culture of compliance.

Professor Synman proposed that there should be:
-sufficient checks on quality
- mitigation and no-go options
- insights of resilience should be incorporated
- formal mechanisms for periodic review of the system
-additional methods of assessment, training and support for officials
- regulation of environmental practitioners
- the setting up of a Socially Responsibility Investment Index
- post authorisation monitoring,
- formulation of an EIA dictionary
- EIAs should formally include climate change, public participation, introduce awareness programmes.

Association of Cementitious Material Producers submission
Dr Dhiraj Rama, Representative, Association of Cementitious Material Producers (ACMP), said that environmental governance and the sustainability of the developmental growth path were essential aspects of the debate. ACMP believed that the current EIA process was an important environment management tool. However, it believed that the same information should be provided at each site level. Delays by authorities were an issue and the same predictable concerns were raised during the public participation process as well as during the appeals process.

Dr Rama believed that there were opportunities to adopt complementary approaches, which could include considerations of:
- The sectoral approach,
- Consistency across authorities,
- Co-operative governance and integrated decisions,
- A General Authorisation “like” approach,
- Quality of decision and cost of compliance
- Responsiveness to amendments and appeals
- Compliance to legislated timeframes
- Application and common understanding of waste policies
- The role of independent Environment Assessment Practitioners (EAPs)
- Alignment of regulatory requirements relating to the different permit requirements
- Compliance with timeframes
- Review of listed activities

Dr Rama overall said the work towards spatial applications and tools (SEAs/EMFs) was commendable and the current efforts to improve systems across all spheres of government was encouraging. However the ACMP recommended that the development of sectoral norms and standards include best available technologies and processes. There should be increased consideration to the adoption of industrial sectoral policies/EMCAs that included best practical environmental option (BPEO) to address the purpose of EIA. Sustainable development should remain the key focus.

AfriForum submission
Mr Julius Kleynhans, Representative, AfriForum, proposed definitions for 'Natural Capital’ and ‘Natural Capital Accounting’. Natural capital was the stock of natural resources, such as water and oil, and many natural resources were non-renewable. Natural capital included many resources on which humans and other animals depended on to live and function, which created tension between depleting and preserving those resources. Natural capital accounting was defined as the process of calculating the total stocks and flows of natural resources and services in a given ecosystem or region, in either physical or monetary terms. This process could subsequently inform government, corporate and consumer decision-making, on use or consumption of natural resources and land, and sustainable behaviour.

Mr Kleynhans said the Environmental Authorization (EA) process ought to remain with the Department of Environmental Affairs (DEA) to avoid a monopoly forming in those departments which were more likely to be in pursuit of economic development, such as the Department of Mineral Resources (DMR). DMR seemed to be trying to issue as many licenses as possible without calculating the risks to the environment.  All NEMA-listed activities must apply to mining areas as well. There were currently too many unresolved issues pertaining to this topic.

Mr Kleynhans said that a problem that existed was the diversity of cultures and languages, if a Public Participation Process (PPP) was done in a specific language, it should be followed through accordingly. The general language was English, but research has shown that different cultures responded better when addressed in their own languages. The National DEA had to provide proper translation and interpreting services to incorporate each person’s comments accurately into the EIA process. Mr Kleynhans believed that it was unacceptable for the Department to send back documents to a community, requesting that the community must translate if the wording was inaccessible. All public participation should happen at optimal levels to ensure consideration of all the relevant economic, social and environmental factors in that community.

Mr Kleynhans proposed that environmental practitioners should be affiliated with a national body to ensure high quality standards, compliance with policy, transparency in projects and communication. In their role they should ensure that both entities, i.e.  the applicant and the interested and affected parties (I&APs) were equally serviced in a neutral EIA environment. Legislation should ensure best practice and enforce penalties where needed. Mr Kleynhans proposed that the EAPs that did not conduct themselves accordingly should lose their licenses and not be allowed to practise.

Mr Kleynhans proposed that the capacity and expertise of the DEA be broadened to ensure environmental compliance in all sectors and sustainable development for the future. There was insufficient personnel and high staff turnover within the departments. This had a detrimental effect on the implementation, understanding and enforcement of the EIA legislation.

Mr Kleynhans said many developments took place without proper Environmental Authorization (EA). Companies had financial power and simply weighed up paying a fine of millions of rand against the substantially larger profits expected from the development.  Legislation should therefore be amended to prevent wealthy companies from exploiting the economic and social needs of the country in order to push through developments which would deplete natural capital. Areas where EA had to be granted should be mapped to indicate where the EA was effective, to avoid future further expansion and ecological degradation due to uninformed and legal manipulation. AfriForum recommended a separate Terms and Conditions document to be added, to hold the developer accountable for the effects and misconduct of any development to the affected parties.

Mr Kleynhans said with regards to EIA reports,  seasons had to be taken into consideration, duplication of reports ought to be avoided and there should be penalties where applicable. The EIA system was aimed at informing project planning and design, but unfortunately it had often been used to justify what was already planned.

Mr Kleynhans proposed the legislation be “State-bound” and all compliance enforcement, criminal liability and penalties should be bound to State to ensure that the law was respected by all and implemented democratically. The State was the custodian of minerals, water and natural resources and should also be accountable for the well-being of these natural assets.

The AfriForum proposed that the no-go zones be identified and treated as such. If these issues were not addressed as a matter of extreme urgency, South Africa may be left with a couple of stones but no water or food. There needed to be long-term economic solutions which protect that natural environment.

Mr F Rodgers (DA) questioned the integrity of decision makers,

Mr Kleynhans suggested that the panel of decision makers could include judges.

The Chairperson said there had to be a good mix of people to create a balanced board and that would ensure that no one could out vote the other as each individual would always champion for their industry.

Agri-SA Western Cape submission: Rethinking Agri-Environmental Management: Lessons and Perspectives from the Western Cape
Mr Charl de Villiers, Representative, Agri-SA Western Cape, said farming was intrinsically resource‐dependent. A 2009 Departmental report had highlighted that “A major shortcoming (in EIA)…. is that biodiversity considerations are usually inadequately reflected in the EIA process, especially with respect to how local site specific issues impact on the broader/regional context…”

Mr de Villiers presented three “innovations” to the Committee. The first was to set up Agri-Environmental Management Frameworks, which would allow for focused strategic planning where it was needed most. This would also identify spatial opportunities for agricultural expansion and also introduce predictability to agricultural planning. The second was to have strategic river maintenance plans, which would elevate planning and management to catchment and ecosystem scale. This would empower resource users to take responsibility for sustainable use of agri‐ecological infrastructure. The third innovation was to have a combined class application process, which would follow one environmental assessment process for multiple projects in similar agri‐environmental settings, ecological consistency and streamlined planning.

Mr de Villiers said no single agency had the answer to complex environmental challenges in a difficult production climate. Therefore collaboration could not be emphasised enough.

Agri-SA also had the following recommendations:
- The need to adopt landscape, agro‐ecosystem perspective to managing farms
- Focus on agro‐ecosystem regulation on key environmental issues
- Support and learn from business and biodiversity best practice Initiatives
- Promote Water User Associations and agricultural resource management committees
- Develop agri‐EMFs for homogenous farming regions subject to significant environmental pressure
- Promote farm plans, using LandCare Area‐wide Planning methods
- Encourage the use of river maintenance plans, and combined and class applications
- Introduce screening and decisions after scoping
- Practice participatory adaptive management at the appropriate agro‐ecosystem scale
- Develop markets for trading ecosystem goods and services

Agri-SA believed that it was apposite now for South Africa to examine where it was, and where it wanted to be. Questions must be asked whether the current environmental regulations were yielding the desired outcomes for agricultural sustainability and efficiency. If not, alternatives had to be sought. Any decision made regarding the way forward had to be critically examined, instead of honing in on only the nearest ‘tool’.

Mr de Villiers said the current regulations were not yielding desired results. A move in strategy was needed and there must be recognition of the differences between agriculture and other sectors.

The Department of Economic Development, Tourism and Environmental Affairs, Free State Province submission
Ms Grace Mkhosana, Head: Environmental Impact Management, Free State Department of Economic Development, Tourism and Environmental Affairs, said the effectiveness of EIA yielded mixed results and, in some cases it had fallen short of expectations. This was attributed to poor management of the process, inconsistent quality of the EIAs, the follow-up mechanisms, and capacity building and communication constraints.

She noted that the effectiveness of EIA as a planning and regulatory tool in relation to EIA review and Environmental Management Plan (EMP) implementation was often diluted as it was used as the only tool for regulation and planning, and other tools were overlooked. Effectiveness was also often undermined because of the lack of conviction by the proponents of the regime; it had to be seen as a necessity rather than an opportunity to achieve sustainable development.

Ms Mkhosana confirmed that the EIA process was indeed a valuable tool, along with EMP. Most of its failures were related to its implementation, and not the process itself.  The South African conference on the topic “Ten Years of EIA in South Africa” recognised the inadequacies of many EIAs, but still concluded that EIAs were marginally effective and still a worthy investment. At the Conference it was agreed that an Environmental Impact Assessment and Management Strategy (EIAMS) should be formulated for South Africa. Her Department supported this initiative.

The Chairperson said it was important to hear the issues that all levels if government were having. The problem raised that some fly-by-night “specialists” were creating useless reports had to be addressed.

Mr J Skosana (ANC) said EAPs needed to be certified and accredited. Legislation gave government certain powers, if they were not making use of that then it should be taken away.

The Chairperson said there had to be a line and standards drawn, as the matter was more complex. The DEA’s integrity rested on such people.

Mr Alf Wills, Deputy Director General, DEA, said there were standards, but they were certainly not strict enough to prevent fly-by-night people.

Mr Rodgers said the main problem was that registration of the specialists was not enforced.

International Association for Impact Assessment (IAIAsa) submission
Ms Terry Calmeyer, Representative, International Association for Impact Assessment (IAIAsa) said this Association’s submission was premised on the fact that South Africa had responded to the need to deal with social and economic challenges presented in the National Development Plan (NDP) and that various proposals for significant infrastructure development were made for the next couple of years. Such infrastructure development may have a significant impact on the environment, so it was essential for all stakeholders and role players in the environmental sector to contribute towards these processes.

IAIAsa was of the belief that the efficacy of an EIA regime was reliant on the quality and ethical values of the professionals who worked in the field of Environmental Impact Management. The successful implementation of Integrated Environmental Management was dependent on the competence and ethical values of EAPs in the private sector, as well as officials responsible for review and decision-making within government.

Ms Calmeyer said IAIAsa saw it as a priority to have a registration authority for Environmental Assessment Practitioners, and had played a key role in supporting the creation of the Environmental Assessment Practitioners Association of South Africa (EAPASA). However, the Minister of Water and Environmental Affairs had, since its launch on 7 April 2011, still not recognised EAPASA as a Registration Authority (RA) in terms of Section 24H of the National Environmental Management Amendment Act (NEMA), Act 107 of 1998. Until such time that EAPASA was a recognised RA, the EIA Regime could not achieve efficiency, as continued unregulated poor environmental practice within the sector would simply continue to undermine any intentions to improve the current EIA regime. EAPASA was just the first step, but the whole context had to be addressed.

IAIAsa also proposed that once the RA was recognised as a requirement there would no longer be a need for the prerequisite of “independence” in legislation. The independence set out in previous legislation had attempted to ensure that EAPs were ethical, but it had actually worked against adoption of best practice environmental options at the earliest phases. The RA, once established, should be able to manage ethical conduct

Ms Calmeyer also proposed that South Africa should adopt one singe EIA Regime for all sectors. Mining, a critical sector of the economy, was the sector that had the most significant impact on the environment. The mining sector’s environmental protection obligations were, however, limited as the DMR retained authority to make decisions on environmental acceptability for mining activities. IAIAsa firmly believed that mining should still fall under NEMA, and one process and unified standards should apply, with no ambiguity, to any development projects. An independent third party, the DEA, would make all decisions on environmental acceptability.

IAIAsa also noted that the current EIA regime made provision for the elective use of various types of review procedures in the EIA process, which were used to different degrees and with different levels of effectiveness across the sector. IAIAsa proposed the strengthening the role of Independent Review (a practice in other countries), as long as it was in a manner that did not significantly impact on the time and cost of EIAs.

Ms Calmeyer said IAIAsa wholeheartedly supported the norms and standards and development guidelines but proposed that there be an increased role of screening in the EIA process. This would streamline the process, making it cost effective and quick enough for the process not to be side-lined and achieve the core objective which was to protect the environment.

One key component missing from the current regime was following up after the EIA had been done, t check whether the predicted impact did occur or if the mitigating proposals were effective. As a result there was no feedback on the effectiveness of the methodology used, and therefore no reworking.

Ms Calmeyer also said that compliance monitoring and enforcement of EMPs and EA conditions of the thousands of approved EIA applications per year was lagging and IAIAsa supported any initiatives that would strengthen that. Inadequate monitoring and reporting or failure of the responsible authorities to review, interpret and take action when required undermined the EIA process.

Ms Calmeyer stressed that EIAs were not a planning tool, but were rather intended to assess the impact of a specific project. However, given the lack of other appropriate planning tools the EIA had been used to make decisions that were not always appropriate. IAIAsa fully supported the implementation of environmental management frameworks, strategic environmental tools and any other tools.

The issue of inconsistency between provinces on how the EIA regulations were implemented was also brought up, and the level of capacity that the officials had to be looked into and addressed.

The EIA regime currently involved a multitude of environmental authorisations that could potentially be required for one activity. It was designed to assess the impacts of a proposal at a project level. The current EIA regime had the potential to achieve sustainability, but sustainable development could not be guaranteed unless the planning and legislative framework provided the context. Overall, the current EIA process was burdened by procedural and administrative requirements, and the focus on sustainability issues was lost. IAIAsa proposed increased flexibility and quality in the process as opposed to the current “tick-box approach”, which provided little assistance to decision-makers in assessing the sustainability of a development proposal.  

The Chairperson said that he was surprised at the proposal to remove the requirement for independence from the legislation.

Ms Calmeyer said South Africa was the only country she knew of where independence was a requirement for an EAP. IAIAsa believed that the requirement should rather be that the practitioner was professional, ethical and competent. The requirement for “independence” had not achieved other core requirements, and currently independence had been over implemented.

The Chairperson did not understand how independence was “over implemented”, as everyone else that had come to the Committee had stated that not a single EAP was independent. If any legal requirement for impartiality was removed, the consequence would surely be that EAPs became part of project planning, as employees who must ensure that a project was implemented.

Ms Calmeyer said the issue of independence would be addressed by the implementation of the Registration Authority, which would require more accountability of EAPs.

The Chairperson said independence was not an institutional arrangement; an institution could only support independence not create it. He asked that IAIAsa should re-think this aspect. What was needed was a profession that could act with integrity whilst earning a living for its practitioners.

Ms Lize McCourt, Chief Operating Officer, DEA, said when the Department did benchmarking with other countries on EIA, it should be done in the full context. She agreed that South Africa was one of the few countries that mentioned the need for an “independent” environmental decision, because the EIA process was an authorisation in its own right. Other international practice in that regard was that the EIA acted as input into the final decision.

South African Wind and Energy Association (SAWEA) submission
Mr Mike Mangnall, Representative, SAWEA, said that the strengths of the current EIA process included that it was clear, structured and robust. The current process was thorough, inclusive and transparent; I&APS were informed of potential projects and afforded opportunity to voice any concerns and support of the projects. Although not always adhered to, the clearly regulated timeframes allowed for proper planning processes. Lastly, the dynamic nature of EMP development allowed for new information to be incorporated.

He also highlighted certain weaknesses in the current regime. These included the fact that the DEA faced an enormous EIA workload, particularly around the renewable projects being tabled. The process was found to be too prescriptive and onerous, which resulted in unnecessary delays and frustrations. The reviews were found to be inconsistent and often exceeded stipulated timeframes. The ease with which stakeholders could lodge appeals was a concern, particularly because of the cost implications. Appeal timelines were, in theory, regulated but in practice were actually open-ended. Environmental Authorisations (EAs) were often conditional on further compliance with other legislation, and other departments, such as those dealing with water or agriculture, often imposed restrictions that conflicted with EA, resulting in amendments which further stretched DEA. Quality of reporting by EAPs and specialists varied dramatically, and mitigation measures for birds and bats were often based on misunderstanding of wind farms and related technology. The current process allowed for little flexibility in development design.

SAWEA recommended that additional resources be employed within DEA to deal specifically with wind (and solar) farm applications. A body of suitably-qualified expertise, or advisory capacity, should be created within DEA that would be capable of scrutinising technical content of EIAs, in particular specialists’ impact mitigation recommendations.

Also, greater effort should be made to integrate various permitting processes. Other government departments should be involved at an early stage, by DEA, to provide inputs into EIA process. This would prevent unnecessary or conflicting comments between various departments, and also reduce amendment applications post-authorisation.

Where project impacts were likely to be low, it was suggested that, instead of requiring full EIA or Basic Assessment process, only implementation of EMP and appointment of ECO should only be requested. Also, where a non-substantive amendment was required, a direct application by the developer should be allowed. However, there was a need for extreme caution if Strategic Environmental Assessments (SEAs) to select Renewable Energy Development Zones (REDZ) continued.

SAWEA  believed that collaboration had to be increased and suggested that this must be facilitated between SAWEA, DEA, environmental specialists and EAPs, to foster greater understanding and promote environmentally responsible and sustainable wind energy development in South Africa. DEA and other departments must improve the integration of permitting, to ensure more efficient, consistent and effective decision-making. There should also be a clear platform allowing for follow-up on progress of EIAs. Appeals within DEA should be established; this could be run online, and could, for instance, include official access rights, waiting lists, list of missing documents, automatic progress updates, and standard checklists for both applicant and case officer. All this would ultimately lead to a more efficient, interactive and clearly-scheduled process.

Ms McCourt said there had been delays on some appeals. In most instances, with wind and solar applications, timeframes had been exceeded as the Department was assisting the applicants to meet the different bidding windows. In fact, the DEA has processed most of the wind and solar applications faster than legislated. Some applications were fast tracked within times shorter than the legislative requirement.

She noted that in regard to the SEA to select Renewable Energy Development Zones (REDZ), the DEA had de-listings and exclusions. Those outside the preferred zone would have to motivate why they should be allowed. The DEA had expected to get 400 applications a year and actually received 600, of which the majority were processed within less time than regulated.

Mr Wills said more than 25 GigaWatts had been approved already through the environmental process. The real challenge the sector faced, in terms of the Integrated Resource Planning, that only 3.8 Giga Watts in the first phase were allowed, in terms of the policy.

Western Cape Property Development Forum submission
Mr van Zyl, Representative, Western Cape Property Development Forum, introduced the Forum as a voluntary organisation representing property developers and property practitioners in the Western Cape. In regard to the environmental legislation, the property industry in general would be advocating for a facilitative mind-set when drafting and interpreting regulations, and urged a practical understanding of what industries were affected.

The NEMA acknowledged the importance of the environment, society and the economy. He said that between 2004 and 2007, when there was a major economic boom in the country, the pendulum should have swung to protecting environmental considerations, and now, faced with the lack of job creation and economic crisis, the pendulum should have swung towards the economy.

One concern related to appeals and making of decisions, as the appeal process had the potential to prevent development, and increased uncertainty. The appeal process may cause an application to miss the seven-year market cycle. An applicant had no comeback against spurious objectors or professional objectors.

The Western Cape Property Development Forum supported the goals and vision of NEMA. However, the needed to be incremental achievement of goals through evolution rather than revolution. It urged for reduced timelines in the decision making process and said there was a need for increased accountability of officials, spurious and professional objectors.

The Chairperson disagreed with Mr van Zyl’s assertions on the emphasis between the three considerations, and said that instead of a swinging in favour of one, there was rather the need to strike a balance. He suggested that Mr van Zyl and the Forum must read the state of the environment report, saying that it was “sickening” what  was being done to the environment. This report looked at all the sectors of the environment and all of them were ailing.

Mr van Zyl said that the Forum was advocating for sensitivity, and was not suggesting that every development was correct.

The Chairperson asked for an example of an application that took seven years to process, and said that the Committee must check up on the delays.

Mr Skosana said the tone of the presentation was very accusatory, and he would have preferred to see recommendations rather than criticisms. If there was indeed an application taking seven years, proactive steps should have been taken to resolve it, rather than raising it now to Parliament.

Mr van Zyl apologised if his presentation was seen as too critical of the Department, but said the purpose was to highlight what property developers were experiencing. One practical suggestion he could make was that where there were problems of interpretation, there was a need to fast-track and get clarity, rather than going to court.

The Chairperson said that the Forum’s members needed to check their place in society, and re-emphasised that “sustainable development” was key, so one concept or consideration should never be allowed to prevail over others, but balance must be found. The economy must fit into the environment, not the reverse.

Mr Gideon Erasmus submission
Mr Gideon Erasmus said he was making the submission in his personal capacity. He believed that the present system simply did not work. It was a precondition for development that every generation “make its own scratches” on the surface of this planet, as part of development or progress, but he agreed there was a need to find the appropriate balance between the environment and development.

He maintained that there were in fact no EIA Reports recommending that authorisation be denied, no applications being withdrawn because applicants were persuaded that the proposed activity was environmentally unjustifiable. The reason was that no paid service provider could ever be independent. EAPs were simply paid service providers, paid to secure authorisations, not to undertake objective assessments. It was absurd to anchor the veracity of an EIA in the “independence” of a paid service provider. Environmental authorities were burdened with reports they could not trust. Mr Erasmus thus urged the Committee and the Department to look into ways of how to ensure the objectivity and reliability of reports received.

Furthermore, he took issue with differentiated listings, which he regarded as a waste f time, because, at its simplest form, activities could simply be divided into those that would have significant impacts, and those that would not. It was  scientifically impossible to anticipate what the nature of impacts would be. Every proposed activity must be assessed on its contextually specific merits. The environment was being betrayed by some types now warranting a lesser assessment.

Mr Erasmus proposed that a better way to process would be to have a single, suitably flexible regime in place of the present artificially-differentiated system. Every EIA must be appropriate to the impacts of a proposed activity, not its listing. In every instance the following should be required:
- Application and Scoping report
- Notification for registration and comment on Scoping proposal
- Revised Scoping if necessary
- EIA phase
- Decision
- Appeal (where necessary)

This would mean going back to the 1998 regulations. However the concept of scoping was perverted by the context, and was devoid of substantive content. The 1998 pitfalls could be avoided by conflating the application and scoping phases, prohibiting authorisation without an EIA Report, and making the applicant responsible for justifying the extent of the assessment to be undertaken.

The Chairperson asked for clarity on the major change that Mr Erasmus was suggesting.

Mr Erasmus said he was suggesting an adequate assessment process that would comprise three phases. In the application phase the applicant would state exactly what it wanted to do. The second phase was the scoping phase, which would amount to a research proposal on the impacts, and calls would be made to interested parties. The last phase, the EIA phase, would involve an assessment and decision.

The Chairperson asked if the introduction of EMFs changed any of the presenter’s views.

Mr Erasmus said it did not. He was strongly in favour of them and thought the same principle applied to EMFs as well.

Mr S Haung (ANC) asked if the proposed process would shorten the period between application and approval.

Mr Erasmus said that, in his experience, most delays could be attributed to the incompetence of the applicant’s team rather than the management of processes in the DEA. These proposals would shift responsibility for the time taken on to the applicants, and would ensure that the  applicant was placed under pressure to provide an adequate and responsible report, on which the decision would be based.

Ms McCourt pointed out that there were three fundamental steps in an EIA process; screening, scoping and assessment.  South Africa took the approach that the listing exercise was a process that gave effect to the screening stage. She felt that there had to be differentiation between scoping and assessment phases, although the current reality was that the two were combined to get to shorter time frames.

The Chairperson proposed that there be a cut-off date that would prevent the process from dragging on. The applicant should be given a certain time period to respond to issues raised, and if that deadline was not met, the file must be closed, and new applications must be brought. This would place the onus on the applicant to provide information.

Mr Erasmus said that he was in agreement with most of the DEA’s comments, but said the question must be raised whether South Africa, whether or not it was a developing country, had an absolute responsibility to the environment, and could therefore not screen in broad brush strokes.

The Chairperson asked that the Department made note of the issues raised by Mr Erasmus and report back to the Committee with comments.

Treasure Karoo Action Group submission
Ms J Le Roux, Representative, Treasure Karoo Action Group, said that there were many unknowns regarding technology and the environment. There was only a relatively good understanding of  geology down to around 400 metres, but some proposed activity in the Karoo would take place far below that.

Ms Le Roux alerted the Committee that drilling was not a listed activity, which was a possible loophole. There was a need for individual EIAs per drilling location, due to varying geology and ecology as well as SEAs for cumulative impacts such as trucks, flaring, waste, pipelines, well-pads and wells.

She also said that there was a need for baseline testing of groundwater, water, and air at minimum, but there was certainly a need for better protection for groundwater. Ecosystem services were currently neglected and there was special concern in agricultural societies.

Ms Le Roux said there was a disconnect between NEMA and MPRDA, and urged for a standardised licence procedure between MPRDA and NEMA to avoid duplication. Hydraulics was a new area in South Africa, and therefore there needed to be strict rules and processes around that starting with an EIA.

Ms Le Roux said the other issues that her organisation had raised, as outlined more fully, reiterated issues stated in earlier presentations. However, she wanted to stress that government policy was needed to deal with the fast-tracking of projects of developmental and social importance, and said that timeframes should be set out clearly for necessary environmental assessment and authorisations.

Ms Le Roux said the current EA process relied on an integrated approach of specialist studies, risk assessment and public participation. The risk evaluation process and rating was not standardised, and the various methods employed relied heavily on the discretion of the EAP. The option for submission and review in electronic format should be explored.

Terry Bengis Submission
Mr Terry Bengis agreed with other commentators that although the concept of an Environmental Impact Assessment was good, there were practical issues that watered down the process and that, when analysed, fuelled the arguments against such processes in terms of time, costs and delays. These spoke mainly to development and developer issues.

Mr Bengis said that the problem arose because the Consultants charged with the task of carrying out the EIA were paid directly by the developers. This needed to change, as it presented an opportunity for corrupt practices. He proposed that all fees for EIAs should be paid into a central fund and consultants should be appointed by the relevant Department of Environmental Affairs, and be paid from that fund. The needs of the public also must be taken care of and an additional consultant must be appointed, separate from the one doing the EIA, to look after the public’s needs.

Mr Bengis noted that the issue of job creation was often seen as almost a sacred component of any project, and a developer would quote figures on direct and indirect job creation as part of the reasons backing the business case. He suggested that any developer should be required to sign an acceptance that, should there be any shortfall in job creation numbers once the project was complete, the entity must make that up. These promises ha been used and abused; although jobs were needed, false promises on jobs were not.

The Chairperson agreed that developers’ plans were often padded out with information that failed to reach the outcome, and agreed that promises were made that never came to fruition. He asked that the Department incorporate that suggestion into its report, and think of some ways to deal with it. There should be ways to hold developers accountable on their promises.

Mr Rodgers agreed with the Chairperson that once the EIA was issued, projects tended to be left to run, and there needed to be legislation or regulation with severe consequences to deal with those developers who embellished facts in the application process.

Dube Tradeport
Mr Owen Mungwe, Representative, Dube Tradeport, described Dube as a legislated entity within the provincial sphere of KwaZulu Natal government. The entity sought to be a catalyst in the global business and trade environment, looking at integrated supply chain, and offering business the ability to compete globally, predominantly in air cargo related activities.

Mr Owen Mungwe said that some of the points he had raised had been dealt with extensively already. Dube Tradeport hoped that land development processes would be looked into, and hoped that there could be a way found to integrate the application processes. Currently, there had to be several different applications made to different spheres of government, which dragged out the process, and it could take two to three years, because of this fragmentation, before projects could start.

Mr Mungwe also spoke on the need for standardisation to avoid the current inconsistencies in awarding approvals. There was also the need to clearly outline “no-go zones”.

Ms McCourt said the Dube Tradeport and King Shaka airport were each a good demonstration of the complexity of EIAs because they were situated in an ecologically sensitive area. If the applications for the projects had only been considered against the environmental impact, there would have been no development, and the applications had to be looked at in terms of a bigger context of sustainable development. This was one example of the off-set agreement, which resulted in a way being found to move forward. She mentioned that this was similar to the issue of job creation mentioned earlier. Justification had to be given for the projects to be approved.

Ms M Wenger (DA) said that if developers did not meet deadlines and their own lack of action caused delay, that was their problem, and they deserved to wait.  She noted that there had to be full compliance for matters to go forward.

Mr Rodgers said it was also up to developers to ensure they did the proper planning, and did not attempt to shift blame to the Department or policy makers for failing them.

Mr Mungwe confirmed that the project was done in phases, which spanned across many years, and that the developers would be abiding by the EIA processes and requirements.

South African Property Owners Association submission
Advocate Douglas Shaw, Representative, South African Property Owners Association (SAPOA), said that SAPOA was in agreement with the DEA that there needed to be environmental improvement, but wished to propose a process that, whilst being no less rigorous, would be quick and efficient, and avoid the backlogs that were created by tedious procedures.

Advocate Shaw agreed with most of the recommendations made to the Committee, regarding the stages of the application process and public participation process, which should run concurrently rather than having a PPP after each stage.

He proposed that a principle be inserted and stated in regulations that explicitly outlined the need to strike a balance. There should be no projects with large environmental costs and marginal economic benefits going ahead. Any projects that had marginal environment costs and large economic benefits should not be rejected or delayed. Everything came down to balance. Perhaps institutional mechanisms should be set up who could be approached for appeals.

He said that on average, process time limits should be reduced, but it was understandable that in some instances the periods had to be longer. The unnecessary participation linked to certain decisions could be done away with, so that there was no longer a need to consult with numerous departments, but only the core entities. Again, the main principles were balance, speed and improving the process.

Advocate Shaw mentioned that there had been an EAP prosecuted for awarding a development that was outrageously contrary to environmental protection, and, when found guilty, the EAP was stripped of his licence. 

The Chairperson said the issues raised food for thought and the Department would have to report on them. He said that cases could not be allowed where an applicant failed to provide information, so that the file lay open for six months and more, and consequences should follow.

Susie Brownlie, Ingrid Coetzee and Mary-Jane Morris submission
Ms Susie Brownlie, Ms Ingrid Coetzee and Ms Mary-Jane Morris said their observations and comments were based on their experience in the sector, that spanned over 25 years of EIA in South Africa. Each had first-hand knowledge of the introduction of Integrated Environmental Management, and how EIA operated prior to legislation being promulgated.

Ms Coetzee said frequent amendments to the legislation created confusion and uncertainty amongst developers. It was also worrying that the determining factor in projects seemed to be economic growth, instead of growth that was sustainable and environmentally sensitive. The current regime looked at minimising impact rather than avoiding projects that were detrimental to the environment.

Ms Coetzee was also touched on the “tick-box” approach mentioned earlier. The decision making process was fragmented. Except for the national environmental management principles outlined in the NEMA, there was no robust or explicit setting out of the criteria that were used when reaching a decision, and, more importantly, there were no trade-off rules to ensure that the goal of ‘sustainable development’ were kept firmly in sight.

Ms Coetzee proposed measures to strengthen environmental governance and enable environmental assessment to give assurance of sustainable development. She maintained that the principles enshrined in NEMA should be observed fully, that fragmentation must be reduced, there should be alignment and integration within the legislative and regulatory framework. The EIA must be seen as a process led by sustainability considerations, and it must measure development against sustainability objectives.

Ms Morris said impacts were underestimated in most cases, and she proposed that EAPs must also evaluate projects against the NEMA principles. It must be identified, in the development applications, who stood to “benefit the most in the development”. There should be alignment and coordination between decision makers.

Ms Brownlie said that currently, at policy and planning level, the environmental costs were not adequately addressed when formulating or conceiving policy and plans. In order to continue the pursuit of sustainability, there would have to be consideration of these environmental costs in the project level, policy and planning stages.

The Chairperson said sustainable development was the principle that drove everything in the Constitution, and therefore there was a need to give full effect and meaning to that principle. South Africa needed to have a debate and reach consensus on a single understanding of “sustainable development”. The environment was always a central issue, but there were differing views on the role and importance of the environment.

Ms Morris said there was a sense of dilution of the EIAs in recent years, and said that EAPs had lost their core understanding of their role. If the EAPs were to be given an opportunity to re-examine their role, they would relish that opportunity.

Ms Brownlie said the legislation was too loose in defining the relationship between spatial and environmental planning. There was no obligation on the planning authority to take the EMF into account, so that the two types of planning were in conflict.

The Chairperson said the Department needed to look into the biggest obstacle, that of coordinating the roles of the DEA and other spheres of government. He suggested the need for memoranda of understanding between departments on how they would synchronise their roles.

The Chairperson welcomed all the submissions over the last two days, which had been fruitful, useful and highly educational. The DEA had to engage more deeply with the Committee, to enhance Members’ understanding of the processes, and the object of these hearings was to enable the Department to respond to issues raised.

The meeting was adjourned.


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